Privacy Policy

Privacy Policy

SISO HOLDINGS LIMITED

WEBSITE PRIVACY POLICY

Introduction

Welcome to the privacy policy applicable to SISO HOLDINGS LIMITED and its subsidiaries (the “SISO Group”).

The SISO Group values your privacy and is dedicated to safeguarding your personal data. This privacy policy aims to provide you with information on how we handle and protect your personal data when you interact with us, including by visiting our website or our online software product (together, the “SISO Platform”), regardless of your location. This policy also outlines your privacy rights and the legal protections available to you.

Please refer to the Glossary section for definition of certain terms used throughout this privacy policy.

1. Important information and who we are

Purpose of this Privacy Policy

This privacy policy aims to give you information on how the SISO Group collects and processes your personal data through your use of the SISO Platform, including any personal data you may provide through your usage of the SISO platform, or when you register as a user on the SISO Platform, or when you subscribe to any part of the SISO Platform.

The SISO Platform is not intended for use by children, and we do not knowingly collect personal data from children under age 16.

It is important that you read this privacy policy in conjunction with any other privacy policy or fair processing policy we may provide on specific occasions when we collect or process your personal data. This will ensure that you have a complete understanding of how and why we use your personal data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Controller

This privacy policy is issued on behalf of all companies in the SISO Group from time to time so when we mention SISO HOLDINGS LIMITED, we, us or our in this privacy policy, we are referring to the relevant company in the SISO Group responsible for processing your data. SISO HOLDINGS LIMITED acts as the controller and is responsible for the SISO Platform.

We have appointed a data privacy manager who is responsible for overseeing inquiries related to this privacy policy. If you have any questions regarding this privacy policy, including questions about exercising your legal rights, please contact our data protection officer using the contact details set out below.

Contact details

If you have any questions about this privacy policy or our privacy practices, please feel free to reach out using the following contact information:

Full name of legal entity:	SISO HOLDINGS LIMITED
Email address:	info@sisotechnologies.com
Postal address:	DD-15-134-004-007, Level 15, Wework Hub71, Al Khatem Tower, Abu Dhabi Global Market Square, Al Maryah Island, Abu Dhabi, United Arab Emirates.
Data Protection Officer	Luke Kyleman (CTO), cto@sisotechnologies.com

If you are concerned about our handling of your personal data, you have the right to lodge a complaint with a privacy supervisory authority. In the European Economic Area, the relevant supervisory authority is determined based on the country or territory where:

you reside;
you work; or
the alleged infringement occurred.

A list of National Data Protection Authorities in the European Economic Area can be found here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm; and for the UK here: https://ico.org.uk/for-organisations/data-protection-and-the-eu; and for the Abu Dhabi Global Market, here: https://www.adgm.com/operating-in-adgm/office-of-data-protection/overview.

However, we kindly request that you provide us with the opportunity to address your concerns before approaching the relevant privacy supervisory authority. Please contact us initially, and we will make every effort to resolve the matter.

Changes to the Privacy Policy and your duty to inform us of changes

We regularly review and update our privacy policy. This version was last reviewed and updated on 21 March 2024.

It is important that the personal data we hold about you is accurate and up to date. Please inform us promptly of any changes to your personal data during your relationship with us.

Third-Party links

The SISO Platform may include links to third party websites, documents, reports, plug-ins and applications (“Third Party Platforms”). Clicking on those links or enabling those connections may allow third parties to collect or share data about you. The inclusion of such links and connections does not imply our endorsement of any Third Party Platform. We do not have control over these Third Party Platforms and cannot be held responsible for their privacy, information, or other practices. When you leave the SISO Platform, we recommend that you carefully review the privacy policy of all such Third Party Platform(s) you visit.

2. The personal data we collect about you

Personal data, also referred to as personal information, means any information about an individual that can be used to directly or indirectly identify that person. It does not include data where the identity has been removed, rendering it anonymous.

We may collect, use, store and transfer various types of personal data about you which we have categorized as follows:

Identity Data includes your first name, maiden name, last name, username or similar identifier, and title;
Contact Data includes your organization name, billing address, delivery address, email address, and telephone numbers;
Financial Data includes bank account and payment card details;
Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us;
Technical Data includes your internet protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technologies on the devices you use to access the SISO Platform;
Profile Data includes your username and password, purchases or orders made by you, preferences, feedback, profile photo, and survey responses;
Usage Data includes information about how you use the SISO Platform, and any other related services; and
Marketing and Communications Data includes your preferences regarding receiving marketing materials from us and our third parties, as well as your communication preferences.

We also collect, use and share Aggregated Data, which refers to statistical or demographic information that has been anonymized and grouped together. Aggregated Data could be derived from your personal data but does not qualify as personal data under the law, as it does not directly or indirectly reveal your identity. For example, we may aggregate Usage Data to calculate the percentage of users accessing a specific feature on the SISO Platform.

However, if the Aggregated Data is combined or connected with your personal data in a manner that enables direct or indirect identification, we treat the combined data as personal data. In such cases, the handling of the combined data will comply with the provisions outlined in this privacy policy.

If you disclose any personal data relating to other people to us or to our service providers in connection with our services, you represent that you have the authority to do so and to permit us to use the information in accordance with this privacy policy.

We do not intend to collect, and we ask that you not send us, any Special or Sensitive Categories of Personal Data, such as information related to race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, or genetic and biometric data. Nor do we collect any information about criminal convictions and offences.

If you fail to provide Personal Data

In cases where collection of personal data is required by law or under the terms of a contract we have with you, and you fail to provide that data when requested, it may hinder our ability to fulfil the contract we have or are attempting to enter into with you. In this case, we may have to cancel a product or service you have with us, but we will notify you if this becomes necessary at the time.

3. How is your personal data collected?

We use various methods to collect personal data from and about you, which include:

Direct interactions. You may give us your personal data by filling in forms or by corresponding with us by post, phone, email or other means. This includes personal data you provide when you, for example:
1. apply for our products or services;
2. create an account on the SISO Platform;
3. accept an invitation to join a project on the SISO Platform;
4. subscribe to our services or publications;
5. request marketing materials to be sent to you;
6. participate in promotions or surveys; or
7. provide feedback or contact us.
Automated technologies or interactions. As you interact with the SISO Platform, we automatically collect Technical Data about your devices, browsing actions and patterns. We collect this personal data by using cookies, server logs and similar technologies. We may also receive Technical Data about you if you visit Third Party Platforms that use our cookies. For more information, please refer to our Cookies & Similar Technologies Policy available at www.sisotechnologies.com.
Third parties or publicly available sources. We receive personal data about you from various third parties and public sources, as set out below.
Technical Data from the following parties:
1. analytics and other online services providers such as Google, based outside the EU;
2. advertising networks, based inside and outside the EU;
3. professional public networking platforms, such as LinkedIn; and
4. search information providers, based inside and outside the EU.
Contact, Financial and Transaction Data from providers of technical, payment and delivery services based inside and outside the EU.
1. Identity and Contact Data from data brokers or aggregators, both inside and outside the EU.
2. Identity and Contact Data from publicly available sources such as the Companies House and the Electoral Register, based inside the EU.
APIs. The SISO Platform may utilize Application Programming Interfaces (APIs) to integrate with other applications or services. Through APIs, the platform can automatically collect data from connected systems, such as social media platforms, cloud storage services, or third-party data providers. This data may include user profile information, preferences, or other relevant data.

4. How we use your Personal Data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data where:

we need to perform the contract we are about to enter into or have entered into with you;
it is necessary for our Legitimate Interests (or those of a third party) and your interests and fundamental rights do not override those interests; or
we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data, although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your Personal Data

We have set out below, in a table format, a description of all the ways we plan to use your personal data and which of the legal bases we rely on to do so. We have also identified what our Legitimate Interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity	Type of data	Lawful basis for processing including basis of Legitimate Interest
To register you as a new customer	Identity Contact	Performance of a contract with you
To process and deliver your order including: 1. Manage payments, fees and charges 2. Collect and recover money owed to us 3. Respond to inquiries and fulfill requests	Identity Contact Financial Transaction Marketing and Communications	Performance of a contract with you Necessary for our Legitimate Interests (to recover debts due to us)
To manage our relationship with you which will include: 1. Notifying you about changes to our terms or privacy policy 2. Asking you to leave a review or take a survey	Identity Contact Profile Marketing and Communications	Performance of a contract with you Necessary to comply with a legal obligation Necessary for our Legitimate Interests (to keep our records updated and to study how customers use our products/services)
To enable you to participate in a prize draw, competition or complete a survey	Identity Contact Profile Usage Marketing and Communications	Performance of a contract with you Necessary for our Legitimate Interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	Identity Contact Technical	Necessary for our Legitimate Interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	Identity Contact Profile Usage Marketing and Communications Technical	Necessary for our Legitimate Interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	Technical Usage	Necessary for our Legitimate Interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you	Identity Contact Technical Usage Profile Marketing and Communications	Necessary for our Legitimate Interests (to develop our products/services and grow our business)
To aggregate and/or anonymize personal data.	Identity Contact Technical Usage Profile Marketing and Communications	Legitimate interests (to generate other data for our use, which we may use and disclose for any purpose, as it no longer identifies you or any other individual)
To accomplish our business purposes: for audits, to verify that our internal processes function as intended and to address legal, regulatory, or contractual requirements.	Identity Contact Technical Usage Profile Marketing and Communications Financial Transaction	Necessary for our Legitimate Interests (for running our business or responding to complaints and concerns) Necessary to comply with a legal obligation

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to understand your preferences and provide you with relevant products, services and offers (referred to as “marketing”).

You may receive marketing communications from us if you have requested information from us or purchased products or services from us, and you have not opted out of receiving such marketing.

Opting out

You can ask us to stop sending you marketing messages at any time by contacting us at our “Contact details” above or using the opt-out method provided in each marketing message.

Please note that if you opt out of receiving marketing-related emails from us, we may still send you important administrative messages, from which you cannot opt out.

Third-party advertising

We use third-party advertising companies to serve advertisements regarding goods and services that may be of interest to you when you access and use the SISO Platform and other websites or online services. You may receive advertisements based on information relating to your access to and use of the SISO Platform and other websites or online services on any of your devices, as well as on information received from third parties. These companies place or recognize a unique cookie on your browser (including through the use of pixel tags). They also use these technologies, along with information they collect about your online use, to recognize you across the devices you use, such as a mobile phone and a laptop.

If you would like more information about this practice, and to learn how to opt out of it in desktop and mobile browsers on the particular device on which you are accessing this privacy policy, please visit http://optout.aboutads.info/#/ and http://optout.networkadvertising.org/#/. You may download the AppChoices app at www.aboutads.info/appchoices to opt out in mobile apps.

Cookies

A cookie is a small text file which is placed onto your device when you access the SISO Platform. Cookies and similar tracking technologies allow us to collect information such as browser type, time spent on our platform, pages visited, language preferences, and other traffic data. We and our service providers use the information for security purposes, to facilitate navigation, to display information more effectively, and to personalize your experience. We also gather statistical information about use of our services in order to continually improve their design and functionality, understand how they are used, and assist us with resolving questions regarding them. Cookies further allow us to select which of our advertisements or offers are most likely to appeal to you and display them while you are on the Services. We may also use cookies or other technologies in online advertising to track responses to our ads. We do not currently respond to browser do-not-track signals. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. You may also wish to refer to http://www.allaboutcookies.org/manage-cookies/index.html. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or may not function properly. You also may not receive advertising or other offers from us that are relevant to your interests and needs. For more information about the cookies we use, please see our Cookies & Similar Technologies Policy available at www.sisotechnologies.com.

Pixel tags

Pixel tags. Pixel tags (also known as web beacons and clear GIFs) may be used to, among other things, track the actions of users of the SISO Platform (including email recipients), measure the success of our marketing campaigns, and compile statistics about usage of the SISO Platform and response rates.

Analytics

We use Google Analytics, which uses cookies and similar technologies to collect and analyze information about use of the SISO Platform and report on activities and trends. This service may also collect information regarding the use of other websites, apps and online resources. You can learn about Google’s practices by going to www.google.com/policies/privacy/partners/, and exercise the opt-out provided by Google by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.

Invisible reCAPTCHA

We use Google’s invisible reCAPTCHA application on the SISO Platform in order to protect against spam and other automated abuse. The reCAPTCHA tool may make use of cookies, as well as other information like IP address, date, time, language, screen size and resolution, and mouse movements, while on the page. The use of the reCAPTCHA service and the treatment of any information collected through the service are subject to Google’s applicable privacy policy, available at https://policies.google.com/privacy, and Google’s terms of service, available at https://policies.google.com/terms?hl=en.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the applicable laws and regulations.

5. Disclosures of your Personal Data

We may share your personal data with the parties set out below for the purposes set out in the table above in the Purposes for which we will use your Personal Data section above. We disclose personal data:

to our affiliates: companies within the SISO Group;
to external third parties: service providers and professional advisors working with the SISO Group;
to third parties in connection with any proposed or actual reorganization, bankruptcy, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our assets;
to any other third party if we have a legal obligation to disclose or share your personal data, or to protect the rights, property and or safety of the SISO Group, our personnel or others; and
to any other third party (i) when required to comply with the requirements of a court, regulator, government agency or other government authority, for example complying with a search warrant or court order or acting in accordance with applicable laws or regulation, (ii) to cooperate with law enforcement, and for other legal reasons, and (iii) to enforce our terms and conditions.

6. International Transfers

Your personal data may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the SISO Platform you understand that your personal data will be transferred to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your personal data.

7. Data Security

We have put in place appropriate security measures designed to protect your personal data within our organization.

Unfortunately, no transmission of data over the internet can be guaranteed to be completely secure. It may be possible for unauthorised third parties, to intercept or access transmissions or private communications unlawfully. While we strive to protect your personal data, we cannot guarantee the security of any personal data you transmit to us. Any such transmission is done at your own risk. If you believe that your interaction with us is no longer secure, please contact us immediately.

8. Data Retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for a certain period after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see Your Legal Rights at section 9 below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Whilst we continue to process your personal data, we will ensure that it is treated in accordance with this privacy policy. Otherwise, we securely erase your information once it is no longer needed.

9. Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. The various rights are not absolute and each is subject to certain exceptions or qualifications. We will grant your request only to the extent that it follows from our assessment of your request that we are allowed and required to do so under data protection laws. Nothing in this privacy policy is intended to provide you with rights beyond or in addition to your rights as a data subject under data protection laws. You have the right to:

request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it;
request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us;
request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request;
object to processing of your personal data where we are relying on a Legitimate Interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms;
request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
1. where you want us to establish the data’s accuracy;
2. where our use of the data is unlawful but you do not want us to erase it;
3. where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
4. you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it;
request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you; and
withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us. We will respond to your request in accordance with applicable law.

No fee usually required

You will not ordinarily have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. Glossary

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our Legitimate Interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our Legitimate Interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.