Introduction

This Privacy Policy is provided by www.sudouae.com, owned and operated by SUDO Technologies LLC (DED Licence No. XXXXX of Office 1004, 10th Floor Boulevard Plaza Tower 2 – Downtown Dubai, United Arab Emirates; referring “SUDO Technologies”, “we”, “us”, “our”), for and on behalf of itself and the various entities operating as part of the SUDO Technologies across the Middle East and other parts of the world, as further specified here.

We are committed to protecting the privacy of the users’ personal information that we collect and process in the course of our business, including the personal information we receive or collect from you (“you” or “your”). This Privacy Policy explains how and why we collect, store and use personal information, and provides information about the rights of the individuals to whom such personal information are related to.

With an intention of data protection law application, SUDO Technologies LLC is typically the “data controller” of any personal information provided to us. Specifically, your data will be controlled by the SUDO Technologies that you have instructed, or that is providing services to or communicating with you. Occasionally, we will work on specific retainers as a “processor” (meaning that we process personal data only in accordance with the directions of a data controller, or as otherwise permitted by law).

Please read the following information carefully to understand our views and practices on how we handle, use, manage, control and transfer your personal information. If you have any queries about our approach to data protection that are not already addressed in this Privacy Policy, please contact us on the address set out at the end of this Privacy Policy.

We at SUDO Technologies, are committed to protecting the privacy of our service users and website visitors.

We may collect personal information from you in the course of our business, when you contact us or request information from us when you instruct us to provide our services when you use our website or mobile app (or other platforms), or as a result of your relationship with any of our personnel or clients.

• Basic details, such as your name, role/title, employer/s, and your contact information (such as your email address, physical address, contact numbers);
• Identification information to enable us to check and verify your identity (e.g. your birthdate; your passport details), and information collected from publicly available resources to verify the same;
• Information relating to the matter on which you are seeking our digital services;
• Bank account or other financial information, if relevant to our engagement with you;
• Technical information (including your location, IP address, browser details, traffic data, location data), such as information from your visits to our website or mobile app (page interaction information, length of visits, etc.), or in relation to marketing emails we send to you;
• Information relating to your visits to our offices or our meetings and events, including appointment details (e.g. time, location, participants), CCTV images and other photographic or video images;
• Personal information provided to us by or on behalf of our clients, or generated by us in the course of providing services to them, which may include special categories of personal data;
• Any other information relating to you which you may provide to us.

• As part of our new business intake and client on-boarding or client maintenance activities, and when you seek services from us;
• When you seek employment from us, as part of our new employee on-boarding and maintenance of the employment relationship, or when you engage with our alumni group;
• When you provide (or offer to provide) services to us, either yourself or on behalf of your employer;
• When we are acting on a matter where you or your employer are a party to the same;
• When you interact with our website or mobile app or use any of our online services;
• When you interact with us in respect of any of our marketing communications or events;
• We collect most of this information directly from you, or through your use of our website.
• However, we may also collect data about you from a third-party source, such as our clients, your employer, other parties to matters in which we are involved, platform operators for technology used in our business (e.g. webinar platforms), other organisations that you have dealings with, regulators or other government authorities, credit reporting agencies, information service providers, or from publicly available records.

The information provided by the users may be confidential, and we are committed to maintain confidentiality and safeguard your information as per our professional obligations and applicable law. We have arrangements in place with personnel and service providers who may process your personal information, to ensure that confidentiality of your information is maintained strictly.

Whether we receive your personal data directly from you or from a third party, we will only use your personal information if we have obtained your consent, or if we have another lawful basis upon which to do so (e.g. 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 such contract; for compliance with a legal obligation on us; to protect your vital interests or those of another natural person; or for our own legitimate interests, or those of a third party, except where such interests are overridden by your own rights or interests).

• Providing our services to you;
• Managing our business relationship with you (or your organisation), whether in connection with the provision of our services, the procurement of your goods and services, or as your employer (or potential or former employer), including processing payments, accounting, auditing, billing and collection and related support services;
• Managing and securing access to our premises and information technology systems, and monitoring the technology side of our operations;
• Keeping your contact details accurate and current using the information provided by you, or information publicly available;
• For any purpose related and/or ancillary to any of the above or any other purposes for which your personal data was provided to us.

We operate a Customer Relationship Management emailing list program, which we use to inform clients and other contacts about our services, including our publications and events. Such marketing messages may contain tracking technologies in order to track subscriber activity relating to engagement, demographics and other data, and to build subscriber profiles. We use this as a means by which to undertake direct marketing. 

If you would like to cease receiving marketing materials from us at any time, please let us know directly.

Cookies are small files that are sent to a computer’s hard drive by a web server, enabling a website to remember who you are. Information from cookies may include information relating to your use of our websites, information about your computer (such as IP address and browser type), and demographic data. We use cookies to improve our website. 

Specifically, we use Google Analytics, and other similar products to track unique visitors to our website and app (storing a unique visitor ID, the date and time of first visit, the time of current visit started and the total number of visits they have made); to register session details (so as to attribute visit information, including conversions and transactions to a traffic source); and to register that a website visit has ended and the browser closed. Most internet browsers have a mechanism notifying you when you receive a new cookie, and telling you how to reject new cookies or disable cookies altogether (if you want that).

We may disclose your personal information to a recipient (i) for the purposes of outsourcing one or more of the purposes-related functions described above; (ii) to confirm or update the information provided by you; (iii) to inform you of events, information about our services, and other important information, or (iv) for other purposes disclosed at or before the time the information is collected. If we re-organise our business, we may need to transfer your personal information to other group entities or to third parties. 

If you tell us you wish to attend an event, your name and organisation may appear on a list which we provide to other delegates at the event. We also take photographs and video of our events, and this may result in your image being captured and used in the course of reporting on the event (e.g. via social media or other means); we will draw this to your attention in materials relating to the specific events. Moreover, we may also process contact details and attendance data to help tackle COVID-19, keeping the public health efforts in our minds. 

In relation to any other disclosures to third parties, we will only do so where you have given your consent, where we are required to do so by law, or where it is necessary for the purpose of or in connection with legal proceedings or in order to exercise or defend legal rights. We do not sell, rent, distribute, or otherwise make, personal information commercially available to any third party.

We will retain your personal information for the length of time needed to fulfil the purposes for which it was collected unless we specifically agree a longer retention period with you, or a longer retention period is required or permitted by law.

Depending on the circumstances and applicable law, you are entitled to various rights. Here is the summary of key rights likely to be available to most data subjects:

• Withdraw consent: When personal information is processed on the basis of consent, you may withdraw consent at any time, although such withdrawal will not affect the lawfulness of processing occurring prior to such withdrawal;
• Access and rectification: You may request access to and rectification or removal of personal information, or restriction of Processing concerning the Data Subject or to object to Processing as well as the right to data portability;
• Objecting and restricting: You may object, on legitimate grounds, to the processing of your personal information, or request that processing be restricted; and
• Complaints: If you believe that your data protection rights may have been breached, you may lodge a complaint with the relevant data protection authority.

If you would like to exercise any of the above rights, or any other rights available to you pursuant to applicable law, please contact us using the contact details set out below.

We have implemented reasonable administrative, technical and physical measures to protect your personal information against loss, misuse and alteration.

We may from time to time make changes to this Privacy Notice. Where these are likely to be material, we will communicate these in advance. Otherwise, these will become effective once the amended Privacy Notice is posted on our website. Please check back regularly to keep informed of updates to this Privacy Notice.

If you have any questions about this Privacy Policy or our processing of your personal data, please contact us using the contact details set out below:

Office 1004,

10th Floor Boulevard Plaza Tower 2

Dubai – United Arab Emirates

e-mail: [email protected]