Privacy Policy

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This Privacy Policy is issued by Qelaris, a company based in Dubai, UAE, with its registered office at [your office address, if applicable] (“Qelaris,” “we,” “us,” or “our”). It outlines how we collect, process, and share Personal Data through our Website and Services. Additionally, it explains your rights concerning your Personal Data and how you can exercise them.

The definitions of key terms used in this Privacy Policy can be found in Section 11. This document is meant to be read alongside our Terms of Use and Terms of Service, which can be accessed at the following links:

Privacy Policy & Terms of Use

We may update this Privacy Policy periodically to reflect changes in our data practices, regulatory requirements, or service enhancements. We encourage you to review this page regularly to stay informed of any modifications.

Last updated: [Insert Date]

If you do not agree with the terms outlined in this Privacy Policy or any future updates, we advise you to discontinue the use of our Website and Services immediately.

1. What Personal Data Do We Collect, and How Do We Obtain It?

At Qelaris, we collect and process Personal Data to provide and improve our Services. Below is a breakdown of the types of Personal Data we collect, how we obtain it, and how it is used.

1.1 Business-Related Personal Data

We maintain a database of business-related Personal Data, which we offer to our customers for business-to-business (B2B) sales prospecting. The data we store for each profile may include:

  • Identity Information: Full name, email address, phone number, postal address.
  • Professional Information: Job title, department, company/employer name, professional email, work address, employment history, educational background, and public social media profiles.

We do not collect or process any sensitive Personal Data (e.g., racial or ethnic origin, political views, religious beliefs, medical records, biometric data) or any Personal Data of minors.

How We Collect This Data

Our database consists of two types of data sources:

  1. Public & Licensed Data ("Output Data") – This data is gathered from publicly available sources, licensed third-party data providers, and market research.
  2. User-Provided Data ("Submitted Data") – This data is voluntarily submitted by our users and customers.

If your profile is included in our database and you wish to have it removed, you may request deletion via our Privacy Center at privacy@qelaris.com. If you do not exercise this right, your data may remain in our database and be accessed by our customers for business-related purposes.

1.2 Personal Data Collected Through Website & Services

1.2.1 User Accounts & Service Provision

When you register an account and use our Services, you may be required to provide:

  • Full name
  • Professional email address
  • Phone number
  • Company name
  • Job title
  • Payment information (e.g., bank account details, credit card number, IBAN) for purchases.

1.2.2 Submitted Data Program

Users and customers may voluntarily share their business-related Personal Data with us to help keep our database accurate and up-to-date. If you participate in our Submitted Data program, we may access:

  • Email account, calendar, and/or contact lists
  • Contact details of third parties, including:
    • Full name
    • Professional email address
    • Phone number
    • Job title
    • Company/employer name and address
    • Public social media handles

Important Notice: We do not access the content of email messages and do not process any Personal Data beyond professional contact details.

If required by law, we will notify contacts added to our database, informing them of their right to manage or remove their Personal Data. You can opt out of the Submitted Data program at any time, after which we will stop collecting and processing new data from your email account, calendar, or contacts.

1.2.3 Cookies & Tracking Technologies

When you visit our Website, we use Cookies and other tracking technologies to enhance your experience.

What Are Cookies?

Cookies are small text files stored on your device when you visit a website. They help websites remember your preferences, improve functionality, and analyze visitor behavior.

Types of Cookies We Use

  • First-Party Cookies: Sent directly from Qelaris to your device to enable platform functionality.
  • Third-Party Cookies: Set by external services for analytics, marketing, or performance tracking. We do not control how third parties use this data.

We collect information such as:

  • IP address
  • Country location & time zone
  • Device & browser type
  • Pages visited
  • User interactions & preferences

If you access the Website via a mobile device, we may also collect information about your mobile provider and device type.

Managing Cookies: You can configure or disable Cookies from the cookie banner on our Website or in your browser settings. However, disabling Cookies may limit certain Website functionalities.

1.2.4 Third-Party Websites

Our Website may contain links to third-party websites. If you choose to visit these sites, they may collect and process Personal Data independently. Qelaris is not responsible for third-party data collection practices, and we encourage you to review their privacy policies before sharing any information.

2. Why Do We Collect and Process Your Personal Data?

At Qelaris, we process Personal Data to provide and improve our Services while ensuring compliance with legal obligations and maintaining security. Below are the key purposes for which we collect and process your data:

2.1 Service Provision & Customer Support

  • Enabling access to our Services (e.g., account login, feature usage).
  • Providing customer support and responding to inquiries.

2.2 Service Improvement & Customization

  • Managing and optimizing our Website and Services.
  • Personalizing content and recommendations.
  • Analyzing trends, user activity, and engagement to enhance user experience.

2.3 Communication & Marketing

  • Sending important service-related updates.
  • Providing news, promotions, and relevant content through various channels (email, phone, text, social media, post, or in person).
  • Opt-in Consent: Marketing communications will only be sent with your prior consent, as required by applicable law.

2.4 Legal & Compliance Obligations

  • Ensuring compliance with applicable laws and regulations.
  • Managing financial activities, including sales, corporate audits, and vendor management.

2.5 Database Compilation & Management

  • Maintaining an accurate and up-to-date B2B sales prospecting database.

2.6 Surveys & Feedback Collection

  • Gathering user insights through surveys to improve our Website and Services.

2.7 Legal Claims & Dispute Resolution

  • Establishing, exercising, or defending legal claims.
  • Managing legal disputes, including evidence collection and formal proceedings.

2.8 Fraud Prevention & Security

  • Detecting, preventing, and investigating fraudulent activities or policy violations.

3. On What Legal Basis Do We Process Your Personal Data?

We process your Personal Data for various purposes, as outlined in Section 2, under the following legal bases:

3.1 Performance of a Contract

We process your Personal Data to fulfill our contractual obligations when providing our Services.

  • Purpose: Provision of our Services
  • Categories of Personal Data:
    • Identification data (e.g., full name)
    • Professional email address
    • Professional phone number
    • Postal address
    • Payment information (e.g., bank account number, credit card number, IBAN details)
    • Data assigned to you (e.g., customer number, account number)
    • Data related to the follow-up of the commercial relationship

3.2 Your Consent

We process certain Personal Data only with your prior consent.

  • Purpose: Communication with you (including direct marketing)
  • Purpose: Surveys
  • Categories of Personal Data:
    • Identification data (e.g., full name)
    • Professional email address
    • Professional phone number
    • Data assigned to you (e.g., customer number, account number)
    • Data related to the follow-up of the commercial relationship
    • Data related to your use of the Website

3.3 Legitimate Interests

We process Personal Data when it is necessary for our legitimate business interests, provided that such processing does not override your rights and freedoms.

  • Purpose: Improvement and customization of our Services
  • Categories of Personal Data:
    • Identification data (e.g., full name)
    • Professional email address
    • Professional phone number
    • Data assigned to you (e.g., customer number, account number)
    • Data related to the follow-up of the commercial relationship
    • Data related to your use of the Website
  • Purpose: Compilation of our Database
  • Categories of Personal Data:
    • Identification data (e.g., full name)
    • Professional email address
    • Professional phone number
    • Postal address
    • Job title, company name, and location
    • Employment history and educational background
    • Related social media profiles
  • Purpose: Financial management
  • Categories of Personal Data:
    • Identification data (e.g., full name)
    • Professional email address
    • Professional phone number
    • Data assigned to you (e.g., customer number, account number)
    • Data related to the follow-up of the commercial relationship
  • Purpose: Establishment, exercise, and defense of legal claims
  • Categories of Personal Data:
    • Identification data (e.g., full name)
    • Professional email address
    • Professional phone number
    • Data assigned to you (e.g., customer number, account number)
    • Data related to the follow-up of the commercial relationship
    • Data collected as part of internal controls
  • Purpose: Fraud prevention
  • Categories of Personal Data:
    • Identification data (e.g., full name)
    • Professional email address
    • Professional phone number
    • Data assigned to you (e.g., customer number, account number)
    • Data related to the follow-up of the commercial relationship
    • Data collected as part of internal controls
    • Data related to your use of the Website/IT tools

3.4 Compliance with Legal Obligations

We process Personal Data to comply with applicable legal and regulatory requirements.

  • Purpose: Compliance with a legal obligation
  • Categories of Personal Data:
    • Identification data (e.g., full name)
    • Professional email address
    • Professional phone number
    • Data assigned to you (e.g., customer number, account number)
    • Payment information (e.g., bank account number, credit card number, IBAN details)

4. Who Do We Share Your Personal Data With, and Under What Circumstances?

To the minimum extent necessary to achieve the purposes outlined in Section 2, we may share your Personal Data with the following parties:

4.1 Customers

  • We may share Personal Data from our Database with our customers as part of our Services.
  • When customers access and process Personal Data for their own purposes, they act as Controllers under the GDPR, meaning they are responsible for how they use that data.

4.2 Professional Advisors

  • We may disclose Personal Data to accountants, auditors, consultants, lawyers, and other professional advisors, subject to binding contractual obligations of confidentiality.

4.3 Third-Party Processors

  • We engage third-party Processors worldwide, subject to strict contractual obligations (outlined in Section 6) to protect your Personal Data. These may include:
    • Data hosting services
    • Email service providers
    • Customer support providers
    • Payment service providers
    • Postal carriers

4.4 Public Forums

  • Our Website may offer publicly accessible blogs or message boards.
  • If you disclose any Personal Data in such public forums, it may be collected, read, and used by any member of the public.
  • We recommend caution when sharing Personal Data in such spaces.

4.5 Legal and Regulatory Authorities

  • We may disclose Personal Data to any relevant regulatory body, governmental authority, law enforcement agency, or court if necessary for:
    • Establishment, exercise, or defense of legal claims
    • Prevention, investigation, detection, or prosecution of criminal offenses
    • Execution of criminal penalties

4.6 Business Transfers

  • In the event of a merger, acquisition, reorganization, dissolution, or liquidation, we may transfer Personal Data to relevant third-party acquirers or successors in title.

4.7 Third-Party Providers

  • If our Website features third-party advertising, plugins, or content, interacting with them may result in your Personal Data being shared with the relevant provider.
  • We recommend reviewing the third party’s privacy policy before interacting with such content.

4.8 Data Protection Measures for Third-Party Processors

When engaging third-party Processors, they are contractually bound to:

  1. Process Personal Data only in accordance with our written instructions
  2. Implement appropriate security measures to safeguard the data
  3. Comply with applicable data protection laws

4.9 No Sale of Personal Data

  • We do not and will never sell your Personal Data to any third party.

5. Where and for How Long Do We Store Your Personal Data?

We take all reasonable steps to ensure that your Personal Data is:

Accurate and up-to-date – Any inaccurate data is promptly erased or rectified.

Limited to what is necessary – We only process Personal Data required for the purposes set out in this Privacy Policy.

Retained for the minimum period necessary – Personal Data is stored only for as long as needed for the purposes outlined below.

5.1 Retention Criteria

We will retain your Personal Data in an identifiable form only for as long as:

Ongoing Relationship

  • You are an active user of our Services.
  • You are lawfully included in our mailing list and have not unsubscribed.

Legal and Business Obligations

  • Your Personal Data is necessary for a valid legal basis outlined in this Privacy Policy.
  • Your Personal Data is included in a contract with us or your employer, and we have a legitimate interest in processing it for business operations and contractual obligations.
  • We are required to retain your Personal Data due to legal or regulatory obligations.

Legal Limitation Periods

  • We will retain Personal Data for the duration of any applicable limitation period under relevant laws (i.e., the time during which legal claims can be made involving your data).
  • An additional two (2) months will be added to the limitation period to allow us to respond to any last-minute legal claims.

Ongoing Legal Claims

  • If any legal claim is filed involving your Personal Data, we will retain and process it for as long as necessary to resolve the claim.

5.2 Data Security During Retention

  • During the retention periods outlined above, we will restrict Processing to storage and security maintenance only.
  • Your Personal Data will only be accessed if necessary for legal claims or compliance with applicable laws.

5.3 Secure Data Deletion

Once the applicable retention periods have ended, we will:

  • Permanently delete or destroy the relevant Personal Data.
  • Anonymize the data so that it can no longer be linked to you.
  • If deletion is not immediately possible, we will securely store and isolate the data until it can be safely erased.

6. How Do We Secure Personal Data?

We have implemented appropriate technical and organizational security measures to protect your Personal Data from:

  • Accidental or unlawful destruction
  • Loss or alteration
  • Unauthorized disclosure or access
  • Other unlawful or unauthorized forms of processing

These measures comply with applicable data protection laws.

6.1 Limitations of Internet Security

While we take all reasonable precautions, the internet is an open system, and the transmission of information online is not entirely secure. Any data you send to us is transmitted at your own risk. We strongly encourage you to use secure channels when sharing Personal Data.

6.2 Commitment to Confidentiality

Our personnel and partners are fully aware of data protection obligations and are committed to ensuring the confidentiality and security of Personal Data they access in the course of their work.

6.3 Response to Data Breaches

If a data breach occurs that poses a risk to your rights and freedoms, we will:

  1. Notify the relevant Data Protection Authority within the time limits prescribed by the GDPR.
  2. If the breach presents a high risk to you, we will:
    1. Notify you directly, as required under GDPR regulations.
    2. Provide necessary information and recommendations to help you mitigate any potential impact.

7. How to access and control your Personal Data?

Pursuant to the UAE Data Protection Law (Federal Law No. 45 of 2021), Federal Decree-Law No. 34 of 2021 on Combatting Rumours and Cybercrimes, and the General Data Protection Regulation (GDPR), you have the following rights regarding the Processing of your Personal Data:

  • Right of access, rectification, and erasure: You have the right to request access to your Personal Data, request corrections if the data is inaccurate, and ask for the deletion of your Personal Data where applicable.
  • Right to data portability: You have the right to receive your Personal Data in a structured, commonly used, and machine-readable format and to transmit it to another Controller. If technically feasible, you may also request us to transfer your data directly to another Controller.
  • Right to restriction and objection: You can request a restriction on the Processing of your Personal Data while your correction, deletion, or objection requests are under review, or if there are no legitimate grounds for further Processing.
  • Right not to be subject to automated decision-making: You have the right to request human intervention if decisions affecting you are made solely by automated means.
  • Right to determine data retention after death: You may specify how your Personal Data should be handled after your passing.
  • Right to lodge a complaint: If you believe your rights have been violated, you have the right to file a complaint with the relevant Data Protection Authority in the UAE, as well as any competent authority under the GDPR. You may also seek compensation through the appropriate legal channels.

Exercising these rights is free of charge. However, if your requests are manifestly unfounded or excessive particularly if they are repetitive we reserve the right to charge a reasonable fee.To exercise your rights, please contact us at

Qelaris, Dubai, UAE, or email us at privacy@qelaris.com.

8. Will your Personal Data be transferred outside your country?

To facilitate our operations, we may transfer Personal Data to third parties as outlined in this Privacy Policy, in line with the purposes specified.

This Privacy Policy applies regardless of where your Personal Data is transferred. We have implemented appropriate safeguards to ensure that your Personal Data remains protected, regardless of the destination country.

We may transfer Personal Data to third parties located in countries that may not have equivalent privacy and data protection laws as those in the UAE or the European Economic Area (EEA). However, we use legally recognized mechanisms to ensure the security and protection of your data, including:

  • The European Commission-approved Standard Contractual Clauses (SCCs) where applicable under GDPR.
  • Binding Corporate Rules (BCRs) where adopted by multinational organizations.
  • Additional contractual, technical, and organizational measures as required under UAE Federal Law No. 45 of 2021.

You may request a copy of our Standard Contractual Clauses or details on our data transfer safeguards by using the contact information provided in Section 10 below.

Please note that if you transfer any Personal Data directly to an entity established outside the UAE or EEA, we are not responsible for that transfer. However, from the point at which we receive your data, we will Process it in accordance with this Privacy Policy.

9. How do we use your Personal Data for marketing purposes?

We Process Personal Data to contact you via email, telephone, direct mail, or other communication channels to provide you with information about Qelaris, our Website, and our Services that may be of interest to you.

We also Process Personal Data to display content tailored to your use of our Website or Services. If we provide our Services to you, we may send or display information about our platform, upcoming promotions, and other relevant updates using the contact details you have provided, always subject to obtaining your prior opt-in consent where required under applicable laws, including the UAE Federal Data Protection Law (Federal Law No. 45 of 2021) and GDPR.

You may unsubscribe from our promotional emails at any time by clicking the unsubscribe link included in each promotional communication. Please note that processing your unsubscribe request may take up to 14 days, during which you may continue to receive communications from us. After unsubscribing, we will cease sending you promotional messages but may continue to contact you regarding essential service-related matters.

10. How can you reach out to us regarding data privacy concerns?

If you have any questions or require more information about our Privacy Policy, please contact us:

Email: privacy@qelaris.com
Address:
Qelaris, Dubai, United Arab Emirates

11. What are the key definitions and terms used in this Privacy Policy?

  • "Cookie" means a small file that is placed on your device when you visit a website (including our Sites). In this Privacy Policy, a reference to a “Cookie” includes analogous technologies such as web beacons and clear GIFs.
  • "Controller" means the entity that decides how and why Personal Data are Processed. In many jurisdictions, the Controller has primary responsibility for complying with applicable data protection laws.
  • "Database" means our database containing all the professional profiles we have collected.
  • "Data Protection Authority" means an independent public authority that is legally tasked with overseeing compliance with applicable data protection laws.
  • "EEA" means the European Economic Area.
  • "GDPR" means the General Data Protection Regulation (EU) 2016/679.
  • "UAE Data Protection Law" means the Federal Law No. 45 of 2021 on the Protection of Personal Data (PDPL), which governs the collection, processing, and storage of personal data in the United Arab Emirates.
  • "Output Data" means the Personal Data we collect and Process from multiple sources that include, without limitation, licensed information from other companies, publicly available information, and market research.
  • "Personal Data" means information that is about any individual, or from which any individual is directly or indirectly identifiable, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that individual.
  • "Process", "Processing", or "Processed" means anything that is done with any Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.
  • "Processor" means any person or entity that Processes Personal Data on behalf of the Controller (other than employees of the Controller).
  • "Relevant Personal Data" means Personal Data in respect of which we are the Controller.
  • "Services" mean the provision of the Output Data, the Metadata, our platform, and the Beta services, as well as any accompanying or related infrastructure, functionality, technology, or analytics, including any services or add-ons described in an order form.
  • "Standard Contractual Clauses" means template transfer clauses adopted by the European Commission or adopted by a Data Protection Authority and approved by the European Commission.
  • "Submitted Data" means the Personal Data we collect and Process from the users of our Website and from our customers.
  • "Website" means the website accessible at the following URL: https://www.qelaris.com.