PRIVACY

1. Introduction

Your privacy is important to us. This Privacy Policy (“Policy”) explains how we collect, use, protect, process, disclose and share Personal Data when you use our website and related portals, sandboxes and services (together, the “Services”), including when you contact us, register interest, participate in pilots, access documentation, or attend events and webinars.

This Policy should be read together with any applicable terms and notices presented to you at the point of collection.

For GCC activities, an entity may be established and/or operate subject to local authorisation requirements (including authorisation with the Central Bank of Bahrain (“CBB”)), and may act as a controller for relevant processing activities once authorised and operational. Where this applies, we will clearly indicate the relevant controller in applicable contractual terms and notices.

2. Definitions

In this Policy, “Personal Data” means information that identifies or can be used to identify an individual. “Processing” means any operation performed on Personal Data, such as collection, storage, use, disclosure, or deletion. Other terms (including “Controller”, “Processor” and “Data Subject”) have the meanings given in applicable data protection law (including the UK GDPR and Data Protection Act 2018).

3. Collection of information

We may collect Personal Data in the following ways:

• + Information you provide (e.g., when you complete forms, request information, contact us, register interest, participate in pilots, or submit enquiries).
• + Information collected automatically (e.g., technical data such as IP address, device and browser type, usage data, pages viewed, timestamps, and event logs).
• + Information from third parties (e.g., business partners, service providers, analytics providers, or where a colleague provides your details for a business introduction).

4. Cookies and analytics

We may use cookies and similar technologies to operate our website, remember preferences, and improve performance. Where required, we use a consent management mechanism to enable you to accept or reject non-essential cookies.

You can manage cookie preferences at any time via the cookie controls made available on the site (where enabled).

5. How we use your Personal Data

We use Personal Data to operate, maintain and improve the Services and our business, including:

• + To respond to enquiries and provide requested information.
• + To manage relationships with participants, partners, and prospective customers.
• + To administer pilots, sandboxes, developer resources and secure access areas.
• + To monitor and improve website performance, security and user experience.
• + To prevent fraud, misuse, and unauthorised access, and to maintain audit and security logs.
• + To comply with legal, regulatory and contractual obligations.

6. Lawful bases for processing

We process Personal Data only where we have a lawful basis, including:

• + Legitimate interests (e.g., operating and improving our Services, ensuring security, and communicating with business contacts), except where overridden by your interests or rights.
• + Contract (where processing is necessary to perform a contract or take steps at your request before entering into a contract).
• + Legal obligation (where we must comply with law or regulatory requirements).
• + Consent (where required, e.g., certain cookies or marketing preferences).

7. Disclosure of information

We may share Personal Data with:

• + Service providers and professional advisers (e.g., IT hosting, security, legal, audit, and analytics providers) acting as processors under appropriate safeguards.
• + Regulatory, law enforcement or judicial bodies where required by applicable law or in response to lawful requests.
• + Parties to a corporate transaction (e.g., reorganisation, sale of assets), subject to appropriate confidentiality and data protection safeguards.

We do not sell Personal Data to third parties.

8. International transfers

Your Personal Data may be transferred to, and processed in, countries outside the UK. Where such transfers occur, we implement appropriate safeguards (such as contractual protections) as required by applicable data protection law.

9. Data security

We maintain appropriate technical and organisational measures to protect Personal Data against unauthorised access, alteration, disclosure or destruction. No internet transmission is completely secure; where you transmit data to us, you do so at your own risk.

10. Data retention

We retain Personal Data only for as long as necessary for the purposes described in this Policy, including to comply with legal, regulatory and contractual obligations and to resolve disputes. Retention periods will vary depending on the nature of the data and the context in which it was collected.

11. Your rights

Subject to applicable law, you may have rights including: access, rectification, erasure, restriction, objection, and data portability. You may also withdraw consent where processing is based on consent.

To exercise these rights, please contact us via the details provided on our Contact page or write to the registered address listed above.

12. Links to third-party websites

Our Services may include links to third-party websites. Those websites have their own privacy policies and we do not accept responsibility for their content or practices. Please review their policies before submitting Personal Data.

13. Changes to this Policy

We may update this Policy from time to time by posting an updated version on this page. Please review this page periodically for changes.

14. Complaints

If you have concerns about how we handle Personal Data, please contact us first so we can investigate. You may also have the right to lodge a complaint with the UK Information Commissioner’s Office (ICO).

ICO website: https://www.ico.org.uk