Privacy Policy

Contents

General Information

Vista Global is committed to respecting your privacy and protecting your personal data.

In this Privacy Policy (this “Policy”), “Vista Global”, “we”, “us” or “our” means Vista Global Holding Limited, a company incorporated in Dubai International Financial Centre, UAE, with registration number 2953, and with principal offices at Dubai International Finance Centre, Gate Village 11, Unit 106, Dubai, United Arab Emirates; “you” or “your” means you, the person who provides us with personal data; and “personal data” shall have the meaning assigned to it as expressed in Federal Law No. 3 1987, Federal Law No. 1 of 2006, Federal Law No. 5 of 2012, DIFC Law Number 1 of 2007 (as amended by DIFC Laws Amendment Law, DIFC Law No. 1 of 2018) and the DIFC Data Protection Regulations (collectively the “UAE Laws”).

All personal data is obtained, held, and processed by Vista Global, in compliance with, this Policy, any and all data protection-related laws and regulations that are applicable to Vista Global (including without limitation, Regulation (EU) 2016/679 of the European Parliament and of the Council (“GDPR”), UAE Laws), and any data protection related terms in any agreement or contract in force between you and Vista Global.

Vista Global is deemed a data controller.

When we ask you to provide certain personal data, then you can be assured that it will only be used in accordance with this Policy. This Policy applies to personal data about you that we collect, use and otherwise process in connection with your relationship with us as a client or potential client, including when you use our services, use our websites or mobile apps, service agents or call centres and book to use our services through third parties (such as agents and brokers).

This Policy applies to you whether you use our services or products on a casual basis, or have registered to use any of our services or products, or have entered into a contract with us in relation to the supply by us to you of services and/or products, or have entered into any other transaction with us, whether financing, M&A, corporate or commercial in nature. Any products and/or services acquired by you from us will be subject to their own terms and conditions which you must also read and accept or as otherwise as agreed between us. In the event of any conflict between this Policy on the one hand, and the terms and conditions of any such products or services or the terms and conditions of any contract or transaction agreed between us on the other hand, then the terms and conditions of those products or services or the terms and conditions of that contract or transaction shall prevail.

This Policy is effective as of the “Effective Date” which appears at the bottom of this Policy. Use the “Last Revised Date” appearing at the bottom of this Policy to determine when this Policy was last updated. This Policy is current as of the “Last Revised Date”. We reserve the right, at our sole and absolute discretion, to change or modify this Policy at any time. Any such changes or modifications will become effective when posted on this page. Please check this page periodically to ensure that you are happy with any such changes or modifications. It is in your own interest to access this page regularly to view the latest version of this Policy. If we make a change or modification to this Policy, we may, where appropriate and where possible in our sole discretion, alert you with a notice on our website or with any other means of notification we deem fit. Your continued access to or use of any of our services or products or your continuing dealings with us or your purchase of any of our products or services or your continued provision of personal data to us following any change or modification to this Policy shall be deemed your acceptance to be bound by any such changes or modifications.

Your access to or use of any our services or products, your dealings with us, and your purchase of any of our products or services through Vista Global or any one of our subsidiaries is entirely voluntary. Please read this Policy carefully, as your access to or use of any our services or products, your dealings with us, and your purchase of any of our products or services constitutes your acceptance of all of the terms and practices described in this Policy, including without limitation, the collection, use, processing, and disclosure of your personal data as described in this Policy. Please do not access or use any of our services or products, or deal with us, or purchase any of our services or products if you disagree with any part of this Policy.

If you have any questions or concerns about this Policy or its implementation, you are invited to contact us at privacy@vistaglobal.com or alternatively at Dubai International Finance Centre Gate Village11, Unit 106, Dubai, United Arab Emirates.

What types of personal data do we collect?

We may from time to time, collect personal data about you either directly or through any one of our subsidiaries or affiliates. Our subsidiaries and affiliates may have their own privacy policies, and any data that we receive will be in adherence and in accordance with their policies and this Policy. As a holding company, we may collect your personal data in a number of ways, for example:

  • From the information that you provide to us;
  • From information about you provided to us by your company or an intermediary, including financial institutions;
  • When you communicate with us by telephone, fax, email or other forms of electronic communication;
  • From information gathered by any one of our subsidiaries or affiliates;
  • From information provided to us by one of our advisors;
  • From information provided to us by one of your advisors;
  • Publicly available sources;
  • Information about your use of our websites, call centres and mobile applications, including information about which pages you view;
  • Information about interactions you have with us and our staff;
  • Your financial and credit card information (including such information as received from third-party banks and other credit institutions and credit rating institutions) which are necessary for us to provide you with the requested product or service; and,
  • Other information that may be required by us, to carry out obligations arising from any contracts entered between you and us, and/or to carry out client surveys and/or offers.

This personal data may include information that you provide to us directly or through companies or agents we work with, as well as information which we collect when we enter into any kind of transaction with you.

When, and why, do we collect ‘sensitive personal data’?

Certain categories of personal data, such as that about race, ethnicity, religion or health, are considered “sensitive personal data” in terms of applicable law both in the UAE and abroad. Sensitive personal data will only be processed where when and as needed to undertake a transaction with you or as may be required by applicable law.

By providing any personal data that is, or could be considered to be “sensitive personal data”, you explicitly agree that we may collect, use, share with third parties and transfer such data, within and outside of the European Economic Area and the DIFC (including the UAE) in accordance with this Policy.

What do we use your personal data for?

We store, handle, send and generally process personal data to provide you with the best service or to fulfil any commitment to you, and in particular for the following reasons:

  • Performance of a contract with you;
  • Administration and management of our business;
  • Third parties whom we engage to assist in delivering services or engaging in business transactions with you;
  • Dealing with professional advisors where it is necessary for us to obtain their advice or assistance, including lawyers, accountants, IT or public relations/marketing advisors;
  • To deal with the general enquiries you raise from time to time on our services;
  • For the purposes of accounting and billing;
  • To ensure that you are not the subject or target of any economic or trade sanction law or regulation;
  • To carry out obligations and/or enforce rights arising from any contracts or transactions entered between you and us;
  • For internal record keeping and the general administration of your records by us which may include for example, accounting and billing, auditing, credit or other payment card verification, anti-fraud screening (including the use of credit reference agency searches and payment card validation checks), safety, security, health, and administrative and legal purposes;
  • For security purposes to protect your personal data held and/or processed by us;
  • For training our employees in respect of providing our service and products to you;
  • For statistical analysis;
  • To improve our products and services;
  • For our general marketing purposes where you have notified us that you consent to receive information about us and our services, products and offers;
  • From time to time, we may also use your personal data to contact you for feedback on our services or the services of any of our subsidiaries or affiliates or third-party supplier services so as to assist us in their improvement and development, and to provide services tailored to your requirements and treat you more personally, for example:
    • To deliver messages and information that we think is relevant and may be of interest to you;
    • To our data storage providers.

We shall keep your personal data for the above purposes in accordance with those retention periods set by applicable law and our internal policies.

Who do we share your personal data with?

We may disclose your personal data (and any third party personal data provided by you to us) to:

  • companies which are part of the group of companies which we may be part of from time to time, to our branch offices, and to our affiliates;
  • our authorised representatives; and
  • third parties:
    1. in the event that we sell our entire business or assets (in which event disclosure shall be to a prospective purchaser and their professional advisers only) or in the event of a due diligence exercise carried out on Vista Global by a potential investor or partner (in which event disclosure shall be to the potential investor or partner and his professional advisers, shall be limited to the extent required, and shall be subject to confidentiality protections to the extent practicable);
    2. if we are under a duty to disclose such personal data in order to comply with any legal or regulatory obligation or request (whether in the United Kingdom, the United States of America, UAE, Malta, or elsewhere);
    3. in order to give effect to and/or enforce the terms and conditions of any contract entered into between you and us;
    4. so as to protect our rights, property and safety and the rights, property and safety of our clients, or others (including by way of exchange of information with third parties for the purposes of fraud protection and credit risk reduction);
    5. to carry out due diligence or other background checks on you (thru’ sanction and enforcement list data) so as to protect our rights, interests property and safety and the interests, rights, property and safety of our clients, or others;
    6. to facilitate your travel arrangements, including carriers and airport operators, customs and immigration authorities, agents or brokers involved in making your travel arrangements, and global distribution systems service providers; and,
    7. who deliver services either to you or to us.

When do we collect personal data about you?

We collect personal data about you when you use our services or products (whether directly provided by us or by another company or agent), when you enter into any contract or transaction with us, and when you use our website, call centres or mobile applications. In addition, we may receive personal data about you from third parties, such as, companies contracted by us to provide services to you

How we use cookies

Cookies are a small amount of data sent from the server, which is then stored on your computer’s hard disc drive. We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual. For the same reason, we may obtain information about your general internet usage by using a cookie file which is stored on the hard drive of your computer. Cookies help us to improve our services and to deliver a better and more personalised service.

You can delete all cookies that are already on your computer, and you may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. However, if you select this setting, you may be unable to access certain parts of our services. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you log on to our services, unless the cookies to be issued require your informed consent.

When will we send you marketing communications?

You may receive marketing communications from us, of from our subsidiaries or affiliates, or from third parties used by us to send marketing communication on our behalf if you have opted in to receive such material. Our marketing communications will always include the option for you to unsubscribe from receiving any further marketing communications.

If you have previously agreed to us using your information for direct marketing purposes, you may change your mind at any time by writing to us at privacy@vistaglobal.com.

Security, storage, and transfer

We are committed to ensuring that your personal data is secure at all times. We have in place suitable physical, electronic and managerial procedures to safeguard and secure the personal data we collect online.

All of our employees and suppliers with access to your personal data and/or who are associated with the processing of that data are contractually obliged to respect the confidentiality of your personal data.

Your personal data will be stored on and processed by our systems and may also be stored on and processed by systems of a third-party data processor(s) appointed by us. The personal data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA") and outside the United Arab Emirates (“UAE”). It may also be processed by employees operating outside the EEA and the UAE who work for us or for any of our subsidiaries or affiliates or for one of our suppliers. Such employees may be engaged in, amongst other things, the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your personal data is treated securely and in accordance with this Policy, the GDPR, UAE laws, and any data protection related laws that are applicable to Vista Global.

Withdrawal of Consent

If you withdraw your consent to the processing of your personal data at any time, it may mean we will not be able to provide all or parts of the products or services you have requested from us. Please be aware that in these circumstances you will not be able to obtain a refund of any fees or monies you would have paid.

On the other hand, if for example, you withdraw your consent to us sending you marketing communications, then such withdrawal should not have any effects.

Transmission of information over the internet

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Services; any transmission is at your own risk. Once we have received your personal data, we will use strict procedures and security features to try to prevent unauthorised access.

Links to third party websites

Our websites, online services and mobile applications may, from time to time, contain links to and from websites of our partner networks, advertisers, subsidiaries and affiliates. If you follow a link to any of these websites, please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services. You are advised to please check these policies before submitting any personal data to these websites or using these services.

Telephone Calls

We may monitor or record telephone conversations to enhance your security and ours, to enable us to handle complaints efficiently, improve our client service and for staff training purposes. If your telephone conversation with us will be recorded, then you will receive a message to this effect before the start of your conversation with us.

Providing information about someone else

If you are providing personal data to us about someone else you confirm that they have appointed you to act for them, to consent to the processing of their personal data, and that you have informed them of our identity, of this Policy, and of the purposes (as set out in this Policy) for which their personal data will be processed.

How to access, review, transfer and delete your personal data

We will make your personal data available to you for review pursuant to a simple request from you. If you tell us that the personal data which we hold about you is incorrect or is used inappropriately, we will correct, update or delete such person data as appropriate. You also have other rights such as the right to request from us erasure of personal data or restriction of processing or to object to processing and the right to data portability. For information about how to get access to your personal data and for exercising your rights, please contact us at privacy@vistaglobal.com.

Complaint, applicable law, Jurisdiction and Severability

Any dispute arising from or related to the acceptance, interpretation or observance of this Policy shall be submitted to the exclusive jurisdiction of the competent DIFC (Dubai International Financial Centre) Courts which shall apply the laws of England.

You may also have the right to lodge a complaint with the DIFC Commissioner of Data Protection or a supervisory authority established within the EEA. List of contact details of supervisory authorities within the EEA is available here.

If any portion of this Policy is held to be invalid or unenforceable for any reason by a court or governmental authority of competent jurisdiction or by a supervisory authority, then such portion will be deemed to be stricken and the remainder of this Policy shall continue in full force and effect.

Further details

Further details about your rights under UAE laws can be accessed here, and details about your rights under the GDPR can be accessed here.

Version Control

Date Version Description
28 May 2019 1 Effective date