PRIVACY POLICY
This Privacy Policy applies to the website of Obsequ.io Technologies Limited, that is https://www.obsequ.io and shall be read in conjunction with the Terms of Use and Disclaimer and together constitutes a legally binding agreement between the Platform and yourself when you use the Platform.
DEFINITIONS
The following definitions apply to the Privacy Policy, in addition to the definitions already specified in the Terms of Use:
Additional Services Package means the additional Services offered by Company which are not included in the Subscription Plan;
AML means Anti-Money Laundering;
Account means a unique user account created on the Platform belonging to an entity that successfully completes the registration process as specified in these Terms of Use for the purposes of obtaining Services;
CIAM means customer identity and access management;
Client is an Account holder that has purchased Subscription Plans;
Company means Obsequ.io Technologies Limited;
Compliance Check means the verification process taken by Client to verify End Users;
Cookies means a small data file of letters and numbers that we store on your browser or device, in accordance with our Privacy Policy, if you use the Platform;
Credits means the credits purchased by Client on the Platform to access Additional Package Services;
EKYC means Electronic-Know Your Customer or a due diligence process to understand the identity of an End User;
End User means the individual or entity who use the Services as requested by the Client to fulfil their internal business needs;
Personal Data means personal information or personally identifiable information of Client on the Platform;
Platform means the online website of Obsequ.io with the URL https://obsequ.io that is managed and handled in entirety by the Company;
Privacy Policy means the Privacy Policy of the Platform that shall be read in conjunction with these Terms of Use and Disclaimer;
Renewal Term means the duration of Subscription Plan that have been automatically renewed by us in accordance with these Terms of Use, commencing on day one of such renewal until termination of the Subscription Plans by the Client or us;
Service Provider means Company authorised third-party that provides us the licence to offer access to the Software and Services;
Services the services offered on the Platform to the Client such as providing a custom onboarding subdomain, digital signature, AML procedure, CIAM and EKYC;
Software means our software, including all modifications, additions and further enhancements, in each case, which are provided by the Company and obtained directly or via a service provider or third-party;
Subscription Fees means the sum payable by Client to secure the Subscription Plans;
Subscription Plans means the subscription of the Client on the Platform to avail Services;
Subscription Term means the duration of a Subscription Plans prior to its renewal, commencing on the first day of Subscription Plan until its date of expiry or date of termination by the Client or us, whichever is sooner;
Terms of Use means this document that contains the terms and conditions that govern your use of the Platform;
Third-party Sites means any third-party website or technology platform or applicable and has meaning as defined in the Privacy Policy;
Trademarks the trademarks, logos, taglines, and service marks displayed on the Platform;
UAE means United Arab Emirates;
Us/ Our/ We refers to the Platform domiciled in the UAE and its affiliates, subsidiaries and related entities;
Visitor means any individual or business entity visiting, using or accessing the Platform who does not have an Account on the Platform; and
You/ Your/ (or a similar reference) refers to you as a Visitor or Client, irrespective of your relationship with us.
SCOPE OF POLICY
Please be aware this Privacy Policy applies only to this Platform.
This Privacy Policy sets out and explains our policies and practices relating to:
a. use of the Platform,
b. collection of information,
c. what we do with the information we collect,
d. protection of personal information,
e. opting out,
f. data processing,
g. data security,
h. data security incidents,
i. Third-party Sites,
j. changes to the Privacy Policy,
k. children and minors use of the Platform, and
l. comments and feedback.
USE OF THE PLATFORM
Before using the Platform and particularly before submitting personally identifiable information via this Platform, you should read this entire Privacy Policy. Your continued use of this Platform constitutes your full agreement to this Privacy Policy together with the Terms of Use. If the Privacy Policy is not acceptable to you, please do not submit any personally identifiable information via this Platform and immediately cease accessing or using the Platform.
You are permitted to make downloads on the Platform however you are responsible to hold and maintain adequate privacy policies and practices as legally applicable to you and any use or dissemination of Personal Data collected or downloaded through the Platform is at your sole risk and liability.
COLLECTION OF INFORMATION
The Platform collects information in two (2) ways: actively and passively. We may collect information including personally identifiable information such as, your full name, email address, address, phone number or any other personally identifiable details and non-personally identifiable information (e.g. aggregate statistics about what parts of the Platform are most popular).
Active information collection can include both personally identifiable information (e.g., your full name, email address or similar information that is unique to you) and non-personally identifiable information (e.g., if we were to ask for your first name and a list of the top three things you like about our Platform).
You shall ensure that all personally identifiable information disclosed to the Platform is honest, true and accurate at all times. In the event that any personally identifiable information submitted by you has experienced a variation, amendment or change, you shall immediately update your information. If this is a material change including but not limited to change in license activity, or change in name or change of control, you understand and agree we will need to undertake compliance checks on you all over again to which you hereby agree to. A breach or refusal hereunder shall be deemed as a material breach of the Terms of Use and this Privacy Policy.
Active information is collected from a user at the following touchpoints and stored in our processor as per the terms of this Privacy Policy:
a. Registration – We may ask you to submit the following personally identifiable information in your registration form to create an Account:
(i) your legal name,
(ii) your phone number,
(iii) your email address,
(iv) create a password
You may ask the Platform to ‘save your password’ for future use.
b. Subscription Plans:
subscription – You will be required to pay the Subscription Fee to secure your Subscription Plan. For this purpose, we may ask you to submit:
(i) your email address,
(ii) your card information (information not saved with us),
(iii) the name on the card, and
(iv) your country or region.
Except for payment information, you may ask the Platform to save your information for future use.
document validation – You will be required to pay the Subscription Fee to secure your document validation. For this purpose, we may ask you to submit:
(v) your email address,
(vi) your card information,
(vii) the name on the card, and
(viii) your country or region.
Except for payment information, you may ask the Platform to save your information for future use.
continuous monitoring – You will be required to pay the Subscription Fee to secure continuous monitoring. For this purpose, we may ask you to submit:
(ix) your email address,
(x) your card information,
(xi) the name on the card, and
(xii) your country or region.
Except for payment information, you may ask the Platform to save your information for future use.
You shall be required to upload a standing payment instruction with your bank to allow deduction of monthly Subscription Fees, as applicable for your Subscription Plans. For clarification, we do not store any financial information and this is usually stored by the payment gateway and is subject to their terms and conditions. We use Stripe as our payment gateway provider and you are advised to read their terms if you so wish to.
We shall have access to the Personal Data of End Users only for the purposes of storage and security on the Platform, however we will not use such Personal Data in any manner for our personal use.
c. Email and communications: we may collect any messages, emails, or any other form of communication used to engage with you.
d. Newsletter – you may subscribe to our newsletter only as a Registered User.
e. Contact us – When you write to us on hello@obsequ.io, your full name and personal message will be shared with us through your email account.
In all such cases, you grant the Platform permission to send you regular emails, until such time you expressly request to unsubscribe from the email chain or terminate your Account, and this request shall not be denied by the us.
Passive information collection refers to instances in which we collect information from you that you have not actively provided. We may use special technologies to passively collect non-personally identifiable information from users. These technologies allow us to collect certain kinds of non-personally identifiable information, including but not limited to the type of web browser you use, internet protocol (IP) address, time zone, the date and time of your visit, the operating system you use, the specific pages you visit, the address of the website you visited prior to entering the Platform and the cookies that are installed on your device. Additionally, as you browse the Platform, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Platform, and information about how you interact with the Platform.
We do not link this passively collected information with personally identifiable information you have actively provided elsewhere on this Platform. We reserve the right to share with third-parties, including our licensors, the anonymous (non-personally identifiable) aggregated information that we have passively collected via this Platform.
We collect information identified above, using the following technologies:
a. Cookies: These are data files that are placed on your browsing device (computer, laptop, smartphone or tablet) and often include an anonymous unique identifier. Cookies help us recognise you and your device and store some information about your preferences or past actions. We will ask for your permission to place Cookies or other similar technologies on your browsing device, except where they are essential for us to provide you with a service that you have requested. You can disable Cookies or manage the Cookies you use on your browsing device at any time. The Cookies we use will only be accessed by us and shall not be accessed by any third-party.
b. Google Analytics that is a web-based analytics service offered by Google that tracks and reports website traffic and allows to analyse in-depth detail about the users on our Platform. We may be required to share certain information We collect on the Platform with Google which will be subject to Google’s policies as follows: https://support.google.com/analytics/answer/6004245.
c. Device and browser identifiers: any identifier we use to identify your device such as your internet protocol address or an assigned user identity document.
d. Coarse location tracking: an approximate of your device location.
e. Your browser and search history: any name searches made on the Platform.
f. Platform log and usage data: services and pages you interacted with the most, information related to our pages or your browser type.
g. NFC data: when you scan your face for liveness and identity verification.
WHAT DO WE DO WITH THE INFORMATION WE COLLECT
The information we collect from you will only be used to:
a. provide you with a better functionality and experience on the Platform;
b. create and manage your Account on the Platform;
c. provide you access to features and Services on the Platform;
d. enforce our policies effectively;
e. ensure quality and effective communication to provide effective customer support and service;
f. prevent fraud, illegal activity, detect security incidents and improve reliability of Platform;
g. to provide you with information, features of the Services;
h. to notify you about the changes to our Platform or the Services;
i. for testing, research, analysis and service development;
j. to protect the rights, property or safety of us, our Customers or others;
k. to respond to law enforcement requests and as required by applicable law, court order or governmental regulations; and
l. remember information so you will not have to re-enter it during your visits.
To clarify further, your personal data or your personally identifiable information will not be shared with any third-party private entity nor used for any advertisement purposes. In the event we are requested or instructed by a governmental authority to make disclosures under the applicable laws, we will do so without any prior notice to you.
We may use a function to automatically remember the information you use on the Platform for the following reasons:
a. remember information so you will not have to re-enter it during your visit;
b. provide custom content and information; and
c. determine the effectiveness of the Platform.
International data transfers
Company is located in the UAE and operates on the basis of their laws on data protection. If you are not located in the UAE you acknowledge and understand your data might be processed with different applicable laws and protections than the country you are in. Any transfers of information are for our use and the use of our service providers in accordance with these terms, however we engage with high standards of security and privacy laws compliant with applicable laws.
PROTECTION OF PERSONAL INFORMATION
We reserve the right to use, store or disclose personal information received via the Platform as necessary to respond to your requests, help and facilitate your purchases on the Platform, comply with applicable laws, regulations, legal processes, and law enforcement inquiries (as required or applicable) to take precautions against liability, and protect the security and integrity of the Platform and you. We will not sell, lease, transfer, share, or otherwise permit access to your personally identifiable information with any third-parties other than as described in this Privacy Policy.
Any personally identifiable information we collected from you and retained can be requested to be deleted, provided that you meet certain exceptions. As soon as we receive and confirm your verifiable consumer request, we will delete your personally identifiable information (and direct our service providers to do so), unless an exception applies.
You may be denied deletion if retaining the information is necessary for us or our licensors to:
a. perform the contract we have with you and complete the transaction for which the personally identifiable information was collected;
b. detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities; and
c. debug Services to identify and repair errors that impair existing intended functionality.
DATA RETENTION
Your Personal Data is retained with us only to fulfil the necessary objectives for which it was collected for, unless we specifically agree a longer retention period with you, or a longer retention period is required or permitted by law. This also includes any legal, accounting, auditing or reporting obligations under applicable law.
OPTING OUT
You can opt out of sharing information by requesting deletion of your account by emailing us at hello@obsequ.io
To respond to your request or inquiry, we may require follow-up or contact information to allow us to verify that you are the person authorised to view the information you are requesting. We may, at our discretion, refuse to allow you access to certain information if, in our view, to provide such access would jeopardise another person’s privacy; would violate any applicable federal, state, or foreign law, regulation, or directive; or would unreasonably burden this Platform.
You can opt out sharing information as follows:
a. Targeted advertising by following these links:
- Facebook: https://www.facebook.com/settings/?tab=ads
- Instagram: https://help.instagram.com/615366948510230
- Google: https://www.google.com/settings/ads/anonymous
- Twitter: https://help.twitter.com/en/safety-and-security/privacy-controls-for-tailored-ads
- LinkedIn: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out
- Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/
b. Revoke access to email and social network accounts:
Upon request, we may be able to provide you with information about whether we hold any of your Personal Data by emailing us at hello@obsequ.io.You may choose to disconnect your Account or unsubscribe from our Platform through your account settings. If you no longer have access to your browsing device, you may also contact your email account provider to revoke our access to your account or contact us at hello@obsequ.io. We will respond to your request within a reasonable timeframe.
c. By emailing us:
When you submit information via this Platform, whether such information is required or optional, you consent to its disclosure and use in accordance with this Privacy Policy. If you ever decide that you do not wish to receive information from us regarding the Platform you may inform us by email at hello@obsequ.io. Please remember opting out of this option may affect your communication with us.
To respond to your request or inquiry, we may require follow-up or contact information to allow us to verify that you are the person authorised to view the information you are requesting. We may, at our discretion, refuse to allow you access to certain information if, in our view, to provide such access would jeopardise another person’s privacy; would violate any applicable federal, state, or foreign law, regulation, or directive; or would unreasonably burden this Platform.
d. unsubscribing from marketing communications or mailers:
If you receive marketing communication from us, you can email us at hello@obsequ.io and ask that we remove you from receiving marketing communications, or request to unsubscribe. Please remember that if you opt out of receiving marketing communication only you may continue to receive administrative messages from us regarding your purchases on the Platform or for the purposes of daily correspondence with us, unless you opt out of this option.
e. Cookies:
Most web browsers accept cookies by default. It is your responsibility to alter these settings and decline or remove any cookies by adjusting respective settings.
f. Emails from third-parties:
Third-parties have their own privacy policy rules and opting in shall be at your own discretion.
DATA PROCESSING
Please be informed that our data processor is located in Bahrain however we reserve the right to transfer it to UAE. We shall, at all times, be compliant with all applicable laws and regulations pertaining to data processing, as applied in the location of the processor, as well as, the place of data collection, i.e. UAE. We shall carry out all our data collection and processing activity in good faith at all times. This Privacy Policy contains the permitted purpose of collection and processing of your data. Your data shall not be collected or processed for any other purposes that are excluded from this Privacy Policy.
Your data shall be processed and retained by us for the entire duration of your registration on the Platform, and for a period of time from the date of termination of your Account, subject to applicable legal requirements. We reserve the right to retain your data following termination of this extended period for compliance purposes and if such retention is required by us by law. We reserve the right to retain your data indefinitely, in the event your use of the Platform has been permanently prohibited by us, and such retention shall be for the sole purpose to prohibit your future access to the Platform. We have taken reasonable and necessary steps to ensure that your personally identifiable information is safely and securely stored with us.
We urge you to thoroughly understand the terms herein and be aware that this Privacy Policy shall be updated from time to time.
We collect, use and are responsible for the Personal Data provided by you. If you are located in the European Economic Area (EEA), you have certain rights in respect of your Personal Data and can exercise them as follows:
a. Right to data portability: users located within the EEA may contact us regarding their Personal Data using the contact information below. Please note that we may request additional information from you to verify your identity before we disclose any Personal Data or Account information.
b. Right to restrict or oppose: where we rely on legitimate interests to process your Personal Data, you have the right to object to such processing by using the contact information below. Please note that some processing is essential to providing services on the Platform.
c. Right to access, correct and rectify: you may access, correct and rectify their Personal Data through your account settings on the Platform.
d. Right to delete: you may request deletion of any of your information collected and stored by us please contact us by email at hello@obsequ.io.
e. Right to opt-out/automated decision making: you may opt-out of sharing your information and profiling furtherance of decisions that produce legal or similar effects concerning you.
f. Right to revoke consent: for the purposes of European Union data protection legislation, we are the “data controller” of your Personal Data. You can contact us directly regarding the processing of your Personal Data by email at hello@obsequ.io.
g. Right to lodge a complaint: you may lodge a complaint regarding your concern with the respective authority.
Google user data
There are certain limits on use of your ‘Google user data’. Notwithstanding anything else in this Privacy Policy, consumer Google account information obtained via the Gmail Application Programming Interfaces, is subject to these additional restrictions:
a. The Platform shall not use such Gmail data for serving advertisements;
b. The Platform shall not allow humans to read this data unless we have your affirmative agreement for specific messages, doing so is necessary for security purposes such as investigating abuse, to comply with applicable law, or for the Platform’s internal operations and even then only when the data have been aggregated and de-identified.
Where you have consented to data processing, your consent provides the legal basis to process your personal information, such as when you consent to processing in relation to the processing of your data purposes of data analysis in accordance with this Privacy Policy. You have the right to withdraw consent at any time. Please note that your withdrawal of consent to collect and process your personal information will not affect the lawfulness of processing your personal information based on your consent before you withdraw your consent.
We may process your personal information on the basis of contractual necessity to perform a contract we have with you or complete your subscription and offer you Services. We may also process your personal information on the basis of our legitimate interests, including analytic reporting and improving the functionality of the Platform.
DATA SECURITY
Although we take reasonable steps to protect the personally identifiable information that you provide via this Platform, no system is 100% secure or error-free and neither is the Platform. It is your responsibility to keep your passwords secure. We strongly recommend that you do not share your passwords with any third-party nor store or save them in a manner that may be easily accessed by a third-party. We take the protection of your information very seriously and employ measures through administrative, technical, and physical safeguards designed to protect information against loss, theft, misuse, unauthorised access, disclosure, alteration, and destruction. We encrypt all data in transit through secure socket layer technology (SSL), and other security protocols, including hardware firewalls that are set up on the hosting side. We take reasonable precautions to ensure the integrity and security of our network and systems but cannot guarantee these security measures will prevent third-parties from obtaining information by illegal actions or attacks.
DATA SECURITY INCIDENTS
Company shall notify you via email of any major or notable security incidents relating to breach of Personal Data belonging to the you. Such notification shall be issued promptly upon Company being aware of such incident occurrence and shall be summarised with respect to its effect on you. Company shall provide you with instructions with the corrective measures that must be immediately followed. Failure to comply with such instructions shall be at your own responsibility and we reserve the right to restrict your Account for failure to comply. Any security breach not caused directly by our act or omission shall not amount to any fault or liability of Company. Similarly, Company is not responsible to you in instances where a report or response has or has not been issued, for reasons determined by Company.
THIRD-PARTY SITES
The Platform may include advertisements or banners or options with external links on to Third-party Sites that are not covered by this Privacy Policy and are likely to have different information practices (“Third-party Sites”). We encourage you to read the privacy policy of all Third-party Sites you visit or use. The third-party references and links that we provide are for your convenience only, to make your browsing experience better on the Platform; this should not be construed as an endorsement or recommendation of Third-party Sites in any manner. You are solely responsible for any interactions you may have with any Third-party Sites.
Once you click or access these Third-party Sites, you will leave the Platform. We do not investigate, review, endorse, represent or control the content of any Third-party Sites, unless otherwise expressly stated in the Privacy Policy. We are not responsible or accountable for the content displayed on Third-party Sites. You will access and use these Third-party Sites at your sole risk and liability. You also agree not to link any other site or Third-party Sites to the Platform without our express prior written consent and approval.
The Third-party Sites may select and deliver (separate and unrelated to this Platform) ad networks, advertising agencies, advertisers and audience segment providers. These Third-party Sites may collect information about you and your online activities, either on the Platform or on other websites, through Cookies, web beacons, and other technologies in an effort to understand your interests and deliver to your advertisements that are tailored to your interests. We do not have access to, or control over, the information that Third-party Sites may collect. The information practices of these third-parties or Third-party Sites are not covered in these Terms of Use or Privacy Policy.
CHANGES TO THIS PRIVACY POLICY
We reserve the right to change this Privacy Policy at any time, at our sole discretion without prior notice. If we do change the Privacy Policy, the new Privacy Policy will be posted here, along with its revision date, and all information collected following the posting of such changes will be subject to the new Privacy Policy. Prior to use or disclosure of your previously collected personally identifiable information in a materially different manner from that to which you agreed, we will first secure your affirmative consent for such use or disclosure. If such consent is not provided, we will use your personally identifiable information in accordance with the Privacy Policy in effect at the time we collected the information.
We encourage you to check this Privacy Policy periodically and prior to each instance in which you provide personally identifiable information through this Platform or use this Platform.
THIS PLATFORM IS NOT INTENDED FOR USE BY CHILDREN OR MINORS
This Platform is not directed towards and does not seek to collect personally identifiable information from, children under the age of twenty one (21) years unless they are listed as an End User in legal documentation. If your End User is a minor is any manner, you are responsible to have and maintain adequate privacy policies in place to manage its use, storage and dissemination and we cannot be responsible for related activity outside the Platform.
We do not permit the Platform to be used or accessed by minors. Nevertheless, if a minor access the Platform for any purpose whatsoever and this comes to our knowledge, we reserve the right to immediately block and close any attempts of use on the Platform, to the extent within our control. For the purpose of this Platform, “minor” refers to any individual under the age of twenty one (21) years.
COMMENTS AND FEEDBACK
If you are interested in receiving electronic updates, alerts, and other information from us regarding this Platform, you must provide us with an email address. We may also ask for optional information, such as how you found us, to help us better serve you and other users in the future. We welcome your comments and feedback regarding this Platform and third-party services and functionalities to our email address hello@obsequ.io that permits you to send through your own email address, comments, and any other information you choose to include. Please remember that email is not secure and we cannot provide you with any guarantees in this respect. You should carefully consider what information you wish to send to us through email or through this feedback option.
Last updated in March 2023 ©