Please read the terms of this policy carefully before using the site.
Introduction
Thank you for visiting www.promo.myffin.com.
This Acceptable Use Policy (Policy) sets out the content standards that apply when you upload content to our site, make contact with other users on our site, link to our site or interact with our site in any other way.
In this Policy, references to we, us, our means to MYFFIN TECH LTD. References to you and your are to users of our website.
By using our site you accept these Terms
When you use our website, you confirm that you accept the terms of this Policy and that you agree to comply with its terms. If you do not agree to the terms of this Policy, you must not use our site.
We recommend that you print a copy of this Policy for future reference.
Other Terms that may apply to you
Our Website Terms and Conditions https://www.promo.myffin.com/legal/privacy-and-security/ also apply to your use of our site.
Who we are and how to contact us
www.promo.myffin.com is a website operated by MYFFIN TECH LTD. We are registered as a Limited Liability Company in Dubai International Financial Centre with company number CL5840 and have our registered office at Dubai International Financial Centre, Innovation Hub, Gate Avenue, Zone D, Level 1, Office 9, Dubai, UAE, 00000, United Arab Emirates.
If you have any queries or concerns regarding www.promo.myffin.com or the information contained on it, please contact us at hello@myffin.com.
Prohibited Uses
You may only use our site for lawful purposes. You may not use our site:
(a) in any way that breaches any applicable local, national or international law or regulation;
(b) in any way that is unlawful or fraudulent or has any unlawful or fraudulent purpose or effect;
(c) for the purpose of harming or attempting to harm minors in any way;
(d) to send, knowingly receive, upload, download, use or re-use any material which does not comply with our Content Standards (see below);
(e) to transmit, or procure the sending of, any unsolicited or unauthorised advertising or promotional material or any other form of similar solicitation (spam); or
(f) to knowingly transmit any data, send or upload any material that contains viruses, Trojan horses, worms, time-bombs, keystroke loggers, spyware, adware or any other harmful programs or similar computer code designed to adversely affect the operation of any computer software or hardware.
You also agree:
(a) not to reproduce, duplicate, copy or re-sell any part of our site in contravention of the provisions of our Website Terms and Conditions https://www.promo.myffin.com/legal/privacy-and-security/; and
(b) not to access without authority, interfere with, damage or disrupt any:
(i) part of our site;
(ii) equipment or network on which our site is stored;
(iii) software used in the provision of our site; or
(iv) equipment or network or software owned or used by any third party.
Interactive Services
We may from time to time provide interactive services on our site, including:
(a) Bulletin Boards;
(b) Flash; or
(c) Chat Room,
(together, Interactive Services).
Where we provide any Interactive Service, we will provide clear information to you about the kind of service offered, if it is moderated and what form of moderation is used (including whether it is human or technical).
We will do our best to assess any possible risks for users (and, in particular, for children) from third parties when they use any Interactive Service provided on our site and we will decide in each case whether it is appropriate to use moderation of the relevant service (including what kind of moderation to use) in light of those risks. However, we are under no obligation to oversee, monitor or moderate any Interactive Service we provide on our site and we expressly exclude our liability for any loss or damage arising from the use of any Interactive Service by a user in contravention of our content standards, whether the service is moderated or not.
The use of any of our Interactive Services by a minor is subject to the consent of their parent or guardian. We advise parents who permit their children to use an Interactive Service that it is important that they communicate with their children about their safety online, as moderation is not fool proof. Minors who are using any Interactive Service should be made aware of the potential risks to them.
Where we do moderate an Interactive Service, we will normally provide you with a means of contacting the moderator, should a concern or difficulty arise.
Content Standards
These Content Standards apply to all material which you contribute to our site (Contribution) and to any Interactive Services associated with it.
The Content Standards must be complied with in spirit as well as to the letter. The Content Standards apply to each part of any Contribution as well as to its whole.
Myffin Tech LTD will determine, in its absolute discretion, whether a Contribution breaches the Content Standards.
A Contribution must:
(a) be accurate (where it states facts);
(b) be genuinely held (where it states opinions); and
(c) comply with the law applicable in Dubai International Financial Centre and in any country from which it is posted.
A Contribution must not:
(a) be defamatory of any person;
(b) be obscene, offensive, hateful or inflammatory;
(c) promote sexually explicit material;
(d) promote violence or racial or religious hatred;
(e) promote discrimination based on race, sex, sexual orientation, religion, nationality, disability or age;
(f) infringe any copyright, database right or trade mark of any other person or any other intellectual property rights;
(g) be likely to deceive any person;
(h) breach any legal duty owed to a third party, such as a contractual duty or a duty of confidence;
(i) promote any illegal activity;
(j) be in contempt of court;
(k) be threatening, abusive or invade another’s privacy, or cause annoyance, inconvenience or needless anxiety;
(l) be likely to harass, upset, embarrass, alarm or annoy any other person;
(m) impersonate any person or misrepresent your identity or affiliation with any person;
(n) give the impression that the Contribution emanates from Myffin Tech LTD, if this is not the case;
(o) advocate, promote or incite any party to commit, or assist any unlawful or criminal act such as copyright infringement or computer misuse;
(p) contain a statement which you know or believe, or have reasonable grounds for believing, that members of the public to whom the statement is, or is to be, published are likely to understand as a direct or indirect encouragement or other inducement to the commission, preparation or instigation of acts of terrorism; or
(q) contain any advertising or promote any services or web links to other sites.
You confirm that in respect of all Contributions submitted by you, you own the rights in everything you submit or if you do not, you have obtained the relevant permissions from the rights owner to submit that Contribution. We will not be responsible or liable to any third party, for the content or accuracy of any Contribution submitted by you and if we become responsible or liable in any way, you agree to fully indemnify us for any costs, losses or any such other amounts which we have incurred as a result of this.
Breach of this Policy
We will determine, in our sole discretion, whether there has been a breach of this Policy through your use of our site. When we consider that a breach of this Policy has occurred, we may take such action as we deem appropriate.
Failure to comply with this Policy constitutes a material breach of the Website Terms and Conditions https://www.promo.myffin.com/legal/privacy-and-security/ upon which you are permitted to use our site, and may result in our taking any of the following actions:
(a) immediate, temporary or permanent withdrawal of your right to use our site;
(b) immediate, temporary or permanent removal of any Contribution uploaded by you to our site;
(c) issue of a warning to you;
(d) legal proceedings against you for reimbursement of all costs on an indemnity basis (including reasonable administrative and legal costs) resulting from the breach;
(e) further legal action against you; or
(f) disclosure of such information to law enforcement authorities as we reasonably feel is necessary or as required by law.
We exclude our liability for all action we may take in response to breaches of this Policy. The actions we may take are not limited to those described above and we may take any other action we reasonably deem appropriate.
Severability
In the event any provision or part-provision of this Policy is found by any court or other authority of competent jurisdiction to be invalid, unlawful or unenforceable, that provision or part-provision shall, to the extent required, be deemed not to form part of this Policy and the validity and enforceability of the other provisions of this Policy shall not be affected.
Variation
Myffin Tech LTD may at its sole discretion amend this Policy at any time. Every time you wish to use our website, please check this Policy and the Website Terms and Conditions to ensure you understand the terms that apply at that time.
Governing Law and Jurisdiction
This Policy shall be governed by, and construed in accordance with, the laws of England and Wales. Any dispute arising out of or in connection with this Policy, including any question regarding its existence, validity or termination, or arising from or related to use of our website, shall be subject to the exclusive jurisdiction of the Courts of Dubai International Financial Centre.
WEBSITE ACCEPTABLE USE POLICY
Our website, www.promo.myffin.com, is operated by MYFFIN TECH LTD a Limited Liability Company in Dubai International Financial Centre with company number CL5840 and whose registered office is at Dubai International Financial Centre, Innovation Hub, Gate Avenue, Zone D, Level 1, Office 9, Dubai, UAE, 00000, United Arab Emirates.
Where we use we, our or us in this notice, we mean MYFFIN TECH LTD unless we say otherwise.
Where we use our site in this notice, we mean www.promo.myffin.com.
Updates
We keep this Cookie Notice under regular review and may update it at any time. Please take a look at the "Last Updated" section at the bottom of this Cookie Notice to see when it was last changed. Any changes in this Cookie Notice will become effective when we make the revised Cookie Notice available on or through our site. We encourage you to check this Cookie Notice on a regular basis.
What are cookies?
Cookies are text files containing small amounts of information which are downloaded to your device when you visit our site. Our site recognises those cookies on each subsequent visit, enabling our site to recognise you.
Unless you have adjusted your browser settings to refuse cookies (and details of how to do this are signposted at the end of this notice), our site will set cookies as soon as you visit our site.
How and why we use cookies
We may use cookies on our site to:
(a) recognise you whenever you visit our site;
(b) remember the notifications you've seen so that we don't show them to you again;
(c) allow you to navigate between pages efficiently; and
(d) measure how you use our site so it can be updated and improved to give you the best possible experience on our site.
The information we obtain from our use of cookies will not usually contain information from which you can easily be identified, such as your name. However, we do collect some personal data relating to your computer or other electronic device, such as your IP address, your browser and other internet log information.
In most cases we will need your consent to use cookies on our site. The exception to this is where the cookie is essential for us to provide you with a service you have requested.
When you open our site in your browser a cookie pop up message will be displayed and this will ask you for your consent for non-essential cookies to be placed on your device. If you do not click to accept cookies but you continue to use our site without disabling cookies, we will consider this to mean that you accept our use of these non-essential cookies. A record of your acceptance will be stored in a functional cookie for 30 days, after which the cookie will expire and the cookie pop up message will be displayed again.
You may withdraw your consent or acceptance at any time by following the instructions for disabling cookies, signposted at the end of this Cookie Notice.
We use the following cookies on our site:
Essential Cookies
These cookies are essential to enable you to move around our site and use its features, such as accessing secure areas of our site. Without these cookies, services you have asked for cannot be provided.
COOKIE NOTICE
Essential Third Party Cookies
Third parties' cookies are used to provide important functionality to our site, as well as collecting anonymous user data for analysis.
Functional Cookies
These non-essential cookies allow our site to remember choices you make. The information these cookies collect may be anonymised and they cannot track your browsing activity on other sites.
Third Party Performance Cookies
These non-essential cookies collect information about how visitors use our site e.g. which pages visitors go to most often and if they get error messages from web pages. These cookies don't collect information that identifies a visitor. All information these cookies collect is aggregated and therefore anonymous. It is only used to improve how a website works.
Where to find more information
You can adjust the settings in your web browser to determine whether sites can set cookies on your computer. More information about cookies and how to manage them, specific to your browser, can be found at https://ico.org.uk/for-the-public/online/cookies/ and www.allaboutcookies.org.
If you have any further questions, comments or requests regarding our Cookie Notice or how we use cookies on our site, please contact us at hello@myffin.com.
Last Updated
This cookies notice was last reviewed and updated on 30 August 2022.
Introduction
Welcome to Myffin Tech LTD’s privacy policy.
Myffin Tech LTD respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
Please use the Glossary to understand the meaning of some of the terms used in this privacy policy.
1. Important information and who we are
Purpose of this Privacy Policy
This privacy policy aims to give you information on how Myffin Tech LTD collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter, purchase a product or service, or take part in a competition.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.
Controller
This privacy policy is issued on behalf of all companies in the Myffin Tech LTD Group from time to time so when we mention Myffin Tech LTD, we, us or our in this privacy policy, we are referring to the relevant company in the Myffin Tech LTD Group responsible for processing your data. Myffin Tech LTD 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:
Myffin Tech LTD
Email address:
hello@myffin.com
Postal address:
Dubai International Financial Centre, Innovation Hub, Gate Avenue, Zone D, Level 1, Office 9, Dubai, UAE, 00000, 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:
(a) you are resident;
(b) you work; or
(c) 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 30 August 2022.
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
Personal data, or personal information, means any information about an individual from which that person can be identified (either directly or indirectly). It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
(a) Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender;
(b) Contact Data includes billing address, delivery address, email address and telephone numbers;
(c) Financial Data includes bank account and payment card details;
(d) Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us;
(e) Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website;
(f) Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses;
(g) Usage Data includes information about how you use our website, products and services; and
(h) Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy 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 is your personal data collected?
We use different methods to collect data from and about you including through:
(a) Direct interactions. You may give us your personal data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
(i) apply for our products or services;
(ii) create an account on our website;
(iii) subscribe to our service or publications;
(iv) request marketing to be sent to you;
(v) enter a competition, promotion or survey; or
(vi) give us feedback or contact us.
(b) Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookie Notice https://www.promo.myffin.com/legal/privacy-and-security/ for further details.
(c) Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below.
(d) Technical Data from the following parties:
(i) analytics providers such as Google based outside the EU;
(ii) advertising networks based inside and outside the EU; and
(iii) search information providers based inside and outside the EU.
(e) Contact, Financial and Transaction Data from providers of technical, payment and delivery services based inside and outside the EU.
(f) Identity and Contact Data from data brokers or aggregators based inside and outside the EU.
(g) Identity and Contact Data from publicly available sources such as the Companies House and the Electoral Register based inside the EU.
4. How we use your Personal Data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data where:
(a) we need to perform the contract we are about to enter into or have entered into with you;
(b) it is necessary for our Legitimate Interests (or those of a third party) and your interests and fundamental rights do not override those interests; or
(c) we need to comply with a legal obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your Personal Data
We have set out below, in a table format, a description of all the ways we plan to use your personal data and which of the legal bases we rely on to do so. We have also identified what our Legitimate Interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Purpose/Activity
Type of data
Lawful basis for processing including basis of Legitimate Interest
To register you as a new customer
(a) Identity
(b) Contact
Performance of a contract with you
To process and deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us

(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our Legitimate Interests (to recover debts due to us)

To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our Legitimate Interests (to keep our records updated and to study how customers use our products/services)
To enable you to participate in a prize draw, competition or complete a survey
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our Legitimate Interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Identity
(b) Contact
(c) Technical
(a) Necessary for our Legitimate Interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical
Necessary for our Legitimate Interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
(a) Technical
(b) Usage
Necessary for our Legitimate Interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you
(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
(f) Marketing and Communications
Necessary for our Legitimate Interests (to develop our products/services and grow our business)
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased from us and you have not opted out of receiving that marketing.
Third-party marketing
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
Cookies
A cookie is a small text file which is placed onto your device when you access our website. We use cookies and other online tracking devices to make your online experience more efficient and enjoyable. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Notice https://www.promo.myffin.com/legal/privacy-and-security/.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. Disclosures of your Personal Data
We may share your personal data with the parties set out below for the purposes set out in the table above in the Purposes for which we will use your Personal Data section.
(a) Internal Third Parties: companies in the Myffin Tech LTD Group;
(b) External Third Parties: including service providers and professional advisors to Myffin Tech LTD Group;
(c) 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;
(d) any other third party if we are under a duty to disclose or share your personal data to comply with any legal obligation, or to protect the rights, property and or safety of Myffin Tech LTD, our personnel or others; and
(e) 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.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. International Transfers
We share your personal data within the Myffin Tech LTD 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:
(a) 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;
(b) 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
(c) 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 unauthorised 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 unauthorised 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
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil 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 unauthorised 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.
In some circumstances you can ask us to delete your data: see Your Legal Rights at section 9 below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Whilst we continue to process your personal data we will ensure that it is treated in accordance with this privacy policy. Otherwise, we securely erase your information once it is no longer needed.
9. 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:
(a) 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;
(b) 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;
(c) 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;
(d) 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;
(e) 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:
(i) where you want us to establish the data’s accuracy;
(ii) where our use of the data is unlawful but you do not want us to erase it;
(iii) 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
(iv) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it;
(f) 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
(g) 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.
10. 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.

WEBSITE PRIVACY POLICY
Please read these Website Terms of Use carefully before using the site.
Introduction
Thank you for visiting www.promo.myffin.com.
In these website terms of use (Terms), references to we, us, our means Myffin Tech LTD. References to you and your are to users of our website.
By using our website you accept these Terms
These Terms, together with the documents referred to in it, set out the terms and conditions on which you make use of www.promo.myffin.com. Please read these Terms carefully before you start to use www.promo.myffin.com. By using our website, you confirm that you accept these Terms and that you agree to comply with them. If you do not agree to these Terms you must not use our website.
Other Terms that may apply to you
These Terms refer to the following additional terms, which also apply to your use of our website:
(a) our Privacy Policy https://www.promo.myffin.com/legal/privacy-and-security/;
(b) our Acceptable Use Policy https://www.promo.myffin.com/legal/privacy-and-security/, which sets out the permitted uses and prohibited uses of our site. When using our site, you must comply with this Acceptable Use Policy;
(c) our Cookie Notice https://www.promo.myffin.com/legal/privacy-and-security/, which sets out information about the cookies on our site; and
(d) if you purchase goods from our site, our terms and conditions of supply https://www.promo.myffin.com/legal/privacy-and-security/ will apply to the sales.
Who we are and how to contact us
www.promo.myffin.com is a website operated by Myffin Tech LTD. We are registered as a Limited Liability Company in Dubai International Financial Centre with company number CL5840 and have our registered office at Dubai International Financial Centre, Innovation Hub, Gate Avenue, Zone D, Level 1, Office 9, Dubai, UAE, 00000, United Arab Emirates.
If you have any queries or concerns regarding www.promo.myffin.com or the information contained on it, please contact us at hello@myffin.com.
Website Content
The content on our website is provided on an "as is" basis and all information, commentary and other materials displayed on our website are intended for general information purposes only. It is not intended to amount to advice on which you should rely. You must obtain professional or specialist advice before taking, or refraining from, any action on the basis of the content on our website.
We update our website regularly and may change the content at any time. Although we make reasonable efforts to update the information on our website, we make no representations, warranties or guarantees, whether express or implied, that the content on our site is accurate, complete or up-to-date. Therefore, we disclaim all liability and responsibility arising as a result of any reliance placed on such information, commentary or other materials contained on www.promo.myffin.com by any visitor to our website or by anyone who may be informed of any of its content.
Restrictions on access and use
Website access
Our site is made available free of charge. We do not guarantee that our site, or any content on it, will always be available or be uninterrupted. If our website is unavailable for any reason and at any time (including for any period of time), we shall not be liable to you for such an occurrence.
To register on our website you must be 18 years or older. Only one registration is allowed per person and once registered, you must ensure you keep your registration information up-to-date.
Suspension, withdrawal and restriction of access
We may in our absolute discretion, suspend, withdraw or restrict access to all or some parts of our website to any persons, which shall include, for the avoidance of doubt, users who have registered with us.
Termination of access
We may in our absolute discretion, terminate your access to www.promo.myffin.com at any time and without notice.
User ID and password
If you establish an account on www.promo.myffin.com you are responsible for maintaining the confidentiality of your user ID and password, and you are responsible for all activities that occur under that user ID or password. You agree that you will not allow anyone to use your account and that you will not use anyone else's account.
We have the right to disable any user ID or password, whether chosen by you or allocated by us, at any time, if in our reasonable opinion you have failed to comply with any of the provisions of these Terms.
If you know or suspect that your user ID or password has been unlawfully disclosed or there has been a known or possible breach of security, you must promptly notify us at hello@myffin.com.
How you may use material on our site
All intellectual property rights contained in the website and all materials published on the website are owned and/or licensed by us with all such rights reserved.
Except as expressly provided in these Terms, no part of www.promo.myffin.com may be copied, reproduced, uploaded, posted, publicly displayed, encoded, translated, transmitted or distributed in any way (including mirroring) to any other computer, server, website or other medium for publication or distribution or for any commercial enterprise, without the express written consent of Myffin Tech LTD.
You may download publicly-available content on www.promo.myffin.com only for your personal, non-commercial use, provided that:
(a) you keep intact all copyright and other proprietary notices; and
(b) if your copying or use of copyrighted materials on www.promo.myffin.com is other than "fair use" under applicable copyright laws, you must seek permission directly from us.
If you print off, copy or download any part of our website in breach of these Terms, your right to use our website will cease immediately and you must, at our option, return or destroy any copies of the materials you have made.
Linking to and from our site
Where our site contains links to other sites and resources provided by third parties, these links are provided for your information only. Such links should not be interpreted as approval by us of those linked sites or information you may obtain from them. We have no control over the contents of those sites or resources. We exclude, to the fullest extent permitted by law, all liability that may arise in connection with or as a result of such external site material causing any damage, costs, injury or financial loss of any kind.
You may link to our home page, provided you do so in a way that is fair and legal and does not damage, or take advantage of, our reputation. You must not establish a link in a way which suggests any form of association, approval or endorsement on our part where none exists. You must not establish a link to our site in any site that is not owned by you.
Our site must not be framed on any other site, nor may you create a link to any part of our site other than the home page. We reserve the right to withdraw linking permission without notice. The site in which you are linking must comply in all respects with the content standards set out in our Acceptable Use Policy https://www.promo.myffin.com/legal/privacy-and-security/. If you wish to link to or make any use of content on our site other than that set out above, please contact us at hello@myffin.com.
Uploading content to our website
Whenever you make use of a feature that allows you to upload content to our website, or to make contact with other users of our website, you must comply with the content standards set out in our Acceptable Use Policy https://www.promo.myffin.com/legal/privacy-and-security/.
You warrant that any such contribution does comply with those content standards, and you will be liable to us and indemnify us for any breach of that warranty. This means you will be responsible for any loss or damage we suffer as a result of your breach of warranty.
Any content you upload to our website will be considered non-confidential and non-proprietary. You retain all of your ownership rights in your content, but you are required to grant us and other users of our site a limited licence to use, store and copy that content and to distribute and make it available to third parties. We also have the right to disclose your identity to any third party who is claiming that any content posted or uploaded by you to our website constitutes a violation of their intellectual property rights, or of their right to privacy.
We have the right to remove any posting you make on our website if, in our opinion, your post does not comply with the content standards set out in our Acceptable Use Policy https://www.promo.myffin.com/legal/privacy-and-security/.
You are solely responsible for securing and backing up your content.
User-generated content is not approved by us
This site may include information and materials uploaded by other users of the site, including to bulletin boards and chat rooms. This information and these materials have not been verified or approved by us. The views expressed by other users on our site do not represent our views or values. If you wish to complain about information and materials uploaded by other users please contact us at hello@myffin.com.
We are not responsible for viruses and you must not introduce them
We do not guarantee that our site will be secure or free from bugs or viruses.
You are responsible for configuring your information technology, computer programs and platform to access our site. You should use your own virus protection software.
You must not misuse our site by knowingly introducing viruses, trojans, worms, logic bombs or other material that is malicious or technologically harmful. You must not attempt to gain unauthorised access to our site, the server on which our site is stored or any server, computer or database connected to our website. You must not attack our site via a denial-of-service attack or a distributed denial-of service attack. We will report any such breach to the relevant law enforcement authorities and we will co-operate with those authorities by disclosing your identity to them. In the event of such a breach, your right to use our site will cease immediately.
Data Protection and Privacy
We shall comply with all applicable data protection legislation, including the General Data Protection Regulation ((EU) 2016/679), and any other national implementing laws, regulations and secondary legislation relating to data protection or privacy, as each of the foregoing may be amended, updated, consolidated, replaced and/or re-enacted from time to time.
We shall use and process your personal information in accordance with our Cookie Notice https://www.promo.myffin.com/legal/privacy-and-security/ and Privacy Policy https://www.promo.myffin.com/legal/privacy-and-security/.
Our Liability
Whilst we try to ensure that all information on www.promo.myffin.com is accurate, no guarantees, representations or warranties are given that the content of our website is accurate, complete, up-to-date or error free. Use of www.promo.myffin.com is entirely at your own risk.
To the fullest extent permitted by law, we hereby expressly exclude:
(a) all conditions, warranties and other terms which might otherwise be implied by statute, common law or the law of equity; and
(b) any liability for any direct, indirect or consequential loss or damage incurred by any user in connection with our website or in connection with the access, use, inability to use, or results of the use of our website, any websites linked to it and any materials posted on it, including liability for:
(i) loss of business;
(ii) loss of income or revenue;
(iii) loss of profits or contracts;
(iv) loss of anticipated savings;
(v) loss of data;
(vi) loss of goodwill;
(vii) wasted management or office time;
(viii) loss or damage caused to any equipment or software; or
(ix) any other loss or damage of any kind, however arising and whether caused by tort (including negligence), breach of contract or otherwise, even if foreseeable.
We will not be liable for any loss or damage caused by a distributed denial-of-service attack, viruses, malicious code or other technologically harmful material that may infect your computer equipment, computer programs, data or other proprietary material due to your use of www.promo.myffin.com or to your downloading of any material posted on it, or on any website linked to it.
This does not affect our liability for death or personal injury arising from our negligence, nor our liability for fraud or fraudulent misrepresentation, or any other liability which cannot be excluded or limited under applicable law.
Severability
In the event any provision or part-provision of these Terms is found by any court or other authority of competent jurisdiction to be invalid, unlawful or unenforceable, that provision or part-provision shall, to the extent required, be deemed not to form part of these Terms and the validity and enforceability of the other provisions of these Terms shall not be affected.
Variation
Myffin Tech LTD may at its sole discretion amend these Terms at any time. Every time you wish to use our website, please check these Terms to ensure you understand the terms that apply at that time.
Governing Law and Jurisdiction
These Terms shall be governed by, and construed in accordance with, the laws of England and Wales. Any dispute arising out of or in connection with these Terms, including any question regarding their existence, validity or termination, or arising from or related to use of our website, shall be subject to the exclusive jurisdiction of the Courts of Dubai International Financial Centre.

WEBSITE TERMS OF USE