i. Overview

The below Privacy Statement outlines the privacy practices of Seaspring (also referred to hereafter as “Seaspring W.L.L.” or   “Company”) in relation to how the Company receives, collects, utilises, retains and archives (also known collectively hereafter as “Process”, “Processed” or “Processing”) Personal Data (also referred to hereafter as “Data”,  “Personal Information” or “Information”) and further sheds light on the measures available to the Users (also referred to hereafter as “User”) of this Website (also referred to hereafter as “Site”) for both desktop and mobile versions, as well as Third-Parties (also referred to hereafter as “Third-Party”) with respect to their Personal Information.

This Privacy Statement accordingly governs any Personal Data that is collected or received by Seaspring, either from Users of this Website, as well as Information provided, collected or received from Third-Parties in the course of their communications and interactions with Seaspring, as detailed in the relevant sections below.

By “Personal Data”, “Data”, “Personal Information” or “Information”, the Company refers to any or all information that identifies or can lead to identify Users, either directly or indirectly.  It includes, but is not limited to a User’s or Third-Party’s name, date of birth, business or personal contact details (such as landline and mobile numbers, fax numbers, email addresses, physical and/or mailing addresses), passport and smart card details including copies, photographs, BIOs, personal, educational, employment history etc.

By providing such Personal Data to Seaspring, either through the usage of this Website or by any other means of communications with the Company, such as via telephone conversations, email exchanges etc, the User or Third-Party agrees to the Terms and Conditions of this Privacy Statement (also referred to hereafter as “Terms”) as well as to the Terms set out under the شروط الاستخدام  section of this Website.

Accordingly, any and all such Personal Data received from or submitted by Users or Third-Parties and/or collected by Seaspring from Users or Third-Parties will be deemed to have been obtained with the Users’ or Third-Parties’ consent to proceed with the necessary Processing of such Data, be it collection, utilisation, retention and archiving of such Data, as detailed in the relevant sections below.

The User or Third-Party reserves the right to decline to provide any Personal Information, however by doing so, the User or Third-Party may be unable to access certain services and sections of this Site, and/or may be unable to obtain further information from, or undertake further business interactions with Seaspring. 

The User or Third-Party is therefore encouraged to read both the Terms set out herewith as well as the Terms set out within the شروط الاستخدام section of this Site.

ii. Collection of Personal Data from Website Users

Seaspring may receive, collect, utilise, retain and archive two (2) types of Personal Data about and from the Users of this Website as detailed below:

a) Personal Information that the User voluntarily provides while using this Site and/or through the submission of Information via this Website’s “Contact” options.

b) Tracking data, which from time to time may be automatically collected from every Website User.  Such tracking data may include, without limitation, information regarding the number and frequency of Users’ visits to the Website, the websites that Users accessed before and after visiting this Website, the software and operating system Users used to access the Website, and Users’ IP addresses and Internet service providers.

Seaspring may Process any or all such Information submitted by and/or obtained from the User.  Such Information that is gathered by the Company may include Users’ names, titles, designations, physical addresses, telephone numbers, mobile numbers, fax numbers, email addresses, or any other elements of Personal Information.

iii. Collection of Personal Data from Third-Parties

In addition to the submission by, or collection of Personal Data from the Users of this Website as detailed above, Seaspring may also collect Personal Data related to Third-Parties, such as its business partners, portfolio companies, suppliers, service providers and interested members of the general public, as well as information related to individuals connected with such Third-Parties, such as owners, shareholders, directors, board members, senior management and key personnel, in the course of, and as part of conducting its business activities.

Such Data may be received or obtained by the Company for the following purposes without limitations:

a) For furthering Seaspring’s business interests and objectives,

b) To organise meetings and/or conduct events,

c) To solicit goods and services and/or to consider bids and tenders for various goods and services,

d) To execute agreements with such Third-Parties to accomplish the requisite business objectives and/or for the provision of the requisite goods and services,

e) To comply with local regulations and legal requirements,

f) To communicate with, support and manage the aforementioned agreements and resulting relationships with such Third-Parties.

Such Data may be collected by Seaspring through in-person meetings, telephone calls, procurement processes/tenders, events, workshops, email exchanges, surveys, questionnaires, either directly or through external agencies authorised to obtain such Data on behalf of Seaspring. 

iv. Processing and Use of Personal Data

All such Personal Data received from and/or collected by Seaspring will be either used, retained or archived (also referred to collectively hereafter as “Process”, “Processed” or “Processing” of Personal Data) for the purpose of conducting the Company’s business activities, and/or the purpose for which such Data has been collected by Seaspring and/or provided by the User or Third-Party, subject to the following without limitation:

a) To respond to Users’ or Third-Parties’ requests or correspondences,

b) To contact Users of the Website regarding its performance,

c) To request Users’ inputs with regards to the ways in which Seaspring might improve the Website,

d) To inform Users and/or Third-Parties about Seaspring’s business activities, or events as well as those of its partners and/or portfolio companies,

e) To engage and interact with Third-Parties for the purpose of conducting Seaspring’s business activities or events, and/or to further the Company’s business objectives, or for the purpose of receiving any goods or services,

f) To main a comprehensive Contacts Database to aid Seaspring’s current and future performance of business activities.

Such Data, particularly Website tracking information, may also be analysed so that Seaspring can provide Users with pertinent information and can further serve Users in the best manner possible by enhancing the features and functionalities of the Site.

v. Disclosure of Personal Data

Seaspring will typically not disclose any Personal Data to any individual or entity, except under the following circumstances:

a) To its employees, partners, affiliates, portfolio companies, agents, consultants and sub-contractors during the course of, and as part of Seaspring conducting its business activities,

b) To service providers who assist the Company in managing and maintaining this Website, and/or who provide requisite services in aid of Seaspring’s business activities,

c) To the concerned legal authorities when such a disclosure is required by law,

d) To protect the rights, property, security or safety of Seaspring and/or the Users of this Website, or that of the Company’s employees, partners, affiliates, portfolio companies, agents, consultants, contractors, service providers and/or the general public,

e) To respond to an emergency situation,

f) To enforce these Terms,

g) Or as otherwise stated in these Terms.

vi. Retention and Archiving of Personal Data

All Personal Data collected and/or received by Seaspring will be retained and archived by the Company for such time as it is deemed necessary by the Company for it to undertake and fulfil the purposes for which such Data has been collected/received, and/or for the purposes of satisfying any legal, archiving, accounting or reporting requirements. The retention and archiving period for such collected/received Data will be decided by Seaspring based on the amount, nature and sensitivity of the Data, the purposes for which such Personal Data is obtained, and limitation periods for claims and applicable legal requirements.

vii. Security of Personal Data

Seaspring will undertake reasonable appropriate measures to prevent unauthorised access, utilisation, alteration, or disclosure of Users’ and Third-Parties’ Personal Data.  However, it should be noted that despite the Company’s best efforts, transmission of Personal Data via the internet is not fully secure. Therefore, under no circumstances shall Seaspring have any liability to any Users of this Website, or to any Third-Parties, for any loss or damage of any Personal Data, or any other loss resulting from using this Website, or from communicating with the Company in the course of regular business interactions, or as part of conducting its business.  Users of this Website therefore understand that their reliance on any information available on the Website is solely at their own risk.  Seaspring is also not liable for any viruses that may infect Users’ computers or any smart devices including, but not limited to, desktops, laptops, tablets, smart TVs or mobile devices as a result of accessing this Website.  Furthermore, Seaspring is not responsible for damages due to any form of electronic communications tampering, including but not limited to, intercepted communications, man-in-the middle-attacks, DNS redirects, or the use of this Website in phishing emails.

viii. Your Rights as a User or Third-Party in Relation to Your Personal Data

If Seaspring has Processed (also known hereafter as “Processing”) your Personal Data, you are entitled to certain rights as detailed below. Such rights are pursuant to the circumstances and applicable law(s) however, they would typically include:

a) The right to be informed upon request of what type of Personal Data, if any, the Company has Processed about you, and to receive a copy of that Data,

b) The right to request to have incomplete or incorrect Personal Data rectified or deleted,

c) The right to withdraw your consent to the Processing of your Personal Data,

d) The right to request that any or all Processing of your Personal Data is restricted, or to object to any or all Processing of your Personal Data.

Please note that your right to object to the Processing of your Personal Data is not applicable in the following instances:

a) If you have given your consent to the Processing of your Personal Data by voluntarily providing and/or submitting your Data through the channels mentioned above,

b) If the Processing of your Personal Data is required for the performance of contractual obligation where you are a party to it,

c) If the Processing of your Personal Data was at your request,

d) If the Processing of your Personal Data is required for the performance of a legal obligation or order issued by legal authorities,

e) If the Processing of your Personal Data is necessary to protect the legitimate interests of Seaspring.

If you need further information or wish to exercise the aforementioned rights, please contact us on [email protected] and the Company will endeavour to assist you at the earliest depending on the nature of your request.

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