Privacy Notice

This Privacy Notice outlines Gulf  Researcher’s approach to privacy to fulfil its obligations under applicable privacy laws.

This Privacy Notice is published in compliance with the following privacy laws: European General Data Protection Regulation and Bahrain’s Personal Data Protection Law.

Throughout this document, the terms “we”, “us”, “our” and “ours” refer to Gulf Researcher. And the terms “you”, “your” and “yours” refer to you (as the Data Subject).

This Privacy Notice applies to all your Personal Data processed by us, whether in physical or electronic mode.

Please note that this Privacy Notice is applicable to all instances where we play the role of a Data Controller or Data Manager of your Personal Data, when we collect and process personal data about you for offering our products or services. There may be instances where we play the role of a Data Processor too, when we process Personal Data on behalf of another organization. In that case, the Privacy Notice of that organization becomes applicable to your Personal Data.

Gulf Researcher is committed to keeping your Personal Data private. We process any Personal Data we collect from you in accordance with the applicable laws and regulations mentioned and the provisions of this Privacy Notice. Please read the following carefully to understand our views and practices regarding your Personal Data and how we treat it.

What Personal Data do we Collect & Process?

Categories of Personal Data that we collect, and process are as follows:

• Demographic and Identity Data (for e.g. name, email address, contact number)
• Records of Communications details (for e.g. emails, instant messages etc.)

Where do we obtain your Personal Data from?

Most of the Personal Data we process is provided by you directly to us when you use our products and/or services.

We may also receive Personal Data about you from third parties and publicly available sources of information.

How do we use your Personal Data?

We use your Personal Data for the following purposes:

• To verify your identity
• To deliver our products and services
• To communicate with you regarding existing products and services availed by you, including notifications of any alerts or updates
• To evaluate, develop and improve our products and services
• For market and product analysis and market research
• To send you information about our other products or services which may be of interest to you
• To handle enquiries and complaints
• To comply with legal or regulatory requirements
• To investigate, prevent, or take action regarding illegal activities, suspected fraud and situations involving potential threats to the safety of any person
• To reach out to you for career options with us

Lawful Bases of processing your Personal Data

We process your Personal Data by relying on one or more of the following lawful bases:

• You have explicitly agreed to/consented to us processing your Personal Data for a specific reason
• The processing is necessary for the performance of the contract we have with you or to take steps to enter into a contract with you
• The processing is necessary for compliance with a legal obligation we have
• The processing is necessary for the purposes of a legitimate interest pursued by us

Where the processing is based on your consent, you have the right to withdraw your consent at any point in time. Please note that should the withdrawal of consent result in us not being able to continue offering our products and services to you, we reserve the right to withdraw or cease our products and services to you upon your withdrawal. You may withdraw consent by contacting us with a written request to the contact details specified below in the ‘Contact Us’ section. Upon receipt of your request to withdraw your consent, the consequences of withdrawal will be communicated to you. Upon your agreement to the same, your request for withdrawal will be processed.

When do we share your Personal Data with third parties?

We may use third parties in the provision of our products and services to you. We may share your Personal Data with such third parties. We have appropriate contracts in place with all such third parties. This means that they are not permitted to do anything with your Personal Data which is outside of the scope specified by us. They are committed to hold your Personal Data securely and retain it only for the period specified in our contracts with them.

a.       Reasons for sharing your Personal Data with third parties:

We may disclose your Personal Data to third parties only where it is lawful to do so. This includes instances where we or they:

• Need to provide you with products or services
• Have asked you for your consent to share it, and you have agreed
• Have a legitimate business reason for doing so
• Have a legal obligation to do so. For e.g. to assist with detecting and preventing fraud
• Have a requirement in connection with regulatory reporting, litigation or asserting or defending legal rights and interests
• We may also disclose your Personal Data to appropriate authorities if we believe that it is reasonably necessary to comply with a law, regulation, legal process; protect the safety of any person; address fraud, security, or technical issues; or protect our rights or the rights of those who use our products & services.

b.       With whom your Personal Data may be shared:

We may disclose your Personal Data to the following third parties:

• Any sub-contractors, agents or service providers who work for us or provide services or products to us
• Law enforcement authorities, government authorities, courts, dispute resolution bodies, regulators, auditors and any party appointed or requested by applicable regulators to carry out investigations or audits of our activities
• Statutory and regulatory bodies, authorities (including the government) investigating agencies and entities or persons, to whom or before whom it is mandatory to disclose Personal Data as per the applicable law, courts, judicial and quasi-judicial authorities and tribunals, arbitrators and arbitration tribunals

Cross-border data transfer

Personal Data we hold about you may be transferred to other countries outside your residential country for any of the purposes described in this Privacy Notice.

Please note that these countries may have differing (and potentially less stringent) privacy laws and that Personal Data can become subject to the laws and disclosure requirements of such countries, including disclosure to governmental bodies, regulatory agencies and private persons, as a result of applicable governmental or regulatory inquiry, court order or other similar process.

How do we secure your Personal Data?

We are committed to protecting your Personal Data in our custody. We take reasonable steps to ensure appropriate physical, technical and managerial safeguards are in place to protect your Personal Data from unauthorized access, alteration, transmission and deletion. We ensure that the third parties who provide services to us under appropriate contracts take appropriate security measures to protect your Personal Data in line with our policies.

How long do we keep your Personal Data?

We keep the Personal Data we collect about you for as long as it is required for the purposes set out in this Privacy Notice and for legal or regulatory reasons. We take reasonable steps to delete or permanently de-identify your Personal Data that is no longer needed.

Children’s Privacy

We do not knowingly collect Personal Data from children. If you are a parent or guardian and aware that your Child has provided us with Personal Data, please contact us using the details in the ‘Contact us’ section of our website.

Your Privacy rights

If you are a Bahrain resident, under the PDPL, you have the following rights and we commit to provide you with the same:

• Right of Access: You have the right to get access to your Personal Data that is with us along with other supporting information.
• Right to Rectification: You have the right to ask us to rectify your Personal Data that is with us that you think is inaccurate. You also have the right to ask us to complete your Personal Data that you think is incomplete.
• Right to Erasure: You have the right to ask us to erase your Personal Data that is with us under certain circumstances.
• Right to Object: You have the right to object to the processing of your Personal Data under certain circumstances including for direct marketing purposes.
• Right to not be subjected to automated individual decision-making, including profiling.
• Right to lodge a complaint with the Supervisory Authority: You have the right to lodge a complaint with a supervisory authority.

In addition to the above rights, if you are an EU resident, under the GDPR, we commit to provide you the following rights as well:

• Right to Restriction of Processing: You have the right to ask us to restrict the processing of your Personal Data under certain circumstances.
• Right to Data Portability: You have the right to ask that we transfer the Personal Data you gave us to another organisation, or to you, under certain circumstances.

If you wish to make a request to exercise any of your rights, you can contact us using the details in the ‘Contact us’ section of our website.

Links to other Websites

Our website may contain links to websites of other organizations. This privacy notice does not cover how those organizations process your Personal Data. We encourage you to read the privacy notices on the other websites you visit.

Contact Us

For any further queries and complaints related to privacy, or exercising your rights, you could reach us using the details in the ‘Contact us’ section of our website.

Notification of changes

We regularly review and update our Privacy Notice to ensure it is up-to-date and accurate. Any changes we may make to this Privacy Notice in future will be posted on this page.