Bellbird Solutions FZC ("QUALIFY") PRIVACY NOTICE

The entity responsible for your Personal Data is Bellbird Solutions FZC.

Bellbird Solutions is a Limited Liability Company incorporated in the Emirate of Sharjah, United Arab Emirates whose principal place of business is located in Sharjah, United Arab Emirates

Bellbird Solutions FZC, and our affiliates and branch offices (also referred to as "we" and "us"), takes our data protection and privacy responsibilities seriously. This Privacy Policy describes how we collect, process, use, disclose and transfer your Personal Data as a data controller. It covers instances when you contact us, use our services and products or interact with our websites, such as trainwithqualify.com, and any Qualify mobile applications (together "Qualify Websites").

1. Terms of Use

   1. Use of the Qualify Websites is subject to our Terms and Conditions ("Terms"). By consenting to this Privacy Policy you also agree to be bound by the Terms. Please ensure you read these carefully and understand them before consenting to this Privacy Policy.

      
      

2. Updates

   1. We may amend this Privacy Policy from time to time to keep it up to date with legal requirements and the way we operate our business. Please regularly check these pages for the latest version of this statement. If we make material changes to this Privacy Policy, we will seek to inform you by either updating the date at the top of the page or by notifying you on our website or by email.

      
      

3. Third Party Websites

   1. The Qualify Websites may link you to other websites, including those of our partners and affiliates. We are not responsible for the way in which third party websites operate or the way in which they may process any Personal Data, which you provide to them. It is important that you understand this and check their respective privacy policies and terms of use.

   2. We may also, from time to time, partner with ad networks and other online advertising providers in order to serve ads on behalf of us or other non-affiliated parties on our websites and across the Internet. These ads may be presented to you based on products and services the advertising providers think are relevant to your interests. These preferences may be inferred based on information collected about your browsing behaviour on our websites and other non-affiliatedsites and apps across time.

      
      

4. WHAT PERSONAL DATA WE COLLECT AND WHEN AND WHY WE USE IT

   1. What is Personal Data

      1. Personal Data in this Privacy Policy means any information relating to an identified or identifiable natural person (a 'data subject'). An identifiable natural person is a person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

   2. Purchasing Qualify products

      1. If you use the Qualify Websites to purchase our product, we will collect and use information about you as necessary to manage the purchase. This may include Personal Data such as your name, date of birth, address, payment details (such as your credit card number, billing address, credit card expiry date etc.), contact information (such as phone number and e-mail address), as well as information collected about your navigation patterns on our websites.

   3. Customer Support and online services

      1. If you contact us by way of email, live chat, message boards or any other facility made available by Qualify with a query or comment about any of our services or products, or would like us to keep you informed about latest news and developments at Qualify, we will need to collect information about you (including your contact details) to help us respond to your query or request or provide our services to you. We may do this when you call our customer support centre, or interact with us through our online support tools. This information may include identification data (such as your name, date of birth, gender, nationality etc.), contact details (such as email address and telephone number) and other information (such as your interests and personal preferences and transaction history).

      2. We may also keep a record of any communications we have with you (including a recording of any calls you make). We do this to help monitor and improve the quality of our customer support services, to make and defend legal claims, and to comply with legal obligations to which we are subject.

         
         

   4. Creating registered accounts on the Qualify Websites

      1. There are a number of sections of the Qualify Websites which we require you to register for in order to be able to make full use of the services available under them.

         
         

      2. If you register with us to create a Qualify Websites account, we will process your personal data to:

         1. manage your access to certain parts of the Qualify Websites and, if applicable, allow you to make certain purchases (such as Qualify products) or receive certain services;

         2. send you newsletters and marketing and promotional materials (including via social media, based on the contact details you provide us), subject to your marketing preferences;

         3. if you purchase a Qualify product from us, to help you to create personalized pathways through the Qualify site on the basis of your preferences which we have ascertained from your navigation of the Qualify Websites including location detection services while using the mobile application; and

         4. to offer you the opportunity to download digital material (if applicable).

            
            

      3. The Personal Data we will collect from you if you register with us to create a Qualify Websites account will include identification data (such as your name, age, gender and country of residence), contact details (such as your email address, phone number and address), your preferences (which we can ascertain from the way in which you have navigated the Qualify Websites), and may also include professional information about you and your photo. If you choose to register an account with us by using a third party app (such as Facebook or Twitter), you will be presented with a dialogue box which will ask your permission to allow Qualify to access your Personal Data from that third party app (e.g. your full name, date of birth, email address and any other information you have made publicly accessible).

         
         

      4. If you create an account with us, we will use your Personal Data to verify your identity when using the Qualify Websites. We will also use your contact details to send you transactional and other non-marketing email messages pertaining to your account and provide certain other account maintenance services.

         
         

   5. Additional information

      1. Sometimes we will require you to provide additional Personal Data. When we do this we will provide further information about why we are collecting your information and how we will use it. Where we provide personalized content, we may ask your permission to review third party data about you, for example, your Twitter, Facebook, LinkedIn, google+, Weibo, We Chat to get to know you better and to provide more effective personalization.

         
         

   6. Information posted by you

      1. The information posted by you on public areas of the Qualify Websites or elsewhere on the internet may be used by anyone including Qualify.

         
         

   7. Automatic Collection

      1. Qualify and third parties that provide content, advertising, or other functionality on our services, may use cookies, pixel tags, local storage, and other technologies to automatically collect information through the services. These are collected for the purposes of:

         1. developing the design and style of our products and services to make improvements;

         2. carrying out statistical, technical and logistical analysis and strategic development;

         3. carrying out market research;

         4. understanding more about you such as your location and demographic information; and

         5. providing you with personalised services, such as recommendations on our websites, apps and in direct marketing and tailored advertising.

            
            

      2. Qualify Websites collect information about how you use our content online, and the device(s) you use to access the site. This includes collecting unique online identifiers such as IP addresses, which are numbers that can uniquely identify a specific computer or other network device on the internet.

         
         

5. LEGAL BASIS FOR USING YOUR DATA

   1. We will only collect, use and share your Personal Data where we have an appropriate legal basis to do so. Depending on where you are, appropriate legal bases may include:

      1. where we need to use your Personal Data to perform a contract or take steps to enter into a contract with you;

      2. our legitimate interests as an organisation, for example we may use customer contact information to keep our customers informed about changes to Qualify and other important service messages; in these cases we will respect your privacy rights and ensure you may object to processing as explained in the "Your Rights" section (section ‎12) below;

      3. where we need to use your Personal Data to comply with a relevant legal or regulatory obligation that we have; and

      4. where we have your consent to use your Personal Data for a particular activity. If you are a data subject in the UAE, this will always be the legal basis upon which your Personal Data will be processed.

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   3. If you would like to find out more about the legal bases upon which we process Personal Data please contact us.

      
      

6. HOW WE SHARE INFORMATION WITH OTHERS

   1. We work closely with a number of trusted partners with whom we need to share your Personal Data to help us provide our services:

      1. banks and payment providers, to authorise and complete payments;

      2. entities with whom

      3. third parties who help manage our business and deliver services. For example, these may include IT service providers who help manage our IT and back office systems.

         
         

   2. We may share your Personal Data with our partners who may send you marketing and promotional information.

      
      

   3. From time to time we may share information about you with government organizations and agencies, including international organisations, to comply with applicable laws, regulations and rules, and legitimate requests from law enforcement, regulatory and other governmental or international agencies, or when to do so is in our legitimate interests, even if we are not compelled to share that information by applicable law.

      
      

   4. If, in the future, we sell or transfer some or all of our business or assets to a third party, we may disclose or transfer information to a potential or actual third party purchaser of our business or assets.

      
      

7. MORE ABOUT DIRECT MARKETING, PROFILING AND AUTOMATED DECISION MAKING

   1. Direct marketing

      1. We are committed to keeping you informed about Qualify and our products and services in line with your personal preferences.

      2. We will usually send this by email but we may choose to contact you in other ways for example by phone, post, SMS and/or other electronic means if that is more appropriate.

         
         

   2. Managing your marketing preferences

      1. To protect privacy rights and to ensure you have control over how we manage marketing with you:

         1. we will take steps to limit direct marketing to a reasonable and proportionate level and only send you communications which we believe may be of interest or relevance to you;

         2. to stop receiving marketing material from us, you can click the "unsubscribe" link that you will find on any electronic communications which you receive from us, or, for other types of communications, by contacting us; and

         3. you can change the way your browser or device manages cookies, which may be used to deliver online advertising, by following the settings on your browser as explained in the "Cookies" section (section ‎11) below.

            
            

      2. We recommend you routinely review the privacy policies and preference settings that are available to you on any social media platforms.

         
         

   3. More about profiling and analytics

      1. We use some of the information you provide to us in order to perform profiling and analytics with the data.

      2. One of the methods by which we do this is by installing and using Cookies on your browser or device. You can learn more about how to adjust settings relating to Cookies on your browser and device, and about our Cookie Policy in the "Cookies" section (section ‎11) below.

      3. Some of the legitimate purposes according to which we profile and analyse data include:

         1. to allow us to enhance our provision of services to you;

         2. to provide you with tailored content online and optimise your experience of our websites;

         3. to offer personalised products when you use our services;

         4. to obtain a better understanding of our customers, what you would like to see from us, and how we can improve our services for you;

         5. to share advertising material we believe may be of interest to you, including from our third party partners; and

         6. to help us operate our services more efficiently.

8. TRANSFERRING PERSONAL DATA INTERNATIONALLY

   1. We operate our organisation from the United Arab Emirates ("UAE"), where we have our head office.

   2. In performing our operations we may need to transfer data, including your Personal Data, to the European Union ("EU") and the UAE. By agreeing to the terms of this Privacy Policy, you agree that your Personal Data may be transferred internationally from your location when you use our services or when you agree to this Privacy Policy. Our third party service providers may also require to transfer your personal data to third countries outside the EU in order to perform their services.

   3. We will take appropriate steps to ensure that transfers of Personal Data are in accordance with applicable laws and carefully managed to protect your privacy rights and interests. If your Personal Data is being transferred outside the EU then transfers will be limited to countries which are recognized as providing an adequate level of legal protection as assessed by the European Commission or where we can be satisfied that alternative data protection arrangements are in place to protect your privacy rights. To this end, if required by law, where we transfer your Personal Data to third parties who help provide our products and services, we obtain contractual commitments from them to protect your Personal Data.

   4. You have a right to contact us for more information about the safeguards we have put in place (including, for EU data subjects, the right to receive a copy of relevant contractual commitments we have put in place, which might be redacted) to ensure the adequate protection of your Personal Data when this is transferred as mentioned above. See also the section titled "Your Rights" (section ‎12), below.

9. HOW WE PROTECT AND STORE YOUR INFORMATION

   1. How we protect your information

      1. We invest an appropriate level of resources to protect the security and confidentiality of Personal Data:

         1. we follow strict security procedures in the storage and disclosure of information which you have given us (including through password protection and, for certain transmissions to our services, encryption), to prevent unauthorised access to that information;

         2. we take all reasonable and appropriate steps to protect your Personal Data but cannot guarantee the security of any data you disclose to us via email or online; and

         3. where you disclose information to us using our mobile app, please ensure that your device remains safe. We cannot be held responsible for any data misuse arising from unauthorised access to your device.

   2. Storing your Personal Data

      1. We will store your Personal Data for as long as reasonably necessary for the purposes for which it was collected, as explained in this Privacy Policy. Where your information is no longer required, we will ensure it is disposed of in a safe manner. In some circumstances we may need to store your Personal Data for longer periods of time, for instance where we are required to do so in accordance with legal, reporting, regulatory, tax, accounting requirements. Should you require information about how we retain particular information you can contact us.

      2. In specific circumstances we may store your Personal Data for longer periods of time so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your Personal Data or dealings.

10. COOKIES

    1. Our policy on "cookies"

       1. A cookie is an element of data that a website sends to your browser, which then stores it on your system. Cookies may collect Personal Data about you. Cookies allow us to understand who has seen which pages, to determine how frequently particular pages are visited and to determine the most popular areas of our website. Cookies also allow us to make Qualify Websites more user-friendly by, for example, allowing us to take you to the language site of last use, so that we can give you a better experience when you return to our website.

       2. Cookies will be deployed on your device when you visit Qualify Websites unless you indicate that you do not wish this to happen or if you have turned this feature 'off' in your web browser or device settings.

       3. Only the issuer of the cookie concerned may read or modify the information contained therein.

    2. Your management and use of cookies

       1. You can manage and modify your use of cookies through your browser software.

       2. The settings you make may change your Internet browsing and your conditions of access and use of certain services on the Qualify Websites that require the use of cookies.

11. YOUR RIGHTS - LEGAL RIGHTS AVAILABLE TO HELP MANAGE YOUR PRIVACY 

    1. You may have rights relating to your Personal Data depending upon the country in which you access the Qualify Websites.

    2. Where you access the Qualify Websites in the European Union (or otherwise benefit from rights as a data subject under the GDPR), you will have certain rights in relation to our handling of your Personal Data below, including the right:

       1. To access 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.

       2. To erase 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. Please note that for certain purposes we may be legally obligated to retain your data. Please see the section titled "How we protect and store your information" (section ‎10).

       3. To restrict the processing of your Personal Data. This enables you to ask us to suspend the processing of your Personal Data in the following scenarios:

          1. if you want us to establish the data's accuracy;

          2. where our use of the data is unlawful;

          3. 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

          4. you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

       4. To transfer 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.

       5. To object to the processing of Personal Data where our lawful basis for such processing is our legitimate interests (or those of a third party) and you can specifically justify an objection to that processing on the basis that it impacts on your fundamental rights and freedoms.

       6. To object to how we use 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.

       7. To obtain a copy of safeguards used when we transfer your Personal Data outside the jurisdiction in which the Personal Data were captured (as per paragraph ‎9.4).

       8. To lodge a complaint with your local supervisory authority. 

    3. Please note that the rights referred to in paragraph ‎12.2 are not absolute and may be subject to our own rights in respect to the Personal Data.

    4. You may have rights to lodge a complaint to a local privacy authority, however whether you lodge a complaint and who you lodge it with is solely your responsibility.

    5. If you wish to access any of these rights, we may ask you for additional information to confirm your identity and for security purposes, in particular before disclosing Personal Data to you. We reserve the right to refuse such access, if your request is manifestly unfounded or excessive.

    6. You can exercise your rights by contacting us. Subject to legal and other permissible considerations, we will make every reasonable effort to honour your request promptly or inform you if we require further information in order to fulfil your request.

    7. We may not always be able to address your request fully, for example if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.

12. INFORMATION ABOUT YOUR DEPENDENTS AND RELATED PERSONS

    1. If you provide Qualify with Personal Data about your next of kin and/or related persons for emergency contact or any other purposes, it is your responsibility to inform such individuals about such activities and to obtain their consent, where necessary, to the processing (including transfer) of that Personal Data as set out in this Privacy Policy.

13. COLLECTION OF DATA FROM MINORS

    1. Qualify Websites will collect data from its users, which may include children under 16 and we do not knowingly collect data from anyone under 16. If we become aware that a person under 16 has provided us with Personal Data, we will delete it immediately.

    2. If you are resident in the UAE and under 21, we are not permitted to contract with you directly and you, by agreeing to this Privacy Policy, you acknowledge and agree that your guardian has read and consented to its terms on your behalf. If we seek your consent to process your Personal Data for a specific purpose in accordance with this Privacy Policy, consent must be granted on your behalf by your guardian.

14. CONTACT US 

    1. If you have any questions, concerns or complaints regarding our compliance with this Privacy Policy and the data protection laws, or if you wish to exercise your rights, please contact us. We will investigate and attempt to resolve complaints and disputes and will make every reasonable effort to honour your wish to exercise your rights as quickly as possible and in any event, within the timescales provided by data protection laws.

    2. In some countries, you may have a right to lodge a complaint with your local data protection supervisory authority. We ask that you please attempt to resolve any issues with us before your local supervisory authority.