Privacy Policy
Last updated on 2nd July 2024
1. INTRODUCTION
Alemdad Alamen for Information Technology Company “GlassHUB” (“we”, “us”, “our” , or “GlassHUB”) is committed to protecting the privacy and security of your personal data. This Privacy Policy explains in detail how we collect, use, disclose, and protect your personal data in accordance with the Saudi Arabian Personal Data Protection Law (PDPL) and the European Union’s General Data Protection Regulation (GDPR). We respect your privacy rights and are dedicated to maintaining the confidentiality and integrity of your personal information.
2. DATA CONTROLLER
GlassHUB, located at Riyadh, Saudi Arabia, is the data controller responsible for your personal data.
3. PERSONAL DATA WE COLLECT
We may collect, use, store, and transfer different kinds of personal data about you, which we have grouped as follows:
a) Identity Data: includes first name, last name, username or similar identifier, title, date of birth, gender, and national ID number.
b) Contact Data: includes billing address, delivery address, email address, and telephone numbers.
c) Professional Data: includes your job title, employer, professional qualifications, and work history.
d) Financial Data: includes bank account details, payment card details, and payment history.
e) Transaction Data: includes details about payments to and from you and other details of products and services you have purchased from us.
f) Technical Data: includes 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 website or services.
g) Profile Data: includes your username and password, purchases or orders made by you, your interests, preferences, feedback, and survey responses.
h) Usage Data: includes information about how you use our website, products, and services.
i) Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We do not collect any Special Categories of Personal Data about you
4. HOW WE COLLECT YOUR PERSONAL DATA
We use different methods to collect personal data from and about you, including:
a) Direct interactions: You may give us your Identity, Contact, Professional, and Financial Data by filling in forms or by corresponding with us by post, phone, email, or otherwise. This includes personal data you provide when you:
• Apply for our products or services
• Create an account on our website
• Subscribe to our service or publications
• Request marketing to be sent to you
• Enter a competition, promotion, or survey
• Give us feedback or contact us
b) Automated technologies or interactions: As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies, server logs, and other similar technologies.
c) Third parties or publicly available sources: We may receive personal data about you from various third parties and public sources, such as:
Technical Data from analytics providers, advertising networks, and search information providers
Contact, Financial, and Transaction Data from providers of technical, payment, and delivery services
Identity and Contact Data from data brokers or aggregators
Identity and Contact Data from publicly available sources
5. PURPOSES AND LEGAL BASIS FOR PROCESSING
We have set out below a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Purpose/Activity | Type of data | Legal basis for processing
a) To register you as a new customer
• Identity Data
• Contact Data
– Performance of a contract with you
b) To process and deliver your order including:
(i) Manage payments, fees, and charges
(ii) Collect and recover money owed to us
• Identity Data
• Contact Data
• Financial Data
• Transaction Data
• Marketing and Communications Data
– Performance of a contract with you
– Necessary for our legitimate interests (to recover debts due to us)
c) To manage our relationship with you which will include:
(i) Notifying you about changes to our terms or privacy policy
(ii) Asking you to leave a review or take a survey
• Identity Data
• Contact Data
• Profile Data
• Marketing and Communications Data
– Performance of a contract with you
– Necessary to comply with a legal obligation
– Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
d) To enable you to partake in a prize draw, competition, or complete a survey
• Identity Data
• Contact Data
• Profile Data
• Usage Data
• Marketing and Communications Data
– Performance of a contract with you
– Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
e) To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting, and hosting of data)
• Identity Data
• Contact Data
• Technical Data
– Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise)
– Necessary to comply with a legal obligation
f) To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
• Identity Data
• Contact Data
• Profile Data
• Usage Data
• Marketing and Communications Data
• Technical Data
– Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
g) To use data analytics to improve our website, products/services, marketing, customer relationships, and experiences
• Technical Data
• Usage Data
– Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
h) To make suggestions and recommendations to you about goods or services that may be of interest to you
• Identity Data
• Contact Data
• Technical Data
• Usage Data
• Profile Data
• Marketing and Communications Data
– Necessary for our legitimate interests (to develop our products/services and grow our business)
6. DATA RETENTION
We will only retain your personal data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting, or other requirements.
In some circumstances, you can ask us to delete your data: see Section 9 below for further information.
In some circumstances, we will anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
7. DATA SHARING AND TRANSFERS
We may share your personal data with the following categories of recipients:
a) Internal Third Parties: Other companies in our group acting as joint controllers or processors.
b) External Third Parties:
• Service providers acting as processors who provide IT and system administration services.
• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance, and accounting services.
• Regulators and other authorities acting as processors or joint controllers who require reporting of processing activities in certain circumstances.
c) Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
International Transfers:
For data subjects in Saudi Arabia: We do not transfer personal data outside Saudi Arabia without ensuring adequate protection measures are in place and obtaining necessary approvals from the Saudi Data & Artificial Intelligence Authority (SDAIA) where required.
For data subjects in the EU/EEA: We do not transfer your personal data outside the European Economic Area (EEA) unless we ensure an adequate level of protection is in place. Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by implementing at least one of the following safeguards:
• Transferring to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
• Using specific contracts approved by the European Commission that give personal data the same protection it has in Europe.
• For providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.
8. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
9. YOUR RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
a) Request access to your personal data.
b) Request correction of your personal data.
c) Request erasure of your personal data.
d) Object to processing of your personal data.
e) Request restriction of processing your personal data.
f) Request transfer of your personal data.
g) Right to withdraw consent.
If you wish to exercise any of these rights, please contact us using the details provided in Section 12.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
10. AUTOMATED DECISION-MAKING
We do not use automated decision-making, including profiling, in a way that produces legal effects concerning you or similarly significantly affects you. [If this is not accurate for your business, please provide details of any automated decision-making you use.]
11. CHANGES TO THIS PRIVACY POLICY
We keep our privacy policy under regular review. This version was last updated on [DATE]. Historic versions can be obtained by contacting us.
12. CONTACT US
If you have any questions about this privacy policy or our privacy practices, please contact us at:
Alemdad Alamen for Information Technology Company (GlassHUB)
7581 Qurtubah Dist. Riyadh 13244، Saudi Arabia
Customer1st@glasshub.ai
+966 50 840 1100
13. COMPLAINTS
For data subjects in Saudi Arabia: If you have concerns about our data practices, you have the right to lodge a complaint with the Saudi Data & Artificial Intelligence Authority (SDAIA).
For data subjects in the EU/EEA: If you have concerns about our data practices, you have the right to lodge a complaint with your local data protection authority in the EU/EEA.
14. COOKIES AND SIMILAR TECHNOLOGIES
We use cookies and similar tracking technologies to track the activity on our service and hold certain information. For more information about how we use these technologies and how you can control them, please see our Cookie Policy [link to Cookie Policy].
15. CHILDREN’S PRIVACY
Our services are not intended for children under the age of 18. We do not knowingly collect personal data from children under 18. If you become aware that a child has provided us with personal data, please contact us immediately.
16. LINKS TO OTHER WEBSITES
Our website may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
17. DISPUTE RESOLUTION AND ARBITRATION
Any dispute, controversy, or claim arising out of or relating to this Privacy Policy, including its formation, interpretation, breach, or termination, and whether based on contract, tort, statute, or other legal or equitable theory, will be resolved through final and binding arbitration in accordance with the Saudi Center for Commercial Arbitration (SCCA) Rules.
17.1 Arbitration Process:
a) The arbitration shall be conducted in Riyadh, Saudi Arabia.
b) The language of the arbitration shall be English.
c) The arbitration tribunal shall consist of one arbitrator appointed in accordance with the SCCA Rules appointed by GlassHUB.
d) The arbitration proceedings shall be confidential.
17.2 Governing Law:
This Privacy Policy and any dispute arising out of or related to it shall be governed by and construed in accordance with the laws of the Kingdom of Saudi Arabia, without giving effect to any choice or conflict of law provision or rule.
17.3 Award:
The arbitrator’s award shall be final and binding on the parties, and judgment on the award may be entered in any court of competent jurisdiction.
17.4 Costs:
The party initiating the arbitration proceedings (the “Claimant”) shall bear all costs and expenses associated with the arbitration, including but not limited to administrative fees, arbitrator’s fees, and reasonable attorney’s fees incurred by both parties.
17.5 Exceptions:
Notwithstanding the foregoing, nothing in this section shall prevent either party from seeking interim or injunctive relief from a court of competent jurisdiction to protect its rights pending the outcome of the arbitration.
17.6 Class Action Waiver:
The parties agree that any arbitration shall be conducted in their individual capacities only and not as a class action or other representative action, and the parties expressly waive their right to file a class action or seek relief on a class basis.
17.7 Time Limitation:
Any arbitration must be commenced by filing a demand for arbitration within one (1) year after the date the party asserting the claim first knows or reasonably should know of the act, omission, or default giving rise to the claim; and there shall be no right to any remedy for any claim not asserted within that time period. If applicable law prohibits a one-year limitation period for asserting claims, any claim must be asserted within the shortest time period permitted by applicable law.
By using our services, you agree to resolve any disputes through binding arbitration as described in this section, and you waive any right to pursue claims in a court of law, except for the interim or injunctive relief mentioned in Section 17.5.
