Privacy Policy

Four Principles is Committed to Respecting Your Privacy

Four Principles is committed to protecting your personal information and complying with relevant laws including, without limitation, the General Data Protection Regulations (“GDPR”). This policy details how Four Principles collects, holds, stores and discloses your personal information that is held via your interface with Four Principles and its website www.fourprinciples.com (“Four Principles Website”).

Please read this Privacy Policy (together with any other privacy policy Four Principles may provide to you on specific occasions where Four Principles is collecting or processing your personal details) carefully to understand Four Principles’ approach towards data protection.

By visiting the Four Principles Website and opting-in to receive information regarding Four Principles, its business and activities, and agreeing to deal with any enquiries you may have in respect of Four Principles, you accept and consent to the practices described in this Privacy Policy.

The collecting or processing of your personal data is based on current legislation, our legitimate interest in reviewing and promoting our services, and, if applicable, any existing contractual relationship we may have with you.

Who Collects Your Information via the Four Principles Website?

The Four Principles Website is owned by Four Principles Management Consulting FZ LLC. a limited liability company registered in Dubai under commercial license no. 94221 and whose registered office is Dubai Media City, Building 8, Office 212, P.O. Box 502621, Dubai, UAE (“Company”). The Four Principles Website is also operated by CROWD CREATIVE WEB DESIGN a Sole Establishment licensed by the Dubai Department of Economic Development (DED) in the Emirate of Dubai, United Arab Emirates (UAE) under license number 751096 and whose registered office is situate at 3F-B-05 Empire Heights Tower, Business Bay, PO Box 124584, Dubai, UAE (“Agency”).

Any information collected via the Four Principles Website is collected and processed by the Company on behalf of Four Principles in accordance with this Privacy Policy. For the purpose of the GDPR, the data controller is the Company.

Information collected about you

Four Principles collects personal information about you to inform you and provide you with information regarding Four Principles, its business and activities and to deal with any enquiries you may have in respect of Four Principles.

Four Principles may collect the following types of information about you:

• Forename(s) and surname;
• E-mail address;
• Telephone number;
• Postal address; and
• IP address based on the Four Principles Website cookies.

You may provide information about yourself by filling in the enquiry form on the Four Principles Website, by corresponding with Four Principles by any of the following methods: the contact e-mail address made available on the Four Principles Website, when you register to receive Four Principles newsletters, by subscribing to Four Principles’ informational post, participating in other social media activities made available via the Four Principles Website, participating in any customer surveys or, when you report a problem with the Four Principles Website or make any form of enquiry.

• Information collected about you via the Four Principles Website. With regard to each of your visits to the Four Principles Website, the following information may be automatically collected by Four Principles using an automated data analytics tool to record and analyze how visitors use our website:
  • technical information, including the internet protocol (IP) address used to connect your computer to the internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and
  • information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from the Four Principles Website (including date and time); pages you viewed; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call any Abdul Latif Jameel contact number.

We may also use website visitor statistical data to analyze trends and demographics of Abdul Latif Jameel’s visitors. Please note that we do not assign each visitor an individual profile.

• Information received from other sources.

Four Principles may receive information about you if you use any other websites operated by any service provided by Four Principles. Four Principles works closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies, customer survey providers) and may receive information about you from them.

Uses made of the information

• Four Principles uses personal information collected about you in the following ways:
  • for internal record keeping and administration;
  • to identify you when you contact Four Principles;
  • to provide you with the information and services you request via the Four Principles Website (including without limitation news items, marketing collateral, information and updates about the Four Principles);
  • to be shared with Four Principles businesses;
  • to provide you with information about goods or services which may interest you;
  • to provide you with information about goods, products and services similar to those you may have already expressed an interest in or enquired about;
  • to perform and analyze the results of customer surveys and feedback about Four Principles, including but not limited to being combined with information gathered from other survey participants;
  • to allow you to be contacted by third parties who carry out customer surveys and feedback about Four Principles (when you consent to the same);
  • to notify you about changes to the Four Principles Website’s service;
  • to address and resolve any enquires you may have raised via the Four Principles Website; and/or
  • to ensure content from the Four Principles Website is presented in the most effective manner for you and for your computer.

• Four Principles uses information collected by the Four Principles Website for the following:
  • to administer the Four Principles Website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
  • to improve the Four Principles Website to ensure content is presented in the most effective manner for you and for your computer;
  • to allow you to participate in interactive features of the Four Principles Website, when you choose to do so;
  • as part of efforts to keep the Four Principles Website safe and secure;
  • to measure or understand the effectiveness of promotional and marketing activities, and to
  • deliver relevant promotional and marketing activities to you; and/or
  • to make suggestions and recommendations to you and other users of the Four Principles Website about goods or services which may interest you or them.

Information that Four Principles receives from other sources.

Information from other sources may be combined with information you provide and information collected about you. This information and the combined information may be used for the purposes set out above (depending on the types of information received). In particular, statistics around email opening and clicks using industry standard technologies (including clear gifs) may be collected to help monitor your response to Four Principles e-newsletters and to improve these e-newsletters.

How will we contact you?

Four Principles and its third party service providers (e.g. marketing fulfillment agencies and the like) as applicable may contact you by post, telephone, email and/or text message unless otherwise instructed by you.

Disclosure of your information

Your personal information will not be sold, distributed or leased to third parties (except as noted in this Privacy Policy) to use for their own purposes unless you give your permission or there is a legal requirement to do so.

However, you agree and consent that:

• Your personal information may be shared with any Four Principles business. In particular, if you submit an enquiry using the enquiry form available on the Four Principles Website, your enquiry and any personal information you provide in it will be sent to the relevant Four Principles (based on the enquiry criteria you select). Your personal information may then be held by such an Four Principles business(es) as part of its enquiry / customer database.
• Your personal information may be shared with selected third parties including:
• Marketing services providers to deliver e-newsletter and updates;
• Market research businesses or similar organizations for the undertaking and analysis of customer surveys and feedback;
• Business partners, suppliers and sub-contractors who perform services on behalf of Four Principles; and
• Analytics and search engine providers who assist in the improvement and optimization of the Four Principles Website.

Your personal information may be disclosed to third parties:

• In the event any business of Four Principles sells or buys any business or assets, in which case your personal data may be disclosed to the prospective seller or buyer of such business or assets;
• If an Four Principles business or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets;
• If there is a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply the Four Principles Website’s Terms of Use and other agreements; or to protect the rights, property, or safety of any Four Principles business, customers, or others. This includes without limitation exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Where your personal data is stored and data transfers

The data collected from you via the Four Principles Website will be initially stored on servers currently located in Germany.

In order to provide you with our services, we may need to transfer your personal information to locations outside of the jurisdiction in which you provide it.

If you are based within the European Economic Area (“EEA”), please note that your personal information may need to be transferred to, and stored at, a destination outside the EEA. It may also be processed by staff operating outside the EEA, who work for Four Principles or for one of its suppliers. In accordance with the GDPR, we will only transfer your data outside of the EEA if:

• the country to which we are transferring your data has been approved by a decision of the European Commission as having adequate levels of protection for data subjects’ rights and freedoms (Please see the following link for the latest list of approved countries: https://ec.europa.eu/info/law/law-topic/data-protection_en);

• we have appropriate safeguards in place to ensure that your data is protected (see more on this below);

• we have your explicit consent to the proposed data transfer after being informed of any potential risks; or

• the transfer is necessary for one of the other reasons under the GDPR, including to allow us to perform any contracts we have with you, to protect your interests, and in limited cases, for our legitimate interest.

By providing your personal data to the Four Principles, you agree to this transfer, storing or processing.

The Company will take all steps reasonably necessary to ensure your data is treated securely, to prevent unauthorized access or disclosure and in accordance with this privacy policy. This may include storing your data using AES 128bit database encryption. Unfortunately, the transmission of information via the internet is not completely secure. Although all steps reasonably necessary will be taken to protect your personal data, the security of your data transmitted to the Four Principles Website cannot be guaranteed; any such transmission is at your own risk. Information submitted via the Four Principles Website is normally unprotected until it reaches the Company. Users are requested not to send confidential details or credit card numbers, for example, by email or the enquiry form. Once your information is received, strict procedures and security features will be used to try to prevent unauthorized access.

For how long is your personal information kept?

The time period for which your information is kept varies according to what your information is used for. In some cases there are legal or regulatory requirements to keep data for a minimum period. Unless there is a specific legal requirement to keep the information, it will be retained for no longer than is necessary for the purposes for which the data was collected or for which it is to be further processed.

Information about your visits to the Four Principles Website will be stored by us for at least three years from the date of our last interaction with you and in compliance with our obligations under the GDPR.

In the event that we provide any services to you, your relevant personal information will be retained for at least six years from the date of our last interaction with you and in compliance with our obligations under the GDPR.

At any time you can ask for your stored information to be deleted from the Company’s database using the contact details below. However, some of your information may be retained in some circumstances, such as to resolve disputes, troubleshoot problems, enforce terms and conditions or as required by regulators. Further, in some circumstances such information is never entirely removed from databases due to technical constraints and systems back-ups.

Confidentiality

We have implemented appropriate information security policies, rules and technical measures to protect the personal information that we have under our control from unauthorized access, improper use or disclosure, unauthorized modification and unlawful destruction or accidental loss.

All of our employees, partners, consultants, workers and data processors (i.e. those who process your personal information on our behalf), who have access to, and are associated with the processing of personal information, are obliged to respect the confidentiality of such personal information.

Your rights

You have the following rights in relation to the personal information held and processed by Four Principles:

• You have the right to access your personal information

ACCESS – you can request access to your personal information and further details about how it is

• You have the right to rectify your personal information

RECTIFY – if the personal information we hold about you is inaccurate or incomplete, you are entitled to request to have it rectified.

• You have the right to request your personal information is erased

ERASURE – you can ask us to delete or remove your personal information where the processing is not necessary for the legitimate interests of Four Principles.

OBJECTION – you have the right to object to or restrict the processing of your personal information unless the processing of your personal information is necessary for the legitimate interests of Four Principles.

• You have the right to data portability

You have the right, in certain circumstances, to obtain personal information you’ve provided us with (in a structured, commonly used and machine readable format) and to reuse it elsewhere or to ask us to transfer this to a third party of your choice.

• You have the right to withdraw your consent

At any time you have the right to withdraw your consent for us to process your personal information.

You will be informed (before collecting your data) if your data is intended to be used for marketing purposes or to be disclosed to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the enquiry form used to collect your data. You can also exercise the right at any time by contacting Four Principles at info@fourprinciples.com.

When you fill in a form on the Four Principles Website (for example, the enquiry form), you must use any check boxes to indicate your preferences regarding use of your information and/or do not provide the relevant information. If you do not want your data to be used in this way, or for your details to be passed on to third parties for marketing purposes, please ensure you indicate this using the relevant box. However, please note if you do not provide all or correct information requested, it may not possible to provide you with the relevant information and/or services.

• You have the right to lodge a complaint

If you have a complaint or concern about our privacy practices or how we have used or processed your personal information, you can report it to the relevant GDPR supervisory authority in your jurisdiction.

Please note that some of the rights listed above may be limited where we have an overriding interest or legal obligation to continue to process your personal data or not disclose the same.

Cookies

Cookies are text files containing small amounts of information which are down loaded to your computer when you visit a website and are used to distinguish your device but cannot identify you personally.

The Four Principles Website uses cookies to distinguish you from other users of the Four Principles Website. This helps provide you with a good experience when you browse the Four Principles Website and also allows improvements to be made to the Four Principles Website.

For detailed information on the cookies used and the purposes for which they are used, managed and deleted, please refer to the Four Principles’ Cookie policy.

Third-party sites and sponsors

The Four Principles Website may contain links to and from the websites of other businesses of Four Principles, partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note these websites have their own privacy policies and the Company does not accept any responsibility or liability for these websites or policies. Please check these policies before you submit any personal data to these websites.

Access to information

The GDPR gives you the right to access information held about you. For more information about this right please see the Information Commissioner’s Office website at https://ico.org.uk/for-organisations/guide- to-the-general-data-protection-regulation-gdpr/.

Children’s privacy

Four Principles does not knowingly collect the information of, or make contact with, children, including to participate in customer research activities.

If you are aged 18 or under, please get your parent/guardian’s permission before you provide any personal information via the Four Principles Website.

Users aged 18 or under without such consent are not allowed to provide us with personal information.

Changes to this privacy policy

We reserve the right to change this Privacy Policy at any time, and we may also make changes in order to comply with changes in applicable laws and regulations.

Where appropriate, we will notify you of significant changes to this Privacy Policy by email, however we encourage you to check back frequently to obtain the latest copy of Four Principles’ Privacy Policy. In the event that it is necessary to process your personal data for a different purpose than the ones mentioned above, we will inform you in advance.

This Privacy Policy does not override any applicable national data privacy laws and regulations in countries where the Company operates.

Contact us

Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed

to info@fourprinciples.com

Date of policy: 24 May, 2018