Vivium Holding Ltd and its subsidiaries (collectively, “Vivium”, “we,” “us,” or “our“) value your security and privacy, and we are committed to protecting your personal data. In accordance with the Data Protection law, DIFC Law No. 5 of 2020 (the “DP Law”), or any other applicable law, we collect information about you when you when you: (i) visit our website (the “Website”), (ii) use the Vivium email address for contact purposes, (iii) become employed by, or act as a service provider to, Vivium, (iv) visit our offices or locations or (v) avail, access or interact with any of our other web-based products, platforms, information or services, including our social media accounts or campaigns, or use our Wi-Fi (collectively, the “Vivium Facilities”).
For the purposes of the DP Law, we are a Controller in respect of your personal data and are responsible for ensuring that we use your personal data in compliance with the DP Law. This privacy policy (the “Policy“) sets out the basis on which any information, including any personal data, we collect from you, or you provide to us, will be processed by Vivium. Each time you access or use the Vivium Facilities or provide us with information, by doing so you acknowledge the practices described in this Policy. For use of specific amenities, i.e., our Wi-Fi, you may be asked to opt-in to our use of the information you submit there. Your rights described herein apply in these instances as well.
The personal data we collect from you, described in more detail below, may include your name, home and/or work address, photo, email address, company name, and phone number (“Personal Data”). Personal Data is any information that can be used to identify you and does not include data from which you can no longer be identified such as anonymized aggregate data.
We collect and process Personal Data in accordance with the DP Law and applicable laws, including for specific, lawful purposes explained herein or at the time of collection, or for the performance of tasks carried out in your interests or the legitimate interests of Vivium.
This Policy applies to persons anywhere in the world who accesses or uses our Vivium Facilities.
When you use the Vivium Facilities, we collect your Personal Data when you fill an electronic form, contact us via email or by telephone, or interact with us on social media. This Personal Data, some of which is sensitive information, may include, but is not limited to:
Personal Data revealing or concerning (directly or indirectly) your racial or ethnic origin, communal origin, political affiliations or opinions, religious or philosophical beliefs, criminal record, trade-union membership and health or sex life and including genetic data and biometric data where it is used for the purpose of uniquely identifying you shall collectively be referred to as “Special Categories of Personal Data”.
If you contact us, we will keep a record of both the correspondence and your contact details used at that time.
When you use the Vivium Facilities, we automatically collect the following information:
If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you (such as paying you or providing a product, service or benefit), exercise our powers and functions (such as the performance of tasks carried out by us), or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of our workers).
We may use your Personal Data for the following purposes:
In instances, where you have expressly given us your consent, we may process your Personal Data for the following purposes:
Where we rely on your consent for such purposes, you have the right to object at any time to the processing of your Personal Data for such purposes.
We will not use your Personal Data for taking any automated decisions affecting you or creating profiles.
We will process your Personal Data if and to the extent applicable law provides a lawful basis for us to do so. We will therefore process your Personal Data only:
In addition, where relevant and applicable, the processing may be based on your consent where you have expressly given that to us.
Without prejudice to the above, whenever we collect Special Categories of Personal Data, in most cases our legal basis will be one of the following:
We maintain your Personal Data only for the duration necessary to fulfill the purposes for which it was collected and processed. This includes consideration of our legal obligations, accounting requirements, and reporting responsibilities. Once your Personal Data is no longer needed, it is securely deleted or anonymized (in which case it is no longer considered Personal Data).
You maintain significant control over your Personal Data and have the following rights:
In the circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact us using the email provided in Section 15 below. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
As set out in Article 39 of the DP Law, we may not discriminate against you for exercising your rights by denying services or changing prices or quality of service, unless reasonable to do so in general, as objectively determined, and applicable to all individuals offered or receiving such benefits.
If you think that any of your rights have been infringed by us, you have the right to lodge a complaint with the DIFC Data Protection Commissioner at this link. If you need more information on this, please contact us at the email address provided in Section 15 below.
Your personal data may be processed, stored, shared, transferred or disclosed by us or other third parties for the purposes described in this Privacy Policy. We do this in order to operate effectively, efficiently and securely in facilitating transactions and providing products and services to our clients, to improve and support our processes and business operations and to comply with our legal and regulatory obligations. This may involve processing, storing, sharing, transferring or disclosing your personal data cross border to other jurisdictions.
Where recipients of your personal data are in jurisdictions that are outside the DIFC, and local laws may not have similar data protection laws as the DIFC, we will take all reasonable steps necessary to ensure that your personal data has an appropriate adequate level of protection and safeguards (which include enforceable right and effective legal remedies for you) to comply with applicable law. In most cases, this means using standard contractual clauses approved by the DIFC Data Protection Commissioner.
For further information, you can contact us for a copy of the relevant standard contractual clauses, or you can refer to the standard contractual clauses available on the DIFC website at www.difc.ae.
In some circumstances we are legally obliged to share information with public authorities or law enforcement. For example, we may be required to provide information related to a court order or where we must cooperate with supervisory authorities in handling complaints or investigations. In any scenario, we’ll attempt to satisfy ourselves that we have a lawful basis on which to share the information and document our decision making with regards to the same.
We may also share information in the event of the non-payment including of a monetary penalty or court ordered costs. If the debt remains outstanding after the specified timeframe for payment, no payment plan is in place or an agreed payment plan is not being adhered to, we may initiate formal proceedings to recover the full amount of the unpaid penalty.
As a result, Vivium will share Personal Data with the litigation and recovery specialists it instructs in order for them to identify assets and undertake recovery action through the courts.
Our services are designed for adult users and we do not knowingly collect information from individuals under 16 years of age. If we discover we have inadvertently gathered data from a minor, we will take prompt steps to delete this information.
We take data security seriously and employ appropriate technical and organizational measures to protect your information. Our security protocols guard against unauthorized access, alteration, disclosure, or destruction of your personal data. Unfortunately, no data transmission over the internet can be guaranteed to be 100 per cent secure. As a result, we cannot warrant or guarantee the security of any Personal Data you transmit to us, and you do so at your own risk.
We have established policies and procedures for securely managing information and protecting Personal Data against unauthorised access. We continually assess our data privacy, information management and security practices. We do this in the following ways:
To the extent permitted by applicable law, we expressly disclaim any liability that may arise should any other third parties obtain the Personal Data you submit through fraud or otherwise where it is no fault of ours.
Our website contains links to other websites on the Internet that are owned and operated by third parties (the “External Sites“). These links are provided solely as a convenience to you and are not to be portrayed as an endorsement by us of the contents or reliability of such External Sites. You acknowledge that we are not responsible for the availability of, or the information and contents of any External Site. You should contact the site administrator or webmaster for those External Sites if you have any concerns regarding such links or the content located on such External Sites.
If you decide to access the linked third-party websites, you do so at your own risk. We do not accept liability, and shall not be liable to you for any loss or damage arising from or as a result of your acting upon the contents of another website to which you may link from the Website. We encourage you to review the privacy policies of any third-party sites you visit through our website.
Building security records containing sign in and sign out information collected at the time of visiting and departing the Vivium office will be maintained in accordance with the applicable building management policy.
To the extent permitted by applicable law, Vivium is not responsible for any contents, whether or not they contain Personal data or other business information, that remain in our premises after you leave our office.
We may update this Policy from time to time and without notice to reflect changes in our practices or legal requirements. If we make significant changes in the way we treat your Personal Data, or to the Policy, we will endeavour to provide you notice through the Website or by some other means, such as email. Your continued use of the Vivium Facilities after such notice constitutes your understanding of the changes. The most current version will always be available on our website, marked with the latest revision date. We encourage you to periodically review this Policy for the latest information on our privacy practices.
For any questions or concerns about this Policy or our privacy practices, please contact us at:
[email protected].