Privacy Policy

Softler (“We” or “Us”) are committed to protecting and respecting Your privacy.

This policy (together with our Terms of Use and Cookie Policy) sets out the basis on which We collect any personal data from You, or that You provide to us, will be processed by Us. Please read the following carefully to understand our views and practices regarding Your personal data and how We will treat it.

For the purpose of the Personal Data Protection Law of the United Arab Emirates (“UAE”), Your data controller is Softler, incorporated in the United Arab Emirates.

Part A of this policy governs our use of personal data collected on individuals, including, through their browsing and use of https://softler.com/.

Part B of this policy sets out the basis on which We will use any personal data collected, or provided, by corporate entities completing and submitting the data by their own initiative in any application or contact forms located on our Website or in any other form via our Website.

Purpose of data collection

We process personal data in accordance to the requirements of laws and regulations, provisions of applicable contracts and Our legitimate and legal interests, including, but not limited to, the following purposes:

To provide services — in order to provide our services We process personal data to enter into contractual relationship with a client for rendering services, for taking necessary actions prior to entering in the contract, for implementation of the contracts signed with the client, for assessment of the client and the persons related to a client with an aim to define a possibility and provisions for cooperation, for due cooperation with a client, for signing contracts in client’s interests, for settlements with the client, for communication with a client.
To ensure performance of our legal obligations — We process personal data to perform Our legal obligations, based on applicable requirements of laws and regulations on electronic money institutions, anti-money laundering and counter-terrorism and proliferation financing, tax liabilities and bookkeeping, payment instruments, payment services, international sanctions, and requirements of other laws and regulations applicable to Us.
To ensure risk management — before and during cooperation with a client We process personal data to provide compliance with our requirements and those of international payment systems and other laws and regulations, to monitor the observance of client’s liabilities, to keep evidence and information on the course of cooperation, to disclose and prevent illegal actions, to ensure physical security and security of Our information systems, to protect our rights, to protect Us against damage, to represent Our interests in the course of examination of claims and disputes.
To ensure Our legitimate interests — We may process personal data to improve the quality of Our services, to provide You with additional services or to develop new products, to carry out internal analysis and statistics, to support Our activities and compliance with the internal administration procedures, to improve and test Our technical infrastructure, to ensure cooperation with Our counterparties, to obtain necessary consultations from outsource specialists, to examine complaints or applications of a client or other persons, to manage Our rights and obligations under the signed contracts.

Changes to our privacy policy

Any changes We may make to our privacy policy in the future will be posted on this page. Please check back frequently to see any updates or changes to our privacy policy.

Part A — Individuals

Information we may collect from you

We may collect and process the following data about You:

Information You give Us. You may give Us information about You by filling in forms on our site or by corresponding with Us by phone, e-mail or otherwise. This includes information You provide when You register to use our site, subscribe to our service, search for a product, place an order on our site, enter a competition, promotion or a survey, and when You report a problem with our site. The information You give Us may include Your name, address, e-mail address and phone number, financial information and personal description.
Information We collect about You. With regard to each of Your visits to our site We may automatically collect technical information, including the Internet protocol (IP) address used to connect Your computer to the Internet, Your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and information about Your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time), products You viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information, and methods used to browse away from the page.
Information We receive from other sources. We may receive information about You if You use any of the other Websites We operate or the other services We provide. We also often work closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers) and may receive information about You from them.

Cookies

Our Website uses cookies to distinguish You from other users of our Website. This helps Us to provide You with a good experience when You browse our Website and also allows Us to improve our site. For detailed information on the cookies We use and the purposes for which We use them please see our Cookie Policy and any other cookies’ notifications on our website.

How we use the information

Information You give to Us. We will use this information to carry out our obligations arising from any contracts entered into between You and Us and to provide You with the information, products and services that You request from Us; to provide You with information about other goods and services We offer that are similar to those that You have already purchased or enquired about; to notify You about changes to our service; and to ensure that content from our site is presented in the most effective manner for You and for Your computer.

Information We collect about You. We will use this information to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes; to improve our site to ensure that content is presented in the most effective manner; as part of our efforts to keep our site safe and secure; to measure or understand the effectiveness of advertising We serve to You and others; and to make suggestions and recommendations to You and other users of our site about goods or services that may interest You or them.

Information We receive from other sources. We may combine this information with information You give to Us and information We collect about You. We may use this information and the combined information for the purposes set out above (depending on the types of information We receive).

Automated decision-making and profiling

As a part of the provision of services, We may apply profiling (i.e. automated data processing) to evaluate You. Taking into account the results of profiling, our employees may perform additional supervision or analysis of a client and take an individual decision. Furthermore, We may automatically verify a client’s data in the registers and databases stipulated in the laws and regulations regarding the prevention of money laundering and terrorism and proliferation financing.

Disclosure of your information

We may share Your personal information with any member of Our group, which means our subsidiaries, our ultimate holding company and its subsidiaries.

We may share Your information with selected third parties including business partners, suppliers and sub-contractors for the performance of any contract We enter into with You or them; analytics and search engine providers that assist Us in the improvement and optimisation of our site.

We may disclose Your personal information to third parties in the event that We sell or buy any business or assets; if Softler or all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets; or if We are under a duty to disclose or share Your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms of Use or any other agreements, or to protect Our rights, property, or safety, or those of Our customers, or others.

Please note that in cases when We transfer or disclose information to any third parties We always carefully consider the conditions under which personal data will be processed and stored after transfer to other entities both in the UAE and outside the UAE.

Where we store your personal data

The data that We collect from You may be stored at a destination or transferred to within and outside the United Arab Emirates. It may also be processed by staff operating within or outside the UAE who work for Us or for one of our suppliers. By submitting Your personal data, You agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this privacy policy.

Unfortunately, the transmission of information via the internet is not completely secure. Although We will do our best to protect Your personal data, We cannot guarantee the security of Your data transmitted to our site; any transmission is at Your own risk. Once We have received Your information, We will use strict procedures and security features to try to prevent unauthorised access.

Data storage and retention

Please be informed that We always try to keep Your personal data for the shortest time possible. However We will always keep Your personal data to protect our legal and legitimate interests for the period of time necessary to fulfil our mutual contractual obligations, until the legitimate period of potential claims has passed or to fulfil our legal obligations according to laws and regulations.

Your rights

In respect to Your personal data You have the rights:

to get familiar with Your personal data and how it is processed;
to demand correcting incorrect, inaccurate or incomplete data, erasing Your personal data or restricting the processing of Your personal data when personal data is processed without complying with legal requirements or when there is another legal basis;
to withdraw Your consent of Your data processing at any time if personal data is processed on a separate consent basis. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal;
the right to portability of personal data, receiving them in an electronic format with the purpose of transferring information to a third party, taking into account the restrictions stipulated by the laws and regulations;
as well other rights as stated in this Privacy Policy, in any Our contract signed with You, or any laws and regulations governing personal data protection.

Our site may, from time to time, contain links to and from the Websites of our partner networks and affiliates. If You follow a link to any of these Websites, please note that these Websites have their own privacy policies and that We do not accept any responsibility or liability for these policies.

Access to information

You have the right to access information held about You. Your right of access can be exercised in accordance with legal acts on data protection. Where requests from You are manifestly unfounded or excessive, in particular because of their repetitive character, We have legal rights either to charge a reasonable fee taking into account the administrative costs of providing the information, or to refuse to act on the request.

Complaints and contacts

You can always exercise Your rights to protect Your personal data at any time in the first place by contacting Us at assistance@softler.com. Questions, comments and requests regarding this privacy policy are welcomed.

In cases where You consider that Your personal data is being processed in a non-compliant manner or Your rights in connection with data processing are violated, You also have the right to contact the relevant data protection authority and file a complaint.

Part B — Corporate clients and corporate use of the site

Our corporate clients may use our website to submit a contact form in order to contact us and that may include personal data of natural persons related to the corporate client (for example, company representatives, directors, shareholders and ultimate beneficial owners).

By submitting any data via our website, the corporate client confirms that it is authorised and, specifically where required by laws governing personal data protection, has the necessary consents to disclose any personal data to us. We shall not be liable for any claim brought by any individual arising from an act or omission resulting from any corporate client’s failure to ensure that the transfer of the personal data was lawful under the applicable laws governing personal data protection.

We will use this information to evaluate the application to receive our services; assess and determine the provisions of an agreement between a corporate client and Us; enable fraud protection and risk management processes; manage all billing and invoicing; offer a client other products and services; and comply with our legal compliance obligations.