This Privacy & Cookies Policy ("Policy") dated May 24th 2018 replaces our previous policies. Please take the time to review before you continue to use our products and services.
This Policy applies to any information you provide to us, including through websites, our mobile apps, communications by email and through social media, by telephone and in person. It also covers any information we receive from third parties.
By using our products and services, including browsing our websites, registering or logging in, you agree we may use your information as outlined in this Policy.
If you do not wish to have your information used in line with this Policy, you must not use our products and services and not otherwise provide us with your information.
Legal basis for the processing
The applicable legal basis for the processing of Personal Information depends on the circumstances relating to the relevant processing activities, as further described below:
If the processing of Personal Information is necessary for one or more specific purposes, GDPR art. 6(1)(a) serves as the legal basis for processing operations.
Performance of a contract. If the processing of Personal Information is necessary for the performance of a contract, such as for providing certain services, to which the data subject is party, GDPR art. 6(1)(b) serves as the legal basis for processing operations. The same applies to such processing operations which are necessary for carrying out pre-contractual measures, for example in the case of inquiries concerning our products or services or post-contractual services such as providing access to the projects database.
Legal obligation. If the processing of Personal Information is necessary for complying with a legal obligation, such as for the fulfillment of tax obligations, GDPR art. 6(1)(c) serves as the legal basis for processing operations.
Vital interests. If the processing of Personal Information is necessary for protecting the vital interests of a natural person, such as if a visitor were injured in our premises and his information would have to be passed on to medical personnel, GDPR art. 6(1)(d) serves as the legal basis for processing operations.
Legitimate interests. If the processing of Personal Information is necessary for processing operations which are not covered by any of the abovementioned legal grounds, but are deemed permissible for the purposes of the legitimate interests pursued by Us, such as marketing, GDPR art. 6(1)(f) serves as the legal basis for processing operations.
Information we may hold about you
- Information you’ve provided to us.
- Information about products and services you’ve ordered, enquired about or shown an interest in.
- Information provided by other companies which have obtained your permission through their own privacy policies to share information about you, including from specialist data companies.
- Information about your interaction with our websites, mobile apps and other products and services, including adverts.
- Information we collect using cookies stored on your device about your use of our websites and/or selected third party websites.
- Information we collect or remember using technologies similar to cookies, such as device identifiers on your mobile device.
- Your IP address, which is the number that identifies a specific network device on the internet which allows your device to communicate with websites and apps.
- Technical information from your device relating to the service you receive.
- Information relating to the location of your device.
- In line with industry best practice guidelines, we have a central database where we compile and hold all the information we have about our customers.
How we may use your information
By using our websites, apps and other products and services, you agree that we may collect, hold, use or otherwise process your information (including personal information) for the purpose of providing you with those products and services and developing our business which shall include (without limitation):
- Verifying your identity (for example when you return to our websites or mobile apps).
- Personalizing the content and advertisements you see on our websites and apps.
- Developing the design and style of our products and services to make improvements.
- Understanding more about you, such as your location and demographic information.
- Informing you about the latest changes to our products and services.
- Informing you of promotional offers that you might find of interest.
- Dealing with, and responding to you about, a comment you have submitted for us or on our message boards, blogs and other such user generated content facilities.
- Enabling you to share our content with others.
- Customer services and support.
- Informing you if you have been successful in any competitions or promotions.
- Compiling customer reviews.
- Conducting market research.
- Carrying out statistical, technical and logistical analysis and strategic development.
- Communicating with you in relation to your account or service, service updates or other non-marketing communications.
- Communicating (and personalizing such communication) with you, according to your preferences.
- Sending you periodic newsletters about your chosen services.
- Sending you direct marketing. This may include communications by post, telephone or email or SMS about us and our business partners’ products and services, events and special offers.
- Maintaining records of our communications with you if you get in contact with us.
- Providing you with location based services advertising relevant to your location and previous locations.
- Blocking disruptive use and ensuring the security of our products and services.
- Ensuring the integrity of votes, competitions and polls.
- Complying with laws and other circumstances permitted under the General Data Protection Regulation (GDPR) (EU) 2016/679.
How we may use your information in specific products or services
Message boards, blogs and other public forums
Our websites may provide message boards, blogs and other user generated content facilities. Anything that you share will become public information. You should always be careful when deciding to disclose your personal information.
Sharing with others
You may only share the details of another person with DMS global, if they have expressed their permission.
Location based services
Where we provide services that utilize your device’s location, such as local offerings, your location will be determined either from a lookup of your IP address in a "GeoIP" database which lists information provided by your ISP (usually your closest town or borough) or your precise location directly from the device (such as through GPS or WiFi on mobile devices) where you have granted permission for us to access this location information. If you have given us permission to use your location, we may use it for marketing and advertising purposes.
Push and in-app notifications on apps
Where you install one of our apps on your mobile device, this may use push notifications or in-app notifications. These notifications are used for a variety of reasons. For example, push notifications may be used to trigger an automatic download of new content (such as a new edition) or to send you an update message. Please see each app’s download or install page for more information on how they use notifications. Within the app, you may be able to select to receive only certain types of notifications.
If you order a product or service from us we may ask for information including your name, e-mail address, delivery and billing address, credit or debit card number and expiry date. Sometimes we may ask for your telephone number to be forwarded to the couriers who may deliver your order. These details allow us to process your orders efficiently.
If you enter a contest or promotion we may ask for your name, address, e-mail address or telephone number. This is so we can run the contest effectively and tell you if you have won.
Sometimes we allow advertisers to show their advertisements directly on our websites and apps, which are tailored to you based upon information they have obtained, such as your browsing history on their own website(s). Other times we will arrange for our customers to be shown advertisements on our own or other websites or apps. These advertisements are tailored to you with information we have obtained from your browsing on our websites and apps, and from information about your likely interests that we obtain from our partners and specialist data companies where they have your permission to share this information with us in line with their privacy policies.
Where we arrange for our customers to be shown advertisements, we use technological and contractual mechanisms to protect your cookie data and to ensure that your browsing data used for advertising is not used by advertisers or other website owners for other purposes, such as linking online behavioral advertising data with your contact details, unless you have provided the advertiser or other website with your express permission to do this.
If you have registered on our websites or apps, we may analyze the information we hold on you in aggregate with our other customers to improve our advertising systems.
When you are shown an advertisement, our advertising systems do not know who you are or your contact details (such as your name, address or email address). Demographic information from your registration on our websites and apps (such as your age, gender and city) may be used to tailor the advertising we arrange to be shown. Your demographic information is not shared with advertisers.
Where you have granted permission to access your device’s location to us, our advertising partners or specialist data companies, this location information may be used to tailor the advertising you receive, including showing you certain advertisements when you are in the vicinity of a particular location.
Social media advertising
We may target advertising on social media sites to specifically include or exclude customers who have registered for our products and services. For example, customers who have an outdated version of our app may see an ad for the latest version, or customers who have already subscribed to our newsletters may not see the ad for those newsletters.
How we may share your information
When you purchase goods or services from us we may partner with specialist companies to fulfil your order. We usually remain the data controller of your information and the other companies only process data under our instructions and cannot use the information for their own purposes. We will use reasonable endeavors to ensure these third parties process your data securely.
Sometimes we bring you promotions from other companies. Here the other company will use your information as the data controller in line with their own privacy policies. We may also use your information for marketing purposes as a data controller.
We’ll let you know the precise arrangement at the time you provide your personal information.
We may share information about you with suppliers that we engage to help us provide the services and/or functionality, e.g. online payment processing, printing material.
We may also share personal information about you to third parties, where you have given us permission or where the third party can confirm that they have your permission for us to do this.
Sometimes your details may be made available to carefully selected third parties such as our sponsors or partners for their own marketing purposes.
We may also provide third parties with certain aggregate statistical data about our customers’ use of our websites and apps, which may include demographic data such as age range and/or geographic location of groups of our customers. This aggregate data does not include contact details (such as the customer’s name, address or email address).
We may transfer, sell or assign any of the information described in this Policy to third parties as a result of a sale, merger, consolidation, change of control, transfer of assets or reorganization of our business.
We may also share your information as required by law and as contemplated by the General Data Protection Regulation (GDPR) (EU) 2016/679.
How long we keep personal information
DMS Global has a Records Management team that works in conjunction with the Privacy Office to implement policies and rules relating to the retention of personal information. We have an Enterprise Records Retention Schedule that is based upon a classification scheme consisting of Business Functions, Record Classes, and Record Types. We retain personal information for as long as we reasonably require it for legal or business purposes. In determining data retention periods, DMS Global takes into consideration local laws, contractual obligations, and the expectations and requirements of our customers. When we no longer need personal information, we securely delete or destroy it.
Safeguards and security for your information
Protection of Information
The registers will be maintained in external service providers’ servers with appropriate safeguards, such as password protection, granting the access to the stored information only to persons working at DMS Global or DMS Global partners who are expressly authorized by DMS Global.
The register is protected by appropriate industry standard, technical and organizational safety measures. Although we make good faith efforts to store the information collected on the services in a secure operating environment that is not available to the public, we cannot guarantee the absolute security of that information during its transmission or its storage on our systems.
DMS Global will post a notice on our website in case material security breach that endangers your privacy or Personal Information.
DMS Global may also temporarily shut down a service to protect Personal Information.
We comply with the General Data Protection Regulation (GDPR) (EU) 2016/679. For more information on the General Data Protection Regulation and your related rights please visit https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32016R0679
Children & young people
Our websites, apps and other products and services are not aimed at children. We do not target, intend to collect, or knowingly collect or otherwise process information from anyone under the age of 16.
If you are under the age of 16, we request that you do not provide us with your information and do not use our websites and apps.
If you are a parent or guardian of a child under 16, please contact us if you are aware that your child has used our websites or apps or otherwise provided their information to us without your consent.
In addition to "your choices" outlined in this Policy, we will delete or otherwise cease processing your child’s personal information within a reasonable time.
If you are aged 13, 14, 15 or 16 we request that you seek your parent or guardian’s permission before providing us with your information or using our websites or apps.
Email & SMS marketing
You can opt out of a particular marketing campaign or newsletter subscription by clicking on the ‘unsubscribe’ link in each email.
You can opt out of marketing text messages by replying ‘STOP’.
In accordance with industry best practice guidelines, we may retain your information (including your selection to opt out) for a reasonable amount of time to make sure that we do not contact you in the future.
Use of your location
You can choose whether to provide us with your precise location from your device through your browser’s "Help" menu, or through the "Location" or "Location Services" options in the "Settings" section on your mobile device.
Use of push notifications
You will be prompted to choose whether to receive push notifications the first time you run each of our apps, and you can update your preferences at any time through Settings on your device.
You should be aware that when you use our websites and apps we may collect information using cookies or similar technologies. This allows our websites to identify you and tailor what you see on the screen.
Our websites, apps and emails often contain small invisible images known as ‘web beacons’ or ‘tracking pixels’. These are used in a way similar to cookies, to understand when a particular part of a webpage, email or app is viewed.
Our apps often use device identifiers in the same way as cookies as used on web browsers. A device identifier is a unique number on your device which allows us to remember your device.
What is the purpose of using cookies?
Cookies are an important part of the internet. They make using websites much smoother and affect lots of the useful features of websites. There are many different uses for cookies, but they fall into four main groups:
- Cookies that are needed to provide the service you have asked for
Some cookies are essential so you can move around our websites and use their features. Without these cookies, services you’ve asked for can’t be provided. These cookies don’t gather information about you that could be used for marketing or remembering your browsing history. For example:
- Keeping you logged in during your visit; without cookies you might have to log in on every page you go to.
- When you add something to the online shopping basket, cookies make sure it’s still there when you get to the checkout.
- Cookies used to improve your browsing experience
These cookies allow our websites to remember choices you make, such as your language or region and they provide improved features. For example:
- Remembering your preferences and settings, including marketing preferences.
- Remembering whether you’ve filled in a survey, so you’re not asked to do it again.
- Showing you information that’s relevant to our products that you have.
- Showing ‘related content’ links that are relevant to the page you’re looking at.
- Remembering a location you’ve provided us with to provide tailored content.
- Linking your browsing history collected by analytics cookies to your registration details to provide you with recommended content and marketing.
- Restricting the number of times you’re shown a particular advertisement. This is sometimes called ‘frequency capping’.
Cookies are also used to enable social media components on our websites, including embedded content from social media sites such as Facebook or Twitter, share buttons and videos. The cookies are set by the relevant social media provider. For more information about these cookies, including how to set your preferences for these cookies, please refer to the relevant social media provider’s website for more information.
- Cookies used to understand how people use our products and services (Analytics)
We like to keep track of what pages, links and sections of our apps are popular and which ones don’t get used as much to help us keep our sites relevant and up to date. It’s also useful to be able to identify trends of how people navigate (find their way through) our sites and if they get ‘error messages’ from web pages. We may use analytics tools that capture how our readers interact with our page content and click/touch, movement, scroll, and keystroke activity.
- Cookies used to show advertising that is relevant to you
In order to protect our advertisers’ brands, we often use a technology that scans the page to ascertain that it is safe from profane, sensitive & potentially brand-negative topics, before serving an ad there. This process is called "ad verification".
Our websites do not respond to "Do Not Track" (DNT) browser settings. To change your cookie preferences for advertising and analytics.
Some of our web pages will contain promotional links to other companies’ sites. If you follow one of these links and then register with or buy something from that other site, a cookie is sometimes used to tell that other site that you came from one of our websites. That other site may then pay us a small amount for the successful referral.
Your cookie choices
Please note that our websites, apps and other products and services may not work correctly (or at all) if you change your preferences. For example, you may not be able to purchase products via our websites. However, you may still be able to place an order via our telephone order line. Please consult our websites for more details.
You can opt out of receiving cookies by changing your web browser settings.
You can usually prevent the operation of web-beacons by changing your web browser cookie settings and your ad choices, or for those in emails, by switching off images in your email client or viewing emails using only the "text" display (rather than "HTML" display"). See the "Help" section of your email client for instructions. Where you use our apps, similar technologies to cookies are used for analytics. Is it not currently possible to opt out of these similar technologies. If you are not happy to be included in our analytics or analysis, please do not use our apps.
Your ad choices
When using a mobile device, you can opt out of receiving online behavioral advertising by selecting ‘Limit Ad Tracking’ in the Settings of your Apple iPhone or iPad, or the "Opt out of interest-based ads" in the Settings on your Android device. You may also be able to reset your unique identifier used for online behavioral advertising (referred to as an "Advertising ID") in the Settings on your Apple or Android device.
Please note that you will continue to receive advertising, however, it may not be tailored to your likely interests using information collected from cookies and similar technologies on your device.
You may change your social media advertising preferences within the social media site. For instance, on Facebook you can select "Hide all from this advertiser" to stop seeing ads from a particular advertiser.
Rights of the Data Subjects and Contact Information
Right to access, correct and object
You may contact us and we will inform what Personal Information we have collected and processed regarding you and the purposes such data are used for. You have the right to have corrected any incorrect, incomplete, outdated, or unnecessary Personal Information stored about you by contacting us.
You may object to certain use of Personal Information, including direct marketing, if such data are processed for other purposes than purposes necessary for the performance of our Services or for compliance with a legal obligation. You may also object any further processing of Personal Information after prior given consent. If you object to the further processing of Personal Information, this may lead to fewer possibilities to use our Services.
Right to deletion and restriction of processing
You may also ask us to delete your Personal Information from our systems. We will comply with such request unless we have a legitimate ground to not delete the data. After the data has been deleted, we may not immediately be able to delete all residual copies from all our systems. Such copies shall be deleted as soon as reasonably possible.
You may request us to restrict processing of certain Personal Information, this may however lead to fewer possibilities to use our website and other Services.
Right to data portability
You have the right to receive Personal Information provided by you to us in a structured, commonly used format.
How to use the rights
These rights may be used by sending a letter or e-mail to us on the addresses set out below, including the following information: name, phone number, login information and details of the Services you have used. We may request the provision of additional information necessary to confirm your identity. We may reject requests that are unreasonably repetitive, excessive or manifestly unfounded.
In case you consider our processing activities of Personal Information to be inconsistent with the applicable data protection laws, a complaint may be lodged with the local supervisory authority for data protection.
Contacting us and accessing your personal information
If you have any queries or comments about this Privacy & Cookies Policy please contact us at firstname.lastname@example.org.
If you wish to review or receive a copy of the personal information we hold about you, or further information about how we handle your information, please write to us at:
P.O.Box 30063, Diraz
Kingdom of Bahrain
Telephone: +973 1740 5590
Where permitted by law, we may charge a small administration fee (not exceeding the maximum permitted) in relation to fulfilling a request for access to personal information.
If you are concerned that we have breached a privacy law please send an email to Info@dmsglobal.net or call +973 1740 5590. We aim to respond in a reasonable time (normally 30 days).
Changes to this Privacy & Cookies Policy
We reserve the right to make changes to our Privacy & Cookies Policy at any time. Where changes are made, we will post the revised Policy here with an updated effective date. Your continued use of our websites, apps, or other products or services will signify your acceptance of these changes.