Privacy Policy

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HIYP Privacy Policy

Table of Contents

1. Background. 2

2. Key terms. 2

3. Personal data we collect about you. 2

4. How your personal data is collected. 3

5. Use of cookies. 3

6. The basis on which we process your personal data. 3

7. The personal data we obtain and process and why. 4

8. Marketing communications. 6

9. Who we share your personal data with. 6

10. Where your personal data is held. 7

11. How long your personal data will be held. 7

12. Transfers of personal data. 8

13. Your rights. 8

14. Keeping your personal data secure. 9

15. Actions in case applicable laws prevent compliance with this policy. 9

16. How to complain. 9

17. Updates to this privacy policy. 9

1. Background

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint.

We collect, use and are responsible for certain personal data about you. When we do so we are subject to applicable data protection laws and we are responsible as a ‘controller' of that personal data for the purposes of those laws. In some instances we may process personal data in our capacity as a processor, or an affiliate or a third party may process personal data on our behalf.

2. Key terms

Key terms used in this policy are as follows:

We, us, our

HIYP Corp L.L.C-FZ and our group companies

Personal data

Any information (in a form in which access to or processing

of the data is practicable) relating to you directly or indirectly  which allows us to practicably identify you.   This can include information such as name, voice, picture, identification   number, online identifier, geographic location, or one or more special   features that express your physical, psychological, economic, cultural or   social identity.

3. Personal data we collect about you

We may collect and use the following personal data about you:

· your name and contact information, including physical address, email address and telephone number, and where you represent a company, job position within the company;

· your username and password, to set up an account on our website;

· profile data such as your company of employment, occupation and biography if you have an account on our website;

· information to enable us to check and verify your identity, eg, your date of birth;

· your gender information,if you choose to give this to us;

· your billing information, transaction and payment card information, information provided by third party payment service providers such as PayPal in relation to a transaction by you;

· your purchase history, where you are purchasing products or services from us;

· information about how you use our website, IT, communication and other systems; 

· information obtained through cookies (please refer to the section titled “Use of cookies” below); and

· if you send us your curriculum vitae (CV) or resume when inquiring about a possible job with us, the information in your CV or resume.

This personal data is required to acquire products and services from you, or to provide products and services to you, or in connection with your employment or possible employment by us (as applicable). In the event that you do not provide the personal data as required, we may not be able to provide you with our products or services.

4. How your personal data is collected

We collect most of this personal data directly from you - via telephone, text messages, email, our website, apps, or through our social media accounts.  However, we may also collect information:

· from publicly accessible sources, eg, companies registries and other government agencies;

· from cookies on our website—for more information on our use of cookies, please refer to the section titled “Use of cookies” below explaining the information we may obtain through cookies; and

· from financial and other sanctions or embargoes lists.

5. Use of cookies

We may collect information about you automatically when you visit our websites. This information is not normally personally identifiable and includes general information about your computer settings and IT equipment, your connection to the internet, your IP address, your browsing patterns, your geographical location and your username and password. We may collect this information through the use of cookies.

A cookie is information which is sent to and stored by your computer when you first visit a website and it allows us to identify your computer (but not you) the next time you visit a website. We may use the information collected in this way to (i) track website usage; and (ii) adapt the website so that it better suits your interests.

Most internet browsers give you the option to reject all cookies, to accept all cookies, to erase cookies stored on your computer or to be notified before a cookie is stored on your computer. Your ease of use of our websites may be reduced if you reject all cookies. You will need to refer to your internet browser instructions to find out more about these options and how to use them.

We may store cookies which are essential for the operation of our websites on your device without your consent, pursuant to applicable laws. You may reject all other cookies through your internet browser but if you do so you may find that certain features on the website, such as online payment, do not work properly.

6. The basis on which we process your personal data

Under data protection laws, we can only process your personal data with your consent, or if we do not have your consent, where we have a proper reason for doing so, for example:

· for protection of national security or the public interest (eg the prevention or detection of crime);

· if the processing is for personal data that has become available and known to the public by your act;

· in connection with legal proceedings; 

· for archival purposes;

· to protect your interests;

· where necessary to fulfil our or your obligations and exercise our or your employment rights or social security rights;

· for the performance of our contract with you or to take steps at your request, to conclude, amend or terminate a contract with you;

· to fulfil obligations imposed on us by any state or investigation agency under whose jurisdiction we fall; or

· where any enactment, rule of applicable laws or an order of a court otherwise enables, requires, authorises us to do so, for example in accordance with our legitimate interests where any enactment, rule of applicable laws or an order of a court provides that this is a basis for processing personal data without consent. A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

7. The personal data we obtain and process and why

The table below explains what we use (process) your personal data for and our reasons for doing so:

What we process your personal data for

Our reasons

· Acquiring products and services from you or providing products and   services to you

· For the performance of our contract with you or to take steps at your   request, to conclude, amend or terminate a contract with you

· Screening for financial and other sanctions or embargoes

· To fulfil obligations imposed on us by any state or investigation   agency under whose jurisdiction we fall

· Preventing and detecting fraud against you or us

· To protect your interests 

· For protection of national security or public interest (eg the   prevention of crime)

· Gathering and providing information required by or relating to audits,   enquiries or investigations by regulatory bodies

· To fulfil obligations imposed on us by any state or investigation   agency under whose jurisdiction we fall

· For our legitimate interests

· Enabling us to understand and monitor our rights in any content   provided by you

· For the performance of our contract with you or to take steps at your   request, to conclude, amend or terminate a contract with you

· For our legitimate interests

· Operational reasons, such as improving efficiency, training and   quality control

· For our legitimate interests

· Ensuring the confidentiality of commercially sensitive information

· For the performance of our contract with you or to take steps at your   request, to conclude, amend or terminate a contract with you

· To fulfil obligations imposed on us by any state or investigation   agency under whose jurisdiction we fall

· Statistical analysis to help us manage our business, eg in relation to   our financial performance, customer base, product range or other efficiency  measures

· For our legitimate interests

· Preventing unauthorised access and modifications to systems

· For our legitimate interests 

· To fulfil obligations imposed on us by any state or investigation   agency under whose jurisdiction we fall

· For protection of national security or public interest (eg the   prevention of crime)

· Updating and enhancing customer records

· For the performance of our contract with you or to take steps at your   request, to conclude, amend or terminate a contract with you

· To fulfil obligations imposed on us by any state or investigation   agency under whose jurisdiction we fall

· For our legitimate interests

· Statutory returns

· To fulfil obligations imposed on us by any state or investigation   agency under whose jurisdiction we fall

· Ensuring safe working practices, staff administration and assessments

· To fulfil obligations imposed on us by any state or investigation   agency under whose jurisdiction we fall

· For our legitimate interests

· Marketing our services to:

- existing and former customers;

- third parties who have previously expressed an interest in our   services; and

- third parties with whom we have had no previous dealings.

· For our legitimate interests

· Staff recruitment

· For our legitimate interests

· Where necessary to fulfil our or your obligations and exercise our or   your employment rights or social security rights

· For the performance of our contract with you or to take steps at your   request, to conclude, amend or terminate a contract with you

· Operating and improving our website 

· For the performance of our contract with you or to take steps at your   request, to conclude, amend or terminate a contract with you

· For our legitimate interests

8. Marketing communications

We may use your personal data to send you marketing updates (by email, text messages, telephone or post) about our products and services.

We have a legitimate interest in processing your personal data for marketing purposes (see the above section titled “The personal data we obtain and process and why”). Where consent is needed to do so, we will ask for this consent separately and clearly.

We will always treat your personal data with the utmost respect and will never share it with other organisations (outside the HIYP group) for marketing purposes.

You have the right to opt out of receiving marketing communications at any time by:

· contacting us at ops@hiypcorp.com; or

· using the ‘unsubscribe' link in emails.

We may ask you to confirm or update your marketing preferences if you instruct us to provide further products or services in the future, or if there are changes in the law, regulation, or the structure of our business.

9. Who we share your personal data with

We routinely share personal data with:

· companies within the HIYP group (HIYP group companies are currently located in the United Arab Emirates and Hong Kong);

· service providers we use to help deliver our products and services to you, eg, payment service providers, wherever they are located;

· other service providers we use to help us run our business, eg, software and apps which enable us to manage our content library, our emails, contact information, and our financial processes, wherever they are located;

· if we have collected personal data in the course of providing or receiving services to or from a client, we may disclose the data to that client and, where permitted by law, to others for the purpose of providing those services. For example, we may provide your name to a customer so that content that we provide to that customer which you are the author of can be attributed to you; and

· our banks.

We only allow our service providers to process your personal data if we are satisfied they take appropriate measures to protect your personal data and your personal data will not be kept longer than is necessary for processing the data for the purpose(s) set out in this policy. We also impose contractual obligations on service providers to ensure they can only use your personal data to provide services to us and / or to you.

We or the third parties mentioned above, occasionally may also share personal data with:

· external auditors, eg, in relation the audit of our accounts;

· with courts, law enforcement authorities, regulators, government officials or attorneys or other parties where it is reasonably necessary for the establishment, exercise or defence of a legal or equitable claim, or for the purposes of a confidential alternative dispute resolution process;

· companies providing services for money laundering and terrorist financing checks, credit risk reduction and other fraud and crime prevention purposes and companies providing similar services, including financial institutions, credit reference agencies and regulatory bodies with whom such personal data is shared;

· our professional advisors; and

· other parties that have or may acquire control or ownership of our business (and our or their professional advisers) in connection with a corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency. Usually, information will be anonymised but this may not always be possible.

The recipient of the information will be bound by confidentiality obligations and is required to comply with all applicable data protection laws.

10. Where your personal data is held

Information may be held at our offices and those of our group companies, third party agencies, service providers, representatives and agents as described above (see the section above titled: “Who we share your personal data with”).

11. How long your personal data will be held

We will keep your personal data while we are providing products or services to you. Thereafter, we will keep your personal data for as long as is necessary and subject to applicable laws:

· to respond to any questions, complaints or claims made by you or on your behalf;

· to show that we treated you fairly; and

· to keep records required by law.

We will not retain your personal data for longer than necessary for the purposes set out in this policy unless the retention is otherwise permitted or required by law. 

12. Transfers of personal data

When we transfer personal data from one territory to another, to HIYP group companies or to third parties, we will use, share and safeguard that information as described in this privacy policy. 

We will protect your personal information by ensuring that transfers comply with all applicable data protection laws. Generally, this means that where we transfer your personal information to a third party that is located in a country which applicable laws deem does not have adequate privacy protection, we will put in place a contract with the third party that includes contractual terms that comply with applicable laws and enable us to transfer the data.

13. Your rights

You have the following rights, which you can exercise free of charge:

· Information

· The right to be provided with   information in relation to what personal data of yours that we process and   why 

· Access

· The right to be provided with a   copy of your personal data in a machine-readable format

· Correction

· The right to require us to   correct any mistakes in your personal data

· Erasure (also known as right to   be forgotten)

· The right to require us to delete   your personal data (in certain situations)

· Restriction of processing

· The right to require us to   restrict processing of your personal data (in certain circumstances), for   example if you contest the accuracy of the data

· To object

· The right to object:

o at any time to your personal data being processed for direct marketing   or conducting statistical surveys; 

o in certain other situations to our continued processing of your   personal data, eg to protect the public interest or third party rights in   accordance with applicable laws; and

o to automated processing that can have legal consequences or   significant consequences for you, including automated profiling (except in   certain circumstances)

· Right to withdraw consent

· If you have provided us with a   consent to use your personal data you have a right to withdraw that consent   easily at any time

· You may withdraw consents by   sending an email to ops@hiypcorp.com

· Withdrawing a consent will not   affect the lawfulness of our use of your personal data in reliance on that   consent before it was withdrawn

· Notification of breach

· The right to be notified of any   breach or infringement to your personal data and the actions that have been   taken by us in this regard

For further information on each of those rights, including the circumstances in which they apply, please contact us.

If you would like to exercise any of those rights, please send an email to ops@hiypcorp.com and provide the following:

· confirmation of the right you wish to exercise and the information to which your request relates;

· enough information to identify you; and

· proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill).

14. Keeping your personal data secure

We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

15. Actions in case applicable laws prevent compliance with this policy

Applicable laws may prevent us from complying with our obligations under this policy. In such circumstances we will, acting reasonably, decide what action to take (which may include, if appropriate, consulting with the relevant data protection regulatory bodies).

16. How to complain

We hope that we can resolve any query or concern you may raise about our use of your information.

We will deal fairly with any complaints that we receive in relation to this this privacy policy, or in relation to applicable data protection regulations.

17. Updates to this privacy policy

From time to time, we may need to make changes to this privacy policy. This may happen as a result of regulation changes, new technologies, change of company policy or structure, or other developments in the area of data protection. Any updates to this privacy policy will be posted on this website. 

HIYP Corp L.L.C-FZ 

Date [20].[09].2023