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Privacy Policy

Last Updated: 1st September 2024

Sen & Ray LLC-FZ ("we," "our," or "us") is committed to protecting the privacy and confidentiality of personal data that we collect, process, and store. This Privacy Policy outlines how we handle personal data in compliance with applicable data protection laws, including the General Data Protection Regulation (GDPR), UAE Federal Decree-Law No. 45 of 2021 on Personal Data Protection, and other relevant privacy regulations.

Scope

This Privacy Policy applies to all personal data processed by Sen & Ray LLC-FZ, regardless of whether the data is collected online, offline, or through other means. It applies to:

  • Individuals within the European Economic Area (EEA).
  • All clients, employees, business partners, and website visitors engaging with us.

What Information We Collect

We may collect and process the following types of personal data:

  • Identity Information: Name, date of birth, passport details, Emirates ID, or other government-issued identification.
  • Contact Information: Email address, phone number, and mailing address.
  • Financial Information: Payment and banking details, tax identification numbers.
  • Professional Information: Job title, company name, and business contact details.
  • Technical Information: IP address, browser type, and activity on our website.
  • Special Categories of Data: Only if required and with explicit consent (e.g., criminal convictions for due diligence purposes).

Legal Basis for Processing

Under GDPR, we process personal data based on the following legal grounds:

  • Consent: When you have explicitly provided consent for specific purposes.
  • Contractual Obligation: Processing necessary for entering or performing a contract.
  • Legal Obligation: Compliance with legal or regulatory requirements.
  • Legitimate Interests: Where processing is necessary for our legitimate business purposes, except where overridden by your rights and freedoms.

Where we rely on consent, you can withdraw your consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.

How We Use Personal Data

We use personal data for the following purposes:

  1. Provision of Services: To deliver consultancy and advisory services.
  2. Compliance: To meet regulatory requirements, including anti-money laundering (AML) and sanctions screening.
  3. Communication: To respond to inquiries and provide updates.
  4. Business Operations: To manage invoices, contracts, and internal operations.
  5. Marketing: To inform clients about new services or promotions (with explicit consent).

Your Rights Under GDPR

Under GDPR, individuals have specific rights regarding their personal data:

  1. Right to Access: Obtain a copy of your personal data.
  2. Right to Rectification: Correct inaccurate or incomplete personal data.
  3. Right to Erasure (Right to be Forgotten): Request deletion of your data, subject to legal or regulatory exceptions.
  4. Right to Restrict Processing: Limit how your data is processed under certain circumstances.
  5. Right to Data Portability: Receive your data in a structured, commonly used format and transfer it to another data controller.
  6. Right to Object: Object to processing based on legitimate interests, including direct marketing.
  7. Right to Withdraw Consent: Withdraw consent for processing where consent is the basis.
  8. Right to Lodge a Complaint: File a complaint with your local data protection authority.

To exercise these rights, please contact us using the details provided below.

Data Sharing and Disclosure

We may share your personal data with:

  • Regulators: To comply with legal and regulatory requirements.
  • Service Providers: Third parties who assist with IT support, payment processing, or other operational services.
  • Affiliates and Partners: For legitimate business purposes and with appropriate safeguards.
  • Authorities: In response to lawful requests or legal obligations.

We ensure all data sharing is done with appropriate contractual safeguards to protect your personal information.

Data Security

We implement technical and organizational measures to protect personal data, including:

  • Encryption of sensitive data during transmission and storage.
  • Regular security assessments and updates.
  • Access controls to ensure data is only accessible to authorized personnel.

Data Retention

Personal data is retained only as long as necessary to fulfill the purposes outlined in this policy or to comply with legal and regulatory requirements. Once retention periods have elapsed, data is securely deleted or anonymized.

Cookies and Online Tracking

We use cookies on our website to enhance functionality and analyze usage patterns. Cookies are categorized as:

  1. Necessary Cookies: Required for the website to function.
  2. Analytics Cookies: To understand how visitors interact with our site (used only with consent).

You can manage your cookie preferences through your browser settings.

Children’s Privacy

We do not knowingly collect data from individuals under the age of 16 without parental consent. If we learn that we have collected such data without proper consent, it will be deleted promptly.

Updates to this Privacy Policy

We reserve the right to update this Privacy Policy to reflect changes in our practices or legal requirements. Any updates will be posted on our website, and significant changes will be communicated directly.

Contact Us

For questions about this Privacy Policy or to exercise your rights under GDPR, please contact privacy@senandray.ae

You may also lodge a complaint with the relevant supervisory authority, such as the UAE Data Office or the data protection authority in your country of residence.

By engaging with Sen & Ray LLC-FZ, you acknowledge and agree to the terms of this Privacy Policy.