Privacy Notice

1. Collection of Personal Data

We collect Personal Data in various ways, including but not limited to when you visit the Website, register on the Website, subscribe to the newsletter, respond to a survey, fill out a form, and in connection with other activities, services, features, or resources we make available on the Website. You may be asked for, as appropriate, your name, email address, mailing address, phone number, and other relevant information.

You may visit the Website anonymously. We will collect Personal Data from you only if you voluntarily submit such information to us. You can always refuse to supply Personal Data, except that it may prevent you from engaging in certain website-related activities.

We may collect the following information from you:

• Identity data including salutation, first name, middle name, last name, date of birth, gender, account number, or similar identifier(s);
• Contact data including residential address, billing address, email address, and telephone number;

We process your information for various purposes contingent upon your engagement with our services. These purposes encompass facilitating the creation and authentication of accounts on our Website, as well as detecting and addressing fraudulent activities. Additionally, we utilize your information for soliciting feedback and communicating with you concerning the utilization of our services. Processing of your information may also be imperative for safeguarding the vital interests of individuals, particularly in preventing harm.

This Privacy Notice applies to all individuals interacting with our Website or services, including but not limited to visitors who provide information through our Contact Us form or other means. Kindly note that the Website does not currently process job applications or collect employment-related data. We encourage you to review this Privacy Notice periodically, as it may be updated from time to time to reflect changes in our practices or legal requirements.

We undertake the processing of your personal data solely when deemed necessary and when a valid legal basis exists for such action. These legal bases encompass your explicit consent, our adherence to applicable laws, the provision of services, fulfilment of contractual obligations, safeguarding your rights, and pursuit of our legitimate business interests as listed in our Terms & Conditions. Furthermore, we engage in data processing activities to safeguard us against instances of fraud. Therefore, we process your information based on the following legal grounds:

• Consent: We process your Personal Data contingent upon your consent. You have the right to withdraw your consent at any time by contacting us or adjusting your preferences in your account settings, although this may affect the availability or functionality of certain features or services.
• Legal Obligation: We process your Personal Data to comply with the legal obligations to which we are subject. This includes obligations imposed by relevant laws, regulations, or court orders, as well as requests from law enforcement or government authorities. We may also use your Personal Data to establish, exercise, or defend legal claims in court or other legal proceedings.
• Contract: We process your Personal Data to comply with our contractual obligations and commitments. This includes our contractual obligations towards both business-to-business (B2B) and business-to-client (B2C). This includes areas such as providing services, support or through our terms and conditions.
• Portal Login and Community Access: Our Website may offer portal login capabilities that allow users to access specific communities we manage. When you create an account or log in to the portal, we may collect additional information relevant to each community, including data associated with your participation, preferences, and interactions within that portal.
• This information will be used to facilitate your access, enhance user experience, and deliver personalized content within each community. All data collected and processed through the portal login is handled in accordance with this Privacy Notice along with the Privacy Notice, as well as any additional terms or notices specific to the respective community portals. Access and use of portal features may be subject to your consent, legal obligations, or contractual obligations, as outlined in the Privacy Notice under Legal Grounds for Processing.

2. Retention of Personal Data

We retain your Personal Data for as long as necessary to fulfil the purposes outlined in this Privacy Notice, unless a longer retention period is required or permitted by law. The criteria used to determine the retention periods include:

• The length of time we have an ongoing relationship with you and provide the services to you;
• Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period before we can delete them);

Once your Personal Data is no longer necessary for the purposes for which it was collected, we will securely delete or anonymize it in accordance with our data retention policies and applicable laws.

3. Correction/Modification to Personal Data

To review or amend your account particulars, or to effectuate the closure of your account, please adhere to the following procedures:

• Log in to your account settings and rectify your user account information;
• Furthermore, you retain the option to communicate with us via provided contact information in this Privacy Notice .

We retain the right to verify the modified or updated data by you on the Website. If we have reasonable grounds to believe that you are presenting false or inaccurate data, then we may, at our discretion, decline the request to modify the data or suspend your access to the services provided by the Website until the issue is resolved.

4. Web Browser Cookies

This website may use cookies to enhance user experience by collecting standard log information to monitor customer traffic patterns. Currently, only essential cookies are utilized, and no additional tracking cookies are in use. These essential cookies may include data such as browser types and device information, which are necessary to ensure the Website operates effectively. The information gathered, typically anonymous, includes data such as IP addresses, browser types, and device information. Cookies are placed on your web browsers for record-keeping purposes and to track relevant information. You have the option to configure your web browser settings to refuse cookies or receive alerts about their transmission. However, it is important to note that disabling cookies may result in some parts of the Website not functioning properly. If additional cookies are implemented in the future, such as for tracking user activity during campaigns, a cookie notification will be activated to obtain user consent in compliance with applicable laws. Your continued use of the Website implies user consent to the described cookie usage. For further details on the handling of personal data, you are encouraged to review the Privacy Notice and our Privacy Notice accessible at ________.

5. Collect, Use, Share, Processing and Disclosure of Personal Data

We may collect and use personal data through our website for the following other purposes:

• The information you provide helps us respond to your customer service requests and support needs more efficiently.
• We may use the information you provide, in aggregated form, to gain a better understanding of how all visitors, as a group, interact with the services and resources offered on the Website.
• We may use the email address to send user information and updates about your order. It may also be used to respond to your inquiries, questions, and/or other requests. If the user decides to opt-in to our mailing list, they will receive emails that may include news, updates, related product or service information, etc.
• We do not sell your Personal Data. We may however share your Personal Data with non-affiliated service providers, futures exchanges, government agencies, courts, and other third parties only under the following specific circumstances, provided that such third parties are required to handle your information in compliance with all applicable privacy and data protection laws and to maintain confidentiality and security of the shared information:
  • To review your account application and provide you with access to our services;
  • To effect, complete, administer and enforce any transactions, you may perform through or with us, including the processing of orders and emailing statements;
  • As required by law or court order;
  • To perform reviews and audits of internal procedures;
• We may also share your Personal Data to achieve the following:
  • To operate, research and improve our services and websites;
  • To launch new services;
  • To display customized content and advertisements.

We are committed to transparent data collection and processing practices. The information collected is used for specified purposes outlined in this Privacy Notice, and you are notified of any changes from time to time.

We process personal data based on legal grounds such as consent, legal obligations, and contract. You can review the legal basis for processing the data. We also provide you with the option to opt out as provided under Section 8 of this Privacy Notice.

6. Cross-Border Data Transfer

We may transfer your Personal Data outside of the UAE in accordance with the provisions set forth in Federal Decree-Law No. 45/2021 on the Protection of Personal Data.

• Transfer with adequate protection: Personal Data may be transferred outside the state if:
  • Te receiving country or territory has legislation specifically addressing the protection of personal data, ensuring privacy, confidentiality, and the ability of data subjects to exercise their rights.
  • Additionally, transfers may occur if bilateral or multilateral agreements related to personal data protection exist between the state and the recipient countries.
• Transfer without adequate protection: Subject to the exceptions outlined above, Personal data may be transferred outside the State in the following circumstances:
  • Contracts or agreements require entities in recipient countries lacking data protection laws to adhere to provisions ensuring data protection, overseen by competent authorities.
  • Transfer is based on the explicit consent of the data subject, provided it does not conflict with the security or public interest of the State.
  • Transfer is necessary to fulfil legal obligations or establish, exercise, or defend legal rights.
  • Transfer is necessary for the performance of a contract between the data controller and the data subject, or between the data controller and a third party, for the benefit of the data subject.
  • Transfer is required for international judicial cooperation procedures.
  • Transfer is necessary to protect the public interest.

7. Data Protection and Security

We adopt appropriate data collection, storage, and processing practices and security measures to protect against unauthorized access, alteration, disclosure, or destruction of your Personal Data, username, password, transaction information, and data stored on the Website.

We do not sell or trade your Personal Data to others. We may share generic aggregated demographic information not linked to any Personal Data regarding visitors and you with our business partners, trusted affiliates, and advertisers for the purposes outlined in this Notice.

8. Opting Out

If you wish to opt out of receiving our promotional and marketing emails, please click on the unsubscribe link given in our correspondence. You will then be removed from our mailing distribution lists. It is important to acknowledge that notwithstanding this opt-out, you may still receive non-marketing communications, including but not limited to service-related updates, account administration notifications, and responses to service requests

9. Individual Rights

You have certain rights under the Law which include:

• The Right to know how we use your Personal Data;
• The Right to Access your Personal Data;
• The Right to Object to the processing of your personal data.
• The Right to rectify your Personal Data;
• The Right to restrict or stop processing of Personal Data;
• The Right to Complain to the UAE Office.

We will comply with our obligations and help you exercise your rights. However, some information may still be registered on our database for the purposes of prevention of fraud, investigations problem resolution etc. We do not store your Personal Data on our Website. Visitor data is securely stored on the Amazon Web Services (AWS) server database where the Website is hosted. AWS is a globally recognized cloud service provider known for its robust security standards and compliance with international data protection regulations. The data is encrypted and protected using advanced security protocols to ensure its confidentiality and integrity. You retain the right to raise a request to us for the deletion of your Personal Data provided to us. It is important to note that once you raise a request for deletion of Your Personal Data and upon successful deletion of Your Personal Data from the AWS server hosting the Website, you thereby cease to utilise the services and facilities provided on the Website to you. Please note that while we will honour your request for data deletion, some information may still be retained to comply with legal obligations or for other legitimate purposes, as permitted by law.

10. Minors

We explicitly declare that we do not engage in the collection of any form of information, in any jurisdiction, from children/minors or individuals below the age of legal maturity as stipulated by their respective legislation. By using our Website, you certify that you are aged 18 or over, or that you are the parent/guardian of a minor utilizing our services with your authorization.

11. Changes to This Privacy Notice

We reserve the right to modify this Privacy Notice from time to time. Substantive changes will be notified to all of you through the registered email and/or Website notifications. If such modifications result in additional methods of collecting or disclosing Personal Data, you may elect to opt out of such amendments by sending an email within 14 days from the publication of the revised Privacy Notice on the Website. The date of the last revision to this Privacy Notice will always be prominently indicated at the beginning of the document. You are responsible for periodically reviewing the Notice to ascertain any alterations. Opting out of this Privacy Notice amendment may, at our sole discretion and with notice, lead to termination of user registration and participation in ongoing or future activities on the Website.

12. Acceptance of This Notice

By using this Website, you understand that we will process the Personal Data highlighted in this Privacy Notice. If you do not agree to this Notice, please do not use our Website. Your continued use of the Website following the posting of changes to this Notice will be deemed your acceptance of those changes.

13. Disclaimer

Strata Global acknowledges that while every effort is made to safeguard the privacy and security of user information, We shall not be held liable for any breach of data resulting from the technological use of third-party services. You are advised to exercise caution and be aware that external factors beyond our control, such as the actions or vulnerabilities of third-party service providers, may impact the security of Personal Data. By using the Website, you agree that we are not responsible for any unauthorized access, disclosure, alteration, or destruction of Personal Data that may occur due to circumstances beyond our reasonable control, including but not limited to actions such as hacking, phishing etc. You are encouraged to review and understand the privacy practices of third-party services and take appropriate measures to protect your information.

14. Contact Us

If you have any questions about this Privacy Notice, the practices of this Website, or your dealings with this Website, please contact us at privacy@www.strata-global.com.

15. Governing Law and Jurisdiction

This Privacy Notice shall be construed and governed by the laws of the Emirate of Dubai, UAE. Any dispute or claims arising out of or in connection with this Privacy Notice shall be settled by the rules and regulations governed by the UAE Data Office.