At TELCCA we want to give you the best possible experience to ensure you make the most of our service today, tomorrow and in the future. To do this, we collect Personal Information and Personal Data from Site visitors for the purposes of providing our services to our users, and for the purposes of better customizing our services for you. That said, your privacy and the security of your personal data is, and will always be, enormously important to us. So, we want to transparently explain how and why we gather, store, share and use your personal data, as well as outline the controls and choices you have around when and how you choose to share your personal data.
Where used in this Privacy Statement, the terms “Personal Information” and “United Arab Emirate’s Privacy Principle(s)” have the meaning attributed to those terms in the Constitution of the UAE (Federal Law 1 of 1971) Penal Code (Federal Law 3 of 1987 as amended). In this Privacy Statement:
• any reference to “TELCCA”, “telcca”, “we”, “us” and “our” includes a reference to TELCCA LLC and each of TELCCA’s related bodies corporate.
This policy sets out:
• what is considered personal information;
• what personal information we collect and hold;
• how we collect, hold, use or disclose personal information;
• the purposes for which we collect personal information;
• what happens if we are not able to collect personal information;
• how to seek access to and correct your personal information;
• whether we disclose personal information outside the UAE; and
• how to contact us.
From time to time, we may develop new or offer additional services. If the introduction of these new or additional services results in any change to the way we collect or process your personal data we will provide you with more information and additional terms or policies. Unless stated otherwise when we introduce these new or additional services, they will be subject to this Policy.
We may, from time to time, review and update this policy, including taking account of new or amended laws, new technology and/or changes to our operations. All personal information held by us will be governed by the most recently updated policy. Your privacy matters to us, so whether you are new to TELCCA or are a long time user, please take the time to get to know our practices and consult this policy regularly for changes.
WHAT IS PERSONAL INFORMATION
When used in this policy, it is any information that can be used to personally identify you. This may include (but is not limited to) your name, age, gender, postcode and contact details (including phone numbers and email addresses) and possibly financial information, including your credit card, direct debit, or PayPal account information. If the information we collect personally identifies you, or you are reasonably identifiable from it, the information will be considered personal information.
WHAT PERSONAL INFORMATION DO WE COLLECT AND HOLD
We may collect personal information including but not limited to:
• mailing or street address;
• email address;
• telephone number;
• age or birth date;
• profession, occupation or job title;
• occupational history;
• educational history;
• details of the products and services you have purchased from us or which you have enquired about, together with any additional information necessary to deliver those products and services and to respond to your enquiries;
• any additional information relating to you that you provide to us directly through our website or indirectly through use of our website or online presence through our representatives or otherwise;
• information you provide to us through our website, customer surveys or information collected by our representatives from time to time.
• If you register to use the Services as a Mentor/Coach, our third party service providers will collect certain information, such as, but not limited to, your name, email address and banking account details, from you to enable us to make payments to you in connection with your activities on the Site and Services.
• we will receive personal data about you and your activity from third parties, including advertisers and partners we work with in order to provide you with our products and services. We will use this personal data either where you have provided your consent to the third party or to TELCCA to that data sharing taking place or where TELCCA has a legitimate interest to use the personal data in order to provide you with our products and services.
COOKIES & IP ADDRESSES
We may also log IP addresses (the electronic addresses of computers connected to the internet) to analyze trends, administer the website, track user movements, and gather broad demographic information.
We may also collect anonymous data (which is not personal information) relating to your activity on our websites (including IP addresses) via cookies, or we may collect information from you in response to a survey. We generally use this information to report statistics, analyze trends, administer our services, diagnose problems and target and improve the quality of our products and services. To the extent this information does not constitute personal information because it does not identify you or anyone else, the United Arab Emirate's Privacy Principles do not apply and we may use this information for any purpose and by any means whatsoever.
HOW WE COLLECT PERSONAL INFORMATION
We collect your personal information directly from you unless it is unreasonable or impractical to do so.
We do this in ways including (but not limited to) :
• through your access and use of our website, apps or sending messages to us;
• through someone else who has provided us with your information (e.g. gift coupons);
• during conversations between you and our representatives; and
• when you complete an application or pay for a service.
We may also collect personal information from third parties including (but not limited to) :
• third party companies such as credit reporting agencies, law enforcement agencies and other government entities;
• mailing lists;
• recruitment agencies;
• contractors and business partners.
WHY DO WE COLLECT, HOLD, USE AND DISCLOSE PERSONAL INFORMATION
The primary purpose for which we collect information about you is to enable us to perform our business activities and functions and to provide best possible quality of customer service. We collect, hold, use and disclose your personal information for the following purposes:
• to provide products and services to you;
• to provide you with news, information or advice about our existing and new products, events, services, Coaches and Mentors;
• to communicate with you including by email, mail or telephone;
• to manage and enhance our products and services;
• to personalize and customize your experience;
• to provide you with access to protected areas of our websites;
• to conduct competitions or promotions on behalf of TELCCA and selected third parties;
• to verify your identity;
• to provide business data to third parties;
• to conduct business processing functions for operation of our websites or our business;
• for our administrative, marketing (including direct marketing), promotional, planning, product/service development, quality control and research purposes, or those of our contractors or external service providers;
• to provide your updated personal information to us, our contractors or external service providers;
• If you register to use the Services as a Mentor or a Coach, the information you provide in your profile (excluding billing information, including billing address and credit card details, and personal contact details such as address and phone number) that you provide (or other profile picture provided by you), and current online/office status may be publicly viewable via the Site. We make this information available so that users and TELCCA visitors can find Mentors and Coaches who meet their mentoring and coaching needs. In addition, if you chose to make any User Content available via the website, we will share such User Content in accordance with the selections you make via the website. If you provide links to information on other sites such as LinkedIn, we may include information from links provided, such as your LinkedIn profile, onto your TELCCA profile to assist users find Mentors and Coaches who meet their mentoring and coaching needs.
• If you decide to use TELCCA to connect and/or video conference or text chat with a Mentor/Coach or Mentee/Coachee online, you may share your Personal Information with the Mentor/Coach or Mentee/Coachee with whom you connect and/or videoconference or text chat. If you interact with a Mentor/Coach or Mentee/Coachee via the website (e.g., to schedule a Mentoring/Coaching Session), we will share your username, as provided to the site, (or the name of the Mentor/Coach, Mentee/Coachee as applicable) with the applicable Mentor/Coach or Mentee/Coachee in order to facilitate the scheduling or communication request. Additionally, if you chose to make any User Content available via the Services, we will share such User Content in accordance with the selections you make via the Services (including with Mentors/Coaches, Mentees/Coachees, as applicable). Any information you provide before participating in a Mentoring/Coaching Session (e.g., information on what you’d like to cover in such Mentoring/Coaching Session) may be shared with the applicable Mentor/Coach and Mentee/Coachee via the Services in connection with your first name. We recommend that you guard your sensitive information.
• to investigate any complaints about or made by you, or if we have reason to suspect that you are in breach of any of our terms and conditions or that you are or have been otherwise engaged in any unlawful activity; and/or
In the event of a data breach, TELCCA is committed to complying in all respects with the requirements of all United Arab Emirate's Privacy Laws. You can also play an important role in keeping your Personal Information secure by maintaining the confidentiality of any password and accounts used on the Site. Please notify immediately if there is any unauthorized use of your account by any other Internet user, or any other breach of security relating to your account.
Third Party Measurement
In order to better understand our users, TELCCA utilizes third party measurement companies to assess Site and mobile Site traffic. A tracking code is used to collect the following information on the usage of the Site:
• The number of page views (or page impressions) that occur on the Site;
• The number of unique visitors to the Site;
• How long these unique visitors (on average) spend on the Site when they do visit; and
• Common entry and exit points into the Site.
This aggregated, non-Personal Information is collated and provided to TELCCA to assist in analyzing the usage of the Site. This data is also accessible by media organizations and research companies, for the purpose of conducting industry comparisons with other Internet websites.
Other information TELCCA may collect
TELCCA may also collect and use information about your mentor/coach seeking needs, characteristics and priorities by collecting and analyzing data about how you use, or interact with, the products and services offered on the Site (including, by way of example, usage patterns around how regularly you update your profile or how often you view certain profiles or articles). TELCCA may use this information, including through automated processes applying algorithms, for the purposes set out in this Privacy Statement, including without limitation to better tailor TELCCA’s offerings to your needs and to provide more targeted services to Mentors/Coaches and Mentees/Coachees including to allow more targeted opportunities to be surfaced to Mentees/Coachees and to create ‘signals’ to Mentors/Coaches and other Users that you may be more or less approachable for opportunities.
TELCCA may also subcontract processing to, or share your personal data with, third parties located in countries other than your home country. Your personal data may therefore be subject to privacy laws that are different from those in your country of residence.
In such instances,TELCCA will try to ensure that the transfer of your personal data is carried out in accordance with applicable privacy laws and in particular that appropriate contractual, technical, and organizational measures are in place such as the Standard Contractual Clauses approved by the EU Commission.
WHAT HAPPENS IF WE CAN’T COLLECT YOUR PERSONAL INFORMATION
If you do not provide us with the personal information described in this policy, some or all of the following may happen:
• We may not be able to provide you with the products or services you requested, either to the same standard, or at all (for example, if you do not register as a member of a website, you will not be able to access features or services that are reserved for members only);
• We may not be able to provide you with information about products, services and Mentors/Coaches that you may want; or
• We may be unable to tailor the content of our websites to your preferences and your experience of our websites may not be as enjoyable or useful.
• As a Mentor/Coach, we may not be able to disclose your profile to any Mentee/Coachee.
HOW DO WE DISCLOSE YOUR PERSONAL INFORMATION
We may disclose your personal information to:
• If you are a Mentor/Coach, to potential Mentees/Coachees;
• our employees, related bodies corporate, contractors or external service providers for the operation of our websites or our business, fulfilling requests by you, and otherwise provide products and services to you, including without limitation, web hosting providers, IT systems administrators, mailing houses, couriers, payment processors, photographic analyzers, data entry service providers, electronic network administrators, debt collectors, and professional advisers such as accountants, solicitors, business advisors and consultants;
• our existing or potential agents, business partners or joint venture entities or partners;
• our sponsors, or promoters of any competition that we conduct or promote via our services;
• specific third parties authorized by you to receive information held by us;
• the police, any relevant authority or enforcement body, or your Internet Service Provider or network administrator in our sole discretion, for example, if we have reason to suspect that you have committed a breach of any of our terms and conditions, or have otherwise been engaged in any unlawful activity, to protect the property and rights of TELCCA or a third party, or if we reasonably believe that disclosure is necessary;
• as required or permitted by any law.
REFER A FRIEND
If you choose to refer a friend to use the TELCCA website and associated services, we may collect the email address of such friend for the purpose of sending a one-time email invitation to use the Site and Services. We will not use the email address for any other purposes. Your friend may request that we delete his or her email address from our records by contacting us at [email protected]
DIRECT MARKETING MATERIALS
We may send you direct marketing communications and information about products and services that we consider may be of interest to you. These communications may be sent in various forms, including mail, SMS or email, in accordance with applicable marketing laws. If you indicate a preference for a method of communication, we will endeavor to use that method whenever practical to do so.
In addition, at any time, you may opt-out of receiving marketing communications from us by contacting us (details below). We will then ensure that your name is removed from our mailing list. We do not provide your personal information to other organizations for the purposes of direct marketing unless expressly authorized by you.
If you receive communications from us that you believe have been sent to you other than in accordance with this policy, or in breach of any law, please contact us using the details provided below.
ACCESSING, CORRECTING OR DELETING YOUR PERSONAL INFORMATION
You may request access to any personal information we hold about you at any time by contacting us (details below). Where we hold information that you are entitled to access, we will try to provide you with suitable means of accessing it (for example, by mailing or emailing it to you). We will not charge for simply making a request and will not charge for making any corrections to your personal information.
If you make an access request, we will ask you to verify your identity. There may be instances where we cannot grant you access to the personal information we hold. For example, we may need to refuse access if granting access would interfere with the privacy of others, or if it would result in a breach of confidentiality. If that happens, we will give you written reasons for any refusal.
If you believe that personal information we hold about you is incorrect, incomplete or inaccurate, then you may request us to amend it. We will consider if the information requires amendment. If we do not agree that there are grounds for amendment, then we will add a note to the personal information stating that you disagree with it.
Members of our websites will generally be able to access and update their membership details online. We request that you keep your information as current as possible so that we may continue to improve our service to you.
If you completely delete all such information, then your Account may become deactivated. If you would like us to delete your Account in our system, please contact us at [email protected] with a request that we delete your Personal Information from our database. We will use commercially reasonable efforts to honor your request. We may retain an archived copy of your records as required by law or for legitimate business purposes.
TELCCA reserves the right to amend or delete any user’s details and/or records if deemed necessary.
HOW YOU CAN COMPLAIN ABOUT A BREACH OF PRIVACY
We will treat your requests or complaints confidentially. Our representative will contact you within a reasonable time after receipt of your complaint to discuss your concerns and outline options regarding how they may be resolved. We will aim to ensure that your complaint is resolved in a timely and appropriate manner.
Please contact our Privacy Officer at:>
Post: PO Box 123
Email: [email protected]
DISCLOSURE OF PERSONAL INFORMATION OUTSIDE THE UAE
• Mentees/Coachees and/or Mentors/Coaches located globally;
• our related bodies corporate located globally;
• our data hosting and Cloud-based IT service providers;
• other external service providers located globally; and
• other third parties operating in jurisdictions where you have authorized us to do so.
If you are a resident of the European Union for the purposes of the GDPR, then in addition to what is set out above, the following applies to you. TELCCA is a data controller and processor for the purposes of the GDPR and by your consenting to this Privacy Statement, TELCCA is able to process your Personal Data in accordance with this Privacy Statement. Our Contact details are set out below.
In providing its services to you, TELCCA may make use of a number of automated processes using your Personal Data and your activity on our Site as tracked by us, in order to provide more tailored and relevant services to you such as providing recommended job opportunities to you through email communication, and on the Site or within our Apps.
TELCCA may also use such data in automated processes aimed at providing more tailored and relevant services to Users.
In addition to your rights set out above, you may:
• update or rectify any of the Personal Data that we hold about you, in the manner described in the “ACCESSING, CORRECTING OR DELETING YOUR PERSONAL INFORMATION” section above.
• withdraw your consent to TELCCA’s use of your Personal Information as described in this Privacy Statement by deleting your account. This will also delete all the Personal Data about you which we hold. This can be done by accessing the Site, logging in to your account, selecting the “Dashboard” and selecting “Trash”
• request that TELCCA provides you with a copy of the Personal Data TELCCA holds about you in a portable and machine readable form; or – share your Personal Data with a nominated third party;
you may request that by contacting us below:
Email: [email protected]
Post: PO Box 00000
Should you have any concerns in relation to TELCCA’s collection and/or processing of your Personal Data, then in addition to the process set out in the “Feedback and Complaints about privacy and the TELCCA website “ set out above (including the right to complain to the Office of the United Arab Emirates' Information Commissioner).
We will take all reasonable steps to protect the personal information that we hold from misuse, loss, or unauthorized access, including by means of firewalls, password access, secure servers and encryption of credit card transactions. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. If you have any questions about security on our Site, you can contact us at [email protected]
If you suspect any misuse or loss of, or unauthorized access to, your personal information, please let us know immediately.
OUR POLICY TOWARD CHILDREN
The services of TELCCA are not directed to persons under 16. We do not knowingly collect personal information from children under 16. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, he or she should contact us at [email protected] If we become aware that a child under 16 has provided us with Personal Information, we will delete such information from our files.
Our website may contain links to other websites operated by third parties. We make no representations or warranties in relation to the privacy practices of any third party website and we are not responsible for the privacy policies or the content of any third party website. Third party websites are responsible for informing you about their own privacy practices.