HUMA QAZI LIMITED PRIVACY POLICY

1               BACKGROUND AND PURPOSE

This Privacy Policy (the Policy) explains how Huma Qazi Limited (HQL, we, our or us) collects and processes your personal information when you:

·      use our website (including any data which you may provide through our website when you contact us or provide feedback),  or when you use our mobile app, or otherwise engage with us electronically (together, the Digital Services); and

·      engage us to provide you with services.

This Policy explains:

·      why and how we may use the personal information that we have obtained from interactions you (or others) may have with us as a business or when you contact us;

·      with whom we share your personal information; and

·      the rights you have in connection with the information we use.

2               WHO WE ARE AND OUR ROLE

Except as mentioned below, HQL is the controller of your personal information. This means that HQL decides why and how your personal information is processed. Please see the section at the end of this Policy for our contact and legal information.

In some circumstances, the organisation receiving your information will be separately responsible to you and use your personal information in the ways described in its privacy notice (and not ours). For example:

If your employer has engaged us to provide you with professional training, they will be the controller in respect of your personal information and we will be a processor acting on their instructions. Please consult your employer’s privacy notice for information about how your personal information is processed.

3               PERSONAL INFORMATION WE COLLECT ABOUT YOU

When you interact with us online or offline, we collect and use information about you in the course of providing you with services. We may collect, use, store and transfer different kinds of personal information about you which we have grouped together as follows:

3.1          Log data

When you visit our website, our servers may automatically log the standard data provided by your web browser. It may include your computer’s Internet Protocol (IP) address, your browser type and version, the pages you visit, the time and date of your visit, the time spent on each page, and other details.

3.2          Device data

We may also collect data about the device you’re using to access our website. This data may include the device type, operating system, unique device identifiers, device settings, and geo-location data. What we collect can depend on the individual settings of your device and software. We recommend checking the policies of your device manufacturer or software provider to learn what information they make available to us.

3.3          Contact data

In some cases, we may ask for personal information in order to attend our programmes or manage our business relationship, such as your:

·       Name

·       Email

·       Phone/mobile number

4               HOW AND WHY WE USE YOUR PERSONAL INFORMATION

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 and complies with data protection law.

Data protection law requires us to have a valid reason to process your personal information for each of the different purposes for which we use that information. The law refers to each reason as a ‘lawful basis’. The purposes for which we use your personal information and the lawful basis on which we rely to process it for each purpose as follows:

Purpose	Data Types	Legal Basis
To provide the Digital Services.	·       Log data ·       Device data	Contract – necessary to perform our contract with you and provide you with the Digital Services.
To enable you to customise or personalise your experience of the Digital Services.	·       Log data ·       Device data	Legitimate Interests – necessary to personalise our services, products, and content suggestions for you.
To enable you to access and use the Digital Services and associated social media platforms.	·       Log data ·       Device data ·       Contact data	Contract – necessary to perform our contract with you and provide you with services.
To contact and communicate with you.	·       Contact data	Legitimate Interests – necessary to respond to you and process your requests and enquiries.
To maintain our internal records.	·       Log data ·       Device data ·       Contact data	Legitimate Interests – necessary to ensure accurate information within our organisation and comply with our legal and regulatory obligations.
To carry out  analytics, market research and business development, including to operate and improve the Digital Services and associated social media platforms.	·       Log data ·       Device data	Legitimate Interests –necessary to evaluate and improve our products and services.
To issue advertising and marketing, including to send you promotional information about our products and services and information about third parties that we consider may be of interest to you.	·       Contact data	Consent –where you have given your consent for us to do so.
To establish, bring or defend legal proceedings.	·       Log data ·       Device data ·       Contact data	Legitimate Interests – necessary to protect our business interests and enforce our legal rights.
To protect the safety of individuals in emergency situations.	·       Contact data	Vital Interests – necessary to ensure the physical safety and wellbeing of individuals.

Automated Decision Making

We do not envisage that any decisions that have a legal or significant effect on you will be taken about you using purely automated means, however we will update this Policy and inform you if this position changes.

5               DATA RETENTION

We retain your personal information for as long as we need to use it for the reasons set out in this Policy. We will also retain it where we need to keep it to comply with our legal obligations, resolve disputes, or enforce our agreements.

6               DISCLOSURE OF PERSONAL INFORMATION TO THIRD PARTIES

We may disclose personal information to:

·        third party service providers for the purpose of enabling them to provide their services, including (without limitation) IT service providers, data storage, hosting and server providers, ad networks, analytics, error loggers, debt collectors, maintenance or problem-solving providers, marketing or advertising providers, professional advisors, and payment systems operators;

·        our employees, contractors and/or related entities;

·        credit reporting agencies, courts, tribunals, and regulatory authorities, in the event you fail to pay for goods or services we have provided to you;

·        courts, tribunals, regulatory authorities, and law enforcement officers, as required by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights;

·        third parties, including agents or sub-contractors, who assist us in providing information, products, services, or direct marketing to you; and

·        third parties to collect and process data.

When sending your information to third parties, we only disclose to them any personal information that is necessary for them to provide their service and we have a contract in place that requires them to keep your information secure and not to use it other than in accordance with our specific instructions.

7               INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION

The personal information we collect is stored and processed in United Kingdom, or where we or our partners, affiliates and third-party providers maintain facilities. By providing us with your personal information, you consent to the disclosure to these overseas third parties.

We will ensure that any transfer of personal information from UK and /or countries in the European Economic Area (EEA) to countries outside the UK and/or EEA will be protected by appropriate safeguards, for example by using standard data protection clauses approved by the European Commission or international data transfer agreement approved by the UK Secretary State, or the use of binding corporate rules or other legally accepted means.

8               YOUR RIGHTS AND CONTROLLING YOUR PERSONAL INFORMATION

Choice and consent: By providing personal information to us, you consent to us collecting, holding, using, and disclosing your personal information in accordance with this Policy. If you are under 16 years of age, you must have, and warrant to the extent permitted by law to us, that you have your parent or legal guardian’s permission to access and use the website and they (your parents or guardian) have consented to you providing us with your personal information. You do not have to provide personal information to us, however, if you do not, it may affect your use of this website or the products and/or services offered on or through it.

Information from third parties: If we receive personal information about you from a third party, we will protect it as set out in this Policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us.

Restrict: You may choose to restrict the collection or use of your personal information. If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by contacting us using the details below. If you ask us to restrict or limit how we process your personal information, we will let you know how the restriction affects your use of our website or products and services.

Access and data portability: You may request details of the personal information that we hold about you. You may request a copy of the personal information we hold about you. Where possible, we will provide this information in CSV format or other easily readable machine format. You may request that we erase the personal information we hold about you at any time. You may also request that we transfer this personal information to another third party.

Correction: If you believe that any personal information that we hold about you is inaccurate, out of date, incomplete, irrelevant, or misleading, please contact us using the details below. We will take reasonable steps to correct any information found to be inaccurate, incomplete, misleading, or out of date.

Object to processing: Where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data, you have the right to object to our processing of your personal information. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.

Erasure: You have the right to ask us to delete or remove your personal information where you have successfully exercised your right to object to processing (see above), where we may have processed your information unlawfully or where we are required to erase your personal information to comply with local 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.

Complaints: If you believe that we have breached a relevant data protection law and wish to make a complaint, please contact us using the details below and provide us with full details of the alleged breach. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint. You also have the right to contact a regulatory body or data protection authority in relation to your complaint.

Unsubscribe: To unsubscribe from our e-mail database or opt-out of communications (including marketing communications), please contact us using the details below or opt-out using the opt-out facilities provided in the communication.

9               COOKIES

We use “cookies” to collect information about you and your activity across our site. A cookie is a small piece of data that our website stores on your computer, and accesses each time you visit, so we can understand how you use our site. This helps us serve you content based on preferences you have specified. Please refer to our Cookie Policy for more information.

10            BUSINESS TRANSFERS

If we or our assets are acquired, or in the unlikely event that we go out of business or enter bankruptcy, we would include data among the assets transferred to any parties who acquire us. You acknowledge that such transfers may occur, and that any parties who acquire us may continue to use your personal information according to this policy.

11            LIMITS OF OUR POLICY

Our website may link to external sites that are not operated by us. Please be aware that we have no control over the content and policies of those sites, and cannot accept responsibility or liability for their respective privacy practices.

12            CHANGES TO THIS POLICY

At our discretion, we may change our Policy to reflect current acceptable practices. We will take reasonable steps to let users know about changes via our website. Your continued use of this site after any changes to this policy will be regarded as acceptance of our practices around privacy and personal information.

13            CONTACT

Huma Qazi

info@humaqazi.com