to how we look after your personal data when you visit our application/website (regardless of where you visit it from)
and tell you about your privacy rights and how the law protects you.
1. Important information and who we are
your use of the website or the mobile application, including any data you may provide through this application/website
when you when you [sign up to our newsletter, register and/or purchase a product or service, as well as installing and
signing up to any QYM's powered application or our mobile applications].
This application/website is not intended for children and we do not knowingly collect data relating to children.
collecting or processing personal data about you so that you are fully aware of how and why we are using your data.
QYM is the controller and responsible for your personal data (referred to as [&QYM&], &();, &() or &() in this
We have appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this
the DPO using the details set out below.
1.3 Contact details
Email address: [DETAILS]
Postal address: [DETAILS]
Telephone number: [DETAILS]
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your
personal data changes during your relationship with us.
1.5 Third-party links
This Platform (Website, Mobile Application, and Client Portal/Dashboard) may include links to third-party websites,
plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or
share data about you. We do not control these third-party applications/websites and are not responsible for them
application/website you visit.
2. Personal Data that we collect
Your personal data, or personal information, means any information about an individual from which that person can
be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which is including but not limited to
a. Identity data includes [first name, maiden name, last name, username or similar identifier, marital status, title,
date of birth and gender].
b. Contact data includes [billing address, delivery address, email address and telephone numbers].
c. Financial data includes [bank account and payment card details].
d. Transaction data includes [details about payments to and from you and other details of services you have
ordered from us].
e. Technical data includes [internet protocol (IP) address, your login data, browser type and version, time zone
setting and location, browser plug-in types and versions, operating system and platform, and other technology
on the devices you use to access this website].
f. Profile data includes [your username and password, purchases or orders made by you, your interests,
preferences, and feedback and survey responses].
g. Usage data includes [information about how you use our website, products and services].
We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated
data could be derived from your personal data but is not considered personal data in law as this data will not directly
or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users
accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so
that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in
We do not collect any Special Categories of Personal Data about you (this includes details about your race or
ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership,
information about your health, and genetic and biometric data). Nor do we collect any information about criminal
convictions and offences.
3. If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to
provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with
you (for example, to provide you with services). In this case, we may have to cancel a service you have with us but we
will notify you if this is the case at the time.
4. How is your personal data collected?
We use different methods to collect data from and about you including through:
4.1 Direct interactions. You may give us your Identity, contact and financial data by filling in forms or by
corresponding with us by post, phone, and email or otherwise. This includes personal data you provide when you
undertake the following:
a. purchases our products or services;
b. creates an account on our application or website;
c. subscribes to our service or publications;
d. request marketing to be sent to you;
e. enters a competition, promotion or survey; or
f. gives us feedback or contact us.
4.2 Automated technologies or interactions. As you interact with our application/website, we will automatically collect
Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies,
server logs and other similar technologies. We may also receive Technical Data about you if you visit other mobile
5. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the
a. Where we need to perform the contract, we are about to enter into or have entered into with you.
b. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental
rights do not override those interests.
c. Where we need to comply with a legal obligation.
d. Where we need to set up your account and administrate it.
e. Where we need to deliver marketing and events communication.
f. Where we need to carry out surveys.
g. Where we need to personalize content, user experience or business information.
h. Where we need to meet audit requirements internally.
i. Where you have given consent.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your
consent before sending third party direct marketing communications to you via email or text message. You have the
right to withdraw consent to marketing at any time by contacting us.
6. Purposes for which we will use your personal data
A) Performance of a contract with you
We process your personal data because it is necessary for the performance of a contract to which you are a party or in
order to take steps at your request prior to entering into a contract or agreement.
In this respect, we use your personal data for the following:
i. To prepare a proposal for you regarding the services we offer;
ii. To provide you with the services as set as the scope of our services, or as otherwise agreed with you
from time to time;
iii. To deal with any complaints or feedback you may have;
iv. For any other purpose for which you provide us with your personal data.
In this respect, we may share your personal data with or transfer it to the following:
i. Subject to your consent, independent third parties whom we engage to assist in delivering the services
to you, including third parties;
ii. Our professional advisers where it is necessary for us to obtain their advice or assistance, including
lawyers, accountants, IT or public relations advisers;
iii. Debt collection agencies where it is necessary to recover money you owe us;
iv. Other third parties such as intermediaries who we introduce to you. We will wherever possible tell
you who they are before we introduce you;
v. Our data storage providers.
The legal basis for the processing of the aforementioned data categories is Art. 6 (1) (a) of the European General Data
Protection Regulation (GDPR). Due to the said purposes, in particular to guarantee security and a smooth connection
setup, we have a legitimate interest to process this data.
B) Legitimate interests
We also process your personal data because it is necessary for our legitimate interests, or sometimes where it is
necessary for the legitimate interests of another person.
In this respect, we use your personal data for:
i. For the administration and management of our business, including recovering money you owe to us,
and archiving or statistical analysis;
ii. Seeking advice on our rights and obligations, such as where we require our own legal advice. In this
respect we will share your personal data with our advisers or agents where it is necessary for us to
obtain their advice or assistance and with third parties and their advisers where those third parties are
acquiring, or considering acquiring, all or part of our business.
C) Legal obligations
We also process your personal data for our compliance with a legal obligation which we are under. In this respect, we
will use your personal data for the following:
i. To meet our compliance and regulatory obligations, such as compliance with anti-money laundering
ii. As required by tax authorities or any competent court or legal authority. In this respect, we will share
your personal data with the following:
iii. Our advisers where it is necessary for us to obtain their advice or assistance;
iv. Our auditors where it is necessary as part of their auditing functions;
v. With third parties who assist us in conducting background checks;
vi. With relevant regulators or law enforcement agencies where we are required to do so.
We will send you marketing about services we provide which may be of interest to you, as well as other information
in the form of alerts, newsletters, discounts or functions which we believe might be of interest to you or in order to
update you with information (such as legal or commercial news) which we believe may be relevant to you. We will
communicate this to you in a number of ways including by post, telephone, email or other digital channels.
E) Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want
or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant
for you (Marketing).
You will receive marketing communications from us if you have requested information from us or purchased services
from us [or if you provided us with your details when you entered a competition or registered for a promotion] and, in
each case, you have not opted out of receiving that marketing.
F) Third-party marketing
i. We will get your express opt-in consent before we share your personal data with any company outside
QYM for marketing purposes.
ii. You can ask us or third parties to stop sending you marketing messages at any time by logging into
the application/website and checking or unchecking relevant boxes to adjust your marketing
preferences or by following the opt-out links on any marketing message sent to you or by contacting
us at any time.
You can set your browser to refuse all or some browser cookies, or to alert you when application/websites set or
or not function properly.
H) Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we
need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an
explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If
we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis
which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in
compliance with the above rules, where this is required or permitted by law.
I) Opting out
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a
result of a product/service purchase, warranty registration, product/service experience or other transactions.
7. Disclosures of your personal data
We may share your personal data with the parties set out in article (6) purposes for which we will use your personal
Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we
may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We
do not allow our third-party service providers to use your personal data for their own purposes and only permit them
to process your personal data for specified purposes and in accordance with our instructions.
8. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or
accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those
employees, agents, contractors, third party service providers and other parties who have a business need to know.
They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any
applicable regulator of a breach where we are legally required to do so.
9. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for,
including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may
retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect
of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the
personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for
which we process your personal data and whether we can achieve those purposes through other means, and the
applicable legal, regulatory, tax, accounting or other requirements.
When it is no longer necessary to retain your personal data, we will delete it.
[Details of retention periods for different aspects of your personal data are [available in our retention policy which you
can request from us by contacting us.
10. What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access
your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is
not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information
in relation to your request to speed up our response.
11. Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if
your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep
12. What we do if the information is incorrect?
We do perform checks on the information that we receive to detect any defects or mistakes. However, we are reliant
upon suppliers, namely Companies House, providing accurate information to us. You have the right to request that we:
Rectify any personal data relating to you that is inaccurate; and
Complete any incomplete data, including by way of a supplementing, corrective statement. This is known as the right
to rectification. If you do exercise your right to rectification, we will take steps to check the information and correct it
13. How do we deal with the 'right to be forgotten'?
You have the right to request the erasure of personal data that we hold about you in certain circumstances, for example
if it were not acquired for, or has ceased to be necessary for, a lawful purpose. This is known as the right to be
forgotten. Where you request that we erase your data, we will usually only do so where the data has ceased to be
publicly available, whether at Companies House or otherwise, or where we no longer use it
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give
you the best service and the best and most secure experience. We make sure we consider and balance any potential
impact on you (both positive and negative) and your rights before we process your personal data for our legitimate
interests. We do not use your personal data for activities where our interests are overridden by the impact on you
(unless we have your consent or are otherwise required or permitted to by law). You can obtain further information
about how we assess our legitimate interests against any potential impact on you in respect of specific activities by
Performance of Contract means processing your data where it is necessary for the performance of a contract to which
you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal
obligation that we are subject to.
Internal Third Parties
Other companies in QYM acting as joint controllers or processors who are based in Egypt and provide IT and system
administration services and undertake leadership reporting.
External Third Parties
Service providers acting as processors-based Egypt who provide IT and system administration services.
Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who
provide consultancy, banking, legal, insurance and accounting services.
Governmental bodies and other authorities acting as processors or joint controllers based in the Arab Republic of
Egypt who require reporting of processing activities in certain circumstances.
YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data (commonly known as a () subject access()). This enables you to
receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate
data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no
good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data
where you have successfully exercised your right to object to processing (see below), where we may have processed
your information unlawfully or where we are required to erase your personal data to comply with local law. Note,
however, that we may not always be able to comply with your request of erasure for specific legal reasons which will
be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and
there is something about your particular situation which makes you want to object to processing on this ground as you
feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing
your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling
legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your
personal data in the following scenarios:
' If you want us to establish the data&()accuracy.
' Where our use of the data is unlawful but you do not want us to erase it.
' Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or
defend legal claims.
' You have objected to our use of your data but we need to verify whether we have overriding legitimate
grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have
chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies
to automated information which you initially provided consent for us to use or where we used the information to
perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not
affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent,
we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you
withdraw your consent.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may
charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to
comply with your request in these circumstances.
How to contact us? If you have any questions about how we use your personal data, or you wish to exercise any of the