PRIVACY POLICY

“We”, Bridgestone Middle East & Africa FZE, P.O. Box 16813, Tower B Building, 17th Floor, JAFZA One, Jebel Ali, Dubai, UAE, process Personal data that we collect from or about “you” while you are using BRPO mobile application (“App”). Since we are based in the United Arab Emirates, we process your Personal data in compliance with the Federal Law No. 45 of 2021 (“UAE Data Protection Law”). This Privacy Policy (“Policy”) informs you how we collect and use your Personal data, how you can control its use and describes our practices concerning the data collected.

What are Personal data?

Personal data is information that directly or indirectly identifies you (the user of the App) as an individual. Direct identification occurs when we are able to identify a specific individual solely through the data we are processing (example: name, ID number, personalized email address). Indirect identification may occur if different sets of data from different sources, when combined, could identify a specific person (example: gender, birth date, licence plate number, geolocation).

How and why do we collect Personal data?

Information that you give us

You will submit and we will use your email address in the online registration process for the purpose of creating an account for you only. Your data will not be used for direct marketing.

We do not collect and process more or other types of Personal data than necessary to fulfil the respective purposes. We will only use Personal data as set forth in this Policy, unless you have specifically provided your consent to another use of your Personal data. If we intend to use your Personal data for purposes other than we originally collected them for, we will inform you in advance and, in cases where the processing is based on your consent, use your Personal data for a different purpose only with your permission.

Information we get from your use of our App

We are constantly seeking to improve your experience when you visit our App or when you are interacting with us through other means. Through your interaction with us and your use of the App, we may collect Personal data. Personal data we collect may include, but is not limited to:

device information (e.g. hardware model, operating system version, device identifiers or phone number);
log information (e.g. IP addresses, system activity, hardware settings, browser type and language, the date and time of your request).

Our lawful basis for processing your Personal data

We process your data only when we have obtained your valid consent. Your completion of the registration form constitutes your consent to our processing the provided data for the given purpose. You have the right to withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

What do we do with your Personal data?

The Personal data we are collecting from you is stored within a secured infrastructure under our management, with support of external suppliers as described in section 5 of this Policy. Depending on your use of the App, we may collect and use your Personal data for the following purposes (“the Purposes”):

registering you as a user of the App and providing you with access to the App;
ensuring that the App’s content is presented to you in the most effective manner for you and your device.

We shall not collect Personal data that are not relevant for the purposes as set out above or otherwise notified to you when we seek your consent for the processing of your Personal data, and shall not retain the data longer than necessary for those purposes or, as the case may be, for the period as determined by law. This means that we store Personal data until the consent for processing is withdrawn and there is no legal interest for keeping personal data.

In general, we will delete the personal data we collected from you if they are no longer necessary to achieve the purposes for which they were originally collected. However, we may be required to store your personal data for a longer period due to requirements by law.

The confidentiality and security of your Personal data

We take data security very seriously. We apply an appropriate level of security and have therefore implemented reasonable physical, electronic, and administrative procedures to safeguard the information we collect from accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to personal data transmitted, stored or otherwise processed. Our information security policies and procedures are closely aligned with widely accepted international standards and are reviewed regularly and updated as necessary to meet our business needs, changes in technology, and regulatory requirements. Access to your Personal data is granted only to those personnel with a business need-to-know or who require it in order to perform their duties.

Among other things, we optimize the security of your Personal data by:

using encryption where appropriate;
using password protection; and
taking all reasonable precautionary measures to ensure that our personnel who have access to your Personal data will be trained in data protection requirements and will process your Personal data exclusively in accordance with this statement and our obligations under applicable privacy laws.

In the event of a data breach containing Personal data, we will follow all applicable data breach notification laws.

To whom do we disclose your Personal data?

We will not disclose your Personal data to third parties unless it is required by law or if you give our explicit consent for such transfer of your Personal data.

User rights with regard to Personal data

As data subject you have specific legal rights relating to the Personal data we collect from you. This applies to all processing activities stipulated in this Policy. We will respect your individual rights and will deal with your concerns adequately.

The following list contains information on your legal rights which arise from applicable data protection laws:

Right to rectification: you may obtain from us rectification of Personal data concerning you.
Right to restriction: you may obtain from us restriction of processing of your Personal data, if you contest the accuracy of your Personal data for the period we need to verify the accuracy; the processing is unlawful and you request the restriction of processing rather than erasure of your Personal data; we do no longer need your Personal data but you require them for the establishment, exercise or defence of legal claims; or if you object to the processing while we verify whether our legitimate grounds override yours.
Right to access: you may ask us for information regarding Personal data that we hold about you.
Right to portability: At your request, we will transfer your Personal data to another controller, where technically feasible, provided that the processing is based on your consent or necessary for the performance of a contract. Rather than receiving a copy of your Personal data you may request that we transfer the data to another controller, specified by you, directly.
Right to erasure: You may obtain from us erasure of your Personal data, where the Personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you have a right to object further processing of your Personal data and execute this right to object to the processing; the Personal data have been unlawfully processed; unless the processing is necessary for compliance with a legal obligation which requires processing from us, in particular for statutory data retention requirements, or for the establishment, exercise or defence of legal claims.
Right to lodge a complaint: In case of an alleged infringement of applicable privacy laws, you may lodge a complaint with the data protection supervisory authority in the country you live in or where the alleged infringement occurred.

In some cases, we may not be able to clearly identify you on the basis of your Personal data due to the identifiers which you provide in your request. In such cases, where we cannot identify you as a data subject, we are not able to comply with your request to execute your legal rights as described in this section, unless you provide additional information enabling your identification.

In order to exercise your legal rights, please log your request at dataprivacymea@bridgestone.ae. If you believe that the processing of your Personal data infringes your statutory rights, you have the right to lodge a complaint with a data protection supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement.

Links

Our App may, from time to time, contain hyperlinks to websites which are not controlled by us. Although we will do our utmost to make sure that the hyperlinks on the App lead exclusively to websites which share our safety and confidentiality standards, we are not responsible for the protection or confidentiality of any data you may submit on such other websites. Before submitting information on such sites, we recommend that you read their privacy and other statements in that regard.

Minors

Individuals under the age of 16 should not provide us with their Personal data without the consent and supervision of their parent or guardian. Without such permission, we do not wish to save Personal data from such individuals, nor process or forward such data to any third parties. If we become aware that Personal data from under aged persons were inadvertently collected, we will delete such data without undue delay.

Sensitive data

We will not process special categories of Personal data concerning you (“sensitive data”). Sensitive data refer to Personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data for the purpose of uniquely identifying a natural person, health or a natural person’s sex life or sexual orientation.

Changes to this Policy

We reserve the right, at our discretion, to modify our privacy practices and update and make changes to this Policy at any time. For this reason, we encourage you to refer to this Policy on an ongoing basis. This Policy is current as of the “last revised” date which appears at the top of this page. We will treat your Personal data in a manner consistent with the Policy under which they were collected, unless we have your consent to treat them differently.

We will also keep prior versions of this Policy in an archive for your review.