Privacy Policy

Updated January 12, 2024

What is the purpose of this document?

Gulf Transactions is committed to protecting the privacy and security of your personal information.

We are considered the “data controllers”. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.

You must read, together with any other privacy notices we may provide on specific occasions when we are collecting or processing personal information about you so that you are aware of how and why we are using such information and what your rights are under the data protection legislation.

Data Protection Principles

We will comply with data protection laws. It says that the personal information we hold about you must be:

• Used lawfully, fairly, and transparently.
• Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
• Relevant to the purposes we have told you about and limited only to those purposes.
• Accurate and kept up to date.
• Kept only as long as necessary for the purposes we have told you about.
• Kept securely.

What Kind of Information?

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, store, and use the following categories of personal information about you: Personal contact details such as name, title, address, telephone number, personal email address, date of birth, gender, payment card or bank account details.

How is your personal information collected?

We initially collected personal information about potential Gulf Transactions clients through our website.

We aim to keep your details up to date and we will conduct procedures to check if the contact details we have for you are correct and, where appropriate, update them.

How will we use information about you?

We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:

• Where we need to perform the contract, we have entered into with you.
• Where we need to comply with a legal obligation.
• Where it is necessary for legitimate interests pursued by us or a third party and your interests and fundamental rights do not override those interests.
• Where we have your consent to do so.

Change of purpose

We will only use your personal information for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

How do we use particularly sensitive personal information?

“Special categories” of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing, and using this type of personal information. We have in place appropriate policy documents and safeguards which we are required by law to maintain when processing such data. We may process special categories of personal information in the following circumstances:

• In limited circumstances, with your explicit written consent.
• where we need to carry out our legal obligations or exercise rights in connection with your use of our website.
• where it is needed in the public interest, such as for equal opportunities monitoring.
• Less commonly, we may process this type of information where it is needed about legal claims where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.

Do we need your consent?

We do not need your consent if we use special categories of your personal information by our written policy to carry out our legal obligations or exercise specific rights. In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If so, we will provide you with the full details of the information that we would like and the reason why we need it, so that you can carefully consider whether you wish to consent. Please be aware that it is not a condition of your membership to our website that you agree to any request for consent from us. However, we may not be able to accept you as a client or deploy you if you are not willing to consent to the disclosure of special categories of personal data.

Data Sharing

We may have to share your data with third parties, including third-party service providers. We require third parties to respect the security of your data and to treat it by the law. If we do, you can expect a similar degree of protection in respect of your personal information.

Why might you share my personal information with third parties?

We will share your personal information with third parties where required by law, where it is necessary to administer our relationship with you, or where we have another legitimate interest in doing so.

How secure is my information with third-party service providers?

All our third-party providers are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third parties to use your data for their purposes. We only permit them to process your data for specified purposes and follow our instructions.

Data security

Third parties will only process your personal information in our instructions and where they have agreed to treat the information confidentially and to keep it secure.

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. In addition, we limit access to your personal information to those employees and other third parties who have a business they need to know.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

Data retention

How long will you use my information for?

We will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including to satisfy any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your data, the purposes for which we process your personal data, and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances, we may make your personal information anonymous so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer a member of our Website, we will retain and securely destroy your personal information following our data retention policy.

Changes to this privacy notice

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.

For inquiries about our services please click here