Privacy Policy
Welcome to BrewScanner and thank you for your interest in this Privacy Policy! This Privacy Policy describes our practices for collecting, using, protecting and disclosing the Personal Data we collect from you when you visit our website and use our services. Welcome to BrewScanner and thank you for your interest in this Privacy Policy! This Privacy Policy describes our practices for collecting, using, protecting and disclosing the Personal Data we collect from you when you visit our website and use our services.
GENERAL INFORMATION
What law applies?
In principle, we will only use your Personal Data in accordance with the applicable data protection laws, in particular the UAE`s Federal Decree-Law No. 45 of 2021 (“Law No. 45”), and the EU`s counterpart the General Data Protection Regulation (“GDPR”).
What is Personal Data?
Personal Data is any information relating to personal or material circumstances that relates to an identified or identifiable individual. This includes, for example, your name, date of birth, e-mail address, postal address, or telephone number as well as online identifiers such as your IP address.
What is processing?
“Processing” means any operation or set of operations which is performed upon Personal Data, whether or not by automatic means. The term is broad and covers virtually any handling of data.
Who is responsible for data processing?
The Data Controller within the meaning of Law No. 45, and the GDPR is BrewScanner Global FZ LLC, FDRK5500, Compass Building, Al Shohada Road, AL Hamra Industrial Zone-FZ, Ras Al Khaimah, United Arab Emirates (“BrewScanner”, “we”, “us”, or “our”). If you have any questions about this policy or our data protection practices, please contact us using info@brewscanner.ae.
What are the legal bases of processing?
In accordance with Law No. 45 and the GDPR, we have to have at least one of the following legal bases to process your Personal Data:
- Consent – This is where we have asked you to provide explicit permission to process your data for a particular purpose.
- Contract – This is where we process your information to fulfill a contractual arrangement we have made with you or reply to your messages, e-mails, posts, calls, etc.
- Legitimate Interests – This is where we rely on our interests as a reason for processing, generally this is to provide you with the best products and service in the most secure and appropriate way. Of course, before relying on any of those legitimate interests we balance them against your interests and make sure they are compelling enough and will not cause any unwarranted harm.
- Legal Obligation – This is where we have a statutory or other legal obligation to process the information, such as for archiving or the investigation of crime.
DATA WE COLLECT AUTOMATICALLY
Log data
When you access and use our website, we collect the Personal Data that your browser automatically transmits to our server. This is technically necessary for us to display our website and to ensure its stability and security. In this sense, we collect the following data: i) IP address of the requesting computer, ii) Date and time of access, iii) name and URL of the file accessed, iv) website from which the access was made (referrer URL), v) browser used and, if applicable, the operating system of your computer as well as the name of your access provider. The legal basis is our legitimate interest.
Hosting
We use the hosting services of Hostinger International, Ltd for the purpose of hosting and displaying our website. Hostinger does so on the basis of processing on our behalf, and that also means that all data collected on our website is processed on Hostinger’s France based servers. The basis for processing is our legitimate interest, and the initiation and/or fulfillment of a contract.
Content Management System (CMS)
We use the Content Management System (CMS) of WordPress by Automattic Inc, to publish and maintain the created and edited content and texts on my website. This means that all content and texts submitted to my website is transferred to WordPress. The legal basis for this processing is our legitimate interest.
Fonts
We integrate Font Awesome of Fonticons Inc, and Bunny Fonts of bunny.net. To enable the display of fonts, a connection to Fonticons’ and Bunny Fonts’ server is established when our website is accessed. This enables Fonticons, and Bunny.net to determine which website sent the request and to which IP address the display of the font is to be transmitted. The integration is based on our legitimate interest.
Cookies
We use so-called cookies on our website. Cookies are pieces of information that are transmitted from our web server or third-party web servers to your web browser and stored there for later retrieval. Cookies may be small files or other types of information storage. There are different types of cookies: a) Essential Cookies. Essential cookies are cookies to provide a correct and user-friendly website; and b) Non-essential Cookies. Non-essential Cookies are any cookies that do not fall within the definition of essential cookies, such as cookies used to analyze your behavior on a website (“analytical” cookies) or cookies used to display advertisements to you (“advertising” cookies).
As set out in Law No. 45 and the EU`s Privacy and Electronic Communications Directive (“PECD”), we need to obtain consent for the use of Non-essential Cookies. For further information on the cookies we use, please refer to our Cookie Policy. The legal basis for processing is our legitimate interest and your consent.
Cookie consent
Our website uses a cookie consent tool, to obtain your consent to the storage of cookies and to document this consent. When you enter our website, the following Personal Data is transferred to us: i) Your consent(s) or revocation of your consent(s); ii) Your IP address; iii) Information about your browser; iv) Information about your device; v) Time of your visit to our website. The basis for processing is our legitimate interest and your consent.
Economic analyses and market research
For business reasons, we analyze the data we have on web and server traffic patterns, website interactions, browsing behavior etc. The analyses serve us alone and are not disclosed externally and processed using anonymous analyses with summarized and or anonymized values. For this purpose we use Google Analytics. The legal basis is our legitimate interest and your consent. For further information, please refer to our Cookie Policy.
Links to other websites
Please note that if you use a link from our website to a third-party website, that third-party may also set new cookies that are not covered by this policy. In such cases, we recommend that you read the cookie policy on the third-party website itself.
DATA WE COLLECT DIRECTLY
Contacting us
If you contact us, we store and process the following data from you: Name, e-mail address, telephone number as well as other Personal Data that you provide when contacting us. This data is collected and processed exclusively for the purpose of contacting you and processing your request and then deleted, provided there is no legal obligation to retain it. The legal bases for processing are contract and our legitimate interest.
Providing our services
The protection of your data is particularly important to us in the performance of our services. We therefore only want to process as much Personal Data as is absolutely necessary. Nevertheless, we rely on the processing of certain Personal Data, to fulfill our contractual obligations to you or to carry out pre-contractual measures.
Newsletter
We use the services of Mailchimp by Intuit Inc to send our Newsletter and if you subscribe we will use your email address to send you information about products, promotions, news and customer satisfaction surveys. You can find an unsubscribe link at the end of each newsletter. The legal basis is your consent.
Aggregated Data
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose including improving our website and Services. 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. 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.
Administration, financial accounting, office organization, contact management
We process data in the context of administrative tasks as well as organization of our business, and compliance with legal obligations, such as archiving. In this regard, we process the same data that we process in the course of providing our contractual services. The processing bases are our legal obligations and our legitimate interest.
SOCIAL MEDIA
General
We are present on social media (currently, Facebook, Instagram, YouTube (Google LLC), TikTok, and X) and if you contact or connect with us via social media websites, we and the relevant social media website are jointly responsible for the processing of your data and enter into a so-called joint controller agreement. The legal basis is our legitimate interest, your consent or, in some cases, the initiation of a contract.
When you visit our profiles and interact with us and others
When you visit our social media profiles, we, as the operator of the profile, process your actions and interactions with our profile (e.g., the content of your messages, enquiries, posts or comments that you send to us or leave on our profile or when you like or share our posts) as well as your publicly viewable profile data (e.g., your name and profile picture).
Which Personal Data from your profile is publicly viewable depends on your profile settings, which you can adjust yourself in the settings of your social media account.
Please take care not to transmit or share sensitive data or confidential information (e.g., application documents, bank or payment data) via social media platforms; we recommend that you use a more secure means of transmission (e.g. e-mail).
MARKETING
General
Insofar as you have given us your separate consent to process your data for marketing and advertising purposes, we are entitled to contact you for these purposes via the communication channels you have given your consent to.
You may give us your consent in a number of ways including by selecting a box on a form where we seek your permission to send you marketing information, or sometimes your consent is implied from your interactions or contractual relationship with us. Where your consent is implied, it is on the basis that you would have a reasonable expectation of receiving a marketing communication based on your interactions or contractual relationship with us.
Direct Marketing generally takes the form of email or SMS but may also include other less traditional or emerging channels. These forms of contact will be managed by us, or by our contracted service providers. Every directly addressed marketing sent or made by us or on our behalf will include a means by which you may unsubscribe or opt out.
SMS and other Mobile Messages
We may also send promotional messages in various formats including mobile or WhatsApp. Promotional messages advertise and promote our business and services and may include promotions, specials and other marketing offers. Mobile messages may be sent using an automated technology, including an autodialer, automated system, or automatic telephone dialing system. Our message frequency will vary but will not exceed 5 messages per Week (excluding appointment reminders).
You agree that we may send you messages regarding the foregoing topics or any topic and that promotional messages and/or calls may be made or placed using different telephone numbers or short codes. We do not charge for mobile messages sent but you are responsible for any message and data rates imposed by your mobile provider, as standard data and message rates may apply for SMS and MMS alerts.
In case of WhatsApp messages we store and use the mobile phone number and profile information and status, you use and – if provided – your first and last name. The legal basis is both your consent and our legitimate interest.
Opt-In
By providing your mobile phone number to us, you are voluntarily opting in and you agree to receive recurring mobile or WhatsApp messages from us at the mobile phone number associated with your opt-in. You agree that any mobile phone number you provide to us is a valid mobile phone number of which you are the owner or authorized user. If you change your mobile phone number or are no longer the owner or authorized user of the mobile phone number, you agree to promptly notify us.
Opt-Out and Support
You may opt-out at any time. If you wish to opt- out and stop receiving calls from us please tell us on the phone directly and if you no longer agree to receive mobile messages from us, reply STOP, QUIT, CANCEL, OPT-OUT, and/or UNSUBSCRIBE to any mobile message from us. You may continue to receive text messages for a short period while we process your request, and you may receive a one-time opt-out confirmation message. You understand and agree that the foregoing is the only reasonable method of opting out. For support, reply HELP to any mobile message from us. Our mobile messaging platform may not recognize requests that modify the foregoing commands, and you agree that we and our service providers will not be liable for failing to honor requests that do not comply with the requirements in these Terms.
Changes
We may also change the telephone number or short code we use and we will notify you of any such change. You acknowledge that any requests sent to a telephone number or short code that has been changed may not be received by us and we will not be responsible for failing to honor a request sent to a telephone number or short code that has been changed.
Affiliate Marketing
We also participate in Affiliate Marketing Programs. In general Affiliate Marketing Programs programs are designed to provide a means for website owners to earn advertising fees by advertising and linking. In our case, we may display certain products of our Vendors in specific parts of our website. Depending on the product and the relevant advertisement, you may also be redirected to the relevant Vendor’s website, or request further information and or services. Being redirected requires your i) IP address; and ii) other technical data related to your access to be disclosed and all data collected through is subject to relevant Vendors’ Privacy Policy and we have no influence over their privacy practices. Finally, you will never be charged a fee through one of our affiliate links, however you may get a discounted rate of the relevant affiliate’s services and we will make a small commission. Our editorial content is not influenced by our Vendors or similar affiliate advertisers partnerships.
ADVERTISING
We would like to show you interesting advertising outside of our website and use various third-party tools and cookies for this purpose. These collect and process information about your activities on our website – for example, which products you are interested in or which pages you visit. By knowing what you are looking for and how you use our website, we can adapt our advertising to your needs. And thus increase the likelihood that you will also be shown suitable and interesting advertising outside our website.
We also analyze this data to evaluate the relevance of the advertisements and to optimize the advertisements for you. Through the tools, your browser regularly establishes a connection to the server of the tool provider when you visit our website. For some tools, we have no direct influence on what data is processed by the providers. The following Personal Data may be processed by third-party providers i) HTTP header information (e.g., IP address, web browser, website URL, date and time); ii) measuring pixel-specific data (e.g., pixel ID and cookie ID); and iii) additional information about visits to our website (e.g., orders placed, products clicked on). The legal bases for processing are our legitimate interest and your consent in case of cookies. For further information, please refer to our Cookie Policy.
PRINCIPLES OF PROCESSING PERSONAL DATA
Storage and Retention
As far as necessary, we process and store your Personal Data for the duration of our business relationship, which also includes, for example, the initiation and execution of a contract.
In addition, we are subject to various storage and documentation obligations, which result from the minimum statutory retention periods in accordance with the Ras Al Khaimah Economic Zone Authority and Ministry of Finance, among others. The retention and documentation periods specified vary between two to eight years.
Security
Our website uses SSL or TLS encryption to ensure the security of data processing and to protect the transmission of confidential content, such as orders, login data or contact requests that you send to us. We have also implemented numerous security measures (“technical and organizational measures”) for example encryption or need to know access, to ensure the most complete protection of Personal Data processed through our website.
Nevertheless, internet-based data transmissions can always have security gaps, so that absolute protection cannot be guaranteed. And databases or data sets that include Personal Data may be breached inadvertently or through wrongful intrusion. Upon becoming aware of a data breach, we will notify all affected individuals whose Personal Data may have been compromised as expeditiously as possible after which the breach was discovered.
Special Category Data
Unless specifically required when using our services and explicit consent is obtained for that service, we do not process special category data.
Automated decision-making
Automated decision-making is the process of making a decision by automated means without any human involvement. Automated decision-making including profiling does not take place.
Do Not Sell
We do not sell your Personal Data.
Sharing and Disclosure
We will not disclose or otherwise distribute your Personal Data to third parties unless this is a) necessary for the performance of our services and, b) you have consented to the disclosure, c) or if we are legally obliged to do so e.g., by court order or if this is necessary to support criminal or legal investigations or other legal investigations or other legal proceedings; or proceedings at home or abroad or to fulfill our legitimate interests.
International Transfer
We may transfer your Personal Data to other companies as necessary for the purposes described in this Privacy Policy. In order to provide adequate protection for your Personal Data when it is transferred, we have contractual arrangements regarding such transfers. We take all reasonable technical and organizational measures to protect the Personal Data we transfer.
YOUR RIGHTS AND PRIVILEGES
Privacy rights
Under Law No. 45 and the GDPR, you can exercise the following rights:
- Right to information
- Right to rectification
- Right to deletion
- Right to data portability
- Right of objection
- Right to withdraw consent
- Right to complain to a supervisory authority
- Right not to be subject to a decision based solely on automated processing.
If you have any questions about the nature of the Personal Data we hold about you, or if you wish to exercise any of your rights, please contact us.
Updating your information
If you believe that the information we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion, or object to its processing, please do so by contacting us.
Withdrawing your consent
You can revoke consents you have given at any time by contacting us. The legality of the data processing carried out until the revocation remains unaffected by the revocation.
Access Request
In the event that you wish to make a Data Subject Access Request, you may inform us in writing of the same. We will respond to requests regarding access and correction as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days, we will tell you why and when we will be able to respond to your request. If we are unable to provide you with any Personal Data or to make a correction requested by you, we will tell you why.
Complaint to a supervisory authority
You have the right to complain about our processing of Personal Data to a supervisory authority responsible for data protection. However, we would appreciate the opportunity to address your concerns before you contact any supervisory authority.
USA SPECIFIC PROVISIONS
The following applies to all users located in the United States. While we understand and appreciate that privacy and consumer data protection laws differ as they are subject to each state’s legislature and that no data protection framework similar to Law No. 45 or GDPR exists on a federal level, we are committed to follow and apply the for your state relevant privacy rules and regulations. As of the day of drafting, the following states had enacted privacy and consumer data protection laws:
- California Consumer Privacy Act (“CCPA”) including its subsequent amendments from the California Privacy Rights and Enforcement Act (“CPRA”);
- Colorado Privacy Act (“CPA”);
- Connecticut Data Privacy Act (“CTDPA”);
- Delaware Online Privacy Protection Act (“DOPPA”);
- Indiana Consumer Data Protection Act (“ICDPA”);
- Iowa Consumer Data Protection Act (“ICDPA”);
- Montana Consumer Data Privacy Act (“MCDPA”);
- Oregon Consumer Privacy Act (“OCPA”);
- Tennessee Information Protection Act (“TIPA”);
- Texas Data Privacy and Security Act (“TDPSA”);
- Utah Consumer Privacy Act (“UCPA”); and
- Virginia Consumer Data Protection Act (“VCDPA”).
Further and under consideration of the similarities of the above provisions, no conflict should arise pursuing a uniform approach in granting all users in the USA the same rights and privileges as set out above. However, should ambiguity occur the most stringent provision is chosen to ensure the most comprehensive approach when it comes to protecting your Personal Data.
Further, the following also apply:
- “Shine the Light”
“Shine the Light” law (Civil Code Section 1798.83) requires us to respond to requests from California asking about the business’s practices related to disclosing Personal Data to third parties for the third parties’ direct marketing purposes. You may make a request about our collection and disclosure of your Personal Data using the contact details provided.
- COPPA (Children Online Privacy Protection Act)
When it comes to the collection of Personal Data from children under the age of 13 years old, the Children’s Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, United States’ consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children’s privacy and safety online. We do not specifically market to children under the age of 13 years old. - CAN SPAM Act
The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations. To be in accordance with CAN SPAM, we agree to the following: If at any time you would like to unsubscribe from receiving future emails, you can email us, and we will promptly remove you from ALL correspondence. - Telephone Consumer Protection Act (TCPA)
If we process your Personal Data for the purpose of sending you SMS marketing communications, you may manage your receipt of marketing and non-transactional communications from us by replying or texting ‘STOP’ if you receive our SMS communications. In this respect, the data processing is carried out solely on the basis of our consent in personalized direct advertising per SMS. - Controls For Do-Not-Track Features
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (‘DNT’) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, our website does not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this policy. - Right to complain
Finally, and in regard to the right to complain to a supervisory authority. You have the right to lodge a complaint about our processing of Personal Data with a supervisory authority responsible for data protection. Users based in the above mentioned States may lodge a complaint with the relevant district attorney or attorney general office. However, we would appreciate the opportunity to address your concerns before you contact any supervisory authority.
CHANGES
We may update this Privacy Policy from time to time. If we make changes to this Privacy Policy, we will revise the effective date.
EFFECTIVE DATE
Tuesday, 30th of April, 2024
QUESTIONS
If you feel that the above is not sufficient or if you have any queries as regards the collection, processing or use of your information we are looking forward to hearing from you. We will make every effort to reply as soon as possible and take into consideration any suggestions from your end.
