Privacy Policy

[Cultivar Insurance Limited] DATA PROTECTION POLICY

Cultivar Insurance Limited (CIL) and/or its affiliates and entities collectively, we value your security and privacy.
CIL is required to comply with DIFC Authority’s Data Protection Law, DIFC Law No. 5 of 2020 (the “DP Law”), and may for certain types of personal data processing, be subject to laws from other jurisdictions.
As such, it is the policy of CIL to respect the privacy of its website services. In accordance with DIFC DP Law.
CIL collects information about you when you use or access our websites or use our online contact form for contact purposes, This online data protection policy (the “Policy”) sets out the basis on which any information, including any personal data, we collect from you, or you provide to us, will be processed by CIL.
Each time you access or use the Website Services or provide us with information, by doing so you acknowledge the practices
described in this Policy.

1. Scope and Application
This Policy applies to persons anywhere in the world who access or use CIL’s Website Services.
2. Collection of Information
Information you give us This is personal data you give us by providing information or filling in forms on the website, or by
corresponding with us (for example, by telephone, e-mail or any other digital or electronic form). It includes for example information you provide when you contact us, register for newsletters or other subscription services, or download, and when you report a problem with our Website Services.
If you contact us, we will keep at least an electronic record of such correspondence, including personal information shared at that time, in order to reply or process it as per your request.
The personal information you give us may include your name, e-mail address and phone number, and other information you choose to provide (“Personal Information” or “Personal Data”).
The Website Services collect and process Personal Data in accordance with the Data protection Law and applicable laws, including for specific, lawful purposes explained herein or at the time of collection, or for the performance of tasks carried out in your interests or the legitimate interests of CIL.
Information we collect about you and your device Each time you use our Website Services we may and often will automatically collect the following information:

  •  Technical information, including the type of mobile device you use, a unique device identifier (for example, mobile network information, your mobile operating system, the type of mobile browser you use, device token, device type, time zone setting (“Device Information”);
  • Details of your use of our Website Services including, but not limited to traffic data, weblogs and other
    communication data.
  • If you do not wish to share certain data with us or do not want us to use / share it for certain purposes (to the extent possible, in accordance with applicable laws and information in this notice), you can alter your preferences at any time. Where applicable, please check with your device provider’s instructions for further information about how to do this.

Other Information We May Collect Through Your Use of the Website Services
When you use any Website Services, we may collect Personal Data including demographic information, for example information that you submit, or that we collect, which may include, but is not limited to current residence, gender, username, mobile network information, your mobile operating system, the type of mobile
browser you use, time zone setting, device location, IP address, business activities and services.

3. Use of Personal Data
We may use Personal Data which you provide to us or we collect from you to:

  • Provide, maintain, and improve our Website Services, including, for example provide products and services you request (and send related information about them), develop new features that will
    enhance your user experience and our efficiency, provide customer support to Users, and send administrative messages, whether information-only or required by applicable law;
  • Perform internal regulatory, administrative and operational requirements, including, for example, to prevent fraud or abuse of our Website Services; to troubleshoot software bugs and operational problems; to conduct permitted data analysis, testing, and research; to ensure you and CIL are complying with internal or external legal requirements, including those that necessitate use of digital systems; and to monitor usage and activity trends;
  • Send you communications we think will be of interest to you based on your previous interactions with us, including information about products, services, promotions, news, and CIL events, where permissible under DIFC Laws and guidance, and according to any other applicable laws;
  • Notify you about changes to this Policy, or Website Services;
  • Allow you to participate in any interactive features of Website Services.
  • Keep our Website Services safe and secure; or
  • Personalize and improve the Website Services, including providing or recommend features, content, social connections, referrals, and advertisements, in accordance with your preferences, to the extent permissible by law.

4. Processing, Storage and Transfer of Personal Data

We will take all steps reasonably necessary to ensure your Personal Data is processed fairly and lawfully, in accordance with the Data protection Law, other applicable laws and this Policy. By submitting your Personal Data (including Log, Device and / or Demographic Information), we expect you to understand that such transfer, storing or processing in order for CIL to perform its general administrative functions is necessary and will be done in a proportionate, lawful manner, including but not limited to responding to enquiries you raise via the Website Services, oversight of the business entities registered in DIFC’s jurisdiction and maintaining contacts for future informational or promotional activities. Unless otherwise notified, CIL does not ordinarily rely solely on automated decision making when processing your Personal Data.
In order to conduct our operations or fulfil regulatory obligations, we must transfer the Personal Data described in this Policy to and from, and process and store it in, the United Arab Emirates and (where applicable or required) with processors in other countries, some of which may have less protective privacy laws than those where you reside. In all such cases, and generally for any processing operations, we take appropriate security measures to protect your Personal Data in accordance with this Policy.
To preserve the integrity of our databases, to carry out on-going Website Services on behalf of all Users, for research, analytics and statistics purposes and to ensure compliance with applicable laws and regulations,
we retain Personal Data submitted by Users for a reasonable length of time unless otherwise prescribed by applicable law.
CIL is not responsible for the accuracy of the information you provide and will modify or update your Personal Data in our databases when you provide updated information or ad hoc upon your request, as further outlined below. We will erase or put beyond active use your Personal Data upon request, unless we are required to retain it in accordance with DIFC or other applicable laws or to perform agreed services, in which case we align with applicable principles such as purpose specification and data minimization.
If it is not disproportionate or prejudicial, and required beyond this policy’s notices, we will contact you to let you know we are processing your personal information.
By accessing or using the Website Services to which this Policy applies, we can reasonably expect that you understand that all information submitted by you through the Website Services or otherwise to CIL may be used by CIL to support these processing operations, in accordance with applicable laws and its policies.
5. Sharing of Personal Data
We may share Personal Data which we collect about you as described in this Policy or as described at the time of collection or sharing, including as follows:

Through Our Website Services We may share Personal Data which we collect about you as described in this Policy or as described at the
time of collection or sharing, including as follows:
Through Our Website Services

We may share your Personal Data:

  • With third parties to provide you a service that you requested through a partnership or promotional
    offering made by a third party or us; or
  • With third parties with whom you choose to let us share your Personal Data, for example other
    websites that integrate with our Website Services, or those with an API or Service with which we integrate

Other Types of Data Sharing
We may share your Personal Data:

  • With CIL subsidiaries and affiliated entities, to the extent permissible by law;
  • With vendors, consultants, marketing and advertising partners, and other service providers who
    need access to such Personal Data to carry out work on our behalf or to perform a contract we enter
    into with them;
  • If we otherwise notify you and you provide your affirmative opt-in to share your data, where needed;
  • In response to a request for information by a competent authority or government entities if we
    determine that such disclosure is in accordance with, or is otherwise required by any applicable law,
    regulation, or legal process;
  • With law enforcement officials, government entities or authorities, or other third parties as required
    by applicable law;
  • With third parties in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company; or
  • With third parties in an aggregated and/or anonymized or pseudonymized form that cannot
    reasonably be used to identify you

Government Data Sharing
In some circumstances we are legally obliged to share information with public authorities or law enforcement. For example, we may be required to provide information related to a court order or where we must cooperate with supervisory authorities in handling complaints or investigations. In any scenario, we’ll attempt to satisfy ourselves that we have a lawful basis on which to share the information, document our decision making, and satisfy ourselves we have a legal basis on which to share the information. All sharing of Personal Data aligns to the extent possible with CIL Government Data Sharing Policy, which is an internal CIL policy that governs fair and lawful sharing of Personal Data requested by government entities within the UAE and elsewhere

6. Your Rights and Choices
Marketing and Preferences
CIL supports Users’ legal rights to opt-in or subsequently opt-out of receiving communications from us and our partners. You have the option to ask us not to process your Personal Data for marketing purposes and to remove it from our database, to not receive future communications or to no longer receive Website Services.

You may change your preferences at any time.
Please note that we may continue to send you transactional or service-related e-mails despite your desire to not receive promotional or marketing e-mail messages. Additionally, please note that if you elect to opt-out of or unsubscribe from receiving promotional or other similar e-mails or messaging from one of our Website
Services, you may continue to receive promotional emails from our other websites, providers, or other, nonaffiliated marketers whose services you may have accessed via CIL Website Services or Finally, while we may remove your individual contact information from our professional contacts database, please be aware that if such information is in a different, third party’s marketing directory through your request or election, you will need to request removal with such third party directly.
Access to and Correction of Your Personal Information You have the right to access information held about you. Your right of access can be exercised for any reason, at any time, in accordance with DIFC and other applicable laws.
You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete. You may also request that we restrict the processing of, erase, transfer the information you gave us from one
organisation to another, or otherwise process your Personal Data in line with the relevant articles providing for such rights set out in the DP Law or other applicable laws.
Any access request generally comes at no cost to you and we must respond within one month unless provided otherwise by the DP Law or other applicable laws. We may, where permissible, impose a reasonable fee to meet any extraordinary administrative costs in providing you with details of the information we hold about you.
When you contact us about a potential Personal Data error or query, we will endeavour to confirm or verify the information in question, then correct verified inaccuracies and respond to the original inquiry. We will endeavour to send a correction notice to businesses or others whom we know to have received the inaccurate
data, where required and / or appropriate. However, some third parties and third party sites may continue to process inaccurate data about you until their databases and display of data are refreshed in accordance with their update schedules, or until you contact them personally to ensure the correction is made in their own files.
As set out in Article 39 on the DP Law, we may not discriminate against you for exercising your rights by denying services or changing prices or quality of service, unless reasonable to do so in general, as objectively determined, and applicable to all individuals offered or receiving such benefits.

7. Security Precautions
CIL makes every effort to ensure that your Personal Data is secure on its system. CIL has staff dedicated to maintaining our data protection and security policies, periodically reviewing them and making sure that CIL employees are aware of our data protection and security practices. Unfortunately, no data transmission over
the internet can be guaranteed to be 100% secure. As a result, CIL cannot warrant or guarantee the security of any Personal Data you transmit to us, and you do so at your own risk.
CIL has established policies and procedures for securely managing information and protecting Personal Data against unauthorized access. We continually assess our data privacy, information management and security practices. We do this in the following ways:

  • Establishing policies and procedures for securely managing information;
  • Limiting employee access to viewing only necessary information in order to perform his or her
    duties;
  • Protecting against unauthorized access to Personal Data by using data encryption, authentication andvirus detection technology, as required;
  • Requiring service providers with whom we do business to comply with relevant data privacy legal and regulatory requirements;
  • Monitoring our websites through recognized online privacy and security organizations;
  • Engaging in regular third party audits of our policies and practices; and
  • Conducting background checks on employees and providing training to our employees.

If you have any further questions about our security and processing activities, please contact CIL team . To the extent permitted by applicable law, CIL expressly disclaims any liability that may arise should any other third parties obtain the Personal Data you submit through fraud or otherwise where it is no fault of CIL.
8.Cookies
A cookie is a small text file that is unique to the web browser on your computer or mobile device, which is used to retain user preferences, and enhance browsing experience (“Cookie”). CIL uses Cookies to track overall site usage and enables us to provide a better user experience. We do not use Cookies to “see” other data on your computer or determine your email address. Cookies can also allow us to tailor the content of our website so we can show you services or adverts we think you may be interested in.
The types of cookies we use on this website
Cookies are now grouped as essential or optional – we will not set optional cookies without your consent. Types of cookies we drop, and the information collected using them include but are not necessarily limited to:

Google analytics _ga
_gat
_gid
-utma
_utmb
_utmc
_utmz		 These cookies are used to monitor the performance of our site. We use the information to help us improve the site. The cookies collect information in an anonymous form, including the number of visits to our site, where visitors have come from to the site and the pages they visited. To opt out of being tracked by Google Analytics across all websites visit https://tools.google.com/dlpage/gaoptout.

Most browsers accept and maintain Cookies by default. The DIFC Data Protection Law requires that CIL entities set such collection methods to collect the bare minimum, necessary cookies in order to operate the relevant website or app. Check the ‘Help’ or ‘Settings’ menu of your browser to learn how to change your Cookie preferences. You can choose to alter Cookies settings related to the use of our Website Services, but this may limit your ability to access certain areas of the Website.
Alternatively you may wish to visit an independent source of information, www.aboutcookies.org, which contains comprehensive information on how to alter settings or delete Cookies from your computer as well as more general information about Cookies. For information on how to do this on the browser of your mobile phone you will need to refer to your handset manual or network operator for advice.
Keeping your personal information safe
Our cookies do not store personal information such as your name, address, phone number or email in a format that can be read by others. The cookies we use cannot read or search your computer, smartphone or web-enabled device to obtain information about you or your family, or read any material kept on your hard drive.
9. External Links
The Website may contain links to other websites on the Internet that are owned and operated by third parties (the “External Sites”). These links are provided solely as a convenience to you and not as an endorsement by CIL of the contents of or reliability on such External Sites. You acknowledge that CIL is not responsible for the availability of, or the information and content of any External Site. You should contact the site administrator or webmaster for those External Sites if you have any concerns regarding such links or the content located on such external Sites.

If you decide to access linked third-party websites, you do so at your own risk. CIL does not accept liability and shall not be liable to you for any loss or damage arising from or as a result of your acting upon the content of another website to which you may link from the Website Services.
10. Changes to this Policy
CIL may change this Policy from time to time and without notice. If we make significant changes in the way we treat your Personal Data, or to the Policy, we will endeavour to provide you notice through the Website Services or by some other means, such as email. Your continued use of the Website Services after such notice constitutes your understanding of the changes. We encourage you to periodically review this Policy for the latest information on our privacy practices. We provide links to it through:

  • Website Services
  • Incorporating it into our contracts, agreements, and other documents as necessary or appropriate

Contact Us
If you have any questions, comments and requests related to this Policy, or if you have any complaints related to how CIL processes your personal data, please contact the Data Protection Officer at the address shown below:

Email: Info@cultivar-insurance.com
Office number: +971 45 79 2066
Registered office: Office 107,Liberty House, DIFC, Dubai, United Arab Emirates