PRIVACY POLICY

Last updated on 21 August 2024

We, QORE MANAGEMENT CONSULTANCIES CO. L.L.C., a company duly incorporated under the laws of the UAE, company address: THE BINARY BY OMNIYAT, Office # 2101-0147, Marasi Drive, Business Bay, Dubai, UAE, UAE License number 1071522, UAE Register number 1744478, (hereinafter referred to as “Company”), are committed to protecting your privacy as a user of this Website.

This Privacy Policy describes the purposes for which and the manner in which the Company collects, uses, stores, and discloses personal data or information collected from users of https://www.qoreadvisory.com/(hereinafter referred to as “Website”). It also describes your data protection rights. It also describes your data protection rights.

The data controller determines the purposes and means by which personal data is processed. With respect to this Website, the Data Controller is the Company.

The Company processes your personal information in accordance with General Data Protection Regulation or “GDPR”: the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC.

By using our Website and/or providing your personal information, you consent to us handling your personal information per this Privacy Policy.

This Privacy Policy may be updated periodically. We will update the date at the top of this Privacy Policy accordingly.

COLLECTION OF INFORMATION

We use different methods to collect data from and about you including through: Direct interactions.

You may give us your Identity, Contact and Financial Data (as defined above) by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
a. create and verify an account on our website;
b. access our Website and use our Services;
c. request marketing to be sent to you; or
d. give us feedback or contact us.

Automated technologies or interactions.

As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We may collect this personal data by using cookies, server logs and other similar technologies.

Third parties or publicly available sources.

We may receive personal data about you from various third parties and public sources including but not limited to social media, search engines, corporate registers and other registers, virtual asset service providers, KYC/AML/CFT service providers (including e-KYC) and screening data vendors.

USE OF PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
a. Where we need to perform the contract (in this case, our Terms of Use) we are about to enter into or have entered into with you.
b. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
c. Where we need to comply with a legal obligation.
d. Where you have provided us with your consent.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. In order to access our Website and Services you will first have to enter into a contract with us governing our relationship. The contract in question is the Terms of Use.

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best Services and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Generally, we do not rely on consent as a legal basis for processing your personal data, with the exception of our marketing and advertising activities. We will ensure to provide you with clear and concise information regarding what you consent to and make it easy for you to withdraw consent at any time.

Purposes for which we use your personal data

We have set out below, in a table format, 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.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have designed a dedicated section on the Website which allows you to view and decide how we use your personal data for marketing purposes. You have the right to withdraw consent to marketing at any time by changing your Notifications preferences in your account Settings.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which Services and offers may be relevant for you (we call this marketing).

You will receive marketing communications if you have requested information from us or accessed certain Services from those available on our Website and have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your data with any third party for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time through the Website by either: checking or unchecking relevant boxes to adjust your marketing preferences in your account, by following the opt-out links on any marketing message sent to you, or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of Service purchase, Service experience, or other transactions.

Cookies

We use cookies and similar technologies to enhance your user experience, provide our Services, and understand how customers use our Services. If you want to learn more about how we use cookies and your choices regarding them, please read our Cookie Policy.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is
compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

DISCLOSURES OF YOUR PERSONAL DATA

We may share your personal data with certain parties as set out below:

a. Internal Third Parties (Affiliated companies of the Company).
b. External Third Parties (Third-party service providers, including financial institutions, KYC and anti-fraud service providers, cloud storage providers, customer support software providers, analytics providers, project management providers, communication providers, auditors, virtual asset service providers, regulators, and law enforcement).
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

We may share your personal data with the third-party providers. This may involve transferring your data outside the Gulf Cooperation Council (GCC).
Please also note that some of our external third parties are based outside the GCC as well, so their processing of your personal data will also involve a transfer of data outside the GCC.

Whenever we transfer your personal data out of the GCC, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

a. We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
b. Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in the EU. For further details, see European Commission: Model contracts for the transfer of personal data to third countries (external link).

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the GCC.

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.

DATA RETENTION

We will only retain your personal data for as long as reasonably necessary to fulfil 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 unauthorised 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.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for a minimum of five (5) years after they cease being customers for compliance purposes. We may retain your personal data for a longer period if required by any other applicable law, regulatory obligations, statutory time limits or accounting/tax regulations.

In some circumstances you can ask us to delete your data – please see the section below for further information about this.

In some circumstances, we will anonymise 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.

YOUR LEGAL RIGHTS

Your principal rights under the GDPR are:
a) the right to access: you can ask for confirmation as to whether or not we process your personal information and to access the personal information, together with certain additional information.
b) the right to rectification and erasure: you can ask for rectification of any inaccurate information about you, or to the erasure of such information without undue delay in certain circumstances (e.g., when it’s used for direct marketing, you withdraw consent, the personal information is
no longer necessary, etc.).
c) the right to restrict processing: in some circumstances, you have the right to restrict the processing (e.g., when you contest the accuracy of the personal data; processing is unlawful but you oppose erasure, etc.).
d) the right to object to processing: on grounds relating to your particular situation unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defense of legal
claims.
e) the right to data portability: to the extent that the legal basis for our processing of your data is: (a) consent; or (b) that the processing is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into a contract, and such processing is carried out by automated means, you have the right to receive your data from us in a structured, commonly used and machine-readable format.
f) the right to complain to a supervisory authority: you have a legal right to complain, if you consider that our processing of your personal information infringes data protection laws. g) the right to withdraw consent: will not affect the lawfulness of processing before the withdrawal.

If you wish to exercise any of the rights set out above, please contact us at info@qoreadvisory.com;.

Please note that by being an entity subject to local and international anti-money laundering, counter terrorist financing and other related regulations, we are obliged to follow relevant regulatory requirements which trigger the restriction on your privacy rights in relation to your personal data.

No fee usually required

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.

What we may need from you

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.

Time limit to respond

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.

COOKIES POLICY

A cookie is a file sent by a web server to a web browser that contains an identifier (a string of letters and numbers) and is saved by the browser. There are two types of cookies: “persistent” and “session.” A persistent cookie will be saved by a web browser and will remain valid until its set expiration date unless the user deletes it before its expiration date; in contrast, a session cookie will expire at the end of the user session when the web browser is closed. Cookies do not typically contain any information that personally identifies a user.

Our use of cookies

We may use cookies to:
a. recognise you whenever you use the Website (this speeds up your access as you do not have to log in each time);
b. prevent fraud on our website;
c. remember your preferences and your device so the Website works as expected;
d.provide visitors with the relevant version of the website;
e. assist with our promotional and marketing efforts;
f. carry out research and statistical analysis to help improve our content, products and services and to help us better understand our users’ requirements.

For further information on cookies generally, visit www.aboutcookies.org or www.allaboutcookies.org.

Types of cookies

There are two types of cookies depending on their lifetime:
a. Session cookies—these allow us to link your actions during a particular session. These expire each time you close the Website and do not remain on your device afterwards.
b. Persistent cookies—these are stored on your device in between sessions. These allow your preferences or actions to be remembered. These will remain on your device until they expire, or you delete them from your cache.

By domain, there are first-party and third-party cookies:
a. First-party cookies are set by the domain pertaining to our website; and
b. Third-party cookies are stored by a different domain to the website’s domain.

The cookies placed on your device fall into the following categories by their purpose:

a. Strictly necessary cookies – these cookies are essential for the operation of the Website and for you to use its features. For example, we may use these cookies to ensure fraud prevention or help you log in to our Website and fill in forms more easily. We also use these types of cookies to ensure that our Website is displayed correctly on your device. Without these cookies, the services you have asked for may not be provided.
b. Functional cookies – these cookies enable the Website to provide enhanced functionality and personalisation. If you do not allow these cookies then some or all of these services may not function properly.
c. Analytical/Performance cookies – these cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site. If you do not allow these cookies we will not know when you have visited our site and will not be able to monitor its performance. All information collected by these cookies is only used to improve how our Website works.
d. Targeting cookies – these cookies are used to deliver adverts more relevant to you and your interests. They may be used to limit the number of times you see an advertisement and help measure the effectiveness of an advertising campaign. They are usually placed by advertising networks with the Website operator’s permission, and the information collected may be used, for example, to provide measurement services or target ads.

We use the following cookies:

Google Analytics

The Website uses Google Analytics for web analytics. To view an overview of the privacy of your Google Analytics cookies please go here: https://support.google.com/analytics/answer/6004245. You may install a Google Analytics opt-out browser add-on by going here: https://tools.google.com/ dlpage/gaoptout?hl=en-GB.

Third Party Cookies

Please note that, throughout the Website, we may link to other websites or applications owned and operated by certain trusted third parties. Some of these third-party websites may also use cookies which are likely to be analytical, performance or targeting cookies– or similar technologies, according to their own separate cookie policies. For privacy information relating to third-party websites and cookies (over which we have no control) please refer to their policies as appropriate.

Managing cookies

You can accept all cookies, delete specific website cookies, or reject all cookies. Please note that if you block all cookies, you will not be able to use all the features on our Website.

You can find information about managing cookies via the following links:

Chrome: https://support.google.com/chrome/answer/95647
Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
Opera:https://help.opera.com/en/latest/security-and-privacy/
Internet Explorer:https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete manage-cookies
Edge: https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy
Safari: https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac

CONTACT & COMMUNICATION WITH US

If you would like further information about the way we collect, store and use your personal information; if you have a complaint or general queries; if you would like to change or delete your personal information, please contact us by email at info@qoreadvisory.com