Last updated June 24, 2021
Marketing MBA, DMCC (“we”, “our” or “MMBA”) is committed to protecting the privacy of all users and Customers (“you”) who access our Website or Services. Please read the following privacy policy (“Privacy Policy”), which explains how we use and protect your information.
By accessing our Website and using our Services, you agree and consent to the collection, use and transfer of your information as set out in this Privacy Policy. You shouldn’t use the Services if you don’t agree with this Privacy Policy or any other agreement that governs your use of the Services.
In this Privacy Policy the following definitions and interpretation apply:
Personal Data: means any information of any form related to an identifiable individual, or an individual who can be identified, directly or indirectly, particularly through their personal identification number, or one or more of their physical, physiological, intellectual, cultural or economic characteristics or social identity;
Process and Processing: means any operation or set of operations carried out on Personal Data by automated or non-automated means, such as collecting, recording, organizing, classifying into groups, storing, modifying, amending, retrieving, using or revealing such data by broadcasting, publishing, transmitting, making them available to others, integrating, blocking, deleting or destroying them;
Any capitalized terms not defined in this policy are defined as specified in MMBA’s Terms of Use.
The purpose of this Privacy Policy is to give you information on how we collect and Process your Personal Data through your use of the Website, including any Personal Data you may provide when using the Services.
It is important that you read this Privacy Policy together with any other privacy notice we may provide on specific occasions when we are collecting or processing Personal Data about you so that you are fully aware of how and why we are using your Personal Data.
We keep our Privacy Policy under regular review and we reserve the right to change this Privacy Policy at any time. If we make any material change to it, the change will be posted on the Website and, where appropriate, notified to you via email, SMS, or when you next log onto the Website. Unless stated otherwise, modifications will become effective on the day they are posted.
As permitted by applicable law, if you continue to use the Services after the effective date of any change, then your access and/or use will be deemed an acceptance of (and agreement to follow and be bound by) the revised Privacy Policy. The revised Privacy Policy supersedes all previous Privacy Policies.
It is important that the Personal Data we hold is accurate and current. Please keep us informed if your Personal Data changes while you are a User of our Services.
The Website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. These websites and any services that may be accessible through them have their own privacy policies and MMBA does not accept any responsibility or liability for those policies or for any Personal Data that may be collected through these websites or services, such as contact and location data. Please check these policies before you submit any Personal Data to these websites or use their services.
We may Process different kinds of Personal Data about you which we have grouped together as follows:
(a) Identity Data: includes names, username or similar identifier, marital status, title, date of birth and gender;
(b) Contact Data: includes billing address, home address (if different), delivery address (if different), email address and telephone numbers;
(c) Financial Data: includes bank account and payment card details;
(d) Transaction Data: includes details about payments and other details of the Services you have used;
(e) Technical Data: includes internet protocol address, login data, data about your browser type and version, time zone setting and location services, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the Website;
(f) Profile Data: includes your username and profile, previous orders made by you, your service preferences and any reviews you may have submitted;
(g) Usage Data: includes information about how you use the Website and/or the Services; and
(h) Marketing and Communications Data: includes your preferences in receiving marketing from us and third parties (i.e. any external partners) and your preferences when receiving communications.
When you visit the Website we may also Process aggregated, anonymized statistical or demographic data, which may be derived from your Personal Data but is not considered Personal Data in law as it cannot directly or indirectly reveal your identity.
If you provide Personal Data relating to other individuals in the order you are representing that you have their authority to provide their Personal Data to us and for the Processing of their Personal Data. We are entitled to rely upon such representations.
If we need to collect Personal Data by law, or under the terms of a contract with you, and you fail to provide such data when requested, we may not be able to perform the contract (an Order Confirmation Form, for example) we have or are trying to enter into with you. In these circumstances, we have the right to cancel or refuse to accept your order, but we will notify you if this is the case at the time.
By accessing the Website and/or Services using mobile digital routes such as, but not limited to, mobile, tablet or other devices/technology, then you should expect that our Processing of Personal Date as set out in this policy will apply in that context too.
Unless you have elected to remain anonymous through your device and/or platform settings, this information may be Processed by us automatically if you use the Service through your mobile device(s), through your mobile's browser/the Website or otherwise.
We use cookies and/or tracking technologies to distinguish you from other users in respect of your use of the Website, or service sites and to remember your preferences. This helps us to provide you with a good experience when you browse the Website and also allows us to improve the Website.
MMBA and service providers acting on our behalf (like Google Analytics and third-party advertisers) use server log files and automated data collection tools like cookies, tags, scripts, customized links, device or browser fingerprints, and web beacons (together, “Data Collection Tools“) when you access and use the Services. These Data Collection Tools automatically track and collect certain Technical Data and Usage Data when you use the Services. In some cases, we tie data gathered through those Data Collection Tools to other data that we collect as described in this Privacy Policy.
MMBA uses the following types of Data Collection Tools for the purposes described:
We may combine information from these types of Data Collection Tools and technologies with information about you from any other source.
Your Personal Data will enable us to provide you with access to the relevant parts of the Website or the Website and to supply the Services you have requested.
Your Personal Data will be Processed as permitted by law. Most commonly, we rely on the following types of lawful basis to Process your Personal Data:
Performance & Conclusion of Contract: in order to fulfill any orders you submit through the Website or in respect of your use of the Services;
Comply with legal obligation: in order for us to comply with any legal or regulatory obligation to which we are subject;
Protection of your vital interests: so that you receive the Service you expect to; and
Exercise our legitimate interests: so that we can conduct and manage our business in order to give you the highest standard of service.
Such activities connected to such lawful basis in respect of Processing your Personal Data may include:
We will only Process your Personal Data for the purposes for which it was collected unless we consider if reasonable that we need to use it for another reason and that reason is compatible with the original purpose.
Where appropriate, now and in the future, you may have the ability to express your preferences around the use of your Personal Data as set out in this Privacy Policy and this may be exercised through your chosen method of using the Services, for example, through the Website.
For information on our use of cookies, we refer you to our Cookie Policy.
Where you have indicated accordingly, you agree that we may use your Personal Data to let you know about our other products and services that may be of interest to you including services that may be the subject of direct marketing and we may contact you to do so by post, telephone, mobile messaging (e.g. SMS, MMS etc.) as well as by e-mail.
Where you have indicated accordingly, you agree that we may also share your Personal Data with third parties to use your Personal Data in order to let you know about goods and services which may be of interest to you (by telephone, mobile messaging (e.g. SMS, MMS etc.) and/or e-mail), and to help us analyze the information we collect so that we can administer, support, improve and develop the Website and Services to you.
If you do not want us to use your Personal Data in this way or change your mind about being contacted in the future, please let us know by using the contact details set out below and/or amending your profile accordingly.
Please note that by submitting comments and feedback regarding the Website and the Services, you consent to us to use such comments and feedback on the Website and in any marketing or advertising materials. We will only identify you for this purpose by your first name and the city in which you reside.
Do Not Track Signals: Since there is no widely accepted standard for the browser-initiated Do Not Track signal, we do not currently recognize or respond to Do Not Track signals.
The Personal Data you provide to us will be transferred to and stored on our servers.
We may disclose your Personal Data to a third-party for a business purpose. When we disclose Personal Data for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Data confidential and not use it for any purpose except performing your contract
We may share your data with third parties under the following circumstances or as otherwise described in this Privacy Policy:
By submitting your Personal Data, you agree to this Processing by such third parties and for the purposes set out in this Privacy Policy. To the best of its ability and knowledge, MMBA will take all steps reasonably necessary to ensure that your Personal Data is treated securely and in accordance with this Privacy Policy.
We will share your Personal Data within MMBA and any such group companies of MMBA. We ensure your Personal Data is protected by requiring all group companies to follow the same rules when Processing your Personal Data.
Some third parties may be based outside of the United Arab Emirates and so the Processing of your Personal Data may require a transfer of Personal Data outside of the United Arab Emirates.
Whenever we transfer your Personal Data to third parties which are based outside the United Arab Emirates we ensure that a similar degree of protection is afforded to your Personal Data.
There are limited occurrences where we are able to transfer your Personal Data outside of the United Arab Emirates. For all other occurrences, your consent will be obtained prior to such transfer.
Our carefully selected partners and service providers may process personal information about you on our behalf as described below:
“Digital Marketing Service Providers
We periodically appoint digital marketing agents to conduct marketing activity on our behalf, such activity may result in the compliant processing of personal information.
All Personal Data you provide to us is stored on our secure servers. Any payment transactions (carried out by us or our chosen third-party provider of payment processing services) will be encrypted using encryption technology. Where we have given you (or where you have chosen) a password that enables you to access certain parts of the Website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Once we have received your Personal Data, we will use strict procedures and security features to protect against unauthorized access to, alteration, disclosure, or destruction of your Personal Data that we collect and store. These measures vary based on the type and sensitivity of the data. Unfortunately, we cannot guarantee that communications between you and MMBA, the Services, or any information provided to us in connection with the data we collect through the Services will be free from unauthorized access by third parties.
The Services or the Website may include social networking, chat room or forum features. Ensure when using these features that you do not submit any Personal Data that you do not want to be seen, collected or used by other users.
We will only retain your Personal Data for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting or reporting requirements.
In some circumstances we will anonymize your Personal Data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
In the event you do not use the Website for a period of one (1) year then we will treat the account as expired and your Personal Data may be deleted.
Under certain circumstances in respect of your Personal Data you have the right to:
Request access to your Personal Data (commonly known as a "data subject access request"). 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 Personal Data unlawfully or where we are required to erase your Personal Data to comply with applicable 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. We may deny your deletion request if retaining the information is necessary for us or our service providers to:
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 the Services to you. We will advise you if this is the case at the time you withdraw your consent.
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 (and you will always be able to opt-out via the “unsubscribe” link on an email from us). 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 situations:
(a) if you want us to establish the accuracy of the Personal Data;
(b) where our use of the Personal Data is unlawful but you do not want us to erase it;
(c) where you need us to hold the Personal Data even if we no longer require it because you need it to establish, exercise or defend legal claims; or
(d) you have objected to our use of your Personal 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. Please note that this right only applies to information which was originally collected electronically and which you either consented to us using or was used to perform a contract with you.
If you wish to exercise any of the rights set out above, please contact us.
You will not usually 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 we consider your request to be unfounded, repetitive or excessive.
We may require specific information from you to help us confirm your identity and ensure your rights to access your Personal Data. This is a security measure to ensure that your Personal Data is not disclosed to someone who has no right to receive it.
We aim to respond to all legitimate requests within one (1) calendar month unless notified otherwise.
You can choose not to provide certain data to us, but you may not be able to use certain features of the Services.
Individuals younger than 18 years of age, but of the required age for consent to use online services where they live, may not set up an account, but may have a parent or guardian open an account and help them access appropriate content. Individuals younger than the required age for consent to use online services may not use the Services. If we learn that we’ve collected personal data from a child under those ages, we will take reasonable steps to delete it. Parents who believe that MMBA may have collected personal data from a child under those ages can submit a request that it be removed to team@marketing.mba.
16.1 Users in California
Users who are California residents have certain rights under the California Consumer Privacy Act, (“CCPA”). If you are an eligible California user, these rights include:
The CCPA has a specific definition of a “sale”. Whereas MMBA does not, in the traditional sense, sell your or the Personal Data of any of our users, we do use cookies that make non personally identifiable information available to certain third parties. To opt out of this, withdraw your consent for cookies via your browser settings. Your browser’s help function should contain instructions on how to set your computer to accept all cookies, to notify you when a cookie is issued, or to not receive cookies at any time.
To exercise any of these rights under the CCPA, please email us at team@marketing.mba. CCPA allows you to designate an authorized agent to make these requests on your behalf. You may also make these requests on behalf of your minor child. You may only make a request for access or data portability twice within a 12-month period.
The request must:
We cannot respond to your request or provide you with Personal Data if we cannot verify your identity or authority to make the request and confirm the Personal Data relates to you.
Making a request does not require you to create an account with us.
Under the CCPA, you also have the right to request certain details about what Personal Data we share with third parties for those third parties’ direct marketing purposes. To submit your request, send us an email to team@marketing.mba.
We will attempt to respond to your request in a timely fashion. In the event of delays over 60 days, we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. Any disclosures we provide will only cover the 12-month period preceding the receipt of your request. The response we provide will explain the reasons we cannot comply with a request, if applicable.
17.2 Users in the United Kingdom (“UK”) and the European Economic Area (“EEA”)
By visiting the Website or using the Services, you consent to storage of your Personal Data on servers located in the United Arab Emirates. If you are using the Services from outside the United Arab Emirates, you consent to the transfer, storage, and processing of your Personal Data in and to the United Arab Emirates or other countries. Personal Data collected in the UK and the EEA is transferred and stored outside those areas. If you are located in the UK or EEA, you have the right to lodge a complaint with your data supervisory authority.
Personal Data is also processed outside of the UK and the EEA by our third party service providers, including to process transactions, facilitate payments, and provide support services as described in Section 4. We use Standard Contractual Clauses adopted by the European Commission to facilitate transfers of personal data from the EEA to third countries and have entered into data processing agreements with our service providers to restrict and regulate their processing of your Personal Data. By submitting your Personal Data or using our Services, you consent to this transfer, storage, and processing by MMBA and its processors.
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