Privacy Policy

This Data Protection Notice (“Notice”) sets out the basis on which QR Souq (“we”, “us”, or “our”) may collect, use, disclose or otherwise process personal data of our customers in accordance with the Personal Data Protection Act (“PDPA”). This Notice applies to personal data in our possession or under our control, including personal data in the possession of organizations which we have engaged to collect, use, disclose or process personal data for our purposes.

PERSONAL DATA

As used in this Notice:

“Customer” means an individual who (a) has contacted us throughany means to find out more about any goods or services we provide, or (b) may,or has, entered into a contract with us for the supply of any goods or servicesby us; and

“Personal data” means data, whether true or not, about a customerwho can be identified: (a) from that data; or (b) from that data and otherinformation to which we have or are likely to have access.

Depending on the nature of your interaction with us, some examplesof personal data which we may collect from you include name, residentialaddress, email address, telephone number and financial information.

Other terms used in this Notice shall have the meanings given tothem in the PDPA (where the context so permits).

COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA

We generally do not collect your personal data unless (a) it isprovided to us voluntarily by you directly or via a third party who has beenduly authorized by you to disclose your personal data to us (your “authorizedrepresentative”) after (i) you (or your authorized representative) have been notifiedof the purposes for which the data is collected, and (ii) you (or your authorizedrepresentative) have provided written consent to the collection and usage ofyour personal data for those purposes, or (b) collection and use of personaldata without consent is permitted or required by the PDPA or other laws. Weshall seek your consent before collecting any additional personal data andbefore using your personal data for a purpose that has not been notified to you(except where permitted or authorized by law).

We may collect and use your personal data for any or all of thefollowing purposes:

(a) performing obligations in the course of or inconnection with our provision of the goods and/or services requested by you;

(b) verifying your identity;

(c) responding to, handling, and processingqueries, requests, applications, complaints, and feedback from you;

(d) managing your relationship with us;

(e) processing payment or credit transactions;

(f) complying with any applicable laws,regulations, codes of practice, guidelines, or rules, or assisting in lawenforcement and investigations conducted by any governmental and/or regulatoryauthority;

(g) any other purposes for which you haveprovided the information;

(h) transmitting to any unaffiliated thirdparties including our third-party service providers and agents, and relevantgovernmental and/or regulatory authorities, whether in Singapore or abroad, forthe aforementioned purposes; and

(i) any other incidental business purposesrelated to or in connection with the above.

We may disclose your personal data:

(a) where such disclosure is required for performing obligationsin the course of or in connection with our provision of the goods and servicesrequested by you; or

(b) to third-party service providers, agents, and other organizationswe have engaged to perform any of the functions with reference to the above-mentionedpurposes.

The purposes listed in the above clauses may continue to applyeven in situations where your relationship with us (for example, pursuant to acontract) has been terminated or altered in any way, for a reasonable periodthereafter (including, where applicable, a period to enable us to enforce ourrights under a contract with you).

RELIANCE ON THE LEGITIMATE INTERESTS EXCEPTION

In compliance with the UAE laws, we may collect, use or discloseyour personal data without your consent for the legitimate interests of QR Souqor another person. In relying on the legitimate interest’s exception of the UAE,QR Souq will assess the likely adverse effects on the individual and determinethat the legitimate interests outweigh any adverse effect.

In line with the legitimate interests’ exception, we will collect,use or disclose your personal data for the following purposes:

a. Fraud detection and prevention;

b. Detection and prevention of misuse of services; and

c. Network analysis to prevent fraud and financial crime, andperform credit analysis.

The purposes listed in the above clause may continue to apply evenin situations where your relationship with us (for example, pursuant to acontract) has been terminated or altered in any way, for a reasonable periodthereafter.

WITHDRAWING YOUR CONSENT

The consent that you provide for the collection, use, anddisclosure of your personal data will remain valid until such time it iswithdrawn by you in writing. You may withdraw consent and request us to stopcollecting, using, and/or disclosing your personal data for any or all of thepurposes listed above by submitting your request in writing or via email to ourData Protection Officer at the contact details provided below.

Upon receipt of your written request to withdraw your consent, wemay require reasonable time (depending on the complexity of the request and itsimpact on our relationship with you) for your request to be processed and forus to notify you of the consequences of us acceding to the same, including anylegal consequences which may affect your rights and liabilities to us. Ingeneral, we shall seek to process your request within twenty (20) business daysof receiving it.

Whilst we respect your decision to withdraw your consent, pleasenote that depending on the nature and scope of your request, we may not be in aposition to continue providing our goods or services to you and we shall, insuch circumstances, notify you before completing the processing of yourrequest. Should you decide to cancel your withdrawal of consent, please informus in writing in the manner described in clause 8 above.

Please note that withdrawing consent does not affect our right tocontinue to collect, use and disclose personal data where such collection, useand disclosure without consent is permitted or required under applicable laws.

ACCESS TO AND CORRECTION OF PERSONAL DATA

If you wish to make (a) an access request for access to a copy ofthe personal data which we hold about you or information about the ways inwhich we use or disclose your personal data, or (b) a correction request tocorrect or update any of your personal data which we hold about you, you maysubmit your request in writing or via email to our Data Protection Officer atthe contact details provided below.

Please note that a reasonable fee may be charged for an accessrequest. If so, we will inform you of the fee before processing your request.

We will respond to your request as soon as reasonably possible. Ingeneral, our response will be within twenty (20) business days. Should we notbe able to respond to your request within thirty (30) days of receiving yourrequest, we will inform you in writing within thirty (30) days of the time bywhich we will be able to respond to your request. If we are unable to provideyou with any personal data or to make a correction requested by you, we shallgenerally inform you of the reasons why we are unable to do so (except where weare not required to do so under the UAE Law).

PROTECTION OF PERSONAL DATA

To safeguard your personal data from unauthorized access,collection, use, disclosure, copying, modification, disposal, or similar risks,we have introduced appropriate administrative, physical and technical measuressuch as a minimized collection of personal data, authentication and accesscontrols (such as good password practices, need-to-basis for data disclosure,etc.), encryption of data, and regular patching of operating system and othersoftware.

You should be aware, however, that no method of transmission overthe Internet or method of electronic storage is completely secure. Whilesecurity cannot be guaranteed, we strive to protect the security of yourinformation and are constantly reviewing and enhancing our information securitymeasures.

ACCURACY OF PERSONAL DATA

We generally rely on personal data provided by you (or your authorizedrepresentative). In order to ensure that your personal data is current,complete, and accurate, please update us if there are changes to your personaldata by informing our Data Protection Officer in writing or via email at thecontact details provided below.

RETENTION OF PERSONAL DATA

We may retain your personal data for as long as it is necessary tofulfill the purpose for which it was collected, or as required or permitted byapplicable laws.

We will cease to retain your personal data, or remove the means bywhich the data can be associated with you, as soon as it is reasonable toassume that such retention no longer serves the purpose for which the personaldata was collected, and is no longer necessary for legal or business purposes.

DATA PROTECTION OFFICER

You may contact our Data Protection Officer if you have any inquiriesor feedback on our personal data protection policies and procedures, or if youwish to make any request, in the following manner:

Email Address: info@qrsouq.com

EFFECT OF NOTICE AND CHANGES TO NOTICE

This Notice applies in conjunction with any other notices,contractual clauses, and consent clauses that apply in relation to thecollection, use and disclosure of your personal data by us.

We may revise this Notice from time to time without any priornotice. You may determine if any such revision has taken place by referring tothe date on which this Notice was last updated. Your continued use of ourservices constitutes your acknowledgment and acceptance of such changes.