Privacy Policy

With this privacy policy (the “Policy“), Sharp Minds - FZCO (located at IFZA Business Park, DDP, Dubai, United Arab Emirates) informs you how we collect, use, and disclose personal data. Other privacy policies or general terms and conditions, conditions of participation and similar documents of Sharp Minds may govern specific matters, which is why this Policy may not be exhaustive where such other notices or terms apply. “personal data” as used in this Policy means all information that relates to an identified or identifiable natural person or, to the extent covered by applicable data protection law, legal entity.

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1. Controller and Contact

The responsible data controller for the data processing activities described in this Policy is Sharp Minds entity with which you maintain a business relationship or otherwise interact with, or which has been notified to you. If you do not yet maintain a business relationship with Sharp Minds and Sharp Minds is not clearly identifiable as the data controller, the following company is the data controller:

Sharp Minds – FZCO
IFZA Business Park, DDP
Dubai
United Arab Emirates

If you have any data protection concerns, you can contact us at the following address:

Sharp Minds – FZCO
IFZA Business Park, DDP
Dubai
United Arab Emirates
info@sharpminds.io

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2. Collection and Processing of Personal Data

The categories of personal data that we may process about you may include, in particular, the following data:

Name and contact information: in particular, first and last name, company name, address, contact person, telephone number, e-mail address, gender, and information related to your professional functions and activities
Contract data, order, and service data: in particular, payment data, payment details, invoice address, services obtained, turnover data in payment transactions, information in connection with queries, complaints and differences about services or the agreements concluded, such as withdrawals and disputes, information on compliance with legal requirements, information from banks, insurance companies, distributors and other contractual partners of us for the use or provision of services, information about you, which you or persons from your environment (employees, consultants, legal representatives, etc.) give us, so that we can conclude agreements with you, with the involvement of you or process them
Data related to marketing activities: in particular, newsletter opt-ins and opt-outs, invitations and participation in events and special activities, personal preferences and interests, consulting protocols
Data related to the use of our website and applications, server log (whereby this data is mostly non-personal): in particular connection data, IP address and other identifiers (e.g. user name in social media, MAC address of the smartphone or computer, data from cookies and similar technologies), date and time of the visit to our website, duration of the visit to the website, requested Internet address (Uniform Resource Locator, URL), referrer URL (i.e. the Internet address of the website from which you accessed our website, if applicable with the search term used), browser type and version, operating system used, amount of data sent in bytes, and the search term used, location data, pages and content accessed, functions used, geolocation data
Communication data: in particular, data exchanged in or in relation to contact with us, in particular, preferred communication channel, communication by letter, telephone, fax, e-mail, text messages (including records of the communication)
Data from public registers: in particular information from the commercial register
Information that we learn in connection with official and judicial proceedings
Information from the media and the Internet about you, if this is indicated in the specific case

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3. Sources of Personal Data

We may receive personal information from the following sources:

Direct sources: In principle, we process personal data that we receive directly from you, for example during our business relationship, the use of the website, visiting events of Sharp Minds, or in direct communication via e-mail, telephone, or other means.
Indirect sources: In certain cases, we may indirectly collect personal data. In particular, we may obtain supplementary information from data sources (e.g. credit agencies, social media). We may obtain personal data from publicly accessible sources (e.g. from debt enforcement registers or debtor directories, land registers, commercial and association registers, the press, the Internet). In individual cases, personal data may be derived from the combination of various non-personal data.

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4. Purposes of the Data Processing and Legal Basis

We may process personal data for the following purposes (Processing Purposes) and, if required under applicable data protection law, based on the following legal bases:

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4.1 For the Performance of Contracts

We process personal data in direct connection with the conclusion and processing of agreements with our customers, suppliers, experts and business partners, in particular in the context of recruiting experts in various fields, connecting experts with our customers, and offering related products and services. This may also include, among other things, the collection of payments, and the handling of queries. The purposes of data processing and any further information related to data protection can be found in the respective contract documents, terms and conditions and/or conditions of participation.

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4.2 To Fulfill Legal Obligations

We process personal data to comply with our legal or regulatory obligations in the United Arab Emirates and abroad. If you work for one of our customers, suppliers, experts or business partners, your data may also be affected in this context. Processing purposes include, but are not limited to:

Documenting compliance with legal and regulatory requirements
Participating in investigations and proceedings, cooperating with and responding to inquiries from authorities and courts

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4.3 To Safeguard Legitimate Interests

We also process personal data for the following purposes if this is necessary to protect the legitimate interests of us or third parties or to protect legitimate public interests:

Offer and further development of our offer: in particular, offering and further developing our products, services, websites, online services, and other platforms on which we are present
Ensuring business operations: in particular, coordinating and optimizing activities and offers and ensuring efficient transaction processing involving Sharp Minds, communicating with other group companies and third parties, processing inquiries (e.g. support requests, advertisements, media inquiries)
Ensuring IT security and IT operations: in particular, troubleshooting, operation and further development of our IT systems, our website and other platforms, identity checks, protection of IT assets, our employees and other persons, and assets (e.g., through network and e-mail scanners)
Quality control: in particular, preparing reports on users, transactions, activities, services and other business aspects of Sharp Minds for corporate management and development, preparing statistics, budgets, records and management information, organizing business operations, project management, research, development and further development of services
Advertising and marketing: in particular, market and opinion research, media monitoring, web analysis and tracking (e.g. using cookies), use, testing and optimization of demand analysis methods (e.g. tracking customer behavior, activities, preferences and needs), improving our visibility, publicizing the content of our services (e.g. using social media plug-ins), sending newsletters and advertising material (including personalized offers, e.g. using web banner advertising), conducting training courses, events and competitions, customer acquisition
Customer care: in particular, maintaining and developing customer relationships, conducting and managing training of employees, managing the users of our website, communication, customer service and support, also outside the scope of the execution of agreements
Risk management: in particular, consultation and exchange of data with credit information agencies to determine creditworthiness and default risks
Ensuring compliance: in particular, verification of compliance with legal and internal rules of Sharp Minds
Implementation of corporate transactions: in particular, the sale or purchase of business units, companies or parts of companies and other transactions, and the related transfer of personal data
Dealing with legal disputes: in particular, assertion of legal claims and defense in connection with legal disputes and official proceedings
Self-protection and protection of third parties: in particular, protection of third parties and our employees, our data, trade secrets and assets as well as assets that have been entrusted to us, safeguarding of house rights, security of our facilities and buildings
Prevention and investigation of criminal offenses and other misconduct: in particular, combating abuse, collecting evidence, conducting inter-agency investigations, data analysis to combat fraud

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4.4 Based on Your Consent

If you have given us your consent to process your personal data for certain purposes (for example, when you register to receive newsletters), we process your personal data within the scope of and based on this consent, unless we have another legal basis and we require such a basis. Consent given can be revoked at any time, but this has no effect on data processing that has already taken place.

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5. Cookies, Tracking and Other Technologies Related to the Use of Our Website

We typically use cookies and similar technologies on our websites that allow us to store information on your device or access information stored on your device. This allows us to better understand user behavior, e.g. to provide our services in a technically error-free, secure, user-friendly and demand-oriented manner:

Cookies: These are small text files that are stored in the cookie file on your computer’s hard drive when you visit our website. Through the use of cookies, your browser receives an identifier and presents it upon request.

Most of the cookies we use are so-called session cookies. They save your entries while you navigate on the website within the same session (e.g. so that your shopping cart contents are not lost). Session cookies are automatically deleted after you visit our website. Permanent cookies, on the other hand, remain stored on your device for several sessions and allow us to recognize your browser the next time you visit the website (and, for example, to perform an automatic log-in or to display the website in your preferred language and according to your preferences). We use permanent cookies to remember your preferences (e.g., language, automatic log-in), to help us understand how you use our services and content, and to provide you with customized offers and advertisements (which may also occur on other companies’ websites; however, we do not tell them who you are, if we even know, because they only see that the same user is on their website who was on a particular webpage of ours). Some of the cookies are set by us, and some are set by contractors with whom we work. If you block cookies, certain functionalities (such as language selection) may no longer work. Permanent cookies are deleted when their expiration date is reached or if you delete them beforehand. Most browsers are set to accept cookies by default.

Tracking pixel (also pixel tag, web beacon, or clear GIF): A tracking pixel is a 1×1 pixel invisible graphic associated with your user ID. Tracking pixels measure, for example, the number of visitors to our website, the number of clicks on important parts of a website, or which files or emails are opened. In this way, they help us analyze the effectiveness of our services.
Analysis-Tools: We use Google Analytics on our website. This is a service of Google LLC in the USA (Google) (www.google.com), with which we can measure and evaluate the use of the website (not personal). Permanent cookies that Google sets are also used for this purpose. Google does not receive any personal data from us (and does not retain any IP addresses), but it can track your use of the website, combine this information with data from other websites that you have visited and which are also tracked by Google, and use this information for its own purposes (e.g. controlling advertising). If you have registered yourself with Google, Google also knows you. The processing of your data by Google then takes place under the responsibility of Google in accordance with its data protection provisions. Google only informs us how our website is used (no information about you personally).

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Cookies and similar technologies generally do not provide personal data, but only anonymous traffic data related to your device (e.g., your IP address) and statistical data (e.g., number and type of website visits). However, to the extent that the identifiers collected are classified as personal data by applicable law, we treat them as such. In addition, we sometimes combine non-personal data collected using these technologies with other personal data held by Sharp Minds. When we combine data in this way, we treat the combined data as personal data for the purposes of this Policy.

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By using our websites, apps and consenting to receive newsletters and other marketing emails, you agree to the use of the above mentioned technologies. If you do not wish to do so, you can block or delete the cookies and similar technologies via the privacy settings of your browser and email program, whereby the deletion may under certain circumstances affect the use of our website.

6. Disclosure of Personal Data

Within Sharp Minds, access to your data is granted to those departments or functions that need them to fulfill the aforementioned Processing Purposes.

In addition, we may disclose personal data to the following categories of recipients, provided that the disclosure serves to fulfill the aforementioned Processing Purposes:

Service providers (including data processors and vicarious agents) within Sharp Minds as well as external third parties
Business partners, including suppliers and experts
Customers of Sharp Minds
Acquirers or parties interested in acquiring business units, companies or other parts of Sharp Minds
Parties to potential or actual legal proceedings
Local, national, and foreign authorities, agencies and courts
The public, including visitors to websites and social media

If we transfer personal data to third parties, the respective current privacy policies of the third parties are also applicable. The third parties may be jointly responsible with us or act as data processors.

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7. Transmission of Personal Data Abroad

We may transfer personal data to recipients in countries of the EU, the EEA and the UK and in any other country of the world, in particular to countries in which Sharp Minds is represented by branches or other offices and representatives as well as to the countries in which our service providers process their data (such as countries of the EU and the UK).

Personal data may be transferred to a country without adequate legal data protection, provided that:

We ensure adequate protection, namely by means of sufficient contractual guarantees such as the standard contractual clauses of the European Commission or binding corporate rules. You can obtain a copy of the contractual guarantees from the contact mentioned above or find out from them where such a copy can be obtained. We reserve the right to redact such copies for reasons of data protection or confidentiality or to provide only excerpts
You give your express consent
It is necessary for the execution of a contract with you or of a contract in your interest
It is necessary for the fulfillment of a legal obligation
It is necessary to safeguard overriding public interests, to establish, exercise or enforce legal claims or to protect the life or physical integrity of you or third parties
You have made the personal data generally accessible and do not expressly prohibit processing or
The personal data originate from a register provided for by law, which is public or accessible to persons with an interest worthy of protection, insofar as the legal requirements for inspection are met in the individual case

8. Duration of the Retention of Personal Data

We process and store personal data as long as it is necessary for the Processing Purpose for which we collected it (e.g. for the duration of the entire business relationship from the initiation and processing to the termination of a contract). In addition, there may be a contractual or legal obligation to retain or document data. It is possible that personal data will be stored for the time during which claims can be asserted against our company and insofar as we are otherwise legally obligated to do so or legitimate business interests require this (e.g. for evidence and documentation purposes). We thus store contract-related personal data in principle for the duration of the contractual relationship and for ten years beyond the termination of the contractual relationship.

If the personal data is no longer required for the fulfillment of the Processing Purpose, it will be deleted or anonymized as far as possible. Subject to an express written agreement, we are under no obligation to you to retain personal data for a specific period of time.

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9. Data Security

We take appropriate technical and organizational security measures to protect your personal data from unauthorized access and misuse, such as the issuance of warnings, training, IT and network security solutions, access controls and restrictions, encryption of data media and transmissions, pseudonymization, controls.

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10. Automated Decision Making

For the establishment and implementation of the business relationship and also otherwise, we do not use any fully automated individual decision-making (as regulated, for example, in article 22 GDPR). Should we use such procedures in individual cases, we will inform you separately and inform you of the associated rights, insofar as this is required under the applicable law.

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11. Rights of the Data Subject

You have the right to:

Information about personal data concerning you;
Correction, deletion or destruction of personal data
Objection to the processing of personal data;
Revocation of consent if the processing of personal data is based on your consent. The revocation is possible at any time and is effective for the future. The revocation does not affect the lawfulness of the data processing that took place until the revocation;
Data output and transmission in certain cases and in a common electronic format that allows further use and transmission;
We will inform you separately about your rights in connection with any automated individual decision-making, insofar as this is required by law. For the establishment and implementation of the business relationship, we do not use any automated individual decision-making processes.

To exercise your rights, please contact the contact address mentioned above. In addition, you can use any options embedded in our services, e.g. link in an e-mail to unsubscribe from a newsletter. The exercise of your rights generally requires that you can clearly prove your identity (e.g. by a copy of your ID where your identity is not otherwise clear or can be verified). We also draw your attention to the fact that by deleting your personal data, services are no longer available or can no longer be used, in whole or in part, and that the exercise of these rights may conflict with contractual agreements and this may have consequences such as the premature termination of the contract or cost consequences. We will inform you in advance if this is not already contractually regulated.

We reserve the right to restrict your rights within the framework of the applicable law and, for example, not to provide any or complete information or not to delete data. You have the right to enforce your claims in court or to file a complaint with the competent data protection authority.

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12. Obligations of the Data Subject

In the context of our business relationship, you must provide the personal data that is required for the establishment and implementation of a business relationship and the fulfillment of the associated contractual obligations (you do not usually have a legal obligation to provide us with data). Without this data, we will generally not be able to enter into or perform a contract with you (or the legal entity or person you represent). Also, the website cannot be used if certain traffic-securing information (such as IP address) is not disclosed.

If you provide us with personal data of other persons (e.g. data of work colleagues), please make sure that these persons are aware of this Policy and only share their personal data with us if you are allowed to do so and if this personal data is correct.

Please note that the Internet is generally not a secure environment because it is an open network that can be accessed by anyone. Therefore, we also emphasize to your personal responsibility with regard to the handling of your personal data. To the extent permitted by law, we exclude liability for the security of data that you transmit to us via the Internet (e.g. by e-mail) or other electronic channels and for any direct or indirect damage. We ask you to choose other communication channels, should this appear necessary or reasonable for security reasons.

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13. Modification of the Privacy Policy

Sharp Minds may amend this Policy at any time without prior notice. The current version published on our website shall apply.

If the Policy is part of an agreement with you, we can inform you about the change of the Policy by e-mail or by other suitable means.