Last updated: 16.03.2018
TYPES OF DATA BEING PROCESSED
When you use our Electronic Services, details of your usage may be automatically registered by our backend systems (such as your IP address, browser, http-header user agent, device-specific information the content you accessed, including time and date of access, usage and user interaction, and the redirecting website from which you came to our Electronic Services). We also process personal data such as your name, address, e-mail address, phone number, date of birth, gender and other data transmitted to us if you register for the usage of our Electronic Services or if you complete a registration form or comment field for a newsletter, product demos, etc.
LEGAL GROUNDS AND PURPOSE OF DATA PROCESSING
We process the data based on the following legal grounds:
- For the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract;
- For compliance with a legal obligation to which we are subject;
- For the purposes of our legitimate interests.
We process the data for the following purposes:
- To comply with bank’s own internal guidelines;
- To check the identity and suitability of clients for certain products and services;
- To establish a basis for future information on the products and services offered by OTCampus FZ-LLC and to improve their quality;
- To facilitate technical administration, research and further development in connection with the OTCampus FZ-LLC Electronic Services;
- To ensure the security and operation of our IT environment;
- To use it for marketing and advertising measures (e.g. newsletters via e-mail, online advertising);
- To analyze and monitor the usage, user behavior and navigation while using the Electronic Services;
- To facilitate client administration.
We process all your personal data in accordance with the applicable laws on data protection and for as long as required.
DISCLOSURE OF ELECTRONIC SERVICES USAGE DATA
OTCampus FZ-LLC only discloses Electronic Services usage data to third parties as permitted by law, if we are legally obliged to do so or if such disclosure becomes necessary to enforce our rights, in particular to enforce claims arising from a contractual relationship. Within this scope as well as for the purpose of optimizing our products and services, we may transmit data within OTCampus FZ-LLC. Furthermore, we may disclose data to external service providers if this is necessary for the provision of products and services. Such service providers may not use the data for any other purpose than to process the order in question. All of the above persons and entities that may receive data must observe the applicable national and international data protection laws as well as the data protection standards of OTCampus FZ-LLC. Where so prescribed by applicable legislation, OTCampus FZ-LLC may on request or under an ongoing duty to provide information disclose data to supervisory authorities, judicial authorities or other persons of authority.
SECURITY MEASURES OF OTCAMPUS FZ-LLC
OTCampus FZ-LLC will make every effort to take appropriate technical and organizational security measures to ensure that your personal data processed within the IT environment controlled by OTCampus FZ-LLC is protected against unauthorized access, misuse, loss and/or destruction, taking account of the applicable legal and regulatory requirements. OTCampus FZ-LLC takes both physical and electronic process-specific security measures, including firewalls, personal passwords, and encryption and authentication technologies. Our employees and the service providers commissioned by us are bound by professional secrecy and must comply with all data protection provisions. Additionally, access to personal data is restricted to only those employees, contractors and third parties who require this access in order to assure the purpose of data processing and the provision of products and services (need to know principle).
TRANSMISSION OF DATA VIA AN OPEN NETWORK
OTCampus FZ-LLC would like to draw your attention to the fact that if you use our Electronic Services via an open network, this may allow third parties (e.g. app stores, network providers or the manufacturer of your device), wherever they are located, to access and process your data. Open networks are beyond OTCampus FZ-LLC’s control and can therefore not be regarded as a secure environment. Any transmission of data via such open network cannot be guaranteed to be secure or error-free as data may be intercepted, amended, corrupted, lost, destroyed, arrive late or incomplete, contain viruses or may be monitored. In particular, data sent via an open network may leave the country – even where both sender and recipient are in the same country – and may be transmitted to and potentially processed in third-party countries, where data protection requirements may be lower than in your country of residence. Where data is transmitted via an open network, we cannot be held responsible for the protection of this data and we accept no responsibility or liability for the security of your data during transmission. We, therefore, recommend avoiding the transmission of any strictly confidential information via open networks.
host name of the accessing electronic device (IP address)
type/version of browser used
referrer URL (website from which visitors are redirected to the OTCampus FZ-LLC Electronic Services by clicking a link)
date and time of server request
may be transmitted to third party servers and is used for analysis purposes.
Please refer to the previous section, “Cookies”, for information on deleting cookies.
QUESTIONS / CONTACT
If you have questions about the processing of your personal data, please feel free to contact us by using our contact form.