Privacy Policy

In this policy, we, us or our means Aroha Ltd, UAE. This policy governs the collection and use of personal information by us. We are committed to protecting and respecting your privacy.  This policy explains the types of personal information we collect, how we use that personal information, who we share it with, how we protect that information, and your legal rights in relation to your personal information. We are committed to abiding by this policy, as well as the requirements of applicable laws, in the operation of our business.

Please read the following carefully as it explains our views and practices regarding your personal information, and how it is handled. By accessing or browsing our website, you confirm that you have read, understood and agree to this policy in its entirety.  If you do not agree with the practices described in this policy, you should not use our website.

Who we are

Aroha Ltd, PO Box 52294, Dubai, U.A.E

Information covered by this Policy

This policy covers all personal information collected and used by us.  In this policy, personal data or personal information means information that (either in isolation or in combination with other information held by us) enables you to be identified as an individual or recognised directly or indirectly.  This may include your name, date of birth, nationality, gender, postal address, email address, phone number, and technical information from the devices you use to access our website or apps.

What information do we collect from you?

We may collect information about you from different sources as detailed below.

Information you give us

You may give us information about yourself when you respond to a communication from us or by filling in forms (both online and offline), over the telephone and through written correspondence with us. The information you give us may include your name, postal address, email address, date of birth, landline and/or mobile telephone number, as well as other personal information.

Information we collect about you

When you visit our website or use our app we may use cookies and other technologies to automatically collect the following information:

• Technical information, including the Internet Protocol (IP) address used to connect your computer to the internet, your login information, browser type and version, device identifier, location and time zone setting, browser plug-in types and versions, operating system and platform, page response times, and download errors;
• Information about your visit, including the full Uniform Resource Locators (URL) clickstreams to, on and from our websites and apps.
• Length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouseovers) and methods used to browse away from the page.
• Information we receive and collect from other sources

We may receive information about you from other websites and apps operated by us or from the other services that we provide. We may also collect information about you from publicly available sources, including publicly available content on social media.

Cookies

Our websites use cookies and similar technology. A cookie is a small file of letters and numbers that our website places on your computer, or other equipment which you use to access our website. These cookies allow us to distinguish you from other users of our website. You can read more about cookies and how to recognise them at www.aboutcookies.org. Cookies perform many functions, such as allowing you to navigate between pages efficiently, remembering your preferences, and generally improving the user experience. They can also help to ensure that advertising that you see online is more relevant to you and your interests. Your use of our website indicates your consent to the cookies described in this policy. Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

How you can control cookies

Your web browser includes an option that allows you to refuse the setting of all or some cookies. However, if you do so, you may not be able to access parts of our website and it may make your browsing experience less enjoyable. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies as described above when you access our website. If you would like to delete any cookies on your computer please refer to your browser manufacturer’s instructions by clicking ‘help’ in your browser menu.

How do we use your personal information?

We may use your personal information to: Comply with legal requirements and exercise or defend legal claims.
How do we use personal information for this purpose? We may sometimes need to process personal information to comply with legal requirements to which we are subject.
What is the legal basis for us processing your information in this way? It is in our legitimate interests to process personal information for the purposes of exercising and defending legal claims. Processing personal information may also be necessary to ensure compliance with our legal obligations.

We may use your personal information to: Process your personal information where this is necessary to keep our website safe and secure.
How do we use personal information for this purpose? We may need to process your personal information in order to keep our website safe and secure and protect against illegal or fraudulent activity such as cyber-attacks.
What is the legal basis for us processing your information in this way? It is in our legitimate interests to process personal information for the purposes of exercising and defending legal claims. Processing personal information may also be necessary to ensure compliance with our legal obligations.

We may use your personal information to: Keep an up to date suppression list where you have asked not to be contacted, so we do not inadvertently re-contact you.
How do we use personal information for this purpose? We understand that you may prefer for us not to contact you.  We keep records of your preferences to ensure that we do not contact you if you have asked us not to.  We may need to process certain of your personal information (such as your name and email address) in order to do this.
What is the legal basis for us processing your information in this way? It is in our legitimate interests to process personal information in order to maintain an up to date suppression list and ensure that we do not contact you where you have asked us not to.

Where we store your personal information

The personal information that we collect from you will be stored in Dubai, although it could be transferred to another company regardless of geographic location, in the process of our business operations. We will take all steps that are reasonably necessary to ensure that your personal information is treated securely and in accordance with this policy and applicable data protection laws.

Security of personal information

All information you provide to us via our website is stored on our secure servers. We have taken steps to safeguard the integrity of our communications and computing infrastructure, which includes implementing authentication, monitoring, auditing, and encryption technology. Security measures have been integrated into the design, implementation, and day-to-day operations of this website as part of our continuing commitment to the security of electronic content and the electronic transmission of information. Despite our best efforts unfortunately the transmission of information via the internet is not completely secure.  Although we have strict procedures and security measures in place, we cannot guarantee the security of your data transmitted to our site. In the event that, pursuant to these terms, personal and/or sensitive personal data (as defined in the EU General Data Protection Regulation 2016/679 (the “GDPR”)) of any individual (the “Individual Data”) is provided by us to a third party or that party otherwise comes into possession of Individual Data, such party shall not, by act or omission, i) breach its obligations under the GDPR and/or ii) cause us to breach its obligations under the GDPR, whether such breach is in relation to the Individual Data or otherwise.

Third party websites and apps

Our websites may contain links to and from third party websites.  Please note that if you follow a link to any of these websites, these websites will have their own terms of use and privacy policies and that we do not accept any responsibility of liability for these policies.  Please check these policies before you submit any personal data to these websites.

Your rights

You have the following rights with respect to the personal information that we hold about you.

• Your right to access the information we hold about you

You can request access to the information we hold about you by contacting us using the contact details set out below.  Our file of your information will usually be made available to you within 30 days, although occasionally we may not be able to give you access to the personal information we hold about you (for example, we may not be able to give you access if it would unreasonably affect someone else’s privacy or if giving you access poses a serious threat to someone’s life, health or safety).  Please note that we may apply an administrative charge for providing access to your information in certain circumstances. Any such charge will be reasonable and we will advise you of the charge and obtain your consent before providing you with access to your personal information. Please note that if you request a copy of your data using electronic means (such as email), then we will provide a copy of your information in electronic form unless you ask us to do otherwise.

• Your right to object to us processing your personal information

You have the right to object to us processing your personal information, even where that processing is necessary for our legitimate interests (for example, where the processing is necessary for the legitimate commercial objectives we pursue in the course of our business). You also have the right to object to any results of a processing activity that prejudice your rights and that are conducted exclusively through automated systems. You also have the right to ask us to stop processing your personal information for direct marketing purposes, including any profiling we undertake for the purposes of direct marketing.  We will in any case only send you marketing communications if you have previously agreed to this, but if you change your mind you can easily unsubscribe from our marketing communications at any time by following the instructions included in these marketing communications. Please note that, if you have consented to receive offers from our partners, our partners are responsible for taking account of your rights, including your right to opt-out of receiving offers from them.

• Your right to have your personal information transmitted to another organisation

Where we hold personal information about you with your consent or for the performance of a contract with you, you also have the right to ask us to provide you with the personal information we hold about you in a structured, commonly used and machine-readable format and, where technically feasible, to transmit that personal information to another organisation.

• Making a complaint

You have the right to lodge a complaint with a local data protection authority in the EEA if you believe that we have not complied with applicable data protection laws. The local data protection authority will differ depending on the country you are in.

Contacting us

If you have any questions or concerns about how we treat your personal information, you wish to ask us to stop processing your personal information, or you would like to request a copy of the personal information we hold about you, please write to us at: Aroha Ltd, PO Box 52294, Dubai, United Arab Emirates. Please include your reply address when you write to us.

How long do we keep your personal information?

Your personal information is stored by us and/or our Service Providers, strictly to the extent necessary for the performance of our obligations and strictly for the time necessary to achieve the purposes for which the information is collected, in accordance with applicable data protection laws.  When we no longer need to use your information, we will remove it from our systems and records and/or take steps to properly anonymise it so that you can no longer be identified from it (unless we need to keep your information to comply with legal or regulatory obligations to which we are subject).

Changes to this Policy

We may update this policy from time to time in response to changing legal, regulatory or operational requirements. Any changes will be updated on our website.  Your continued use of our website and/or services after any such updates take effect will constitute acceptance of those changes.