CUPAGAHWA, Binghatti Holding Ltd. and its affiliates and subsidiaries referred as (the Binghatti Group, we or us) respects the privacy of its customers and is committed to keeping customers’ personal information and other data confidential and secure.
The Personal Data the Binghatti Group may receive from customers may include, but is not limited to:
• Identity Data: names, usernames, marital status, title, date of birth, gender; passport, nationality, place of birth, photographs;
• Contact Data: address, email address and telephone numbers; • Financial Data: bank account and credit and payment card details;
• Transaction Data: details about payments to and from you and other details of products and services you have purchased from us;
• Technical Data: internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our websites;
• Profile Data: your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses;
• Usage Data: information about how you use our website, products and services; and
• Marketing and Communications Data: your preferences in receiving marketing from us and our third parties and your communication preferences.
The Binghatti Group may ask for other information voluntarily from time to time to enable it to improve its service or consider the wider needs of its customers or potential customers. If customers choose not to provide the information the Binghatti Group needs to process customers’ requests for a specific products or services, the Binghatti Group may not be able to provide customers with those requested products or services.
The Binghatti Group websites and apps are not intended for children and we do not knowingly collect data relating to children.
From time to time, the Binghatti Group may receive customers’ personal information via the various channels through which customers communicate with us, including through:
• use or access of our websites and other web-based products, information or services;
• third-party social media networks;
• telephone, e-mail, text messaging services, chat bots, or any other digital or electronic form or communication;
• online or off-line registration or application forms, surveys, questionnaires, contracts, agreements, identification documents and other documents submitted to us;
• transactions with us (e.g., letter of credit issuance, cheques, account enquiry, bank or money transfer); and
• verification of the validity and accuracy of customers’ personal and/or relevant corporate details by any third party.
Before using the Binghatti Group’s websites, apps or services, customers must understand and agree that customers’ Personal Data may be disclosed, transferred or shared:
* within the Binghatti Group and to other relevant authorized service providers which are registered and/or incorporated in UAE during back-office processing procedures;
• with vendors, consultants, marketing and advertising partners, and other service providers who need access to such Personal Data to carry out work on our behalf or to perform a contract we enter into with them;
• in response to a request for information by a competent authority or government entities if we determine that such disclosure is in accordance with, or is otherwise required by, any applicable law, regulation, or legal process;
• with law enforcement officials, government entities or authorities (e.g. the DFSA), or other third parties as required by applicable law;
• with third parties in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company;
• with third parties in an aggregated and/or anonymized form which cannot reasonably be used to identify you.
We retain Personal Data submitted by you for a reasonable length of time unless otherwise prescribed by applicable law, and only for as long as reasonably necessary to fulfil the purposes for which we collected it.
The Binghatti Group is not responsible for the accuracy of the information you provide, and will modify or update your Personal Data in our databases upon your request, as further outlined below. We will erase or archive from active use your Personal Data upon request unless we are required to retain it in accordance with DIFC or other applicable laws or to perform agreed services. By accessing or using our apps and websites or otherwise providing us with Personal Data, you thereby represent and warrant that you understand that all information submitted by you to us may be used by us in accordance with applicable laws and our policies.
We may use the Personal Data which you provide to us or we collect from you to:
• respond to any queries or expressions of interest made by you;
• register you as a customer and provide you with products or services, including managing payments, fees, charges and collecting monies owed to us;
• manage our relationship with you;
• to enter into or conclude or perform any contract we have entered into with you;
• process your payments to us and protect against fraudulent transactions; • comply with our legal obligations and defend legal claims;
• further our legitimate business interests or those of a third party where your interests and fundamental rights do not override those interests;
• provide, maintain, and improve our services, including, for example, to facilitate payments, send receipts, provide products and services you request (and send related information about them), develop new features, provide customer support to users, authenticate users, and send administrative messages, whether information or required by applicable law;
• perform internal administration and operations, including, for example, to prevent fraud and abuse of our services, to troubleshoot software bugs and operational problems, conduct data analysis, testing, and research and to monitor and analyse usage and activity trends;
• send you communications we think will be of interest to you, including information about products, services, promotions, news, and Binghatti Group events, where permissible under DIFC Laws and according to any other applicable laws; and to process contest, sweepstake, or other promotion entries and fulfil any related awards and enable you to partake in any surveys, contests, sweepstakes, prize draws or competitions;
• notify you about changes to our products and services;
• allow you to participate in any interactive features of our app or websites; • keep our apps and websites safe and secure; and
• personalize and improve our products and services, including to provide or recommend features, content, social connections, referrals, and advertisements.
The Binghatti Group maintains strict security standards and procedures for the purpose of protecting customers’ Personal Data. When accessing the Binghatti Group’s services, customers must go a through verification and authorization process to confirm each customer’s identity through our KYC Process.
We make every effort to ensure that your Personal Data is secure on our systems. The Binghatti Group has staff dedicated to maintaining our data protection and security policies, periodically reviewing them and making sure that our employees are aware of our data protection and security practices. Unfortunately, no data transmission over the internet can be guaranteed to be 100% secure. As a result, the Binghatti Group cannot warrant or guarantee the security of any Personal Data you transmit to us, and you do so at your own risk.
If a customer’s browser is appropriately configured it should tell the customer whether the information the customer is sending will be secure (generally by displaying an icon such as a padlock). The combination of a secure browser at the customer’s end and the Binghatti Group’s security measures provide customers with the best security currently available.
Once the Binghatti Group receives a customer’s information, the Binghatti Group will take all reasonable steps to protect that information. If the Binghatti Group no longer needs a customer’s information, the Binghatti Group will destroy or de-identify it, subject to the extant record retention guidelines.
You have the right to access information held about you. Your right of access can be exercised in accordance with DIFC and other applicable laws. Any access request generally comes at no cost to you, but may, where permissible, be subject to a fee to meet any extraordinary administrative costs in providing you with details of the information we hold about you.
When you contact us about a potential Personal Data error, we will endeavor to confirm or verify the information in question, then correct verified inaccuracies and respond to the original inquiry. We will endeavor to send a correction notice to businesses or others whom we know to have received the inaccurate data, where required and / or appropriate. However, some third parties and third party sites may continue to process inaccurate data about you until their databases and display of data are refreshed in accordance with their update schedules, or until you contact them personally to ensure the correction is made in their own files. You may also request that we restrict, erase or otherwise process your Personal Data in line with the your rights as set out in the DIFC Data Protection Law.
The Binghatti Group is not liable for any potential loss or damages under the following conditions:
• Natural disaster, war, terrorist attack, interruption of electric power, fire, water, etc. which is beyond the Binghatti Group’s control;
• Disclosure, misuse, lending/delegation to any third party, transfer of the OTP Token/security password and/or user password by the customer;
• Telecommunication problems which are beyond the Binghatti Group’s control;
• Functionality problems with customers’ electronic devices;
• Misuse of the Binghatti Group’s services; and
• Any other circumstances which are beyond the Binghatti Group’s control.
This notice is prepared and maintained by the Binghatti Group and is governed by the laws of DIFC, including the Data Protection Law DIFC No. 5 of 2020, and may for certain types of Personal Data processing, be subject to laws from other jurisdictions. From time to time, information and/or services may be amended in accordance with changes of the governing law.