PRIVACY POLICY
This Privacy Policy describes how The7AMConsultingGroup, a company registered in Dubai operating under the trading name The1Identity (hereinafter the “Company,” “we,” or “us”), collects, uses, protects and discloses the personal data of its customers (“you”) when they use our website and online training services.
We are committed to protecting your privacy and complying with the European Union General Data Protection Regulation (“GDPR”) where applicable.
The7AMConsultingGroup is the data controller responsible for your personal data.
1. DEFINITIONS AND GENERAL PRINCIPLES OF DATA COLLECTION AND PROCESSING
Definitions
“Personal Data” or “Data” means any information directly or indirectly identifying a natural person (for example, surname, first name, telephone number, date of birth or address), within the meaning of personal data legislation.
“Data Controller” means the natural or legal person who, alone or jointly with others, determines the purposes and means of processing.
“Data Subject” means any user whose Personal Data is collected and processed by the Company.
These terms have the same meaning in the singular and plural.
General principles of data collection and processing
In accordance with Article 5 of Regulation (EU) 2016/679, the collection and processing of Personal Data follow these principles:
Lawfulness, fairness and transparency: Personal Data is collected and processed on an appropriate legal basis, and Data Subjects are informed of the collection and its purposes.
Purpose limitation: Data is collected and processed for specific purposes described in this Privacy Policy.
Data minimisation: Only Data necessary to achieve those purposes is collected.
Storage limitation: Data is retained for a limited period, or according to communicated retention criteria.
Integrity and confidentiality: The Data Controller undertakes to protect the integrity and confidentiality of the Data.
In accordance with Article 6 of the GDPR, Personal Data processing must meet at least one of the following conditions:
The Data Subject has given consent.
Processing is necessary for the performance of a contract.
Processing is necessary to comply with a legal obligation.
Processing is necessary to protect the vital interests of a person.
Processing is necessary for a task carried out in the public interest or in the exercise of official authority.
Processing is necessary for legitimate interests pursued by the controller or a third party.
2. PERSONAL DATA COLLECTED
We collect and process your Personal Data as part of our online sales and training activities.
Accounting and financial compliance
Purpose: Bookkeeping, annual accounts, customer and supplier invoices, tax and social declarations, cash management, and financial and regulatory compliance.
Data collected: Customer identification, contact details, financial and payment data, transaction documents, planning information, budgets and forecasts.
Legal basis: Legal obligation.
Retention: 10 years after the end of the relevant financial year.
Contract management
Data collected: Identity, professional contact information, contract terms, prices, accounting and payment information.
Legal basis: Contract.
Retention: For the duration of the commercial relationship; archived for up to 5 years after the contract ends for evidence, or 10 years for accounting and tax evidence.
Customer and supplier invoicing
Data collected: Identity and contact information; invoice number, date, products or services, amount due and paid, payment method.
Legal basis: Contract.
Retention: For the duration of the commercial relationship; archived for up to 5 years after the contract ends for evidence, or 10 years for accounting and tax evidence.
Customer and team testimonials
Purpose: Promotion of Company services through former student testimonials, team testimonials and customer reviews.
Data collected: Name, age, photograph.
Legal basis: Legitimate interest.
Retention: Until withdrawal of consent by the individual concerned.
Website communications and promotional content
Data collected: Name, age, professional and compensation history of a person providing a testimonial.
Legal basis: Legitimate interest.
Retention: Until withdrawal of consent by the individual concerned.
Newsletters and commercial prospecting
Data collected: Name and email address.
Legal basis: Consent.
Retention: 3 years from collection or the last contact initiated by the individual.
Promotion of Company services
Data collected: Name, age, telephone number and profession.
Legal basis: Consent.
Retention: 3 years from collection or the last contact initiated by the individual.
Sales contracts, digital content and customer support
Data collected: Name, email address, telephone number, address and billing information.
Legal basis: Contract.
Retention: During the contractual relationship and for 10 years after its end (5 years if the contract was not electronically signed).
Data protection rights requests
Data collected: Identity and contact details.
Legal basis: Legal obligation.
Retention: 5 years after the request is closed.
Personal Data breaches
Data collected: Identity and contact details.
Legal basis: Legal obligation.
Retention: 5 years after resolution of the dispute.
Litigation and pre-litigation management
Data collected: Identity and contact details.
Legal basis: Legitimate interest.
Retention: 5 years after resolution of the dispute.
3. LEGAL BASIS AND CONSENT
3.1 How do we obtain your consent?
We collect your Personal Data when you provide it during a transaction, including a purchase, credit card verification, order, delivery or return. In these circumstances, we use the information for the purposes of completing that transaction.
For other purposes, particularly marketing, we request your explicit prior consent and give you the opportunity to decline.
3.2 How can you withdraw your consent?
If you change your mind after giving consent, you may withdraw it at any time by emailing contact@the1identity.com.
This includes withdrawing consent to the collection, use or disclosure of your information.
3.3 Your data protection rights
Under the GDPR, you have the following rights in relation to your Personal Data:
Right of access: Obtain confirmation that your Data is processed and receive a copy.
Right to rectification: Have inaccurate or incomplete Data corrected.
Right to erasure: Request deletion of your Data, subject to applicable conditions.
Right to restriction of processing: Request that processing be restricted.
Right to data portability: Receive Data you provided in a structured, commonly used, machine-readable format and transmit it to another controller.
Right to object: Object to processing where permitted by applicable law.
Right to lodge a complaint: Complain to a competent supervisory authority, such as the CNIL in France where relevant.
To exercise these rights, contact contact@the1identity.com.
4. DISCLOSURE AND TRANSFERS OF DATA OUTSIDE THE EU
4.1 Disclosure
We disclose your Personal Data to third parties only where necessary to provide our services, required by law or authorised by your consent.
This may include:
Legal obligations: Where required by a court order, search warrant or other legal process.
Enforcement of our Terms and Conditions: Where you violate our Terms of Sale and Use.
Third-party service providers: As described in Section 5, where needed to deliver our services.
4.2 Transfers of Data Outside the EU
As the Company is based in Dubai, United Arab Emirates, some of your Data may be transferred and processed outside the European Economic Area (“EEA”).
To protect your Data during such transfers, we ensure that appropriate safeguards are in place in accordance with the GDPR, including the European Commission’s Standard Contractual Clauses with our processors and service providers where applicable.
5. HOSTING AND PAYMENT PROCESSING (SYSTEME.IO)
Our website is hosted on Systeme.io, which provides the tools needed to offer our online services.
5.1 Data storage
Your Data is stored in Systeme.io’s storage systems, databases and general application. Data is held on a secured server protected by a firewall.
5.2 Payment processing
If you purchase through a direct payment gateway, the original policy states that Systeme.io stores payment card information encrypted in accordance with the Payment Card Industry Data Security Standard (“PCI DSS”).
Purchase transaction information is retained only as long as necessary to complete the order and is then deleted.
Direct payment gateways are subject to PCI DSS, administered by the PCI Security Standards Council, established through the efforts of payment card companies including Visa, Mastercard, American Express and Discover.
For further information about Systeme.io’s practices, please consult its Terms of Use and Privacy Policy.
6. THIRD-PARTY SERVICES
Generally, third-party providers used by us collect, use and disclose your information only to the extent necessary to perform the services they provide.
However, some providers, including payment gateways and payment transaction processors, have their own privacy policies concerning the information we must provide for your purchases. We recommend reviewing these policies.
Some providers may be located or operate facilities in jurisdictions different from yours or ours.
If you proceed with a transaction involving a third-party provider, your information may be subject to the laws of the jurisdiction where that provider or its facilities are located.
For example, a payment processed in the United States may be subject to applicable US laws.
Once you leave our website or are redirected to a third-party website or application, this Privacy Policy and our Terms of Sale and Use no longer govern that third-party service.
Links to third-party websites
Our website may contain links to other websites. We are not responsible for their privacy practices and encourage you to read their privacy policies.
7. DATA SECURITY
We take reasonable precautions and follow recognised industry practices to protect your Personal Data from loss, misuse, unauthorised access, disclosure, alteration or destruction.
When you provide payment card information, the original policy describes encryption using SSL (Secure Socket Layer) and AES-256.
Although no internet transmission or electronic storage method is completely secure, the original policy states that PCI DSS requirements and additional generally accepted industry standards are followed.
Cookies
We use the following cookies, as described in the original policy, to support website operation and improve your experience:
sessionid: Unique session identifier that allows Systeme.io to store session information, including referrer and landing page.
systeme.iovisit: Records website visits for internal statistics; no Personal Data retained; lasts 30 minutes after the last visit.
systeme.iouniq: Counts unique store visits; no Personal Data retained; expires at midnight on the following day based on the visitor’s location.
cart: Unique shopping cart identifier; lasts 2 weeks.
securesession_id: Unique session identifier.
storefront_digest: Used to determine whether a visitor has access to a password-protected store; duration unspecified.
You can manage cookie preferences through your browser settings.
8. AGE OF CONSENT
By using this website, you represent that you are at least the age of majority in your state or province of residence.
If you are an adult and the primary user, you also authorise any minors in your care to use this website under your supervision and responsibility.
9. CHANGES TO THIS PRIVACY POLICY
We reserve the right to modify this Privacy Policy at any time and encourage you to review it regularly.
Changes and clarifications take effect immediately upon publication on the website.
If we make material changes, we will notify you here so that you are aware of the information we collect, how we use it and under what circumstances we disclose it.
If our website is acquired by or merged with another company, your information may be transferred to the new owners so that we can continue to provide products and services.
10. QUESTIONS AND CONTACT DETAILS
For questions, requests to access, correct, amend or delete Personal Data, complaints or further information, please contact:
The7AMConsultingGroup
Trading name: The1Identity
Email: contact@the1identity.com
Registered in: Dubai, United Arab Emirates