We are ILAJ Services FZCO (“Lazim”, “Company”, “our”, “us” or “we”). We own and operate the website (accessible at https://www.lazim.ae/) (“Website”) and the associated applications, including Lazim, Lazim Gatekeeper, and Lazim Technician (collectively referred to as “Software” and provide such other services in relation to the ERP system designed specifically for owner association management services and related services (collectively referred to as the “Services”).

 

By accessing or using our Services or Software, or by providing your Personal Data, you agree to the terms outlined in this Policy. Where required, you consent to the collection, use, and disclosure of your Personal Data as described in this Policy. We request you to carefully read this Policy and if you do not agree with its terms, please do not use our Software, request our Services, or share your Personal Data with us.

 

We are committed to respecting your privacy and ensuring the Personal Data collected from you is adequately secured and protected from malicious third parties.

 

By using our Services, including usage of the Software and the Website or otherwise expressly giving us your Data or information, you agree to the terms of this Policy. You also expressly consent to our use and disclosure of your Data (as defined below) in the manner prescribed under this Policy and further signify your agreement to this Policy and the EULA (as defined below).

 

If you want to withdraw consent for the collection or processing of your Data, please send us an email at info@lazim.ae. Upon receipt of such request from you, we shall make every endeavour to delete or anonymize the data within 48 hours.

 

If you do not agree to this Policy, do not access, use, or subscribe to the Services, or give us any of your Data.

 

1.       INTRODUCTION

 

1.1.    The protection and security of your personal information/data are our top priority, and please be assured that we have taken all necessary and reasonable measures to protect the confidentiality of the user information and its transmission through the internet.

 

1.2.    This Policy discloses and explains how we collect, process, store, share and protect Personal Data, Usage Data, or any other data about you. This Policy does not apply to data we collect by other means (including offline) or from other sources, except as detailed here in this Policy.

 

1.3.    This Policy explains what data of yours will be collected by Lazim when you access or use our Services, how the data will be used, and how you can control the collection, correction, and/or deletion of data. Further, this policy also provides how you can access and update your Personal Data. We will not use or share your data with anyone except as described in this Privacy Policy. The use of data collected through our Website and other services shall be limited to the purposes under this Policy.

 

2.       EXCLUSIONS

 

2.1.    Unsolicited information: This Privacy Policy does not apply to any information other than information collected by the Company through the Website, Software or Services. This Policy will not apply to any unsolicited information provided by you through our Website, Software or through any other means. This includes, but is not limited to, information posted on any public areas of our Software. Such information will be deemed non-confidential and may be used or disclosed without limitation.

 

2.2.    Third-Party Responsibilities: The Company takes reasonable measures to protect Personal Data shared with authorized third-parties. However, the Company shall not be held responsible for any breaches or misuse of information by such third-parties outside the scope of the Company’s agreement with them.

 

3.       DEFINITIONS

 

3.1.    In addition to all the definitions in this Policy, the following terms shall have the meaning as set out below:

 

(a)      “Cookie” means small packets of information stored by the Website to provide seamless services;

 

(b)      “Cookie Data” means and includes such data which is collected through Cookies;

 

(c)      “Data” shall mean and include Personal Data, Cookie Data, Usage Data and any other types of data;

 

(d)      “End-User License Agreement” or “EULA” shall mean and refer to Lazim’s End User License Agreement, accessible at https://www.lazim.ae/our/privacy-policy

 

(e)      “Internet Protocol Address” or “IP Address” is a unique set of number that is assigned to all devices that are connected to the internet;

 

(f)       “Personal Data” means any information relating to an identified or identifiable natural person; and

 

(g)      “Usage Data” means such analytical data and other types of data collected by us which is based on your usage of our Software or Services.

 

4.       COLLECTION OF DATA

 

4.1.    The types of information we collect depend on how you interact with Lazim. We may ask you to provide or collect Data from you:

 

(a)      when you engage us for accessing or using our Services;

(b)      to use of our Services, including using our Software and Website;

(c)      to join Lazim community(ies) on different social media websites;

(d)      when you interact with our marketing partners;

(e)      make financial transactions;

(f)       update your information on our Software;

(g)      transfer any amount to us for the purpose of availing our Services;

(h)      subscribe to our newsletter; and/or

(i)       engage in any manner with us.

 

5.         CATEGORIES OF DATA COLLECTED

 

5.1.    Personal Data:

 

(a)      Data that you provide at the time of registration to engage us for our Services, including any  that data or can be used to identify, contact, or locate you such as name, address, email address, country of residence or incorporation, bank details, and phone number.

 

5.2.    Usage Data:

 

(a)      We automatically collect various types of data about your use of our Website, Software or Services, including your search history, products or services you view, what you clicked on and other uses of our features, the amount of time you spend looking at different parts of our Website or the Software, and inferences we draw about your preferences, such as a preference for information about a certain type of feature or service.

 

(b)      In addition to the above, we collect some information about the browser and device you use to interact with or avail our Services, including the browser type and settings, device type and settings, operating system, unique identifiers, version of the operating system or app you are using, IP address, crash reports, and system activity.

 

5.3.    Cookie Data

 

(a)      Our Website creates and collects different types of cookies and related information, discussed below in detail under Clause 9 of this Policy.

 

6.         ROLE AS A DATA CONTROLLER AND DATA PROCESSOR

 

6.1.    We understand our obligations and duty to properly handle any Data collected from you for providing our Services. As a data controller, we are responsible for determining the purposes and means of processing the Data in alignment with relevant data protection laws and regulations.

 

6.2.    For the purpose of processing your Data, we may engage data processors and sub-processors, to effectively and efficiently provide you with the Services.

 

6.3.    We will process the Data only for the purpose of adequately providing the Services and to comply with the statutory requirements.

 

6.4.    For any queries regarding this Policy, including collection and processing of Data, we can be contacted by mail at info@lazim.ae.

 

7.         LEGAL BASIS FOR PROCESSING AND YOUR RIGHTS

 

7.1.    The legal basis for the collection and processing of Data by us, shall be according to either of the following:

 

(a)      you provided consent at the time of providing the Personal Data;

 

(b)      for the purpose of providing Services;

 

(c)      for the purpose of executing a contractual arrangement with you;

 

(d)   it is in our legitimate interests to do so and not overridden by your rights (for example, in some cases for direct marketing, fraud prevention, network and data systems security, responding to your communications, the operation of networks of groups by the network administrators, and improving our Website, Software or Services;

 

(e)      to protect your vital interests or those of another person; and/or

 

(f)       comply with a legal requirement.

 

7.2.    As part of our legal requirement and our commitment to protecting your privacy, we would like to ensure that you are completely aware of all your data protection rights. Thereby, every user whose Data is being processed by us is entitled to the following rights:

 

(a)      Right to rectification: You have the right to request that we correct any data you believe is inaccurate. For the purpose of rectification, you shall provide us with the correct details. You also have the right to request that we complete the data you believe is incomplete;

 

(b)      Right to be forgotten: You have the right to request that we erase your Data after you stop accessing our Services;

 

(c)      Right to restrict processing: You have the right to request that we restrict the processing of your Data, under certain conditions;

 

(d)      Right to object to processing: You have the right to object to our processing of your Data, under certain conditions; and

 

(e)      Right to data portability: You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.

 

For the purpose of exercising any of the rights, as mentioned in the foregoing, please email us at info@lazim.ae.

 

7.3.    The foregoing rights become applicable to you and to the extent as per the applicable data protection laws.

 

7.4.    The rights mentioned in the foregoing are subject to statutory and judicial directions or requirements, including paying requisite fees and other compliance.

 

7.5.    If you find any factual error in the Personal Data, we have procured from you, you can send us an email at info@lazim.ae for correction, and we will try to fix the error, as per your directions to correct the error. We are committed to protecting your privacy and hence we may take steps for the verification of your identity before giving access or making any changes to the pre-existing data. We do so strictly for security purposes.

 

8.         USE OF THE PERSONAL DATA COLLECTED

 

8.1.    Use of the Data for Services: We shall use the Data provided by you or collected from you to:

 

(a)      provide you the Services;

(b)      to market, advertise and perform other commercial activities;

(c)      observe, improve and administer the quality of our Services;

(d)      analyse how our Services are used;

(e)      diagnose technical problems or issues with our Services;

(f)       remember the basic information provided by you for effective and seamless access;

(g)      confirm your identity in order to determine your eligibility to use the Website and avail the Services;

(h)      notify you about any changes to the Website or our Software;

(i)       enable us to comply with the legal and regulatory obligations;

(j)       be able to reach out to you for new/ exclusive offers, announcements and relevant updates;

(k)      send administrative notices and Service-related alerts and similar communication, as detailed under this Privacy Policy, with a view to optimizing the efficiency of our Services;

(l)       perform market research, troubleshoot any errors, protect you against malicious third party, plan project, detect fraud and other illegal activity; and/or

(m)    enforce Lazim’s EULA.

 

9.       COOKIE DATA

 

9.1.    We may use Cookies to provide seamless Services by collecting Usage Data, including Website traffic, usability trends, internet protocol (IP) address, browser type and version, operating system type and version, and duration of your visit.

 

9.2.    Whenever you visit our Website or access our Software, you will be prompted with a cookie banner. You shall always have the option to accept or decline Cookies. If you choose to decline usage of Cookies, we shall not use cookies to collect such data, as mentioned in the foregoing. However, such a decline to use cookies may lead to certain limitations in our rendering of Services. If you accept to use Cookies, you also have the ability to later delete Cookies that you have accepted. If you choose to delete Cookies, any settings and preferences controlled by these cookies will be deleted.

 

9.3.    We may also use DART cookies to display advertisements on our Website. However, you shall have the right to decline the use of DART cookies by visiting the Google Ad and content network privacy policy at https://policies.google.com/technologies/ads.

 

9.4.    Please note that we will manage Cookies in accordance with our Cookie Policy, accessible at https://www.lazim.ae/our/privacy-policy.

 

10.   SHARING OF YOUR DATA

 

10.1.     Consulting: The Company may partner with another party to provide certain specific services if required. When you sign-up for such services, the Company will share Personal Data that is necessary for the third party to provide these Services. The Company’s contractual arrangements with such third parties restrict these parties from using personally identifiable information except for the explicit purpose of assisting in the provision of these Services.

 

10.2.     Targeted Advertising: You expressly acknowledge and agree that we may also share or transfer your Data to third-party service providers, for the limited purpose of allowing or permitting such third-party service providers, including Google, and other third-party websites to display Lazim’s advertisements and notifications on sites across the internet, based on your past preferences and visits to the Website or the Software as part of its Services.

 

10.3.     Regulatory Disclosures: We shall cooperate with government and law enforcement officials and agencies to enforce and comply with the law. Thus, we may access, use, store, transfer and disclose your Data (including Personal Data) to such government or law enforcement officials or agencies, as we reasonably determine is necessary and appropriate:

 

(a)    to satisfy any applicable law, regulation, governmental requests or legal process;

(b)    to protect the safety, rights, property or security of the Company, our Services, the Website or any third party;

(c)    to protect the safety of the public for any reason; to detect, prevent or otherwise address fraud, security or technical issues; and

(d)    to prevent or stop any activity we consider to be, or to pose a risk of being, an illegal, unethical, or legally actionable activity. Such disclosures may be carried out without notice to you.

 

10.4.     Referrals: When you e-mail a service available on the Website to a friend, you and your friend’s names, phone number and e-mail addresses are requested. Your email and your friends’ e-mail addresses will only be used for this purpose unless permission is otherwise granted.

 

10.5.     Link to Third Party Websites: This Website may contain links which may lead you to other Websites. Please note that once you leave the Company’s Website you will be subjected to the privacy policy of the concerned third-party website that you are visiting. Please be aware that the Company is not responsible for the privacy practices of such third-party websites, therefore, we encourage you to read their privacy policy to identify the manner and extent of collection and processing of Personal Data. If you decide to access any of the third-party websites linked to the Website, you acknowledge and agree that you do this entirely at your own risk. Any website link to any partner of the Company, is as per the information furnished by these partners, therefore, the Company will not be responsible for notification of any change in name or location of any information on the Website.

 

10.6.     Disclosure to Third-Parties: We may further disclose your Personal Data to third parties with whom we have entered into a contractual relationship to disclose your Personal Data for the purpose of rendering of Services.

 

11.     SECURITY OF INFORMATION

 

11.1.     The Company has put in place appropriate technical and organisational measures to safeguard and secure your Data. The Company shall only process Data in a way that is compatible with and relevant for the purpose for which it was collected or authorized by the user. The Software allows its users to access their Personal Data and allows them to correct, amend or delete any inaccurate Personal Data.

 

11.2.     The Company uses technical and organisational measures and industrial best practices, including commercially reasonable precautions to preserve the integrity and security of your Data against any unauthorized access, disclosure, reproduction, use, destruction or amendment.

 

11.3.     The Personal Data that is collected from you may be transferred to, stored and processed at any destination within UAE or within such other jurisdiction as identified by the Company to provide its services. By submitting your Personal Data within our Software, you agree to transfer, storage and processing of your Personal Data.

 

11.4.     While using our Software, you accept the inherent security implications of data transmission over the internet. Therefore, the use of our Software will be at your own risk and the Company assumes no liability for any disclosure of Personal Data due to errors in transmission, unauthorized third-party access or other acts of third parties, or acts or omissions beyond our reasonable control and you agree not to hold the Company responsible for any breach of security.

 

11.5.     In the event the Company becomes aware of any breach of security of your Data, we will promptly notify you about the breach as maybe required under the applicable laws and take appropriate action to the best of our abilities to remedy such a breach.

 

12.   DATA RETENTION

 

12.1.     The Company shall not retain your Data longer than is necessary to fulfil the purposes for which it was collected and as permitted by applicable laws. If you wish to terminate your account or request that the Company no longer use your Data, including any Personal Data to provide you Services, contact us through email at info@lazim.ae. You acknowledge and agree that after your account is terminated, the Company may retain your Data as needed to comply with our legal and regulatory obligations, resolve disputes, conclude any activities related to cancellation of an account, investigate or prevent fraud and other inappropriate activity, to enforce our agreements, and for other business reasons.

 

13.     CONSENT

 

13.1.     By accessing or using our Services, communicating with us, or interacting with our Services, you acknowledge that you have thoroughly read this Policy and have understood the terms and conditions as stated herein.

 

13.2.     By consenting to this Policy, you acknowledge that you have granted us the right to collect, transfer, store, or process the Data, in accordance with the terms and conditions of this Policy.

 

14.     DATA BREACH

 

14.1.     Securing and protecting your Data is our top priority and we have deployed state-of-the-art form of data protection mechanisms in compliance with the existing industry practices and as required under the applicable data protection laws. Despite our best efforts to implement reasonable security measures, in the event of a data breach resulting in unauthorized access, usage, duplication, deletion, or alteration of any of your Data, including Personal Data, the Company and its directors, officers, employees, promoters, or affiliates shall not be held liable for any loss or damage arising from such breach.

 

14.2.     In the event that any of your Data is compromised due to data breach, we shall:

 

(a)      promptly notify the Supervisory Authority in compliance with the applicable data protection laws;

 

(b)      take all the necessary steps to contain that breach;

 

(c)      notify you in case any of your Data has been compromised or is at the risk of being compromised, as required under the applicable data protection laws.

 

15.   CHILDREN DATA

 

15.1.     Protection of children is of utmost importance and make every endeavour to prevent the collection and storage of any children’s data (i.e. individuals below the age of eighteen (18) years). We encourage parents and guardians to observe, participate in, and/or monitor and guide their wards’ online activity.

 

15.2.     For the avoidance of doubt, Lazim does not knowingly collect, process, or store any Data from children in connection with the provision of its Services, nor is such Data necessary or required for the effective performance of the Services. Lazim is committed to complying with all applicable laws and regulations concerning the protection of children’s data and takes all reasonable measures to ensure that its practices align with these obligations.

 

15.3.     If you think that your child has provided any kind of data on our website, we strongly encourage you to contact us immediately at info@lazim.ae and we will do our best efforts to promptly remove such data from our records within a reasonable timeframe.

 

16.     OPT OUT

 

16.1.     If you wish to opt out from receiving non-essential communications such as promotional and marketing-related information regarding our Services, please send us an email at info@lazim.ae. Upon receipt of an email from you to opt out, we shall take every endeavour to delete your name from the mailing list within our database.

 

17.   GRIEVANCE REDRESSAL

 

17.1.     For any queries or concerns, and to exercise any of your rights, as mentioned under this Policy or as may be available under the applicable data protection laws, email us at info@lazim.ae or reach out to our Data Protection Officer (DPO):

 

DPO Name: ILAJ Services FZCO

 

DPO Email Address: info@ilaj.ae

 

18.   GOVERNING LAW AND JURISDICTION

 

18.1.     This Policy is published and shall be governed by and construed in accordance with the applicable laws of Dubai, UAE, as amended from time to time, without reference to conflict of laws principles. The courts in Dubai, UAE shall have the exclusive jurisdiction to determine any disputes arising in relation to or under this Policy

 

19.   NOTIFICATION OF CHANGES

 

19.1.     From time to time, the Company may update this Privacy Policy to reflect changes to its Data processing practices. Any changes to this Policy will be effective immediately upon the posting of the revised Policy. If we make any material change to the Policy, we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on the Services prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

 

(ADDDENDUMS ON THE FOLLOWING PAGE)

 

United Kingdom Data Protection Act (DPA) Addendum

 

This United Kingdom Data Protection Act Addendum (“Addendum”) is based on the Data Protection Act, 2018 (“DPA”). If You are a user of our Services in the United Kingdom, this Addendum applies to You. Except as otherwise modified by this DPA Addendum, all provisions of the above Privacy Policy shall remain in effect and full force.

 

1.         Rights under the DPA

 

Under the DPA, You shall have the following rights:

 

1.1.    Right to access

 

You shall have the right to obtain confirmation from us as to whether or not we are processing your Personal data and if so, the manner and purpose of processing your Personal Data.

 

1.2.    Right to rectification

 

You shall have the right to rectification of any inaccurate Personal Data.

 

1.3.    Right to erasure

 

You shall have the right to erasure of Personal Data that you provided to Us. However, this right shall not extend to any Personal Data that is being processed for the purpose of complying with any statutory obligations or direction of any governmental authority.

 

1.4.    Right to restriction in processing

 

You shall have the right to restrict processing of your Personal Data, when:

 

(a)    The accuracy of the Personal Data is contested by You;

 

(b)    The processing is unlawful;

 

(c)    The purpose of the Personal Data for which it was collected has been served; and

 

(d)    You have utilised the right to object however, the same is pending verification.

 

1.5.    Right to data portability

 

You shall have the right to transmit the Personal Data that you provided Us to another entity.

 

1.6.    Right to object

 

You shall have the right to object to processing of Personal Data, on the grounds that the processing of Personal Data is being carried out for the purpose of:

 

(a)    public interest; and

 

(b)    legitimate interests

 

2.         For the purpose of children’s data, a child shall refer to any person who is under the age of thirteen (13) years.

 

3.         We will not discriminate against You and/or charge You for exercising any of these rights, as mentioned under Paragraph 1, which is further in line with Your rights mentioned under the DPA. You may request up to twice annually and after that if We are satisfied that the request is manifestly unfounded, excessive, or repetitive, We may charge you a reasonable fee to cover the administrative costs of complying with the request or decline to act on the request.

 

4.         To exercise your rights, contact us by emailing at info@lazim.ae or contact the DPO at info@lazim.ae

 

5.         We will acknowledge receipt of your request within ten (10) business days and provide a substantive response within forty-five (45) calendar days or inform you of the reason and extension period (up to 90 days) in writing.

 

6.         In the event that you are dissatisfied by the decision, you may approach the Information Commissioner as mentioned under the DPA.

 

 

California Consumer Privacy Act (CCPA) Addendum

 

If You are a User in California, this Addendum applies to you. Except as otherwise modified by this CCPA Addendum, all provisions of the above Privacy Policy shall remain in full force and effect.

 

1.       Your rights under the CCPA:

 

Under the CCPA, you have the right to:

 

1.1   Access the categories and specific pieces of personal data Lazim has collected, the categories of sources from which the personal data is collected, the business purpose(s) for collecting the personal data, and the categories of third parties with whom Lazim has shared personal data;

 

1.2   Delete personal data under certain circumstances; and

 

1.3   Opt out of the “sale” of personal data. We do not sell your personal data in the conventional sense. However, like many companies, we use advertising services that try to tailor online ads to your interests based on information collected via cookies and similar technologies about your online activity. This is called interest-based advertising. The CCPA’s statutory definition of the term “sale” is broad and may include interest-based advertising.

 

1.4   You can get more information and opt out of the use of cookies on our sites for interest-based advertising purposes by clicking the ‘Do not sell my personal information/data’ link https://www.lazim.ae/our/privacy-policy in the webpage footer, and setting your preferences. You will need to set your preferences from each device and each web browser from which you wish to opt out. This feature uses a cookie to remember your preference, so if you clear all cookies from your browser, you will need to reset your settings.

 

1.5   Lazim will not discriminate against you and/or charge you for exercising any of these rights, which is further in line with your rights under the CCPA. Lazim is not obliged to respond to more than two requests within a 12-month period.

 

1.6   To exercise your rights, contact us by emailing at info@lazim.ae. To opt out of the use of cookies on our sites for interest-based advertising purposes, follow the instructions in this Privacy Policy.

 

1.7   We will acknowledge receipt of your request within ten (10) business days, and provide a substantive response within 45 business days, or inform you of the reason and extension period (up to 90 days) in writing.

 

1.8   Under the CCPA, only you or an authorized agent may make a request related to your personal data. Note that to respond to your requests to access or delete personal data under the CCPA, we must verify your identity. We may do so by requiring you to log into your Lazim account (if applicable), provide information relating to your account (which will be compared to information we have, such as profile information), give a declaration as to your identity under penalty of perjury, and/or provide additional information. You may designate an authorized agent to submit your verified consumer request by providing written permission and verifying your identity, or through proof of power of attorney.

 

2.       California’s Shine the Light Law

 

California Civil Code Section 1798.83, also known as “Shine the Light” law, permits California residents to annually request information regarding the disclosure of your Personal Information (if any) to third parties for the third parties’ direct marketing purposes in the preceding calendar year. We do not share Personal Information with third parties for the third parties’ direct marketing purposes.

 

 

Canada Personal Information Protection and Electronic Documents Act (PIPEDA) Addendum

 

If You are a User in Canada, this Addendum applies to you. Except as otherwise modified by this PIPEDA Addendum, all provisions of the above Privacy Policy shall remain in full force and effect.

 

1.       Your rights under PIPEDA:

 

Under the PIPEDA, you have the right to:

 

1.1      Access to the personal information we hold about you;

 

1.2      Challenge the accuracy and completeness of such information;

 

1.3      Withdraw consent on any activities which you have not consented on such as direct marketing or cookies, or delete any user generated content you have posted on our website;

 

1.4      Amendment to such information as appropriate.

 

2.       By providing us with personal data, you acknowledge and agree that your personal data may be transferred to other jurisdictions for processing and storage, where laws regarding the protection of personal data may be less stringent than the laws that apply in your jurisdiction. Further, your personal data may be accessible to law enforcement, national security authorities, and the courts of such jurisdictions. Where necessary to make such transfers, we will comply with our legal and regulatory obligations in relation to the personal data

 

3.       We do not send any commercial electronic messages (“CEMs”), as such term is defined under Canada’s Anti-Spam Legislation (Statutes of Canada 2010, c 23) and its associated regulations (collectively, “CASL”) or cause or permit the sending of CEMs on behalf of Lazim, or otherwise in connection with the services without your prior consent or as otherwise agreed to or in accordance with any other agreement.

 

4.       Lazim may share, transfer, disclose, make available or otherwise provide access to Personal Information to Sub-processors and in order to provide the Services contemplated by the Services Agreement, and to any third party as required by law.

 

5.       To exercise your rights, contact us by emailing info@lazim.ae. Note that to respond to your requests to access or delete personal data under the PIPEDA, we must verify your identity.

 

6.       Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that we have collected Personal Data from anyone under the age of 13 without verification of parental consent, we take steps to remove that information from our servers.