Last updated: 07, February 2024

1. Introductory provisions


1.1. This Privacy Policy describes the information that SBS EAST FZCO , a company registered in accordance with the laws of United Arab Emirates, whose registered office address is at Dubai Silicon Oasis, DDP, Building A1, Dubai, United Arab Emirates (hereafter “Company”, “We”, “Us”) collects from you in connection with provision of services (the “Services”) available on the website https://sbs-east.com/ (the “Site”), and/or your access and use of the Site and how We use collected information, how We protect it, and your rights.

1.2. Personal Data in the text of this Privacy Policy means any information relating to you, as an identified or identifiable natural person, including your name, identification number, location data, or an online identifier, or to one or more factors specific to your physical, economic, cultural, or social identity as a natural person. This Privacy Policy does not apply to anonymised data, as it cannot be used to identify You.

1.3. This Privacy Policy applies to anyone who accesses the Site and/or uses the Services. Please take a moment to read this Privacy Policy carefully. By using our Services, You acknowledge that collection, use, and sharing of your Personal Data will take place as described in this Privacy Policy. If you have any questions about this Privacy Policy, please contact Us at help@sbs-east.com.

1.4. We are data controller in relation to the Personal Data processed within the framework of this Privacy Policy.

1.5. Eligibility. Please note, that We do not provide Services to persons under the legal age of majority. In terms of this Privacy Policy, this means that We do not knowingly collect Personal Data from individuals under the age of 18. If it comes to Our attention that a person using the Services is under the age of 18, we will take steps to remove such person’s Personal Data from our database, as well as to prevent such person from accessing and using the Site and/or the Services.

1.6. BY ACCESSING OR USING THE SERVICES, YOU ACKNOWLEDGE THAT YOU HAVE READ THIS PRIVACY POLICY AND THAT YOU UNDERSTAND YOUR RIGHTS IN RELATION TO YOUR INFORMATION AND HOW WE WILL COLLECT, USE AND PROCESS IT. IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY IN GENERAL OR ANY PART OF IT, YOU SHOULD NOT USE THE SERVICES.

1.7. We may amend any of the terms of the privacy policy by posting the terms. We will also update the “Last Updated” date at the top of this policy, which reflects the effective date of such policy. Your continued access to or use of Services and/or Site after the date of the updated policy constitutes your acceptance of the updated policy. If you do not agree to the updated policy, you must stop accessing or using Services. 

1.8. If you have any questions about this privacy policy or our information-handling practices, please contact us at help@sbs-east.com

2. Data that We Collect


2.1. We may collect the following types of information about You:

2.1.1. Personal Data. Depending on what Services you use, you may be required to provide Us with your Personal Data, including (but not limited to) your full name, residential address and contact details (e.g. email address, telephone number, fax etc.), date of birth, place of birth, gender, citizenship, payment information, tax identification and other information to help Us identify you, contents of Your communications with Us and your contact information when you contact Our Customer Service or respond to our communications (e.g., email, telephone number) or subscribe to Our marketing letters (you can opt-out from receiving Our marketing letters at any time by following instructions contained in relevant letter or by contacting Us as at help@sbs-east.com).

 2.1.2. Usage Data. Usage Data is collected automatically when you are using the Site and/or the Services. Usage Data may include information such as your device’s internet protocol address (IP address), time and date of your visit, unique device identifiers. When you access the Site and/or the Services by or through a mobile device, we may also automatically collect certain information, including, but not limited to, type of mobile device you use, your mobile device ID, IP address of your mobile device, your device’s operating system, type of mobile Internet browser you use, unique device identifiers.

   2.1.3. Tracking Technologies and Cookies. We use Cookies to track your activity on the Site and/or the Services and store certain information and settings. A Cookie is a piece of information that is stored locally on your device, that your device provides to the Site each time you submit a query. You can decide if and how your device will accept cookies by configuring Cookie preferences within your web browser, using the instructions provided in your browser. If you choose to decline Cookies, however, some of the functionality of the Site might be impaired.

 2.1.4. Information received from third parties. The Site and/or the Services may contain links to Third Party Sites (as defined in Our Terms) operated by third parties, and information (including Personal Data) that you provide on Third Party Sites will be collected by respective third parties.
Should you choose to visit Third Party Sites, you should review their privacy policies to ensure that you understand and are comfortable with their practices concerning your information (including Personal Data). We are not responsible for privacy policies and information collection, use, and sharing practices of any Third Party Sites (regardless of whether such websites are linked or included on the Site and/or the Services).
Some of Our partners and/or third-party service providers may ask you to provide certain information (including Personal Data) on their websites and may share such information with Us, as governed by their respective privacy policies.
We may also collect information (including Personal Data) about you from third parties and third-party service providers, such as Our business partners, vendors, or from publicly available information. The conditions under which We may obtain such information are governed by respective third parties.

2.1.5. Anonymized Data. Anonymization is a data processing method that removes or modifies personal information so that it cannot be associated with specific individual. Except for this section, no other provisions of this Privacy Policy apply to anonymized or aggregated Personal Data (i.e., information about Users that We combine together so that it no longer identifies or references to an individual User). We may use anonymized data for any business purpose, including to improve user experience, improve Our products and services, conduct business intelligence and marketing, and detect security threats. We may perform Our own analytics on anonymized data or enable analytics provided by third parties.

2.2. We do not knowingly collect any sensitive personal data or special categories of personal data.

2.3. By providing Personal Data to Us, you warrant and represent that such data is true, accurate and up to date.

3. Legal bases and purposes for processing of your Personal Data


3.1. We use following legal bases when processing your Personal Data (each legal basis is followed by respective purposes for the processing of your Personal Data):

   3.1.1. Processing necessary for the performance of the contract between you and Us or in order to take steps at your request prior to entering into a contract with Us:
       a. to verify your identity;
       b. to process transactions with you;
       c. to send you administrative or Service-related information.

   3.1.2. Processing necessary for compliance with legal obligations under the contracts We signed with You or under the applicable laws to which We are subject:
       a. to carry out compliance and risk management;
       b. to monitor and prevent fraud, misuse (e.g., use of the Site and/or the Services for illegal purposes), money laundering and terrorist financing by Users.

   3.1.3. Processing necessary to protect Our legitimate interests:
       a. to analyze and improve quality and the general user experience;
       b. to process inquiries from authorities, to resolve disputes, to ensure security of Company’s assets, systems and networks;
       c. to conduct market research, business management and continuous development of the Services;
       d. for quality control and staff training;
       e. to enhance security, prevent fraud, combat spam or other malware or security risks;
       f. to maintain operation, performance and administration of the Site and the Services.
More information regarding balancing between Our legitimate interests and your interests could be received by way of submitting a request to help@sbs-east.com.

   3.1.4. Processing based on Your consent:
       a. for direct marketing and advertising (e.g., satisfaction surveys, newsletters, and other advertising communications).

4. Disclosure of Personal Data


4.1. We may share Your Personal Data with third parties in the following circumstances:
       a. with our service providers (including providers of analytics, marketing and support services). We ensure appropriate contractual control over third parties assisting Us in processing your Personal Data, securing that your rights are upheld, your Personal Data is secure, appropriate security and privacy arrangements are in place;
       b. in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of our business to another company;
       c. with law enforcement or regulatory bodies and/or agencies, as may be required by applicable law;
       d. other third parties, upon reception of Your explicit consent or direction to do so.

5. Retention of your Personal Data


We retain your information for as long as it is necessary to provide you with Services so that we can fulfil our contractual obligations and rights in relation to the information involved, or for other legitimate purpose such as complying with our legal obligations, resolving disputes, and enforcing our agreements. Where we do not need your information in order to provide Services to you, we retain it only for so long as we have a reasonable business purpose in keeping such data.

6. Security of Your Information

We take appropriate administrative, technical and physical security measures to safeguard your personal information from unauthorized access and disclosure. Only authorized employees are permitted to access personal information, and they may do so only for permitted business functions. In addition, we use encryption in the transmission of certain your personal information between your system and ours, and we use firewalls to help prevent unauthorized persons from gaining access to your personal information. Please be advised, however, that we cannot fully eliminate security risks associated with the storage and transmission of your personal information. You should use caution whenever submitting information through Services and take special care in deciding which information you provide us with. You are responsible for maintaining the secrecy of your password and account information at all times.

7. Children Protection

Services are not directed to children, and if you are under the age of 16 or statutory age of majority as required by the laws of the country of your domicile, you may not use Services. We have zero tolerance to any form of child abuse or exploitation. Your data (including private messages) may be shared with legal agencies if we in our good faith believe that you have engaged in child abuse, or if we are requested to do so by relevant legal agencies.

8. Your rights

8.1. You have ultimate rights over Personal Data that you have communicated to Us.
8.2. Your right regarding Your Personal Data are as follows:
Your right - Description
Information and Access - The right to know whether your Personal Data is being processed, right to get information regarding processing of your Personal Data, right to request a copy of Personal Data being processed.

Rectification (correction) - The right to correct your Personal Data that We process.

Erasure - The right to request deletion of your Personal Data from Our database so that We are not able to continue processing and storage of such data, with exceptions, provided in applicable law.

Restrict processing - The right to introduce the restriction regime on processing of your Personal Data, so that in each case relevant data may be processed only upon your separate consent, with exceptions, provided in applicable law.

Data portability - The right to request your Personal Data to be given in a machine-readable format so that it could be transferred to a third party or to request your Personal Data to be transferred directly to a third party designated by you.

Object - The right to object to processing of your Personal Data in case when respective processing performed on the basis Our legitimate interest.

Withdraw consent - Right to withdraw consent to processing of your Personal Data by Us.

8.3. The abovementioned rights are not absolute. In order to exercise some of the rights, you shall meet certain conditions and requirements, specified in applicable law.
8.4. For more information regarding your rights in relation to your Personal Data, please contact help@sbs-east.com. In order to exercise your rights, please submit a request to email@sbs-east.com.
8.5. In addition to the rights mentioned above, as a resident of EU, you also have a right to complain to Supervisory Authority in your jurisdiction.

9. Transfer of Personal Data


9.1. We may maintain servers around the world and your information collected by Us will firstly be stored and processed in servers nearest to your region, but in several cases your information may be stored and processed in any other country where We maintain data collection facilities. We have complied with relevant applicable data localization rules with respect to our data transfer practices. We take appropriate steps to ensure that the information we collected is processed in accordance with the privacy policy and the relevant applicable laws and regulations. If We provide any information about you to any legal agency, we will take appropriate measures to ensure such receiving institutes protect your information adequately in accordance with this privacy policy and the applicable laws.

9.2. Please be aware that if you are a resident of EU/EEA, Personal Data that We collect from you may be transferred outside of EU/EEA, including to countries which European Commission does not recognize as providing adequate level of data protection.


9.3. Subject to sections 1, 2 (c) of article 46 of General Data Protection Regulation, We rely on standard contract clauses approved by the European Commission when carrying out international data transfers of EU/EEA residents to jurisdictions outside of EU/EEA.