1. Who is the controller of my personal data?
Unless we notify you otherwise, PMG Middle East & Africa SPC is the controller of your personal data as it is the entity who alone or jointly determines how or why your personal data is being processed. Our affiliates may be the controller of your personal data in certain circumstances depending on our relationship, and the services we are providing to you. A list of our group of affiliates can be found here.
2. How do we collect your personal data?
We use different methods to collect personal data from and about you, including: -
3. For which purposes and on which legal basis do we process your personal data?
We have set out below a description of all the ways we plan to use your personal data.
4. How do we use personal data for direct marketing purposes?
We may send you marketing communications to keep you up to date with our products and services, including those we think may be of interest to you.
Do we send targeted e-mails? We send targeted electronic direct marketing to business contacts at our clients or other companies with whom we want to develop or maintain a business relationship in accordance with applicable marketing laws. Our electronic direct marketing typically includes web beacons, cookies, and similar technologies that allow us to know whether you open, read, or delete the message, and links you may click. When you click a link in an electronic direct marketing message, we will also use a cookie to log what pages you view and what content you download from our websites, even if you are not registered at or signed into our site. Please see our cookies policy (section 12) for further details.
Do we maintain Customer Relationship Management (CRM) databases? Like most companies, PMG uses customer relationship management (CRM) database technology to manage and track our marketing efforts. Our CRM databases include personal data belonging to business contacts at our clients and other companies with whom we already have a business relationship or want to develop one. The personal data used for these purposes includes relevant business information such as: contact data, publicly available information (e.g. board membership, published articles, press releases, your public posts on social media sites if relevant for business purpose), your responses to targeted electronic direct marketing (including web activity following links from our e-mails), website activity of registered users of our website and other business information included by PMG professionals based on their personal interactions with you.
What are your rights regarding marketing communications? You can elect to not receive marketing communications from us by, or by utilising opt-out mechanisms in e-mails we send to you. You can also object to receiving marketing communications or request that your personal data be removed from our CRM databases by contacting us at email@example.com.
5. What about sensitive data?
We do not generally seek to collect sensitive data (also known as special categories of personal data) from individuals and we request that you please do not submit sensitive data to us. In the limited cases where we do seek to collect such data, we will do this in accordance with data privacy law requirements and/or ask for your consent.
The term "sensitive data" refers to the various categories of personal data including racial or ethnic origin, political opinions, religious, philosophical or other similar beliefs, membership of a trade union, physical or mental health, biometric or genetic data, sexual life or orientation, or criminal convictions and offences (including information about suspected criminal activities).
6. What about persons 18 or under?
We are concerned to protect the privacy of children. We do not knowingly contact or collect information from persons under the age of 18. The website is not intended to solicit information of any kind from persons under the age of 18. If you believe that we have received information pertaining to or from persons under the age of 18 please contact us at firstname.lastname@example.org. If we become aware that a person under the age of 18 has provided us with personal information, we will take steps to delete such information.
7. Will we share your personal data with third parties?
We may share personal data with the following categories of recipients:
Before we share your personal data with any third parties, we take the necessary steps to ensure that your personal data will be given adequate protection in accordance with relevant data privacy laws and PMG’s internal policies.
8. How long will your personal data be retained by us?
We retain your information for no longer than necessary for the purpose for which it was collected. We maintain specific records management and retention policies and procedures, so that in determining how long your information will be stored, we will consider:
9. Do we transfer your data internationally?
As we are a global organisation with a presence in a number of jurisdictions and countries, we may transfer your personal data to our affiliates internationally. If you are located in the EEA, this may involve transferring your data outside the EEA. To ensure that such transfers are in accordance with applicable law and carefully managed to protect your privacy rights, any inter-company transfers of personal data are covered by agreement(s) which contractually oblige(s) us to ensure adequate and consistent levels of protection wherever personal data is transferred within our group of companies. We may also share your personal data with third parties (see section 7), some of which are based outside the EEA. Whenever we transfer your personal data outside the EEA, we ensure a similar degree of protection is afforded to it by ensuring appropriate safeguards are implemented, for example we may use specific contracts approved by the European Commission. Under the provisions of PPDL, we are bound to transfer your personal data, where required, to only such countries which are deemed by the Bahrain Personal Data Protection Authority to have sufficient data protection laws. Please contact us (see our details at section 13 below) if you would like further information on the mechanism used by us when transferring your personal data outside the EEA.
10. Data security
We maintain organisational, physical and technical security arrangements for all the personal data we hold. We have protocols, controls and relevant policies, procedures and guidance to maintain these arrangements taking into account the risks associated with the categories of personal data and the processing we undertake, including as appropriate: -
11. Which rights do you have with respect to the processing of your personal data?
If you are based within the EEA, you may be entitled under certain circumstances to: -
Please contact us at email@example.com to exercise any of these rights. We will process any request in line with any local laws and our policies and procedures. We may ask you for additional information to confirm your identity and for security purposes, before disclosing information requested to you.
12. Cookies Policy
12.1. When you visit one of our websites, PMG uses “cookie” technology try to make that experience simple, personalised and meaningful. Cookies are small pieces of information which are issued to your computer or any similar device you use to access the internet e.g. smart phone, tablet or other mobile device when you visit a website and which store and sometimes track information about you're use of the website. A number of cookies PMG use last only for the duration of your web session and expire when you close your browser. Other cookies are used to remember you when you return to the website and will last for longer.
12.3. Some of the cookies used by PMG websites are set by us, and some are set by third parties who are delivering services on our behalf. Most web browsers automatically accept cookies but, if you prefer, you can change your browser to prevent that or to notify you each time a cookie is set. You can also learn more about cookies by visiting www.allaboutcookies.org which includes additional useful information on cookies and how to block cookies using different types of browser. Please note however, that by blocking or deleting cookies used on an PMG website(s) you may not be able to take full advantage of the website(s) if you do so.
12.4. Certain cookies are either set by third parties on the Website or these are set by us using the third parties cookie code. More information about cookies placed by third parties and how to restrict or block their cookies can be accessed by following the link to their website. In addition to cookies, tracking gifs may be set by us or third parties in respect of your use of the Site. Tracking gifs are small image files within the content of our site or the body of our newsletters so we or third parties can understand which parts of the website are visited or whether particular content is of interest.
12.5. In addition to cookies, tracking gifs may be set by us or third parties in respect of your use of the Site. Tracking gifs are small image files within the content of our site or the body of our newsletters so we or third parties can understand which parts of the website are visited or whether particular content is of interest.
13. What if you have questions or want further information?
Any questions regarding our privacy practices should be sent in writing to the Data Protection Officer, PMG Middle East & Africa SPC, PO Box 75810, Manama, Bahrain, or by email at firstname.lastname@example.org.
If you wish to make a complaint about how we use your information, please contact us at email@example.com and we will do our best to help. If you are located in the EEA, you have the right to lodge a complaint with the appropriate data protection supervisory authority in your country. We would, however, appreciate the chance to deal with your concerns before you approach your local supervisory authority so please contact us in the first instance.
14. Conflict of provisions: