enterprise-privacy

CALIMALA LIMITED

ENTERPRISE PRIVACY

Please read the Enterprise Privacy carefully before using the Calimala platform as a business user.

Effective Date: February 1st, 2025

Introduction

Welcome to CALIMALA LIMITED’s enterprise privacy document.

CALIMALA LIMITED respects your privacy and is committed to protecting your personal data. This Privacy Policy describes our practices with respect to Personal Data we collect from or about you when you use our website, applications, and services (collectively, “Services”).

This Privacy Policy does not apply to content that we process on behalf of customers of our offering for individuals. Our use of that data is governed by our customer agreements covering access to and use of those offerings.

1. Data Controller

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

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact our data privacy manager in the following ways:

Full name of legal entity:	CALIMALA LIMITED
Email address:	websupport@calimala.ai
Postal address:	ADGM Square, Al Maryah Island, Abu Dhabi, United Arab Emirates

If you are concerned about our handling of your personal information, you can lodge a complaint with a privacy supervisory authority. In the European Economic Area, the relevant supervisory authority is the one in the country or territory where:

you are resident;
you work; or
the alleged infringement took place.

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.

We would appreciate the chance to deal with your concerns before you approach the relevant privacy supervisory authority, so please contact us in the first instance.

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

We keep our privacy policy under regular review. This version was last reviewed and updated on 11 June 2024.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-Party links

This website may include links to third party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

2. The data we collect about you

We collect personal data relating to you (“Personal Data”) as described below:

Personal Data You Provide: We collect the following Personal Data when you create an account or communicate with us:

Account Information: When you create an account with us, we collect information associated with your account, including your name, contact information, account credentials, and transaction history (collectively, “Account Information”).
User Content: When you use our Services, we collect Personal Data that is included in the input, file uploads, or feedback that you provide to our Services (“Content”).
Communication Information: If you communicate with us, we collect your name, contact information, and the contents of any messages you send (collectively, “Communication Information”).
Social Media Information: We have pages on social media sites like Instagram, Facebook, Medium, X, YouTube and LinkedIn. When you interact with our social media pages, we collect Personal Data that you choose to provide to us, such as your contact details (collectively, “Social Media Information”). In addition, the companies that host our social media pages may provide us with aggregate information and analytics about our social media activity.
Other Information You Provide: We collect other information that you may provide to us, such as when you participate in our events or surveys or provide us with information to establish your age or identity (collectively, “Other Information You Provide”).

Personal Data We Receive Automatically From Your Use of the Services: When you visit, use, or interact with the Services, we receive the following information (“Technical Information”):

Log Data: Information that your browser or device automatically sends when you use our Services. Log data includes your Internet Protocol address, browser type and settings, the date and time of your request, and how you interact with our Services.
Usage Data: We may automatically collect information about your use of the Services, such as the types of content that you view or engage with, the features you use and the actions you take, as well as your time zone, country, the dates and times of access, user agent and version, type of computer or mobile device, and your computer connection.
Device Information: Includes name of the device, operating system, device identifiers, and browser you are using. Information collected may depend on the type of device you use and its settings.
Cookies and Similar Technologies: We use cookies and similar technologies to operate and administer our Services, and improve your experience. For details about our use of cookies, please view our Cookie Policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide Personal Data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

3. How we use your Personal Data

We will only use your personal data when the law allows us to. We may use Personal Data for the following purposes:

to provide and maintain our Services;
to communicate with you, including to send you information or marketing about our Services and events
to prevent fraud, criminal activity, or misuses of our Services, and to protect the security of our systems and Services
To comply with legal obligations and to protect the rights, privacy, safety, or property of our users, us, our affiliates, or any third party

5. Disclosure of Personal Data

In certain circumstances we may disclose your Personal Data to:

Vendors and Service Providers: To assist us in meeting business operations needs and to perform certain services and functions, we may disclose Personal Data to vendors and service providers, including providers of hosting services, customer service vendors, cloud services, content delivery services, data warehouse services, support and safety monitoring services, email communication software, web analytics services, payment and transaction providers, and other information technology services providers. Pursuant to our instructions, these parties will access, process, or store Personal Data only in the course of performing their duties to us;
Business Transfers: If we are involved in strategic transactions, reorganization, bankruptcy, receivership, or transition of service to another provider (collectively, a “Transaction”), your Personal Data and other information may be disclosed in the diligence process with counterparties and others assisting with the Transaction and transferred to a successor or affiliate as part of that Transaction along with other assets.third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy;
Government Authorities or Other Third Parties: We may share your Personal Data, including information about your interaction with our Services, with government authorities, industry peers, or other third parties in compliance with the law (i) if required to do so by law or in the good faith belief that such action is necessary to comply with a legal obligation, (ii) to protect and defend our rights or property, (iii) if we determine, in our sole discretion, that there is a violation of our terms, policies, or the law; (iv) to detect or prevent fraud or other illegal activity; (v) to protect the safety, security, and integrity of our products, employees, or users, or the public, or (vi) to protect against legal liability.any other third party for the purposes of acting in accordance with the requirements of a court, regulator or government agency, for example complying with a search warrant or court order or acting in accordance with an applicable law or regulation.
Affiliates: We may disclose Personal Data to our affiliates, meaning an entity that controls, is controlled by, or is under common control with Calimala Limited. Our affiliates may use the Personal Data we share in a manner consistent with this Privacy Policy.

6. International Transfers

We share your personal data within the CALIMALA LIMITED Group. This may involve transferring your data outside the European Economic Area (EEA).

Our external third parties may be based outside the EEA so their processing of your personal data may involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries;
where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries; or
where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7. Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

Unfortunately, no transmission of data over the internet is guaranteed to be completely secure. It may be possible for unauthorized third parties, to intercept or access transmissions or private communications unlawfully. While we strive to protect your personal data, we cannot ensure or warrant 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.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data Retention

We will only retain your personal data for as long as reasonably necessary to fulfill 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 unauthorized 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 six years after they cease being customers for tax purposes.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years 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 10 below for further information.

9. Legal Basis for Processing

Purpose/Activity	Type of data	Lawful basis for processing including basis of Legitimate Interest
To provide and maintain our Services	a. Account Information b. User Content c. Communication Information d. Other Information You Provide e. Log Data f. Usage Data g. Device Information h. Cookies and Similar Technologies	Where necessary to perform a contract with you, such as generating your professional profile.
To communicate with you, including to send you information or marketing about our Services and events.	a. Account Information b. User Content c. Communication Information d. Other Information You Provide e. Log Data f. Usage Data g. Device Information h. Cookies and Similar Technologies	Where necessary to perform a contract with you, such as processing your contact information to send you a technical announcement about the Services. Your consent when we ask for it to process your Personal Data for a specific purpose that we communicate to you, such as processing your contact information to send you certain forms of marketing communications.
To prevent fraud, criminal activity, or misuses of our Services, and to protect the security of our systems and Services	a. Account Information b. User Content c. Communication Information d. Social Media Information e. Other Information You Provide f. Log Data g. Usage Data h. Device Information i. Cookies and Similar Technologies	Where necessary to comply with a legal obligation.Where we are not under a specific legal obligation, where necessary for our legitimate interests and those of third parties, including in protecting our Services from abuse, fraud, or security risks, such as processing data from security partners to protect against fraud, abuse and security threats in our Services.
To comply with legal obligations and to protect the rights, privacy, safety, or property of our users, us, our affiliates, or any third party	a. Account Information b. User Content c. Communication Information d. Social Media Information e. Other Information You Provide f. Log Data g. Usage Data h. Device Information i. Cookies and Similar Technologies	Where necessary to comply with a legal obligation, such as retaining transaction information to comply with record-keeping obligations.Where we are not under a specific legal obligation, where necessary for our legitimate interests and those of third parties and broader society, including in protecting our or our affiliates’, users’, or third parties’ rights, safety, and property, such as analyzing log data to identify fraud and abuse in our Services.

When we process your Personal Data for the purposes described above, we rely on the following legal bases:

10. 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:
- where you want us to establish the data’s accuracy;
- where our use of the data is unlawful but you do not want us to erase it;
- 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
- 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.

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.

11. 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.