Privacy Policy

1. About this Privacy Policy:

Centus Web Services FZ-LLC (“Centus”, “we”, “our”, “us”) is the data controller for the processing of the personal data described in this Privacy Policy. Please read this Policy carefully to receive information on how and why Centus collect and process your personal data and what are your personal data rights. This Privacy Policy, together with our Terms of Services (“Terms”) and all other policies published on the Platform (as defined below), sets out how we use and protect your personal data, and govern your access to and use of the Platform. By using the Platform, you agree to be bound by our policies, which are incorporated into our Terms. This Policy does not intend to override the Terms. Any terms, words, phrases which are not defined in the Policy shall have the same meanings as ascribed to them in the Terms. When you visit our website, pages, features, mobile applications, or other products and services (“Platform”), and more generally use or participate or engage in any services offered through our Platform, we appreciate you trusting us with your personal information.

This Privacy Policy, together with our Terms of Services (“Terms”) and all other policies published on the Platform (as defined below), sets out how we use and protect your personal data, and govern your access to and use of the Platform.

By using the Platform, you agree to be bound by our policies, which are incorporated into our Terms. This Policy does not intend to override the Terms. Any terms, words, phrases which are not defined in the Policy shall have the same meanings as ascribed to them in the Terms.

When you visit our website, pages, features, mobile applications, or other products and services (“Platform”), and more generally use or participate or engage in any services offered through our Platform, we appreciate you trusting us with your personal information.

2. The types of personal data we collect

Personal information includes any information which may, by itself, or in collaboration with other information be able to identify you. We take your privacy very seriously; and so, this Policy (as amended from time to time) sets out how we collect, process, use, maintain, store, transfer, disclose, erase, or destroy your confidential and personally identifiable user data, obtained from and through the Platform and related services via the Platform.

We process different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes personal identifiers such as your name, title, date of birth, and marital status.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes Payment related information such as card details.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback, and survey responses.
• Usage Data includes information about how you interact with and use our Platform, products, and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

3. How do we collect data?

We use different methods to collect data from and about you including through:

User interactions with us. This includes the following:

• Users provide it directly to us when users register for an account.
• Users provide it directly to us when the users communicate with the freelancers and/or agents/ customer care support staff and/ or administrative staff through the Platform.
• Users provide it directly to us when they participate in online messaging, provide feedback and reviews, and post comments etc.
• Users provide it directly to us when the user use the Platform.
• Users contact us or subscribe to our mailing list.

Automated technologies or interactions. As you interact with our Platform, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies.

4. Why do we collect and use your personal information?

Legal basis for processing

We collect and use personal information from different categories of individuals for several different purposes. The legal basis for processing your personal information will typically be one of the following:

• Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose.
• Performance of a contract with you: Where we need to perform the contract, we are about to enter into or have entered into with you or a relevant party.
• Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation to which we are subject. We will identify the relevant legal obligation when we rely on this legal basis.

Direct marketing

• During the registration process on our Platform when your personal data is collected, you will be asked to indicate your preferences for receiving direct marketing communications from us via email, telephone or short message service.
• We may also analyse your Identity, Contact, Technical, Usage and Profile Data to form a view of which products, services and offers may be of interest to you so that we can then send you relevant marketing communications.

Opting out of marketing

• You can ask to stop sending you marketing communications at any time by contacting us.
• If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes.

Cookies

For more information about the cookies, we use and how to change your cookie preferences, please see https://centus.com/cookie-policy.

5. Disclosures of your personal data:

We may share your data with:

• Selected third-party marketing and advertising providers to personalise your experience with the Platform.
• Authorised third parties who provide us with services to facilitate purchases and payments.
• We employ fulfilment providers to help us perform e-commerce functions including order management and delivery of services.
• Where legally compelling grounds exist, we may also disclose your personal information to governmental and law enforcement agencies, and otherwise in the defence of legal claims.

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.

We protect your information using measures that reduce the risks of loss, misuse, unauthorised access, disclosure, and alteration. We minimise the amount of personal information we disclose to what is necessary to fulfil the purposes described in this Privacy Notice and service providers may not use it for any other purposes. We have signed contractual agreements with our third-party service providers, and we ensure that they respect the security of your personal data in compliance with data protection laws.

6. International transfers:

Where your personal data is being transferred to countries outside the UAE either by us or by third party service providers acting on our behalf, we will ensure that those transfers are adequately protected, by putting in place the necessary organisational and technical measures and guarantee the lawful processing of your personal information in accordance with the relevant law.

7. Data security:

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third 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 take all appropriate technical and organisational measures to ensure that your personal information is protected, in compliance with our legal obligations. We protect your information using measures that reduce the risks of loss, misuse, unauthorised access, disclosure, and alteration. 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 retention:

How long will you retain my personal data for?

We will only keep your personal information for as long as it is necessary to fulfil the purposes outlined in this Privacy Notice, to comply with legal requirements, prevent fraud and resolve disputes. Where a legal requirement obliges the retention of personal data for a specific minimum period, we will retain data for at least that period. Once your personal information is no longer necessary or upon expiry of a specific retention period, we will dispose of it securely according to our data retention and deletion policies.

If you need more information of the data retention and deletion, please contact us.

9. Your data protection rights:

If you wish to exercise any of the data protection rights set out below, please contact us at support@centus.com

• Receive information relating to your personal data being processed by us (commonly known as a “data subject information request”).
• Request transfer of the personal data we hold about you to another controller if it is technically feasible.
• Request correction of the personal data that we hold about you. We want to make sure that your personal data is accurate and up to date. You may ask us to correct or remove information you think is inaccurate.
• Request erasure of your personal data. In some circumstances you can ask us to delete your data. Note, however, that we may not always be able to comply with your erasure request and if that is the case, we will notify you of the specific legal reasons for our inability comply at the time of your request.
• Restrict processing of your personal data where you object to the accuracy of your personal data and want to restrict processing for a specific period to allow us to verify the accuracy of the data. You may also restrict processing if you feel that the processing is in violation of the agreed upon purpose or if the processing is carried out in violation of applicable law.
• 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, for conducting statistical analysis that is not related to the protection of public interest, or the processing is performed in violation of the processing controls outlined under applicable law.
• 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.

10. Contact details:

If you have any questions about this Privacy Policy or about the use of your personal data or you want to exercise your privacy rights, please contact us in the following ways:

• Email address: support@centus.com.
• Address: Ground Floor, DMC5, Dubai Media City, Dubai, United Arab Emirates

11. Changes to our Privacy Policy and your duty to inform us of changes

We keep our Privacy Policy under regular review. 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, for example a new address or email address.