Privacy Policy

  1. Policy Version: 3 January 2022
  2. 1 - https://trevex.io (“Site”) is provided by TREVEX Technology Limited, a company registered in Dubai International Financial Centre (“DIFC”) under company registration number 5069 (‘we’, ‘our’, ‘us’ or ‘Trevex’). Our registered office is at Unit GA-00-SZ-L1-RT-201, Level 1, Gate Avenue – South Zone, Dubai International Financial Centre, Dubai, United Arab Emirates. We are the controller of Personal Data obtained via our Site, meaning we are the organisation legally responsible for deciding how and for what purposes it is used.
  3. 2 - We value and respect your privacy. This Privacy Policy explains how we, Trevex, collect and handle the Personal Data (defined below) that is provided to us by you, the person providing data (“you” or “your”) on those web sites of Trevex that post or link directly to this Privacy Policy and through offline means, and explains how we use, disclose, and protect such data, and the choices you have concerning our use of such data. Please read this Privacy Policy carefully. Trevex may from time to time update this Privacy Policy. Any changes to this Privacy Policy will become effective when we post or link to the revised Privacy Policy on the Site.
  4. 3 - We collect, use and are responsible for certain Personal Data about you. When we do so we are subject to the Data Protection Law DIFC Law No. 5 of 2020 (“DIFC DPL”). We are also subject to the EU General Data Protection Regulation (“EU GDPR”) in relation to goods and services we offer to individuals and our wider operations in the European Economic Area (“EEA”). In case of any conflict between DIFC DPL and EU GDPR, DIFC DPL shall prevail.
  5. 4 - This Site is not intended for users under the age of 18. Trevex is not responsible for any consequences resulting from the use of users under the age of 18. We request that individuals under the age of 18 do not provide Personal Data through the Site.
  6. 5 - This privacy policy relates to your use of our Site only. Throughout our Site we may link to other Sites owned and operated by certain trusted third parties to maintain up-to-date information on the business records provided on our Site. Those third-party websites may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to those third-party websites, please consult their privacy policies as appropriate.
  7. 6 - You do not have to provide us with any Personal Data to visit the Site. However, if you choose to withhold requested information, you may not be able to visit all sections or use all features of the Site.
  8. 7 - You hereby agree that by continuing to use the Site or by clicking “I agree” or by registering on the Site, you consent and agree to the processing of your Personal Data and Other Data, as defined below, in accordance with the content of this Privacy Policy.
  9. 8 - By continuing to use this Site or by clicking “I Agree”/By Registering on the Site, under Article 12 of DIFC DPL, you hereby agree that your consent is freely given.
  10. ‍
  11. 9 - Collection of Personal Data and Other Data
  12. ‍We gather Personal Data as described below
    1. 9.1 - Personal data is information that identifies you or can be used to identify or contact you, e.g., your name, email address, address, or phone number. In case of a corporate entity, the Personal Data of a legal person shall include the business name, business email and business address business records of the corporate entity and any related information such as memorandums and articles of association, certificates of incorporation, trade licenses, financial statements and other documents required for the establishment and operation of any business ('Personal Data'). We may need to collect and process Personal Data in order to provide requested information, products or services to you (including the Site) or because we are legally required to do so and/or we have a legitimate interest to do so.
    2. 9.2 - You hereby consent and agree that any Personal Data provided to Trevex is voluntarily given and with your consent.
    3. 9.3 - Trevex will request Personal Data from you if you the Site requires you to register to access a service. The registration form will request Personal Data as defined above.
    4. 9.4 - Trevex may receive Personal Data from social media platforms if you choose to use your social media credentials to register with Trevex and may include Personal Data that is part of your social media profile.
    5. 9.5 - Trevex may collect Personal Data that is voluntarily provided by you, including emails, online forms, order and registration forms, surveys, promotion participation and various other means.
    6. 9.6 - Trevex may require Personal Data from users of the Site to comply with applicable anti-money laundering laws and other applicable laws.
    7. 9.7 - Trevex may use third-party payment services which may require redirection to a website hosted by the payment service provider and may require the submission of Personal Data to the website. Any Personal Data provided to such payment services will be collected by the payment service and not by Trevex and will be subject to the privacy policy of the payment service. Trevex has no control over and is not responsible for the use of Personal Data collected by a payment service.
    8. 9.8 - Trevex also collects information through various other methods, including online searches, conferences, events, individual introductions, from businesses who register with Trevex, and from selected third-party business associates. Occasionally, Trevex may also acquire from third-parties specific lists with the names and contact details of businesses and individuals who may potentially require the services of Trevex.
    9. 9.9 - In case of a corporate entity, the Personal Data of a legal person shall include the business records of the corporate entity and any related information such as memorandums and articles of association, certificates of incorporation, trade licenses, financial statements and other documents required for the establishment and operation of any business.
    10. ‍
  13. 10 - Use of Personal Data
    1. 10.1 - Under Article 9 and 10 of DIFC DPL, we can only use your Personal Data if we have a proper reason, eg: (a) where you have given consent (b) to comply with our legal and regulatory obligations (c) for the performance of a contract with you or to take steps at your request before entering into a contract, or (d) for our legitimate interests or those of a third party
    2. 10.2 - A legitimate interest is when we have a business or commercial reason to use your Personal Data, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own.
    3. 10.3 - We will use your Personal Data for legitimate business purposes, to enable us to perform our contractual obligations and to maintain our contractual relationship with you, and to comply with our legal and regulatory obligations, including the following: (a) Creating and managing your account with us; (b) Conducting checks to identify you and verify your identity or to help prevent and detect fraud against you or us’ (c) Customise our Site and its content to your particular preferences based on a record of your selected preferences or on your use of our Site’ (d) To enforce legal rights or defend or undertake legal proceedings; (e) Communications with you not related to marketing, including about changes to our terms or policies or changes to the products and/or services or other important notices; (f) Protecting the security of systems and data used to provide the services; (g) Statistical analysis to help us understand our customer base; (h) Updating and enhancing records; (i) Disclosures and other activities necessary to comply with legal and regulatory obligations that apply to our business, eg to record and demonstrate evidence of your consents where relevant; (j) Marketing our services to existing and former customers; (k) The audit of us to the extent not covered by ‘activities necessary to comply with legal and regulatory obligations’; (l) Retaining and evaluating information on your recent visits to our Site for analytics purposes to understand how people use our Site so that we can make it more intuitive or to check our Site is working as intended; and (m) To share your Personal Data with members of our group and third parties that will or may take control or ownership of some or all of our business (and professional advisors acting on our or their behalf) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency. In such cases information will be anonymised where possible and only shared where necessary
    4. 10.4 - From time to time, Trevex may use Personal Data to inform you of products, services and promotions that Trevex believes may be recommended for you. We may also use Personal Data of media contacts for press release distribution or sharing other newsworthy developments related to our business activities. You may opt-out of receiving marketing communications by accessing your preferences on the Site. Please also note that if you choose not to receive marketing-related messages from us, we may still send you important administrative messages, and you cannot elect to stop receiving such administrative messages, unless you choose to stop receiving services from us.
    5. 10.5 - Trevex reserves the right to use Personal Data to contact you for administrative communications regarding important information regarding the Site and the usability of the same. Trevex will also contact you to update you about important changes relevant to the use of the Site, products and/or services. You may not opt-out of such communications as Trevex will only contact you to maintain its contractual relationship with you.
    6. ‍
  14. 11 - Collection and use of Other Data
  15. ‍Trevex may also collect the following types of “Other Data”:
    1. 11.1 - Monitoring Data: Trevex and its service providers may collect and/or track other information such as demographic information, domain names, computer type, browser types, screen resolution, and other statistical data involving the use of the Site ('Monitoring Data'). We use Monitoring Data to help us understand who uses the Site and to improve and market it, as well as our other web sites and services. Unless combined with Personal Data, Monitoring Data does not personally identify you or any other user, and we may use it for any purpose.
    2. 11.2 - Cookies: To enhance the Internet experience on the Site, Trevex may use ‘cookies’ on the Site. Cookies are text files that a web server transfers to an individual's computer for recordkeeping and other purposes. We use cookies and other technologies to facilitate users' ongoing access to and use of our Site. We will ask for your consent to place cookies or other similar technologies on your device, except where they are essential for us to provide you with a service that you have requested (eg to process and track your activity on the Site and use our services).
    3. 11.3 - If you do not want information collected through the use of cookies, most browsers allow you to automatically decline cookies, or to be given the choice of declining or accepting the transfer of a particular cookie, or cookies from a particular web site to your computer. If cookies are disabled, however, all features of the Site may not operate as intended. Information about disabling cookies can be found on your internet browser provider’s web site.
    4. 11.4 - Trevex may also use various common internet tools such as 'pixel tags,' ‘action tags,’ ‘web beacons,’ ‘.gif tags,’ 'JavaScript' or similar technologies (together, 'Tools') in connection with Site pages and email messages in certain formats to, among other things, track the actions of Site users and email recipients, to determine the success of marketing campaigns and to compile statistics about Site usage and response rates. Tools allow us to count users who have visited certain pages of the Site, to deliver services, and to help determine the effectiveness of promotional or advertising campaigns. When used in email messages in certain formats, Tools can tell the sender whether and when the email has been opened. We believe cookies and Tools add value to the user experience.
    5. 11.5 - We may use third-party services to verify that you are a human user. Any information collected as part of such verification is subject to the privacy policy of the third-party service provider.
    6. 11.6 - If we are required to treat Other Data as Personal Data under applicable law, then we may use and disclose it for the purposes described above, as well as for the purposes for which we use and disclose Personal Data as detailed in this Privacy Policy.
    7. ‍
  16. 12 - Who we share your Personal Data with
    1. 12.1 - We routinely share Personal Data with: (a) third parties we use to help deliver our products and/or services to you, eg payment service providers. (b) other third parties we use to help us run our business, eg website hosts and website analytics providers (c) We may use and disclose Personal Data about you to law enforcement, emergency teams and compliance teams as we believe to be appropriate: (a) in compliance with laws, rules, or regulations in any country in which Trevex operates, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from government or public authorities, including government and public authorities outside your country of residence; (d) to enforce our Terms of Use; (e) to protect our operations or those of any affiliated entities; (f) to protect the rights, privacy, safety or property of Trevex, its affiliated entities, you, or others; and (g) to permit us to pursue available remedies or limit the damages that we may sustain. For example, we may, to the fullest extent the law allows, disclose Personal Data about you to law enforcement agencies to assist them in identifying individuals who have been or may be engaged in unlawful activities.
    2. 12.2 - We only allow those organisations to handle your Personal Data if we are satisfied they take appropriate measures to protect your Personal Data. We also impose contractual obligations on them to ensure they can only use your Personal Data to provide services to us and to you.
    3. 12.3 - Trevex uses external organisations to process Personal Data on its behalf, additional security arrangements need to be implemented under Article 28 of DIFC DPL in contracts with those organisations to safeguard the security of Personal Data. In particular, contracts with external organisations must provide that: (a) the organisation may act only on the written instructions of Trevex; (b) those processing the data are subject to a duty of confidence; (c) appropriate measures are taken to ensure the security of processing; (d) sub-contractors are only engaged with the prior consent of Trevex and under a written contract; (e) the organisation will assist Trevex in providing subject access and allowing individuals to exercise their rights in relation to data protection; (f) the organisation will assist Trevex in meeting its obligations in relation to the security of processing, the notification of data breaches and data protection impact assessments; (g) the organisation will delete or return all Personal Data to Trevex as requested at the end of the contract; and (h) the organisation will submit to audits and inspections, provide Trevex with whatever information it needs to ensure that they are both meeting their data protection obligations, and tell Trevex immediately if it is asked to do something infringing data protection law.
    4. ‍
  17. 13 - Retention Period
  18. We will not keep your Personal Data for longer than we need it for the purpose for which it is used. If your accounts remains inactive for a [X] period of time or if you delete your account or if you choose to stop receiving services from us, we may retain your account data under applicable law for a period that is no longer than necessary to fulfil the purposes for which it was processed. Personal Data that is no longer required will be anonymised or deleted permanently from our information systems and any hard copies will be anonymised or destroyed securely.
  19. ‍
  20. 14 - Your Rights
  21. You may access a copy of your Personal Data, correct, update, erase, delete, withdraw consent or otherwise object to or restrict the use of your Personal Data that you have provided to us. You may also request to receive an electronic copy of your Personal Data stored with us. If you would like to exercise any of those rights, please email, call or write to us. When contacting us please: (a) provide enough information to identify yourself (eg your full name, address and any additional identity information we may reasonably request from you), and (b) let us know which right(s) you want to exercise and the information to which your request relates.
  22. ‍
  23. 15 - Keeping your Personal Date Secure
    1. 15.1 - We have appropriate security measures to prevent Personal Data from being accidentally lost or used or accessed unlawfully. We limit access to your Personal Data to those who have a genuine need to access it. We continually test our systems and we follow top industry standards for information security.
    2. 15.2 - We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so under Article 42 of DIFC DPL.
    3. 15.3 - Trevex may transfer Personal Data outside the United Arab Emirates to Germany and/or to international organisations on the basis that Germany, or other international organisations are designated as having an adequate level of protection and that the organisation receiving the information has provided adequate safeguards by way of standard data.
    4. 15.4 - Trevex takes compliance with this policy very seriously. Failure to comply with the policy puts at risk the individuals whose Personal Data is being processed; and carries the risk of significant civil and criminal sanctions for the individual and Trevex; and may, in some circumstances, amount to a criminal offence by the individual failing to comply.
    5. ‍
  24. 16 - Changes to this Privacy Policy
  25. We may change this privacy policy from time to time. When we make significant changes we will take steps to inform you, for example by including a prominent link to a description of those changes on our Site for a reasonable period or by other means, such as email.
  26. ‍
  27. 17 - Jurisdiction
  28. Any dispute, difference, controversy or claim arising out of or in connection with this Privacy Policy, including (but not limited to) any question regarding its existence, validity, interpretation, performance, discharge and applicable remedies, shall be subject to the laws of Dubai International Financial Centre and shall be subject to the exclusive jurisdiction of the Courts of the Dubai International Financial Centre.
  29. ‍
  30. 18 - Contact Us
  31. ‍You can contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint. Our contact details are shown below:TREVEX Technology Ltd
    1. DIFC FinTech Hive, Gate Avenue
    2. Al Mustaqbal Street - Dubai
    3. United Arab Emirates
    4. contact@trevex.io
    5. +971 52 260 2838
  1. 1 - https://trevex.io (“Site”) is provided by TREVEX Technology Limited, a company registered in Dubai International Financial Centre (“DIFC”) under company registration number 5069 (‘we’, ‘our’, ‘us’ or ‘Trevex’). Our registered office is at Unit GA-00-SZ-L1-RT-201, Level 1, Gate Avenue – South Zone, Dubai International Financial Centre, Dubai, United Arab Emirates. We are the controller of Personal Data obtained via our Site, meaning we are the organisation legally responsible for deciding how and for what purposes it is used.
  2. 7 - You hereby agree that by continuing to use the Site or by clicking “I agree” or by registering on the Site, you consent and agree to the processing of your Personal Data and Other Data, as defined below, in accordance with the content of this Privacy Policy.
  3. 8 - By continuing to use this Site or by clicking “I Agree”/By Registering on the Site, under Article 12 of DIFC DPL, you hereby agree that your consent is freely given.
  4. ‍
  5. 9 - Collection of Personal Data and Other Data
  6. ‍We gather Personal Data as described below
    1. 9.1 - Personal data is information that identifies you or can be used to identify or contact you, e.g., your name, email address, address, or phone number. In case of a corporate entity, the Personal Data of a legal person shall include the business name, business email and business address business records of the corporate entity and any related information such as memorandums and articles of association, certificates of incorporation, trade licenses, financial statements and other documents required for the establishment and operation of any business ('Personal Data'). We may need to collect and process Personal Data in order to provide requested information, products or services to you (including the Site) or because we are legally required to do so and/or we have a legitimate interest to do so.
    2. 9.2 - You hereby consent and agree that any Personal Data provided to Trevex is voluntarily given and with your consent.
    3. 9.3 - Trevex will request Personal Data from you if you the Site requires you to register to access a service. The registration form will request Personal Data as defined above.
    4. 9.4 - Trevex may receive Personal Data from social media platforms if you choose to use your social media credentials to register with Trevex and may include Personal Data that is part of your social media profile.
    5. 9.5 - Trevex may collect Personal Data that is voluntarily provided by you, including emails, online forms, order and registration forms, surveys, promotion participation and various other means.
    6. 9.6 - Trevex may require Personal Data from users of the Site to comply with applicable anti-money laundering laws and other applicable laws.
    7. 9.7 - Trevex may use third-party payment services which may require redirection to a website hosted by the payment service provider and may require the submission of Personal Data to the website. Any Personal Data provided to such payment services will be collected by the payment service and not by Trevex and will be subject to the privacy policy of the payment service. Trevex has no control over and is not responsible for the use of Personal Data collected by a payment service.
    8. 9.8 - Trevex also collects information through various other methods, including online searches, conferences, events, individual introductions, from businesses who register with Trevex, and from selected third-party business associates. Occasionally, Trevex may also acquire from third-parties specific lists with the names and contact details of businesses and individuals who may potentially require the services of Trevex.
    9. 9.9 - In case of a corporate entity, the Personal Data of a legal person shall include the business records of the corporate entity and any related information such as memorandums and articles of association, certificates of incorporation, trade licenses, financial statements and other documents required for the establishment and operation of any business.
    10. ‍
  7. 10 - Use of Personal Data
    1. 10.1 - Under Article 9 and 10 of DIFC DPL, we can only use your Personal Data if we have a proper reason, eg: (a) where you have given consent (b) to comply with our legal and regulatory obligations (c) for the performance of a contract with you or to take steps at your request before entering into a contract, or (d) for our legitimate interests or those of a third party
    2. 10.2 - A legitimate interest is when we have a business or commercial reason to use your Personal Data, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own.
    3. 10.3 - We will use your Personal Data for legitimate business purposes, to enable us to perform our contractual obligations and to maintain our contractual relationship with you, and to comply with our legal and regulatory obligations, including the following: (a) Creating and managing your account with us; (b) Conducting checks to identify you and verify your identity or to help prevent and detect fraud against you or us’ (c) Customise our Site and its content to your particular preferences based on a record of your selected preferences or on your use of our Site’ (d) To enforce legal rights or defend or undertake legal proceedings; (e) Communications with you not related to marketing, including about changes to our terms or policies or changes to the products and/or services or other important notices; (f) Protecting the security of systems and data used to provide the services; (g) Statistical analysis to help us understand our customer base; (h) Updating and enhancing records; (i) Disclosures and other activities necessary to comply with legal and regulatory obligations that apply to our business, eg to record and demonstrate evidence of your consents where relevant; (j) Marketing our services to existing and former customers; (k) The audit of us to the extent not covered by ‘activities necessary to comply with legal and regulatory obligations’; (l) Retaining and evaluating information on your recent visits to our Site for analytics purposes to understand how people use our Site so that we can make it more intuitive or to check our Site is working as intended; and (m) To share your Personal Data with members of our group and third parties that will or may take control or ownership of some or all of our business (and professional advisors acting on our or their behalf) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency. In such cases information will be anonymised where possible and only shared where necessary
    4. 10.4 - From time to time, Trevex may use Personal Data to inform you of products, services and promotions that Trevex believes may be recommended for you. We may also use Personal Data of media contacts for press release distribution or sharing other newsworthy developments related to our business activities. You may opt-out of receiving marketing communications by accessing your preferences on the Site. Please also note that if you choose not to receive marketing-related messages from us, we may still send you important administrative messages, and you cannot elect to stop receiving such administrative messages, unless you choose to stop receiving services from us.
    5. 10.5 - Trevex reserves the right to use Personal Data to contact you for administrative communications regarding important information regarding the Site and the usability of the same. Trevex will also contact you to update you about important changes relevant to the use of the Site, products and/or services. You may not opt-out of such communications as Trevex will only contact you to maintain its contractual relationship with you.
    6. ‍
  8. 11 - Collection and use of Other Data
  9. ‍Trevex may also collect the following types of “Other Data”:
    1. 11.1 - Monitoring Data: Trevex and its service providers may collect and/or track other information such as demographic information, domain names, computer type, browser types, screen resolution, and other statistical data involving the use of the Site ('Monitoring Data'). We use Monitoring Data to help us understand who uses the Site and to improve and market it, as well as our other web sites and services. Unless combined with Personal Data, Monitoring Data does not personally identify you or any other user, and we may use it for any purpose.
    2. 11.2 - Cookies: To enhance the Internet experience on the Site, Trevex may use ‘cookies’ on the Site. Cookies are text files that a web server transfers to an individual's computer for recordkeeping and other purposes. We use cookies and other technologies to facilitate users' ongoing access to and use of our Site. We will ask for your consent to place cookies or other similar technologies on your device, except where they are essential for us to provide you with a service that you have requested (eg to process and track your activity on the Site and use our services).
    3. 11.3 - If you do not want information collected through the use of cookies, most browsers allow you to automatically decline cookies, or to be given the choice of declining or accepting the transfer of a particular cookie, or cookies from a particular web site to your computer. If cookies are disabled, however, all features of the Site may not operate as intended. Information about disabling cookies can be found on your internet browser provider’s web site.
    4. 11.4 - Trevex may also use various common internet tools such as 'pixel tags,' ‘action tags,’ ‘web beacons,’ ‘.gif tags,’ 'JavaScript' or similar technologies (together, 'Tools') in connection with Site pages and email messages in certain formats to, among other things, track the actions of Site users and email recipients, to determine the success of marketing campaigns and to compile statistics about Site usage and response rates. Tools allow us to count users who have visited certain pages of the Site, to deliver services, and to help determine the effectiveness of promotional or advertising campaigns. When used in email messages in certain formats, Tools can tell the sender whether and when the email has been opened. We believe cookies and Tools add value to the user experience.
    5. 11.5 - We may use third-party services to verify that you are a human user. Any information collected as part of such verification is subject to the privacy policy of the third-party service provider.
    6. 11.6 - If we are required to treat Other Data as Personal Data under applicable law, then we may use and disclose it for the purposes described above, as well as for the purposes for which we use and disclose Personal Data as detailed in this Privacy Policy.
    7. ‍
  10. 12 - Who we share your Personal Data with
    1. 12.1 - We routinely share Personal Data with: (a) third parties we use to help deliver our products and/or services to you, eg payment service providers. (b) other third parties we use to help us run our business, eg website hosts and website analytics providers (c) We may use and disclose Personal Data about you to law enforcement, emergency teams and compliance teams as we believe to be appropriate: (a) in compliance with laws, rules, or regulations in any country in which Trevex operates, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from government or public authorities, including government and public authorities outside your country of residence; (d) to enforce our Terms of Use; (e) to protect our operations or those of any affiliated entities; (f) to protect the rights, privacy, safety or property of Trevex, its affiliated entities, you, or others; and (g) to permit us to pursue available remedies or limit the damages that we may sustain. For example, we may, to the fullest extent the law allows, disclose Personal Data about you to law enforcement agencies to assist them in identifying individuals who have been or may be engaged in unlawful activities.
    2. 12.2 - We only allow those organisations to handle your Personal Data if we are satisfied they take appropriate measures to protect your Personal Data. We also impose contractual obligations on them to ensure they can only use your Personal Data to provide services to us and to you.
    3. 12.3 - Trevex uses external organisations to process Personal Data on its behalf, additional security arrangements need to be implemented under Article 28 of DIFC DPL in contracts with those organisations to safeguard the security of Personal Data. In particular, contracts with external organisations must provide that: (a) the organisation may act only on the written instructions of Trevex; (b) those processing the data are subject to a duty of confidence; (c) appropriate measures are taken to ensure the security of processing; (d) sub-contractors are only engaged with the prior consent of Trevex and under a written contract; (e) the organisation will assist Trevex in providing subject access and allowing individuals to exercise their rights in relation to data protection; (f) the organisation will assist Trevex in meeting its obligations in relation to the security of processing, the notification of data breaches and data protection impact assessments; (g) the organisation will delete or return all Personal Data to Trevex as requested at the end of the contract; and (h) the organisation will submit to audits and inspections, provide Trevex with whatever information it needs to ensure that they are both meeting their data protection obligations, and tell Trevex immediately if it is asked to do something infringing data protection law.
    4. ‍
  11. 13 - Retention Period
  12. We will not keep your Personal Data for longer than we need it for the purpose for which it is used. If your accounts remains inactive for a [X] period of time or if you delete your account or if you choose to stop receiving services from us, we may retain your account data under applicable law for a period that is no longer than necessary to fulfil the purposes for which it was processed. Personal Data that is no longer required will be anonymised or deleted permanently from our information systems and any hard copies will be anonymised or destroyed securely.
  13. ‍
  14. 14 - Your Rights
  15. You may access a copy of your Personal Data, correct, update, erase, delete, withdraw consent or otherwise object to or restrict the use of your Personal Data that you have provided to us. You may also request to receive an electronic copy of your Personal Data stored with us. If you would like to exercise any of those rights, please email, call or write to us. When contacting us please: (a) provide enough information to identify yourself (eg your full name, address and any additional identity information we may reasonably request from you), and (b) let us know which right(s) you want to exercise and the information to which your request relates.
  16. ‍
  17. 15 - Keeping your Personal Date Secure
    1. 15.1 - We have appropriate security measures to prevent Personal Data from being accidentally lost or used or accessed unlawfully. We limit access to your Personal Data to those who have a genuine need to access it. We continually test our systems and we follow top industry standards for information security.
    2. 15.2 - We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so under Article 42 of DIFC DPL.
    3. 15.3 - Trevex may transfer Personal Data outside the United Arab Emirates to Germany and/or to international organisations on the basis that Germany, or other international organisations are designated as having an adequate level of protection and that the organisation receiving the information has provided adequate safeguards by way of standard data.
    4. 15.4 - Trevex takes compliance with this policy very seriously. Failure to comply with the policy puts at risk the individuals whose Personal Data is being processed; and carries the risk of significant civil and criminal sanctions for the individual and Trevex; and may, in some circumstances, amount to a criminal offence by the individual failing to comply.
    5. ‍
  18. 16 - Changes to this Privacy Policy
  19. We may change this privacy policy from time to time. When we make significant changes we will take steps to inform you, for example by including a prominent link to a description of those changes on our Site for a reasonable period or by other means, such as email.
  20. ‍
  21. 17 - Jurisdiction
  22. Any dispute, difference, controversy or claim arising out of or in connection with this Privacy Policy, including (but not limited to) any question regarding its existence, validity, interpretation, performance, discharge and applicable remedies, shall be subject to the laws of Dubai International Financial Centre and shall be subject to the exclusive jurisdiction of the Courts of the Dubai International Financial Centre.
  23. ‍
  24. 18 - Contact Us
  25. ‍You can contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint. Our contact details are shown below:TREVEX Technology Ltd
    1. DIFC FinTech Hive, Gate Avenue
    2. Al Mustaqbal Street - Dubai
    3. United Arab Emirates
    4. contact@trevex.io
    5. +971 52 260 2838
  1. 1 - https://trevex.io (“Site”) is provided by TREVEX Technology Limited, a company registered in Dubai International Financial Centre (“DIFC”) under company registration number 5069 (‘we’, ‘our’, ‘us’ or ‘Trevex’). Our registered office is at Unit GA-00-SZ-L1-RT-201, Level 1, Gate Avenue – South Zone, Dubai International Financial Centre, Dubai, United Arab Emirates. We are the controller of Personal Data obtained via our Site, meaning we are the organisation legally responsible for deciding how and for what purposes it is used.
  2. Policy Version: 3 January 2022
  3. 7 - You hereby agree that by continuing to use the Site or by clicking “I agree” or by registering on the Site, you consent and agree to the processing of your Personal Data and Other Data, as defined below, in accordance with the content of this Privacy Policy.
  4. 8 - By continuing to use this Site or by clicking “I Agree”/By Registering on the Site, under Article 12 of DIFC DPL, you hereby agree that your consent is freely given.
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  6. 9 - Collection of Personal Data and Other Data
  7. ‍We gather Personal Data as described below
    1. 9.1 - Personal data is information that identifies you or can be used to identify or contact you, e.g., your name, email address, address, or phone number. In case of a corporate entity, the Personal Data of a legal person shall include the business name, business email and business address business records of the corporate entity and any related information such as memorandums and articles of association, certificates of incorporation, trade licenses, financial statements and other documents required for the establishment and operation of any business ('Personal Data'). We may need to collect and process Personal Data in order to provide requested information, products or services to you (including the Site) or because we are legally required to do so and/or we have a legitimate interest to do so.
    2. 9.2 - You hereby consent and agree that any Personal Data provided to Trevex is voluntarily given and with your consent.
    3. 9.3 - Trevex will request Personal Data from you if you the Site requires you to register to access a service. The registration form will request Personal Data as defined above.
    4. 9.4 - Trevex may receive Personal Data from social media platforms if you choose to use your social media credentials to register with Trevex and may include Personal Data that is part of your social media profile.
    5. 9.5 - Trevex may collect Personal Data that is voluntarily provided by you, including emails, online forms, order and registration forms, surveys, promotion participation and various other means.
    6. 9.6 - Trevex may require Personal Data from users of the Site to comply with applicable anti-money laundering laws and other applicable laws.
    7. 9.7 - Trevex may use third-party payment services which may require redirection to a website hosted by the payment service provider and may require the submission of Personal Data to the website. Any Personal Data provided to such payment services will be collected by the payment service and not by Trevex and will be subject to the privacy policy of the payment service. Trevex has no control over and is not responsible for the use of Personal Data collected by a payment service.
    8. 9.8 - Trevex also collects information through various other methods, including online searches, conferences, events, individual introductions, from businesses who register with Trevex, and from selected third-party business associates. Occasionally, Trevex may also acquire from third-parties specific lists with the names and contact details of businesses and individuals who may potentially require the services of Trevex.
    9. 9.9 - In case of a corporate entity, the Personal Data of a legal person shall include the business records of the corporate entity and any related information such as memorandums and articles of association, certificates of incorporation, trade licenses, financial statements and other documents required for the establishment and operation of any business.
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  8. 10 - Use of Personal Data
    1. 10.1 - Under Article 9 and 10 of DIFC DPL, we can only use your Personal Data if we have a proper reason, eg: (a) where you have given consent (b) to comply with our legal and regulatory obligations (c) for the performance of a contract with you or to take steps at your request before entering into a contract, or (d) for our legitimate interests or those of a third party
    2. 10.2 - A legitimate interest is when we have a business or commercial reason to use your Personal Data, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own.
    3. 10.3 - We will use your Personal Data for legitimate business purposes, to enable us to perform our contractual obligations and to maintain our contractual relationship with you, and to comply with our legal and regulatory obligations, including the following: (a) Creating and managing your account with us; (b) Conducting checks to identify you and verify your identity or to help prevent and detect fraud against you or us’ (c) Customise our Site and its content to your particular preferences based on a record of your selected preferences or on your use of our Site’ (d) To enforce legal rights or defend or undertake legal proceedings; (e) Communications with you not related to marketing, including about changes to our terms or policies or changes to the products and/or services or other important notices; (f) Protecting the security of systems and data used to provide the services; (g) Statistical analysis to help us understand our customer base; (h) Updating and enhancing records; (i) Disclosures and other activities necessary to comply with legal and regulatory obligations that apply to our business, eg to record and demonstrate evidence of your consents where relevant; (j) Marketing our services to existing and former customers; (k) The audit of us to the extent not covered by ‘activities necessary to comply with legal and regulatory obligations’; (l) Retaining and evaluating information on your recent visits to our Site for analytics purposes to understand how people use our Site so that we can make it more intuitive or to check our Site is working as intended; and (m) To share your Personal Data with members of our group and third parties that will or may take control or ownership of some or all of our business (and professional advisors acting on our or their behalf) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency. In such cases information will be anonymised where possible and only shared where necessary
    4. 10.4 - From time to time, Trevex may use Personal Data to inform you of products, services and promotions that Trevex believes may be recommended for you. We may also use Personal Data of media contacts for press release distribution or sharing other newsworthy developments related to our business activities. You may opt-out of receiving marketing communications by accessing your preferences on the Site. Please also note that if you choose not to receive marketing-related messages from us, we may still send you important administrative messages, and you cannot elect to stop receiving such administrative messages, unless you choose to stop receiving services from us.
    5. 10.5 - Trevex reserves the right to use Personal Data to contact you for administrative communications regarding important information regarding the Site and the usability of the same. Trevex will also contact you to update you about important changes relevant to the use of the Site, products and/or services. You may not opt-out of such communications as Trevex will only contact you to maintain its contractual relationship with you.
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  9. 11 - Collection and use of Other Data
  10. ‍Trevex may also collect the following types of “Other Data”:
    1. 11.1 - Monitoring Data: Trevex and its service providers may collect and/or track other information such as demographic information, domain names, computer type, browser types, screen resolution, and other statistical data involving the use of the Site ('Monitoring Data'). We use Monitoring Data to help us understand who uses the Site and to improve and market it, as well as our other web sites and services. Unless combined with Personal Data, Monitoring Data does not personally identify you or any other user, and we may use it for any purpose.
    2. 11.2 - Cookies: To enhance the Internet experience on the Site, Trevex may use ‘cookies’ on the Site. Cookies are text files that a web server transfers to an individual's computer for recordkeeping and other purposes. We use cookies and other technologies to facilitate users' ongoing access to and use of our Site. We will ask for your consent to place cookies or other similar technologies on your device, except where they are essential for us to provide you with a service that you have requested (eg to process and track your activity on the Site and use our services).
    3. 11.3 - If you do not want information collected through the use of cookies, most browsers allow you to automatically decline cookies, or to be given the choice of declining or accepting the transfer of a particular cookie, or cookies from a particular web site to your computer. If cookies are disabled, however, all features of the Site may not operate as intended. Information about disabling cookies can be found on your internet browser provider’s web site.
    4. 11.4 - Trevex may also use various common internet tools such as 'pixel tags,' ‘action tags,’ ‘web beacons,’ ‘.gif tags,’ 'JavaScript' or similar technologies (together, 'Tools') in connection with Site pages and email messages in certain formats to, among other things, track the actions of Site users and email recipients, to determine the success of marketing campaigns and to compile statistics about Site usage and response rates. Tools allow us to count users who have visited certain pages of the Site, to deliver services, and to help determine the effectiveness of promotional or advertising campaigns. When used in email messages in certain formats, Tools can tell the sender whether and when the email has been opened. We believe cookies and Tools add value to the user experience.
    5. 11.5 - We may use third-party services to verify that you are a human user. Any information collected as part of such verification is subject to the privacy policy of the third-party service provider.
    6. 11.6 - If we are required to treat Other Data as Personal Data under applicable law, then we may use and disclose it for the purposes described above, as well as for the purposes for which we use and disclose Personal Data as detailed in this Privacy Policy.
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  11. 12 - Who we share your Personal Data with
    1. 12.1 - We routinely share Personal Data with: (a) third parties we use to help deliver our products and/or services to you, eg payment service providers. (b) other third parties we use to help us run our business, eg website hosts and website analytics providers (c) We may use and disclose Personal Data about you to law enforcement, emergency teams and compliance teams as we believe to be appropriate: (a) in compliance with laws, rules, or regulations in any country in which Trevex operates, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from government or public authorities, including government and public authorities outside your country of residence; (d) to enforce our Terms of Use; (e) to protect our operations or those of any affiliated entities; (f) to protect the rights, privacy, safety or property of Trevex, its affiliated entities, you, or others; and (g) to permit us to pursue available remedies or limit the damages that we may sustain. For example, we may, to the fullest extent the law allows, disclose Personal Data about you to law enforcement agencies to assist them in identifying individuals who have been or may be engaged in unlawful activities.
    2. 12.2 - We only allow those organisations to handle your Personal Data if we are satisfied they take appropriate measures to protect your Personal Data. We also impose contractual obligations on them to ensure they can only use your Personal Data to provide services to us and to you.
    3. 12.3 - Trevex uses external organisations to process Personal Data on its behalf, additional security arrangements need to be implemented under Article 28 of DIFC DPL in contracts with those organisations to safeguard the security of Personal Data. In particular, contracts with external organisations must provide that: (a) the organisation may act only on the written instructions of Trevex; (b) those processing the data are subject to a duty of confidence; (c) appropriate measures are taken to ensure the security of processing; (d) sub-contractors are only engaged with the prior consent of Trevex and under a written contract; (e) the organisation will assist Trevex in providing subject access and allowing individuals to exercise their rights in relation to data protection; (f) the organisation will assist Trevex in meeting its obligations in relation to the security of processing, the notification of data breaches and data protection impact assessments; (g) the organisation will delete or return all Personal Data to Trevex as requested at the end of the contract; and (h) the organisation will submit to audits and inspections, provide Trevex with whatever information it needs to ensure that they are both meeting their data protection obligations, and tell Trevex immediately if it is asked to do something infringing data protection law.
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  12. 13 - Retention Period
  13. We will not keep your Personal Data for longer than we need it for the purpose for which it is used. If your accounts remains inactive for a [X] period of time or if you delete your account or if you choose to stop receiving services from us, we may retain your account data under applicable law for a period that is no longer than necessary to fulfil the purposes for which it was processed. Personal Data that is no longer required will be anonymised or deleted permanently from our information systems and any hard copies will be anonymised or destroyed securely.
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  15. 14 - Your Rights
  16. You may access a copy of your Personal Data, correct, update, erase, delete, withdraw consent or otherwise object to or restrict the use of your Personal Data that you have provided to us. You may also request to receive an electronic copy of your Personal Data stored with us. If you would like to exercise any of those rights, please email, call or write to us. When contacting us please: (a) provide enough information to identify yourself (eg your full name, address and any additional identity information we may reasonably request from you), and (b) let us know which right(s) you want to exercise and the information to which your request relates.
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  18. 15 - Keeping your Personal Date Secure
    1. 15.1 - We have appropriate security measures to prevent Personal Data from being accidentally lost or used or accessed unlawfully. We limit access to your Personal Data to those who have a genuine need to access it. We continually test our systems and we follow top industry standards for information security.
    2. 15.2 - We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so under Article 42 of DIFC DPL.
    3. 15.3 - Trevex may transfer Personal Data outside the United Arab Emirates to Germany and/or to international organisations on the basis that Germany, or other international organisations are designated as having an adequate level of protection and that the organisation receiving the information has provided adequate safeguards by way of standard data.
    4. 15.4 - Trevex takes compliance with this policy very seriously. Failure to comply with the policy puts at risk the individuals whose Personal Data is being processed; and carries the risk of significant civil and criminal sanctions for the individual and Trevex; and may, in some circumstances, amount to a criminal offence by the individual failing to comply.
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  19. 16 - Changes to this Privacy Policy
  20. We may change this privacy policy from time to time. When we make significant changes we will take steps to inform you, for example by including a prominent link to a description of those changes on our Site for a reasonable period or by other means, such as email.
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  22. 17 - Jurisdiction
  23. Any dispute, difference, controversy or claim arising out of or in connection with this Privacy Policy, including (but not limited to) any question regarding its existence, validity, interpretation, performance, discharge and applicable remedies, shall be subject to the laws of Dubai International Financial Centre and shall be subject to the exclusive jurisdiction of the Courts of the Dubai International Financial Centre.
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  25. 18 - Contact Us
  26. ‍You can contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint. Our contact details are shown below:TREVEX Technology Ltd
    1. DIFC FinTech Hive, Gate Avenue
    2. Al Mustaqbal Street - Dubai
    3. United Arab Emirates
    4. contact@trevex.io
    5. +971 52 260 2838
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