Privacy Notice.
This is the privacy notice of Big Boys Media. In this document, “we”,
“our”, or “us” refer to Big Boys Media.
We are registered in the United Arab Emirates and in the United
States of America.
Introduction.
This is a notice to inform you of our policy about all information that
we record about you. It sets out the conditions under which we may
process any information that we collect from you, or that you provide to
us. It covers information that could identify you (“personal
information”) and information that could not. In the context of the law
and this notice, “process” means collect, store, transfer, use or
otherwise act on information.
We regret that if there are one or more points below with which you are
not happy, your only recourse is to leave our website immediately. We
take seriously the protection of your privacy and confidentiality. We
understand that all visitors to our website are entitled to know that
their personal data will not be used for any purpose unintended by them,
and will not accidentally fall into the hands of a third party. We
undertake to preserve the confidentiality of all information you provide
to us, and hope that you reciprocate. Our policy complies with relevant
laws accordingly implemented, including where applicable, that required
by the EU General Data Protection Regulation (GDPR).
The law requires us to tell you about your rights and our obligations to
you in regards to the processing and control of your personal data. We
do this now, by requesting that you read the information provided at
www.knowyourprivacyrights.org Except as set out below, we do not share,
or sell, or disclose to a third party, any information collected through
our website.
The bases on which we process information about you.
The law requires us to determine under which of six defined bases we
process different categories of your personal information, and to notify
you of the basis for each category.
If a basis on which we process your personal information is no longer
relevant then we shall immediately stop processing your data. If the
basis changes then if required by law we shall notify you of the change
and of any new basis under which we have determined that we can continue
to process your information.
Information we process because we have a contractual obligation with you.
When you create an account on our website, buy a product or service from
us, or otherwise agree to our terms and conditions, a contract is formed
between you and us. In order to carry out our obligations under that
contract we must process the information you give us. Some of this
information may be personal information.
We may use it in order to:
1. verify your identity for security purposes
2. sell products to you
3. provide you with our services
4. provide you with suggestions and advice on products, services
and how to obtain the most from using our website
We process this information on the basis there is a contract between us,
or that you have requested we use the information before we enter into a
legal contract.
Additionally, we may aggregate this information in a general way and use
it to provide class information, for example to monitor our performance
with respect to a particular service we provide. If we use it for this
purpose, you as an individual will not be personally identifiable. We
shall continue to process this information until the contract between us
ends or is terminated by either party under the terms of the contract.
Information we process with your consent.
Through certain actions when otherwise there is no contractual
relationship between us, such as when you browse our website or ask us
to provide you more information about our business, including [job
opportunities and] our products and services, you provide your consent
to us to process information that may be personal information.
Wherever possible, we aim to obtain your explicit consent to process
this information, for example, by asking you to agree to our use of
cookies. Sometimes you might give your consent implicitly, such as when
you send us a message by e-mail to which you would reasonably expect us
to reply. Except where you have consented to our use of your information
for a specific purpose, we do not use your information in any way that
would identify you personally. We may aggregate it in a general way and
use it to provide class information, for example to monitor the
performance of a particular page on our website.
If you have given us explicit permission to do so, we may from time to
time pass your name and contact information to selected associates whom
we consider may provide services or products you would find useful.
We continue to process your information on this basis until you withdraw
your consent or it can be reasonably assumed that your consent no longer
exists. You may withdraw your consent at any time by instructing us at
[insert contact email address here]. However, if you do so, you may not
be able to use our website or our services further.
Information we process for the purposes of legitimate interests.
We may process information on the basis there is a legitimate interest,
either to you or to us, of doing so. Where we process your information
on this basis, we do after having given careful consideration to:
1. whether the same objective could be achieved through other
means
2. whether processing (or not processing) might cause you harmbr
3. whether you would expect us to process your data, and whether
you would, in the round, consider it reasonable to do so
For example, we may process your data on this basis for the purposes of:
• record-keeping for the proper and necessary administration of
our Big Boys Media
• responding to unsolicited communication from you to which we
believe you would expect a response
• protecting and asserting the legal rights of any party
• insuring against or obtaining professional advice that is
required to manage Big Boys Media risk
• protecting your interests where we believe we have a duty to do
so.
Information we process because we have a legal obligation.
We are subject to the law like everyone else. Sometimes, we must process
your information in order to comply with a statutory obligation.
For example, we may be required to give information to legal authorities
if they so request or if they have the proper authorisation such as a
search warrant or court order.
This may include your personal information.
Specific uses of information you provide to us.
Information provided on the understanding that it will be shared with a
third party.
Our website allows you to post information with a view to that
information being read, copied, downloaded, or used by other people.
Examples include:
1. posting a message / comment to our forum or blog
2. tagging an image
3. clicking on an icon next to another visitor’s message to
convey your agreement, disagreement or thanks
In posting personal information, it is up to you to satisfy yourself
about the privacy level of every person who might use it.
We do not specifically use this information except to allow it to be
displayed or shared.
We do store it, and we reserve a right to use it in the future in any
way we decide.
Once your information enters the public domain, we have no control over
what any individual third party may do with it. We accept no
responsibility for their actions at any time.
Provided your request is reasonable and there is no legal basis for us
to retain it, then at our discretion we may agree to your request to
delete personal information that you have posted. You can make a request
by contacting us at [insert contact email address here].
Complaints regarding content on our website.
We attempt to moderate user generated content, but we are not always
able to do so as soon as that content is published.
If you complain about any of the content on our website, we shall
investigate your complaint.
If we feel it is justified or if we believe the law requires us to do
so, we shall remove the content while we investigate.
Free speech is a fundamental right, so we have to make a judgment as to
whose right will be obstructed: yours, or that of the person who posted
the content that offends you.
If we think your complaint is vexatious or without any basis, we shall
not correspond with you about it.
Job application and employment.
If you send us information in connection with a job application, we may keep it for up to years in case we decide to contact you at a later date.
Sending a message to our support team.
When you contact us, whether by telephone, through our website or by
e-mail, we collect the data you have given to us in order to reply with
the information you need.
We record your request and our reply in order to increase the efficiency
of our Business.
We keep personally identifiable information associated with your
message, such as your name and email address so as to be able to track
our communications with you to provide a high quality service.
Complaining.
When we receive a complaint, we record all the information you have
given to us.
We use that information to resolve your complaint.
If your complaint reasonably requires us to contact some other person,
we may decide to give to that other person some of the information
contained in your complaint. We do this as infrequently as possible, but
it is a matter for our sole discretion as to whether we do give
information, and if we do, what that information is.
We may also compile statistics showing information obtained from this
source to assess the level of service we provide, but not in a way that
could identify you or any other person.
Cookies.
Cookies are small text files that are placed on your computer’s hard
drive by your web browser when you visit any website. They allow
information gathered on one web page to be stored until it is needed for
use on another, allowing a website to provide you with a personalised
experience and the website owner with statistics about how you use the
website so that it can be improved.
Some cookies may last for a defined period of time, such as one day or
until you close your browser. Others last indefinitely.
Your web browser should allow you to delete any you choose. It also
should allow you to prevent or limit their use.
Our website uses cookies. They are placed by software that operates on
our servers, and by software operated by third parties whose services we
use.
When you first visit our website, we ask you whether you wish us to use
cookies. If you choose not to accept them, we shall not use them for
your visit except to record that you have not consented to their use for
any other purpose.
If you choose not to use cookies or you prevent their use through your
browser settings, you will not be able to use all the functionality of
our website.
We use cookies in the following ways:
1. to track how you use our website
2. to record whether you have seen specific messages we display
on our website
3. to keep you signed in our site
4. to record your answers to surveys and questionnaires on our
site while you complete them
5. to record the conversation thread during a live chat with our
support team
Personal identifiers from your browsing activity.
Requests by your web browser to our servers for web pages and other
content on our website are recorded.
We record information such as your geographical location, your Internet
service provider and your IP address. We also record information about
the software you are using to browse our website, such as the type of
computer or device and the screen resolution.
We use this information in aggregate to assess the popularity of the
webpages on our website and how we perform in providing content to you.
If combined with other information we know about you from previous
visits, the data possibly could be used to identify you personally, even
if you are not signed in to our website.
Our use of re-marketing.
Re-marketing involves placing a cookie on your computer when you browse
our website in order to be able to serve to you an advert for our
products or services when you visit some other website.
We may use a third party to provide us with re-marketing services from
time to time. If so, then if you have consented to our use of cookies,
you may see advertisements for our products and services on other
websites.
Disclosure and sharing of your information.
Information we obtain from third parties.
Although we do not disclose your personal information to any third1
party (except as set out in this notice), we sometimes receive data that
is indirectly made up from your personal information from third parties
whose services we use.
No such information is personally identifiable to2 you.
Third party advertising on our website.
Third parties may advertise on our website. In doing so, those parties,
their agents or other companies working for them may use technology that
automatically collects information about you when their advertisement is
displayed on our website.
They may also use other technology such as cookies or JavaScript to
personalise the content of, and to measure the performance of their
adverts.
We do not have control over these technologies or the data that these
parties obtain. Accordingly, this privacy notice does not cover the
information practices of these third parties.
Credit reference.
To assist in combating fraud, we share information with credit reference agencies, so far as it relates to clients or customers who instruct their credit card issuer to cancel payment to us without having first provided an acceptable reason to us and given us the opportunity to refund their money.
Data may be processed outside the European Union.
Our websites are hosted in Europe.
We may also use outsourced services in countries outside the European
Union from time to time in other aspects of our business.
Accordingly data obtained within the UK or any other country could be
processed outside the European Union.
For example, some of the software our website uses may have been
developed in the United States of America or in Australia.
We use the following safeguards with respect to data transferred outside
the European Union:
1. the processor is within the same corporate group as our
business or organisation and abides by the same binding corporate rules
regarding data processing.
2. the data protection clauses in our contracts with data
processors include transfer clauses written by or approved by a
supervisory authority in the European Union
3. we comply with a code of conduct approved by a supervisory
authority in the European Union
Access to your own information.
Access to your personal information.
At any time you may review or update personally identifiable information
that we hold about you, by signing in to your account on our website.
To obtain a copy of any information that is not provided on our website
you may send us a request at [insert contact email address here].
After receiving the request, we will tell you when we expect to provide
you with the information, and whether we require any fee for providing
it to you.
Removal of your information.
If you wish us to remove personally identifiable information from our
website, you may contact us at [hello@bigboysmedia.com].
This may limit the service we can provide to you.
Verification of your information.
When we receive any request to access, edit or delete personal identifiable information we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.
Other matters.
Use of site by children.
We do not sell products or provide services for purchase by children,
nor do we market to children.
If you are under 18, you may use our website only with consent from a
parent or guardian.
We collect data about all users of and visitors to these areas
regardless of age, and we anticipate that some of those users and
visitors will be children.
Such child users and visitors will inevitably visit other parts of the
site and will be subject to whatever on-site marketing they find,
wherever they visit.
Encryption of data sent between us.
We use Secure Sockets Layer (SSL) certificates to verify our identity to
your browser and to encrypt any data you give us.
Whenever information is transferred between us, you can check that it is
done so using SSL by looking for a closed padlock symbol or other trust
mark in your browser’s URL bar or toolbar.
How you can complain.
If you are not happy with our privacy policy or if have any complaint
then you should tell us by email. Our address is hello@bigboysmedia.com
If a dispute is not settled then we hope you will agree to attempt to
resolve it by engaging in good faith with us in a process of mediation
or arbitration.
If you are in any way dissatisfied about how we process your personal
information, you have a right to lodge a complaint with the relevant
data protection authority.
Retention period for personal data.
Except as otherwise mentioned in this privacy notice, we keep your
personal information only for as long as required by us:
1. to provide you with the services you have requested;
2. to comply with other law, including for the period demanded by
our tax authorities;
3. to support a claim or defence in court.
Compliance with the law.
Our privacy policy has been compiled so as to comply with the law of
every country or legal jurisdiction in which we aim to do business. If
you think it fails to satisfy the law of your jurisdiction, we should
like to hear from you.
However, ultimately it is your choice as to whether you wish to use our
website.
Review of this privacy policy.
We may update this privacy notice from time to time as necessary. The
terms that apply to you are those posted here on our website on the day
you use our website. We advise you to print a copy for your records.
If you have any question regarding our privacy policy, please contact
us."
Important Considerations:
1. Legal Expertise: This revised version is a starting point. It's crucial for Big Boys Media to have this reviewed and adapted by legal professionals specializing in data privacy in the UAE and the US. Data privacy laws are complex and vary significantly.
2. Specific Registsration Details: You'll need to insert the precise registration details for Big Boys Media in the UAE and the US. This includes company numbers, registered addresses, and any other legally required identifiers.
3. Contact Email: hello@bigboysmedia.com.
4. Authority: Data Protection The "relevant data protection authority" will vary depending on where the user is located. You may need to provide specific information for the UAE, the US (federal and state level), and any other regions you operate in.
5. GDPR Applicability: Even if Big Boys Media is based in the UAE and US, the GDPR may still apply if you process the personal data of individuals in the EU. Hence, I've left the GDPR reference in, but its applicability should be confirmed by legal counsel.
6. International Data Transfers: If data is transferred between the UAE, the US, and other countries, ensure that appropriate safeguards are in place to comply with data protection laws. This might involve standard contractual clauses, adequacy decisions, or other mechanisms.
7. State Laws (US): In the US, data privacy laws vary significantly by state (e.g., California Consumer Privacy Act (CCPA), Virginia Consumer Data Protection Act (CDPA)). You'll need to ensure compliance with the specific laws that apply to your operations and users.
8. UAE Data ProtectionLaw: The UAE has its own data protection law, and you must ensure full compliance with its requirements.
