DATA USE POLICY
This policy describes the information we process for the operation of INVESTDUBAI and all associated Products and Services.
  • 1. Types of information collected
    To provide the INVESTDUBAI Services, we need to process information about Users. The types of information we collect depend on how they use our Services.

    Learn how to access and delete the information we collect by visiting the INVESTDUBAI Settings.
  • 1.1. What Users Do and Provide
    - Information and content you provide. 
    We collect content, communications, and other information that Users provide when they use our Services, including when they create an account. 

    - Specially Protected Data 
    Users may choose to provide information in their INVESTDUBAI profile fields. This and other information (such as racial or ethnic origin, philosophical beliefs, or trade union membership) are subject to special protections under European law.

    - Use 
    We collect information about how Users use our Services, such as the features they use, the actions they take and the time, frequency and duration of their activities.
    We also collect information about how they use our features.

    - Information about transactions on our Services
    If Users use our Services to make purchases or other financial transactions, we collect data about that purchase or transaction. 
    This includes their payment information, such as your credit or debit card number and other card information, other account and authentication information, as well as billing and shipping information, and contact information.
  • 1.2. Device Information 
    As described below, we collect information about and from the computers, phones, connected televisions and other web-connected devices that Users use and that integrate with our Services, and we combine this information across the different devices used. 

    The information we obtain from these devices includes the following: 

    - Device Attributes
    Information such as operating system, hardware and software versions, battery level, signal strength, available storage space, browser type, name and type of applications and files, and plugins.

    - Activities on the device
    Information about operations and behaviour on the device.

    - Device signals
    Bluetooth signals and information about nearby Wi-Fi hotspots, beacons and telecommunication towers.

    - Data from device settings
    Information that Users allow us to receive through the settings of the device they activate.

    - Network and connection
    Information such as the name of the mobile operator or internet service provider, language, time zone, mobile phone number, IP address, connection speed and, in some cases, information about other devices in the vicinity or on the network.

    - Data from cookies
    Data from cookies stored on Users' devices, including cookie identifiers and settings.
  • 1.3. Information provided by the partner 
    Advertisers, application developers and publishers may send us information.
    These partners provide information about Users' activities outside of INVESTDUBAI (including information about their device, the websites they visit, the purchases they make, the advertisements they see, and their use of their services), regardless of whether Users have an INVESTDUBAI account or are logged into INVESTDUBAI. Partners receive data from Users either when they access or use their services or through third parties with whom they work. 

    We require that each partner be legally authorized to collect, use and share User data before providing it to us.
  • 2. Use of this information
    We use the information available to us as described below, in order to provide and operate the INVESTDUBAI Services and the related services described in the INVESTDUBAI TOU.
  • 2.1. To offer, personalise and improve our Services
    We use the information at our disposal to provide our Services, in particular to personalise their features.

    - Information about all INVESTDUBAI Services and devices
    We link information about Users' activities across different INVESTDUBAI Services and devices to provide them with a more personalized and consistent experience across all INVESTDUBAI Services they use, regardless of the medium on which they use them. We may also make their experience more seamless, for example, by automatically filling in their registration information (including phone number) from an INVESTDUBAI Service when they create an account.

    - Geographic Information
    We use geographic information (such as current location, place of residence, places Users like to go, and businesses and people nearby) to provide, customize, and improve our Services, including advertisements, for Users. This geographic information may include, but is not limited to, the precise location of devices, IP addresses, and information about how Users (and others) use the INVESTDUBAI Services (including visits or events that Users attend).

    - Research and Development of the Services
    We use the information at our disposal to develop, test and improve our Services, including conducting surveys and research, and testing and troubleshooting new products and features.

    - Advertisements and Other Sponsored Content
    We use the information about Users available to us (including information about their interests, actions, and connections) to select and customize the advertisements, offers, and other sponsored content that we show you.
  • 2.2. Safety, integrity and security
    We make every effort to verify accounts and activities, to combat unsafe behaviour, to detect and prevent unwanted content and other negative experiences, to maintain the integrity of our Services and to promote safety and security on and off the INVESTDUBAI Services.
  • 2.3 Communication with Users
    We use the information available to us to send marketing communications to our Users, to tell you about our Services and to inform them of our terms and regulations. We also use their information to respond to you when they contact us.
  • 3. Sharing of this information
  • 3.1 New owner
    If ownership or control of some or all of our Products or their components changes, we may share User information with the new owner.
  • 3.2 Sharing with Third Party Partners
    We work with third party partners who help us provide and improve our Services or who use INVESTDUBAI professional tools to develop their business. We do not sell any User information to anyone and will never do so. We also place strict restrictions on how partners may use and disclose the data we share with them. The types of third parties with whom we share information include

    Companies in the same group

    INVESTDUBAI belongs to the GREENBULL GROUP. In the context of the proper functioning of the Services and in order to offer a complete experience and synergy between the various activities of the Group that may be of interest to Users, User data may be made available to subsidiaries of the Group.

    Advertisers

    We provide advertisers with reports on the types of people who see their ads and the performance of their ads, but we do not share personally identifiable information about Users (information such as their name or email address that can be used to contact or identify them) unless Users give us permission to do so.

    Suppliers and Service Providers.

    We provide information and content to suppliers and service providers who support our business, including providing technical infrastructure services, analyzing the use of our Services, providing customer service, facilitating payment processes or conducting surveys.

    Law enforcement or legal requests.

    We share information with law enforcement or in response to legal requests.
  • 4. Collaboration between INVESTDUBAI and entities of the same Group
    INVESTDUBAI shares its infrastructure, systems and technology with other entities in the same group in order to provide Users with an innovative, relevant, consistent and safe experience across the Services and products of GREENBULL GROUP entities. We also process User information across GREENBULL GROUP entities for these purposes, to the extent permitted by applicable law and in accordance with their terms and policies.
  • 5. Legal Basis
    We collect, use and share data in our possession in the ways described below:

    - To the extent necessary to comply with our INVESTDUBAI Terms and Conditions of Use;
    - In compliance with Users' consent, which they may revoke at any time through the INVESTDUBAI settings;
    - To the extent necessary to fulfill our legal obligations;
    - To protect the vital interests of Users or those of others;
    - To the extent necessary in the public interest;
    - To the extent necessary for our (or others') legitimate interests, including our interests in providing an innovative, personalised, secure and beneficial service to our users and partners, unless those interests are overridden by the interests or fundamental rights and freedoms of Users requiring the protection of their personal data.
  • 6. Exercise of Rights under the GDPR
    In accordance with the General Data Protection Regulation, Users have the right to consult, rectify, transfer and delete their data.  They also have the right to object and restrict the processing of their data.
    This includes

    - the right to object to our processing of their data for direct marketing purposes;
    - the right to object to our processing of their data when we are carrying out a task in the public interest or when we are pursuing our legitimate interests or those of a third party.
  • 7. Data retention, deactivation and deletion of an account
    We store data until it is no longer necessary to provide our INVESTDUBAI Services, or until the Users account is deleted, whichever comes first.
    This is a case-by-case decision that depends on aspects such as the nature of the data, the reason for its collection and processing, and the legal or operational retention requirements involved. 
  • 8. Responding to legal requests
    We access, store and share User information with regulatory bodies, legal authorities or others:

    - To respond to a legal request, if we believe in good faith that the law requires it. We may also respond to legal requests when we believe in good faith that the response is required by the law of that jurisdiction, affects users in that jurisdiction, and is consistent with internationally accepted standards.

    - When we have a good faith belief that it is necessary to detect, prevent, and control fraud, unauthorized use of the Services, violations of our terms or regulations, or other unsafe or illegal activities; to protect ourselves (including our rights, property, or Services), Users, or others, including in connection with investigations or regulatory requests; or to prevent death or imminent bodily harm. User information we receive may be accessed and retained for an extended period of time when it is the subject of a legal request or requirement, a government investigation, or investigations of possible violations of our terms of use or regulations, or to prevent other harm. We also retain for a minimum of one year information about accounts that are deactivated as a result of a violation of the Terms of Use, in order to prevent repeat abuse or other violations of the Terms of Use.
  • 9. International data management and transfer
    We share information globally, both internally with Entities belonging to the same Group as INVESTDUBAI (GREENBULL GROUP and its subsidiaries), and externally with our partners and with those with whom Users connect and share content worldwide, in accordance with this policy.
    Information controlled by INVESTDUBAI will be transferred or transmitted to, or stored and processed in, the United Arab Emirates or other countries outside the country where Users live for the purposes described in this policy. These data transfers are necessary to provide the services set out in INVESTDUBAI's General Terms of Use, and to operate and provide our Services worldwide. 

    Information controlled by INVESTDUBAI will be transferred or transmitted to, or stored and processed in, the United Arab Emirates or other countries outside the country where Users live for the purposes described in this policy. These data transfers are necessary to provide the services set out in INVESTDUBAI's General Terms of Use, and to operate and provide our Services worldwide.
  • 10. Updating of this policy
    We will notify Users of any material changes to this Policy and provide them with the opportunity to review the revised version before continuing to use our Services.
  • 11. Addressing Questions
    Users can learn more about privacy on INVESTDUBAI.If they have any questions about this policy, they can contact us through the means described below.

    The data controller for the information is INVESTDUBAI, which Users may contact online or by mail at

    Greenbull Services FZ LLC
    Platinium tower - 30th floor
    Jumeirah Lakes Tower
    DUBAI
    UAE
Date of last revision: 1 April 2021