This is the TECHBRIDGE MEA PRIVACY POLICY
The controller as per the Federal Decree by Law No. (45) of 2021 Concerning the Protection of Personal Data and EU General
Data Protection Regulation (GDPR) is:
TechBridge FZCO, a private company limited by shares incorporated and registered in Jebel Ali Freezone, whose registered
office is LB181002WS02, Jebel Ali Free Zone, Dubai, United Arab Emirates, with company registration number 6085550
Data protection officer for TECHBRIDGE MEA entities:
Officer Corporate Data Protection
Email: legal@tbdistr.com

Privacy Policy

We appreciate you visiting our website and your interest in the products we offer. We place a high priority on protecting your personal information. This Privacy Policy explains the collection, use, sharing, and other processing of your Personal Data (as defined below) by TechBridge FZCO private company limited by shares incorporated and registered in Jebel Ali Freezone, whose registered office is LB181002WS02, Jebel Ali Free Zone, Dubai, United Arab Emirates and TBD Trading LLC, a company registered in the Dubai, United Arab Emirates, with Professional license number 1306669, whose registered office is Office Number 001, Al Safeenah Bldg., (Malaysia Trade Centre Building) Oud Metha, Dubai, United Arab Emirates, (collectively, “TechBridge” “we,” “us,” or “our”), as well as your rights in relation to it.

1. DEFINITIONS

“Personal Data” means any data which relates to a living individual who can be identified from that data or from that data and other information which is in the possession of, or is likely to come into the possession of TechBridge (or its representatives or service providers). In addition to factual information, it includes any expression of opinion about an individual and any indication of the intentions of TechBridge or any other person in respect of an individual.

“Controller”, “data controller”, “processor”, “data processor”, “data subject”, “Personal Data”, “processing” and “appropriate technical and organisational measures”: as set out in the Federal Decree by Law No. (45) of 2021 Concerning the Protection of Personal Data.

“Data Protection Legislation”: All applicable laws and regulations relating to the processing of Personal Data including the UAE Data Protection Legislation and the EU’s General Data Protection Regulation (“GDPR”) (2016/679/EC), including all law and regulations implementing or made under them and any amendment or re-enactment of them and all other legislation and regulatory requirements in force from time to time which apply to a party relating to the use of Personal Data (including, without limitation, the privacy of electronic communications) any other applicable data protection legislation;

“UAE Data Protection Legislation”: all applicable data protection and privacy legislation in force from time to time in the UAE including Federal Decree by Law No. (45) of 2021 Concerning the Protection of Personal Data as amended.

2. THE SOURCES OF THE INFORMATION WE COLLECT

2.1. This Privacy Policy concerns the following sources of information that we collect in connection with our products and services, which include:

− Our website (e.g., “https://mea.tbdistr.com/”), emails, and marketing communication; as you interact with our website, we will 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. Please see our Cookie Policy at https://mea.tbdistr.com/wp-content/uploads/2024/02/Cookies-Policy.pdf for further details;

− Information we receive through our business partners and vendors. We are not responsible for any failure on the part of our partners and vendors to obtain explicit consent of the Personal Data subject in accordance with the applicable legal provisions;

− Information we receive through and from all of our services;

− Third parties or publicly available sources. We will receive Personal Data about you from various third parties and public sources as set out below:

  • Technical data from the following parties:
    (i) Analytics providers such as Google; and
    (ii) Search information providers such as Lexis Nexis.
  • 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.

3. DATA PROTECTION

Our Privacy Policy on the use of our websites does not apply to your activities on the websites of social networks or other providers that can be accessed using the links on our websites. Please read the data protection provisions on the websites of those providers.

4. COLLECTING AND PROCESSING YOUR PERSONAL DATA

4.1. We collect certain information whenever you visit our websites, including the type of browser and operating system you are using, the date and time of your visit, the interaction status (e.g., whether you were able to access the website or received an error message), how you use the website’s features, any search terms you enter, the frequency of your visits to different websites, the names of the files you access, the amount of data transferred, the URL you came from before visiting our website, and the URL you visited after visiting our website, whether through links on our websites or by typing a domain directly into the input field of the tab (or window) of the browser in which you have our websites open.

4.2. We only process other Personal Data if you, our partner, or third party provide this data, e.g. as part of a registration, contact form, chat, survey, price competition or for the execution of a contract. In these instances, we will obtain your explicit consent in accordance with the applicable legal provisions. You have the right to withdraw your consent at any time. Please note that if we received your Personal Data from our partner or any other third party, we are not responsible if the partner or third party failed to obtain explicit consent of the Personal Data subject in accordance with the applicable legal provisions.

4.3. Sharing your personal information is not generally required by law or contract; it may be necessary to provide certain services or functionalities on our websites. Some functions on our websites, though, could require exchanging Personal Data. These functions might not be available to you or might only be partially functioning if you do not give your personal information in these situations.

4.4. Purposes of use
We may process your Personal Data for the following purposes (“Permitted Purposes”):
− for ongoing review and improvement of the information provided on TechBridge website to ensure it is user-friendly and to prevent any potential disruptions or cyberattacks;
− to allow you to use and access the functionality provided by the TechBridge products and the services;
− to assess your application for TechBridge products and services, where applicable;
− to understand feedback on TechBridge products and services and to help provide more information on the use of those products and services quickly and easily;
− to communicate with you in order to provide you with: (i) our products and services; (ii) information about us and our products and services; or (iii) offers and marketing information, subject to your consent where required by applicable law;
− to send you e-mail updates on the latest IT trends, news, upcoming events and other marketing or promotional materials;
− to understand your needs and interests;
− for the management and administration of our business;
− for improvement of our products and services;
− to comply with and to assess compliance with applicable laws, rules and regulations, and internal policies and procedures;
− for the administration and maintenance of databases storing Personal Data to market TechBridge’s products and services; or
− for back-up and data loss prevention.

4.5. When we process Personal Data, we verify the existence of a lawful ground for such processing activity, including:
4.5.1. performing our contractual obligations;
4.5.2. a lawful consent has been obtained;
4.5.3. compliance with legal or regulatory obligation;
4.5.4. exercising or defending our rights;
4.5.5. legitimate business interests, such as:
(i) effectively and efficiently manage and administer the operation of our business;
(ii) maintaining compliance with internal policies and procedures;
(iii) enabling quick and easy access to information on our products and services;
(iv) sending you e-mail updates on our products and services, the latest IT trends, news, upcoming events, and other marketing or promotional materials.

4.6. We will take steps to ensure that your Personal Data is accessed only by such individuals that have a need to do so for the purposes described in this Privacy Policy.

4.7. We do not retain, use, sell or disclose Personal Data for any purpose other than for the specific purpose of providing our products and services as well as performing our contractual obligation or as otherwise strictly permitted under this Privacy Policy.

4.8. We utilize the Personal Data we obtain when you visit our website to safeguard our IT systems from attacks and other illegal activity and to make using them as convenient as possible for you.

4.9. If you provide us with additional information, such as through a survey, chat, registration form, we will use it for customer management, the specified purposes.

4.10. Furthermore, we utilize personal information only to the extent that we are required by law to do so (for example, storing data to satisfy commercial or tax-related retention requirements, or releasing data in compliance with official or judicial mandates, such as those issued to law enforcement authorities).

5. TRANSFER TO THIRD PARTIES; SOCIAL PLUGINS; USE OF SERVICE PROVIDERS

5.1. Our websites may also contain offers from third parties. When you click on one of these offers, we only send the necessary data to the relevant provider such as the fact that you found the offer through us and, if relevant, any additional information you have previously submitted on our websites for this purpose. This data is shared securely and only with your consent, where required by applicable law. Please note that we are not responsible if the partner or third party failed to obtain explicit consent of the Personal Data subject in accordance with the applicable legal provisions.

5.2. We integrate social plug-ins from social networks like Facebook and LinkedIn into our websites in the following ways:

5.3. When you visit our websites, the social plug-ins are turned off, so the owners of these networks do not receive any data. Click on the appropriate social plug-in to establish a direct connection to the network server in order to access a specific network. Should you have a user account with the network and be logged in when you activate the social plug-in, the network may associate your visit to our websites with your account. If you would like to avoid this, please log off the network before turning on the social plug-in.

5.4. When you activate a social plug-in, the available content is sent across the network to your browser, which then integrates it into our websites. In this case, there may also be data transmissions initiated and controlled by the relevant social network. Your connection to a social network, data transfers between it and your system, and activity on its platform are all governed by its privacy policies. The social plug-in remains active until you deactivate it or delete your cookies. Please see our Cookies Policy https://mea.tbdistr.com/wpcontent/uploads/2024/02/Cookies-Policy.pdf for further details.

5.5. When you click on an offer or enable a social plug-in, personal information may be accessed by providers located outside of the UAE. These providers may not provide a level of protection for the processing of personal information that is considered “adequate” under data protection standards defined by UAE Law. Before you click on a link or activate a social plug-in and cause a transfer of your data, please keep this in mind.

5.6. We also use qualified service providers (e.g., IT service providers, marketing agencies) to operate, optimize and secure our websites. We only pass on Personal Data to the latter when it is necessary for the provision and use of the website and its functionalities, for the pursuit of legitimate interests, to comply with legal obligations, or when you have explicitly consented to it. Please note that if we received your Personal Data from our partner or any other third party we are not responsible if the partner or third party failed to obtain explicit consent of the Personal Data subject in accordance with the applicable legal provisions. You will find more information regarding recipients of Personal Data in our consent management system under “Cookies Policy” in the footer at the bottom of the website.

6. COOKIES

6.1. Cookies and similar software tools such as HTML cookies, Web/DOM Storage, and Local Shared Objects (also known as “Flash cookies”) may be used when you visit our websites. These tools enhance your user experience by remembering your preferences, tracking your activities on our site for analytics purposes, and providing personalized content.

6.2. Cookies are small files that are stored, and later read out, on your desktop, notebook or mobile device while you visit a website. Cookies provide various features such as recognizing your usage-based interests, offering you specific functions, considering your preferred language or other settings, and determining whether a connection has already been made between the device and the websites. Cookies may include personal information, such as your browsing history or preferences. However, they will not store sensitive personal information like your name, address, or credit card details.

6.3. More details and choices for how to proceed are available in the “Cookies Policy” footer at the bottom of the webpage.

6.4. The settings of the web browser you are using, such as Microsoft Edge, Google Chrome, Apple Safari, or Mozilla Firefox, also affect how cookies are used. You may normally modify your web browser’s default setting to automatically accept specific types of cookies. Stored cookies are always removable. It is possible to remove local shared objects and web/DOM storage independently. The user manual or help guide for the browser or device you are using will explain how this operates.

6.5. Acceptance, rejection, and removal of cookies are dependent on the device and the specific web browser you are using. You can choose to use alternative settings or decisions if you use different devices or web browsers.

6.6. Features such as personalized content, saved preferences, and usage tracking might not be available to you or might only work partially if you choose to disable or reject cookies.

7. SECURITY

To prevent authorized individuals from tampering, losing, destroying, or accessing your information under our management, we implement both technical and organizational security measures. In keeping with technical developments, we are always enhancing our security protocols.

8. DATA RETENTION

8.1. 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.

8.2. 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.

8.3. By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for five years after they cease being customers for tax purposes.

8.4. In some circumstances you can ask us to delete your data: see the ‘Your Legal Rights’ section below for further information.

8.5. 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.

8.6. Whilst we continue to process your Personal Data we will ensure that it is treated in accordance with this Privacy Policy. Otherwise, we securely erase your information once it is no longer needed.

9. YOUR LEGAL RIGHTS

9.1. Under certain circumstances, you have rights under data protection laws in relation to your Personal Data. The various rights are not absolute and each is subject to certain exceptions or qualifications. We will grant your request only to the extent that it follows from our assessment of your request that we are allowed and required to do so under data protection laws. Nothing in this Privacy Policy is intended to provide you with rights beyond or in addition to your rights as a data subject under data protection laws.

9.2. You have the right to:

  • request access to your Personal Data (commonly known as a “data subject access request”). This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it;
  • request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us;
  • request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your Personal Data to comply with local law. Note that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request;
  • object to processing of your Personal Data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms;
  • request restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of your Personal Data in the following scenarios:
    • (a) where you want us to establish the data’s accuracy;
    • (b) where our use of the data is unlawful but you do not want us to erase it;
    • (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
    • (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it;
  • request the transfer of your Personal Data to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you; and
  • withdraw consent at any time where we are relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

9.3. We ask you to address your claims or declarations to the following contact address if possible: legal@tbdistr.com. We try to respond to all legitimate requests within one month. Occasionally it could take us longer 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. NEWSLETTER

If you subscribe to a newsletter offered on our website, the information provided during registration for the newsletter will be used solely for the purpose of mailing the newsletter unless you consent to its use for additional purposes. You may cancel the subscription at any time by using the option to unsubscribe contained in the newsletter.

11. DATA TRANSMISSION OUTSIDE THE UAE

11.1. We may disclose your Personal Data to affiliated companies, third parties that provide services to us that reasonably require access to Personal Data relating to you for one or more of the purposes outlined in the “Purposes of use” section above. The following external parties may for instance be involved:
− external service providers, we rely on for various business services;
− law enforcement authorities under the relevant legislation;
− external professional advisors (e.g. attorneys or consultants of TechBridge).
If our business enters into a joint venture with or is sold to or merged with another business entity, your information may be disclosed to our new business partners or owners.

11.2. Please note that some of the recipients of your Personal Data referenced above may be based in countries outside of the UAE whose laws may not provide the same level of data protection. Should this be the case appropriate safeguards to process your Personal Data under the data protection legislation have been taken.

11.3. Whenever we transfer Personal Data out of the UAE, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
− we will only transfer Personal Data to countries that have been deemed to provide an adequate level of protection for Personal Data and if the country upholds its own data protection legislation that does not contradict with the UAE Personal Data protection law, and is in bilateral or multilateral agreements on data protection legislation;
− we may use specific agreements with foreign companies to comply with the UAE Personal Data protection law, and where either consent is provided or the transfer is contractually necessary.

11.4. We also want to clarify that we may receive Personal Data from our partners from outside of the UAE. Therefore, we are not responsible if these partners fail to obtain the explicit consent of the Personal Data subject in accordance with the applicable legal provisions. In general, we will take all steps reasonably necessary to ensure that your data is treated securely and under this Privacy Policy.

11.5. We reserve the right to disclose your personal information as required by law, or when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, request from a regulator or any other legal process served on us.