SKY CONNECT FZC LLC strives to protect the users' personal data. This Privacy Policy describes how we collect, use, and protect the personal information of individuals who use the website qsrtele.com (hereinafter referred to as "the Site") and who leave their data for the purpose of entering into partnerships and cooperation.
By subscribing to our Site, you acknowledge and agree that this Privacy Policy applies to all services offered by us and to all of our sites or apps, but excludes services and sites or apps that have separate privacy policies that do not incorporate this Privacy Policy.
Users will find below the provisions regarding the processing of personal data which apply during any visit to or use of the Site by the Users (hereinafter referred to as the “Privacy policy”).
If you give us personal information about another person that we have requested in relation to the provision of a service, you are responsible for ensuring that they know and agree to us keeping records about them and that we will process their personal information in accordance with this Privacy Policy.
Our Site may contain, from time to time, links to and from the websites of our partner networks, advertisers and affiliates, including online stores and service providers hosted within our Site, which are operated by third party merchants. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these third party privacy policies before you submit any personal information to these websites.

1.Background

SKY CONNECT FZC LLC processes personal data belonging to Users of the Site for the purposes and within the limits of the Privacy policy, during any visit to or use of the Site.
When processing personal data, SKY CONNECT FZC LLC takes care to comply with current laws and regulations, first and foremost with Federal Decree by Law No. (45) of 2021 Concerning the Protection of Personal Date, hereinafter “the Law”.
In this respect, and pursuant to this Law, SKY CONNECT FZC LLC: - Is legally bound to process the personal data of Users. This processing is explained in Article 2.1 of the Privacy policy;
- Also processes personal data to enable Users to use the Site and for the necessary and legitimate purposes set out in Article 2.2 of the Privacy policy;
- Processes the personal data set out and for the purposes given in Article 3, further to the prior, free and express consent of Users.

2.    Processing of personal data that does not require the consent of Users

2.1. Legal obligations of SKY CONNECT FZC LLC and data processing required for use of the Site

Personal data provided by the User is held in a record which is controlled by and remains the responsibility of SKY CONNECT FZC LLC at all times, as set out in Article 7.1.

a. What personal data is processed?

The following personal data is processed:
- name, email address, the name of the company in which the user is employed/the name of the company that the user represents on his behalf;
- the User’s browsing history and activities on the Site, visits (browser data, IP address), particularly through the use of cookies;
- the channel you chose to purchase our products or services;
- any other information we need to provide a particular service or product;
- any other information that may be exchanged between SKY CONNECT FZC LLC and the User, namely by email.

Cookies

Like many other websites, we use cookies. Cookies are little files that websites put on your device to provide you with a better, more personal and relevant experience online. Some cookies are essential for websites to work and others remember things about you to give you a better, more enjoyable experience online. By continuing to use our websites, you are agreeing to our use of cookies. Alternatively, you can manage them in your browser settings. However, refusing cookies may mean that you are unable to access certain parts of our websites.
We use various types of cookies, including essential cookies (which help you move around the secured areas of the websites and do things you have specifically come to the websites for, for examples remembering products you put in your basket and information you enter in forms), cookies for website information (which collect anonymous information about how visitors use our websites, including the most popular pages and any error pages you see), and cookies that save your settings.

b. What data processing does SKY CONNECT FZC LLC carry out?

The data processing consists of collecting, recording, retaining, consulting, organising, using, cross-referencing or any other transaction that becomes necessary or useful under the legal and regulatory provisions set out in Article 2.1.c). Processing may also consist of transferring personal data:
- Legal and administrative authorities;
- to SKY CONNECT FZC LLC suppliers, whose services are required for use of the Site and who are cited on a list that may be requested from the contact person detailed in Article 7.5;
- subsidiaries, affiliated companies, and trusted third parties (including agents, resellers, subcontractors and suppliers who are directly involved in the supply of the services ordered by you.
We may disclose your personal information in accordance with pre-defined procedures, if such disclosure is necessary:
- permitted by UAE applicable laws;
- expressly permitted by the UAE telecommunications regulations or any other aspect of the UAE regulatory framework;
- in response to legal process (e.g. police, emergency services, etc..) in order to comply with a court order or applicable law or in connection with judicial proceedings or other legal process;
- necessary for the execution of the agreement between us and the provision of our services to you;
- made in order to protect us or our customers’ legitimate interests;
- expressly permitted by you (express opt-in consent).
We may be required to disclose your personal information or legally intercept the services to comply with the laws of the UAE or the express instructions of a competent authority (such as the Telecommunications Regulatory Authority) or where it is deemed necessary in the interests of public or national security. In addition, we may share aggregated and/or anonymized (non-personally identifiable) information, derived from your personal information, publicly and with our partners such as publishers, advertisers, website owners etc.

c. What are the purposes of this data processing?

1) SKY CONNECT FZC LLC is required to process personal data as per Articles 2.1.a) and b) in order to comply with the legal and regulatory obligations by which it is bound, namely the following legal provisions:
- Federal Decree by Law No. (45) of 2021 Concerning the Protection of Personal Date;
- Federal Decree by Law No. (44) of 2021 on the Establishment of the UAE Data Office;
- Federal Decree by Law No. (3) of 2003 on Regulating the Telecommunications Sector, as amended;
- Federal Law No. (14) of 2016 on Administrative Violations and Penalties in the Federal Government.
2) SKY CONNECT FZC LLC also processes personal data set out in Article 2.1.a) to authenticate Users and allow them to access and use the Site. This processing is then carried out in order to: 
- registering and managing; 
- communication with Users, including support and dispute resolution.

2.2. Other data processing that does not require the consent of Users

SKY CONNECT FZC LLC also processes the following personal data for the legitimate purposes set out below. This processing of personal data carried out by SKY CONNECT FZC LLC does not require the consent of Users under Article 4 of the Legal.
Personal data provided by the User is held in a record which is controlled by and remains the responsibility of SKY CONNECT FZC LLC at all times, as set out in Article 7.1. 

a. What personal data is processed? 

The following personal data is processed: 
- name, email address, the name of the company in which the user is employed/the name of the company that the user represents on his behalf; 
- the User’s browsing history and activities on the Site, visits (browser data, IP address), particularly through the use of cookies;
- the channel you chose to purchase our products or services;
- any other information we need to provide a particular service or product;
- any other information that may be exchanged between SKY CONNECT FZC LLC and the User, namely by email.

b. What data processing does SKY CONNECT FZC LLC carry out?

The processing consists of collecting, recording, retaining, consulting, organising, using, cross-referencing of personal data set out in Article 2.2.a). It also consists of transferring this personal data to third parties, a list of whom may be accessed on request from the contact person detailed in Article 7.5.

c. What are the legitimate purposes of the data processing?

SKY CONNECT FZC LLC processes personal data set out in Article 2.2.a) for the following legitimate purposes:
- to promote, advertise and market its offering of new services, which includes sending text messages, telephone calls, paper or electronic newsletters;
- to conduct satisfaction surveys, statistical studies, trend analyses, and market research in order to improve services.  

3.Processing of personal data that requires the consent of Users

By using the SKY CONNECT FZC LLC Site, for any reason whatsoever, the User expresses their free, individual, informed and unambiguous consent to expressly authorise SKY CONNECT FZC LLC to process personal data pursuant to the Regulation, within the limits of and for the purposes set out below and without prejudice to the data processing stipulated in Article 2.    
Personal data provided by the User is held in a record which is controlled by and remains the responsibility of SKY CONNECT FZC LLC at all times, as set out in Article 7.1. 
The User shall also have certain rights, including the right to withdraw their consent at any time, according to the terms of Article 3.4.

3.1. Nature of the personal data processed 

SKY CONNECT FZC LLC processes the following personal data:
- name, email address, the name of the company in which the user is employed/the name of the company that the user represents on his behalf; 
- the User’s browsing history and activities on the Site, visits (browser data, IP address), particularly through the use of cookies;
- the channel you chose to purchase our products or services;
- any other information we need to provide a particular service or product;
- any other information that may be exchanged between SKY CONNECT FZC LLC and the User, namely by email.
Personal data provided by the User is held in a record which is controlled by and remains the responsibility of SKY CONNECT FZC LLC at all times, as set out in Article 7.1. 

3.2. The data processing 

The processing consists of collecting, recording, retaining, consulting, organising, using, cross-referencing of personal data set out in Article 3.1. It also consists of transferring this personal data to third parties, a list of whom may be accessed on request from the contact person detailed in Article 7.5.

3.3. Purposes of the personal data processing

The personal data is collected and processed by SKY CONNECT FZC LLC for the following purposes: 
- registration of affiliates in the affiliate program;
- communication with affiliates regarding the affiliate program;
- processing payments and payouts to affiliates based on the generated traffic;
- Conducting satisfaction surveys, statistical studies, trend analyses, and market research for management, marketing and reporting purposes, including profiling that does not fit
within the framework of the provision described in article 2.2.c);
- Analysing Affiliate performance and traffic generation;
- improving and optimizing the affiliate program. 

4. Rights of the User

Without prejudice to Article 2 and 5, Users may exercise their rights to request that their data be rectified, to object to it being processed and to limit the processing, according to the terms and within the limits set out below.  

4.1. Right of access

a. SKY CONNECT FZC LLC can provide Users with the following information:
- the name and contact details of the data controller: 
- the contact details of data protection officer; 
- the personal data processed;
- the purposes for which the personal data is being processed and the legal basis for this processing; 
- the recipients or categories of recipients of personal data, as appropriate; 
- and, if relevant, the fact that the data controller intends to transfer personal data to a country outside the UAE. 
- The option to object to the automated processing of their data, including profiling, unless there are justified grounds requiring SKY CONNECT FZC LLC to process this data, as well as the option to object to any processing of their personal data for marketing purposes.   
b. Users have the right to request to see the information referred to in this Article and in Article 3.1. at any time via the contact person detailed in Article 7.5. SKY CONNECT FZC LLC  shall respond to such requests for information within one month.
c. Users may obtain a copy of personal data that is processed. We reserve the right to charge a reasonable administrative fee for additional copies of personal data requests.
d. Users shall have the right to access the information or a copy thereof in a structured format, such that the personal data is provided to them in a format that meets technical standards in place when the request for access was made.  This format shall therefore allow for automatic readability.   

4.2. Right to request rectification 

SKY CONNECT FZC LLC guarantees and compels Users to update and rectify their personal data if this data becomes incorrect or incomplete. 
The right to rectify data may be exercised by contacting the person detailed in Article 7.5.

4.3. Right to object to the processing of data 

SKY CONNECT FZC LLC allows Users to object to their personal data being processed in full or in part on the following grounds:
- The data is inaccurate; 
- The processing is no longer required for the purposes for which the data was collected; 
- The User has withdrawn consent;
- The data has been processed illegally. 
In addition, SKY CONNECT FZC LLC allows Users to object to:
The automatic processing of their data, including profiling, unless there are justified grounds requiring SKY CONNECT FZC LLC to perform this processing. 
Any processing of their personal data for marketing purposes, including profiling if it is linked to this marketing.   
The right to object to the processing of data may be exercised by contacting the person detailed in Article 7.5.

4.4. Right to be forgotten

SKY CONNECT FZC LLC also undertakes to follow up any request to erase personal data at the earliest opportunity (right to be forgotten), when:  
- the processing is no longer required for the purposes for which the data was collected; 
- the User has withdrawn consent;
- the data has been processed illegally or must be erased pursuant to a legal obligation. 
The User objects to the automatic processing of their data, such as profiling, and there are no justified grounds requiring SKY CONNECT FZC LLC to perform this processing.
The User objects to the processing of their personal data for marketing purposes, such as profiling, if it is linked to this marketing.   

4.5. Right to limit the processing of data

Users also have the right to limit SKY CONNECT FZC LLC processing of their personal data when: 
- the User believes the personal data to be inaccurate, whilst SKY CONNECT FZC LLC checks the accuracy of the information; 
- the processing is illegal and the User does not wish for their data to be erased but requests to limit the processing thereof; 
- the User objects to automatic processing, including profiling or to the processing of their personal data for marketing purposes and it is necessary to verify the legitimacy of SKY CONNECT FZC LLC reasons for seeking to continue this processing;  
- SKY CONNECT FZC LLC no longer requires the personal data processed but the data subject would like it to be held to establish, exercise or defend legal claims;
The right to limit the processing of data may be exercised by contacting the person detailed in Article 7.5.

4.6. Transferring data to a data controller

Users may transfer their personal data to another data controller without objection from SKY CONNECT FZC LLC. 

For such a transfer to be technically possible, Users may ask SKY CONNECT FZC LLC that it be performed directly by its data controller.  
4.7. Modalities

The rights recognized by SKY CONNECT FZC LLC to the User must be exercised in accordance with the modalities defined by article 7.5.

4.8. Notification 

SKY CONNECT FZC LLC shall notify the User of any data that is erased or rectified in accordance with Articles 4.2 and 4.4, unless such notification proves impossible or involves disproportionate efforts. 

This notification shall be sent by letter or email, using the contact details provided by the User. 

5. Location, retention and retention period of personal data

5.1. SKY CONNECT FZC LLC retains Users’ personal data appropriately and securely in a form which enables it to be identified and made available.   

Personal data may be transferred outside the UAE, including to countries that may not have the same level of data protection as the UAE. Such transfers will only take place in accordance with applicable UAE data protection laws. Where required, we will ensure that adequate safeguards are in place, including the use of Standard Contractual Clauses (SCCs), user consent, or approvals from UAE Data Office.

5.2. Users’ personal data is retained by SKY CONNECT FZC LLC for the purposes set out in Articles 2 and 3.   It is retained for a period of 10 years for all of the purposes governed by Article 2.a); SKY CONNECT FZC LLC therefore reserves the right to retain Users’ personal data for any reasons imposed by law. Users declare that they have been informed of this and agree that, in relation to the Law on the Federal Decree Law No (20) of 2018 on Anti-Money Laundering and Combating the Financing of Terrorism and Illegal Organisations SKY CONNECT FZC LLC is required to retain a photocopy of the User’s identity card or the document used for identification for at least ten years from the date of the player’s last activity on the Site.   

For all of the cases governed by Article 2.2. and 3., personal data is only retained for the period required for the purpose of the processing. The data is then erased from SKY CONNECT FZC LLC’s files on the User’s request sent to the contact person referred to in Article 7.5.  

After the end of the provision of services to the User, their personal data will be stored for a period of 24 months for legal and accounting purposes, after which it will be securely deleted.   

6. Liability of SKY CONNECT FZC LLC – Data controller      

6.1. SKY CONNECT FZC LLC undertakes to ensure that the processing of personal data is carried out in a lawful, loyal and transparent manner with regard to the User concerned. Any data processing operation performed by SKY CONNECT FZC LLC shall comply with the Federal Decree by Law No. (45) of 2021 Concerning the Protection of Personal Date and this Privacy policy. 
SKY CONNECT FZC LLC shall implement all reasonable and appropriate means to ensure the confidentiality, integrity and availability of the personal data it processes. These namely technical and organisational measures are explained in the data protection manual which may be obtained from the contact person detailed in Article 7.5. 
Technical measures include the anonymisation and encryption of personal data, depending on the purpose.  
Organisational measures include carrying out internal audits, in addition to audits to which SKY CONNECT FZC LLC may be subject by the Commission des jeux de hasard in particular.
If necessary, SKY CONNECT FZC LLC and the data protection officer shall carry out an impact assessment when the data processing is likely to pose a high risk for Users.      
6.2. Users’ personal data is not sent to any third parties other than suppliers and partners of SKY CONNECT FZC LLC, except for the purposes set out in Articles 2.1, 2.2 and 3 and, consequently, if:
The data transfer is made mandatory by a law or regulation or when ordered by an administrative or judicial authority;
The data transfer proves necessary for the supply of services, or maintenance services;   
The User has consented to such a transfer;
The partner shall not be deemed a data controller unless they process Users’ personal data on behalf of SKY CONNECT FZC LLC. SKY CONNECT FZC LLC shall not be held liable for the processing of User’s personal data by partners who supply their own services in their own name on their own behalf or if it proves that it is not responsible for the event that gave rise to the damage. 
It is understood that in the event that SKY CONNECT FZC LLC acts in the capacity of the processor’s partner, SKY CONNECT FZC LLC shall be liable for damage caused by processing personal data contrary to the Regulation or this Privacy policy only where it has not complied with obligations of the Regulation or this Privacy policy directed to processors, or where it has acted outside or contrary to lawful instructions of the partner. Similarly, SKY CONNECT FZC LLC shall not be held liable if it proves that it is not responsible for the event that gave rise to the damage.  
6.3. SKY CONNECT FZC LLC shall ensure that when the processing is carried out by a processor on behalf of SKY CONNECT FZC LLC, the processor shall provide sufficient assurances that appropriate technical and organisational measures have been implemented and, more generally, that the Regulation has been complied with. In particular, the processor is required to comply with the Regulation and, therefore, keep a record of processing activities. 
6.4. SKY CONNECT FZC LLC undertakes to ensure that in the event of a security problem related to data processed which may affect the confidentiality thereof, SKY CONNECT FZC LLC shall report the incident at the earliest opportunity to the data protection authority stipulated in Article 7.4. 
SKY CONNECT FZC LLC shall also inform the Users concerned, insofar as the personal data breach poses a high risk to the rights and freedoms of the User; the User shall be informed by letter or email using the contact details that they have provided.  

7. Miscellaneous 

7.1. Record of personal data and data protection manual 

As a personal data controller, SKY CONNECT FZC LLC may maintain a record of processing activities (ROPA) where deemed necessary or required by applicable UAE data protection laws. This record contains all of the information about the type of data processed, data subjects, potential data recipients, the purposes of the data processing and how long the data shall be retained for, as well as a general description of technical and organisational security measures in place.   
Personal data provided by the User, any processing of this data and the purposes of such processing are held in a record which is controlled by and remains the responsibility of SKY CONNECT FZC LLC at all times. In addition to the information above, this record includes: 
a. a description of the purposes of the processing; 
b. a description of the categories of data subjects and categories of personal data; 
c. the categories of recipients to whom the personal data has been or shall be sent, including recipients in non-EU countries and UAE or international organisations; 
d. the deadlines for erasing various categories of data; 
e. a general description of technical security measures.

7.2. Entire agreement - modification of the Privacy policy

The Privacy policy contains all of the contractual provisions binding Users, without prejudice to the general provisions in the Terms and Conditions of Use of the Site of which they form an integral part. The Terms and Conditions of Use of the Site shall remain applicable for any matters that do not relate to the protection of personal data.  
In addition, SKY CONNECT FZC LLC reserves the right to modify the Privacy policy. Any updates are enforceable against Users once published on the Site. SKY CONNECT FZC LLC undertakes to state the date on which the Privacy policy that appears on the Site was placed online.

7.3. Probative value 

The User acknowledges that the electronic documents exchanged and electronic data collected during their registration or use of the Site have the same probative value as if these documents and data had been sent or communicated on paper. They therefore undertake to not dispute their force or probative value due to the fact that they are in electronic form.   

7.4. Data protection authority 

Pursuant to Federal Decree by Law No. (45) of 2021 Concerning the User has the right to request additional information or lodge a complaint with the data protection authority. The Independent State Data Protection Authority is UAE Data Office. Contact details are as follows: 
    Address: BLA-BR3-257, AMC - Boulevard - A Building, Ajman Media City
    Email: Info@qsrtele.com    

7.5. Contact – Information on the identity of the data controller and data protection officer

SKY CONNECT FZC LLC may be contacted for any questions regarding the protection of Users’ personal data via the following:
Address: BLA-BR3-257, AMC - Boulevard - A Building, Ajman Media City
Email: Info@qsrtele.com