Privacy Policy

Version 1.0, last updated 30th of November 2022

This Privacy Notice explains in detail how the company I.Engineer-FZCO collects, uses and discloses your personal data. Please read this Privacy Notice carefully before submitting any personal data to us.

  1. GENERAL INFORMATION
    1. About the Privacy Notice. This the company I.Engineer-FZCO Privacy Notice (the “Privacy Notice”) governs the processing of personal data collected from persons (“you” and “your”) through the online platform www.theprojectring.com and Project Ring™ Mobile App (the “Platform”). The Privacy Notice does not cover any third-party websites, applications, software, products, or services that integrate with the Platform or are linked to form the Platform.
    2. About the Platform. The Platform provides you with access to store and collects data you provide us for your use and benefit (the “Content”).
    3. Data controller. The Platform is owned and operated by I.Engineer-FZCO having a registered office at Dubai Digital Park, with service license number 15205 (“we”, “us”, or “our”). We act in the capacity of a data controller with regard to the personal data processed through the Platform in terms of the UAE Data protection laws and other applicable data protection laws enforced in the UAE. As a data controller, we are responsible for collecting your personal data through the Platform and making decisions about the purposes for which your personal data is used. The Platform Project Ring™ Mobile App does not allow any third-party websites, applications, software, products or services to integrate with the Platform Project Ring™ App or link to form the Platform Project Ring™
    4. Your consent. Before you submit any personal data through the Platform, you are encouraged to read this Privacy Notice that is always available on the Platform to understand on what legal bases (other than your consent) we rely when handling your personal data. In some cases, if required by the applicable law, we may seek to obtain your informed consent for the processing of your personal data. For example, you consent may be necessary if:
      • (i) we intend to collect other types of personal data that are not mentioned in this Privacy Notice.
      • (ii) we would like to use your personal data for other purposes that are not specified in this Privacy Notice; or (iii) we would like to transfer your personal data to third parties that are not listed in this Privacy Notice.
    5. Minors. The Platform is not intended for use by children (i.e., persons who are minors in their country of residence). Therefore, we do not knowingly collect minors’ personal data.
    6. Term and termination. This Privacy Notice enters into force on the effective date indicated at the top of the Privacy Notice and remains valid until terminated or updated by us.
    7. Amendments. The Privacy Notice may be changed from time to time to address the changes in laws, regulations, and industry standards. We encourage you to review our Privacy Notice to stay informed. For significant material changes in the Privacy Notice or, where required by the applicable law, we may seek your consent.
  2. INFORMATION COLLECTED AND THEIR PURPOSE
    1. We collect only a minimal amount of personal data through the Platform that is necessary for your use of the Platform. We use your personal data for limited, specified, and legitimate purposes explicitly mentioned in this Privacy Notice. In short, we use it only for the purposes of enabling you to use the Platform, providing you with services, maintaining and improving the Platform, conducting research about the Platform and our business activities, replying to your enquiries, and pursuing our legitimate business interests. We do not repurpose your personal data. It means that we do not use it for any purposes that are different from the purposes for which your personal data was provided.
      • Registration of User Account. When you register your user account, we collect your name, email address, country, phone number, and other necessary data. We use such data to register and maintain your user account, enable your access to the Platform, provide you with the services, contact you, if necessary, and maintain our business records. The legal bases on which we rely are ‘performing a contract with you and ‘pursuing our legitimate business interests (i.e., analyse, grow, and administer the Platform).
      • IP address. When you visit and browse the Platform, we or our third-party analytics service providers collect your IP address. We use your IP address to analyse the technical aspects of your use of the Platform, prevent fraud and abuse of the Platform, and ensure the security of the Platform. The legal basis that we rely on when processing your IP address is ‘pursuing our legitimate business interests (i.e., to analyse and protect the Platform). We store such data as long as it is necessary for analytics purposes but no longer than 2 years.
      • Cookies. When you browse the Platform, we collect your cookie-related data. The legal bases on which we rely are ‘pursuing our legitimate business interests’ (i.e., to analyse and promote our business) and ‘your consent’. We store such data as long as it is necessary for analytics purposes (but no longer than 5 years), your cookies expire, or until you withdraw your consent.
    2. Sources of personal data. We obtain your personal data from the following categories of sources:
      • Directly from you. For example, if you submit certain personal data directly to us when registering on the Platform, completing the necessary forms, or contacting us.
      • Directly or indirectly through your activity on the Platform. When you use the Platform, we automatically collect technical information about your use of the Platform.
      • From third parties. We may receive information about you from third parties to whom you have previously provided your personal data, if those third parties have a lawful basis for disclosing your personal data to us.
    3. Log files and analytics data. In order to analyse your use of the Platform, we and our analytics service providers automatically collect certain technical non-personal data about your use of the Platform. Such data does not allow us to identify you as an individual person in any manner. The non-personal data includes the following information:
      • Your activity on the Platform
      • Your device type
      • The operating system of your device
      • Your browser type
      • URL addresses clicked to and from the Platform
      • Your other online behavior
    4. Your feedback. If you contact us, we may keep records of any questions, complaints, recommendations, or compliments made by you and any subsequent responses. Where reasonably possible, we remove all personal data that is not necessary for keeping such records.
    5. Purposes of technical (non-personal) data. We use your technical (non-personal) data for the following purposes:
      • To analyse what kind of users visit the Platform
      • o examine the relevance, popularity, and engagement rate of the Content
      • To investigate and help prevent security issues and abuse
      • To develop and provide additional features to the Platform
      • To personalize the Platform for your specific technical needs (e.g., to adjust the design and resolution for your device)
  3. RETENTION PERIOD OF THE PERSONAL DATA
    1. Retention of personal data. Your personal data is stored in our systems only for as long as such personal data is required for the purposes described in this Privacy Notice or until you request us to delete your personal data, whichever comes first. After your personal data is no longer necessary for its primary purposes and we do not have another legal basis for storing it, we securely delete your personal data from our systems.
    2. Retention of technical (non-personal) data. We retain non-personal data pertaining to you for as long as necessary for the purposes described in this Privacy Notice. For example, we can store it for the period of time needed for us to pursue our legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes and enforce our agreements.
    3. Retention as required by law. In certain cases, we are required by law to store your personal data for certain period of time (e.g., for business records or accountancy purposes). Thus, we keep your personal data for the time period stipulated by the applicable law and securely delete it as soon as the required storage period expires.
  4. DISCLOSURE OF PERSONAL DATA
    1. Disclosure to data processors. From time to time, your personal data is disclosed to our service providers with whom we cooperate (our data processors). For example, we share your personal and non-personal data with entities that provide certain technical support services to us, such as hosting and email distribution services. We do not sell your personal data to third parties. The disclosure is limited to the situations when your personal data is required for the following purposes:
      • Ensuring the proper operation of the Platform
      • Ensuring the delivery of the Content that you have purchased
      • Providing you with the requested information
      • Pursuing our legitimate business interests
      • Enforcing our rights, preventing fraud, and security purposes
      • Carrying out our contractual obligations
      • If you provide your prior consent to such a disclosure
    2. List of our data processors. We use a limited number of data processors. We choose them only if they agree to ensure an adequate level of protection of your personal data that is consistent with this Privacy Notice and the applicable data protection laws. The data processors that have access to your personal data are:
      • Our hosting and cloud storage service provider
      • Our registered professional service providers
      • Our email marketing service provider
      • Our analytics service provider
      • Our marketing service provider
      • Our independent contractors and consultants
    3. Disclosure of technical (non-personal) data. Your technical (non-personal) data may be disclosed to third parties for any purpose. For example, we may share it with prospects or partners for business or research purposes, for improving the Platform, planning the Content, responding to lawful requests from public authorities or developing new products and services.
    4. Legal requests. If we are contacted by a public authority, we may need to disclose information about you to the extent necessary for pursuing a public interest objective, such as national security or law enforcement.
    5. Successors. In case the Platform is sold partly or fully, we will provide your personal data to a purchaser or successor entity and request the successor to handle your personal data in line with this Privacy Notice. We will notify you of any changes of the data controller.
    6. Selling personal data. We do not directly sell your personal data to third parties. However, some of your personal data, including online identifiers (e.g., cookie-generated data and IP addresses) may be used for advertising, marketing, and monetization purposes (e.g., programmatic advertising, retargeting, third-party marketing, profiling, or cross- device tracking). To make sure that you have full transparency and control over your personal data, we provide you with a possibility to manage your personal data used for such purposes as described in this notice below.
  5. PROTECTION OF PERSONAL DATA
    1. Our security measures. We implement organizational and technical information security measures to protect your personal data from loss, misuse, unauthorized access, and disclosure. The security measures taken by us include:
      • Secured networks
      • SSL protocol
      • Encryption
      • Strong passwords
      • Password hashing
      • Limited access to your personal data by our staff
    2. Security breaches. Although we put our best efforts to protect your personal data, given the nature of communications and information processing technology and the Internet, we cannot be liable for any unlawful destruction, loss, use, copying, modification, leakage, and falsification of your personal data that was caused by circumstances that are beyond our reasonable control. In case a serious breach occurs, we will take reasonable measures to mitigate the breach, as required by the applicable law. Our liability for any security breach will be limited to the highest extent permitted by the applicable law.
  6. COMMUNICATION
    1. Newsletters. If we have your email address, we may send you a newsletter to keep you updated about the latest developments related to the Platform and our special offers. You will receive our newsletters in the following instances:
      • If we receive your express (“opt-in”) consent to receive marketing messages
      • If you voluntarily subscribe for our newsletter
    2. Opting-out. You can opt-out from receiving our commercial communication at any time free of charge by clicking on the “unsubscribe” link included in our newsletters, adjusting the settings of your user account, or by contacting us directly.
    3. Service-related notices. If necessary, we will send you important informational notices, such as appointment confirmations, technical or administrative emails, and other administrative updates. Please note that such notices are sent on an “if-needed” basis and they do not fall within the scope of commercial communication that may require your prior consent. You cannot opt-out from service-related notices.
    4. Complaints. If you would like to launch a complaint about the way in which we process your personal data, we kindly ask you to contact us first and express your concerns. If we receive your complaint, we will investigate it and provide you with our response as soon as possible. If you are not satisfied with the outcome of your complaint, you have the right to lodge a complaint with your data protection authority located in the United Arab Emirates.
  7. TARGETED ADVERTISING
    1. You may be served targeted interest-based advertisements on the Platform and other websites on the Internet. Such advertisements are generated on the basis of your use of the Platform, other websites on the Internet, and the data generated by cookies installed in your browser for more information.
    2. You can control how targeted advertising is shown to you or opt-out from targeted advertising. Please note that, depending on the country where you reside, advertisements are served and third-party marketing activities are conducted on an opt-in or opt-out basis.
  8. GOVERNING LAW AND JURISDICTION
    1. You agree that all questions respecting the negotiation, execution, construction, performance, interpretation, breach, or enforcement of this agreement or the rights, obligation and liabilities of you and us shall be determined in accordance with the applicable provision of the law of the United Arab Emirates. Should any party in this agreement assert that a violation has occurred; the party shall have the right and entitlement to take action to remedy the violation or issue in the Dubai Courts. The decision by the Dubai Courts is final and binding on all the parties to this agreement and the decision is enforceable on the other party in their competent jurisdiction.