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Privacy policy

We are very pleased about your interest in our company. Data protection is of particularly high importance to the management of Your Mellon Group. The websites of Your Mellon Group can generally be used without providing any personal data. However, if a data subject wishes to make use of special services offered by our company via our website, the processing of personal data may become necessary. If the processing of personal data is necessary and there is no legal basis for such processing, we generally obtain the consent of the data subject. The processing of personal data, such as the name, address, email address, or telephone number of a data subject, is always carried out in line with the General Data Protection Regulation (GDPR) and in accordance with the country-specific data protection regulations applicable to Your Mellon Group. By means of this privacy policy, our company would like to inform the public about the nature, scope, and purpose of the personal data we collect, use, and process. In addition, this privacy policy informs data subjects of the rights to which they are entitled. As the controller, Your Mellon Group has implemented numerous technical and organizational measures to ensure the most complete protection possible for personal data processed through this website. However, internet-based data transmissions may generally contain security gaps, so absolute protection cannot be guaranteed. For this reason, every data subject is free to transmit personal data to us by alternative means, for example by telephone.

Definitions

The privacy policy of Your Mellon Group is based on the terminology used by the European legislator when enacting the General Data Protection Regulation (GDPR). Our privacy policy is intended to be easy for the public, as well as our customers and business partners, to read and understand. To ensure this, we would like to explain the terminology used in advance. In this privacy policy, we use, among others, the following terms:

a) Personal data

Personal data means any information relating to an identified or identifiable natural person (hereinafter referred to as the “data subject”). A natural person is considered identifiable if they can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or one or more factors specific to the physical, physiological, genetic, psychological, economic, cultural, or social identity of that natural person.

b) Data subject

A data subject is any identified or identifiable natural person whose personal data is processed by the controller.

c) Processing

Processing means any operation or set of operations which is performed on personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.

d) Restriction of processing

Restriction of processing means the marking of stored personal data with the aim of limiting its processing in the future.

e) Profiling

Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person’s work performance, economic situation, health, personal preferences, interests, reliability, behavior, location, or movements.

f) Pseudonymization

Pseudonymization means the processing of personal data in such a way that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures ensuring that the personal data is not attributed to an identified or identifiable natural person.

g) Controller

Controller or data controller means the natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data. Where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its designation may be provided for by Union or Member State law.

h) Processor

Processor means a natural or legal person, public authority, agency, or other body which processes personal data on behalf of the controller.

i) Recipient

Recipient means a natural or legal person, public authority, agency, or another body to which personal data is disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients.

j) Third party

Third party means a natural or legal person, public authority, agency, or body other than the data subject, the controller, the processor, and persons who, under the direct authority of the controller or processor, are authorized to process personal data.

k) Consent

Consent means any freely given, specific, informed, and unambiguous indication of the data subject’s wishes by which they, by a statement or by a clear affirmative action, signify agreement to the processing of personal data relating to them.

Name and address of the controller

Controller within the meaning of the General Data Protection Regulation, other data protection laws applicable in the Member States of the European Union, and other provisions of a data protection nature is:
Your Mellon Group Cloud Services and Human Resources Consultancy - FZCO
Building A1 IFZA Business Park
Dubai Silicon Oasis, Dubai, UAE
Tel.: +49 561 47 39 64 59
Email: info@yourmellon.group
Website: www.yourmellon.group

Cookies

The websites of Your Mellon Group use cookies. Cookies are text files that are placed and stored on a computer system via an internet browser. Numerous websites and servers use cookies. Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier of the cookie. It consists of a character string that enables websites and servers to assign the specific internet browser in which the cookie was stored. This allows visited websites and servers to distinguish the individual browser of the data subject from other internet browsers containing different cookies. A specific internet browser can be recognized and identified through the unique cookie ID. By using cookies, Your Mellon Group can provide users of this website with more user-friendly services that would not be possible without the setting of cookies. By means of a cookie, the information and offers on our website can be optimized with the user in mind. Cookies enable us, as already mentioned, to recognize users of our website. The purpose of this recognition is to make it easier for users to use our website. For example, a user of a website that uses cookies does not have to re-enter their login data each time they visit the website, because this is handled by the website and the cookie stored on the user’s computer system. Another example is the cookie of a shopping cart in an online shop. The online shop remembers the items that a customer has placed in the virtual shopping cart by means of a cookie. The data subject may, at any time, prevent the setting of cookies by our website by means of a corresponding setting in the internet browser used, and may thus permanently object to the setting of cookies. Furthermore, cookies that have already been set may be deleted at any time via an internet browser or other software programs. This is possible in all common internet browsers. If the data subject disables the setting of cookies in the internet browser used, not all functions of our website may be fully usable.

Collection of general data and information

The website of Your Mellon Group collects a series of general data and information each time the website is accessed by a data subject or an automated system. This general data and information is stored in the server log files. The following may be collected: (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our website (so-called referrer), (4) the sub-websites accessed via an accessing system on our website, (5) the date and time of access to the website, (6) an Internet Protocol address (IP address), (7) the internet service provider of the accessing system, and (8) other similar data and information used for security purposes in the event of attacks on our information technology systems. When using this general data and information, Your Mellon Group does not draw any conclusions about the data subject. Rather, this information is needed to (1) deliver the content of our website correctly, (2) optimize the content of our website as well as the advertising for it, (3) ensure the ongoing functionality of our information technology systems and the technology of our website, and (4) provide law enforcement authorities with the information necessary for prosecution in the event of a cyberattack. This anonymously collected data and information is therefore evaluated by Your Mellon Group both statistically and with the aim of increasing data protection and data security in our company, in order to ultimately ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files is stored separately from all personal data provided by a data subject.

Registration on our website

The data subject has the option to register on the website of the controller by providing personal data. Which personal data is transmitted to the controller is determined by the respective input form used for registration. The personal data entered by the data subject is collected and stored exclusively for internal use by the controller and for its own purposes. The controller may arrange for the transfer to one or more processors, for example a parcel service provider, which will also use the personal data exclusively for internal use attributable to the controller. When registering on the website of the controller, the IP address assigned by the data subject’s internet service provider (ISP), as well as the date and time of registration, are also stored. This data is stored against the background that this is the only way to prevent misuse of our services and, if necessary, to enable the investigation of committed offenses. In this respect, the storage of this data is necessary to safeguard the controller. As a rule, this data is not passed on to third parties unless there is a legal obligation to do so or the disclosure serves criminal prosecution. Registration of the data subject, with the voluntary provision of personal data, enables the controller to offer the data subject content or services that, due to their nature, can only be offered to registered users. Registered persons are free to modify the personal data provided during registration at any time or to have it completely deleted from the data records of the controller. Upon request, the controller will at any time provide any data subject with information as to what personal data concerning them is stored. Furthermore, the controller will correct or delete personal data at the request or notice of the data subject, provided that no statutory retention obligations prevent this. All employees of the controller are available to the data subject as contact persons in this context.

Contact option via the website

The website of Your Mellon Group contains information required by law that enables rapid electronic contact with our company and direct communication with us, which also includes a general address for so-called electronic mail (email address). If a data subject contacts the controller by email or via a contact form, the personal data transmitted by the data subject is automatically stored. Such personal data transmitted by a data subject to the controller on a voluntary basis is stored for the purpose of processing the request or contacting the data subject.

Routine erasure and blocking of personal data

The controller processes and stores personal data of the data subject only for the period necessary to achieve the purpose of storage or insofar as this has been provided for by the European legislator or another legislator in laws or regulations to which the controller is subject. If the storage purpose no longer applies, or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data will be routinely blocked or erased in accordance with the statutory provisions.

Rights of the data subject

a) Right to confirmation

Every data subject has the right granted by the European legislator to obtain from the controller confirmation as to whether or not personal data concerning them is being processed. If a data subject wishes to exercise this right of confirmation, they may contact an employee of the controller at any time.

b) Right of access

Every data subject affected by the processing of personal data has the right granted by the European legislator to obtain at any time, free of charge, information from the controller about the personal data stored concerning them and a copy of that information. Furthermore, the European legislator has granted the data subject access to the following information:

the purposes of the processing, the categories of personal data concerned, the recipients or categories of recipients to whom the personal data has been or will be disclosed, in particular recipients in third countries or international organizations, where possible the envisaged period for which the personal data will be stored or, if not possible, the criteria used to determine that period, the existence of the right to request from the controller rectification or erasure of personal data concerning them or restriction of processing, or to object to such processing, the existence of the right to lodge a complaint with a supervisory authority, where the personal data is not collected from the data subject: any available information as to its source, the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject

Furthermore, the data subject has the right to obtain information as to whether personal data has been transferred to a third country or to an international organization. Where this is the case, the data subject also has the right to be informed of the appropriate safeguards relating to the transfer. If a data subject wishes to exercise this right of access, they may contact an employee of the controller at any time.

c) Right to rectification

Every data subject affected by the processing of personal data has the right granted by the European legislator to request the immediate rectification of inaccurate personal data concerning them. Furthermore, taking into account the purposes of the processing, the data subject has the right to have incomplete personal data completed, including by means of providing a supplementary statement. If a data subject wishes to exercise this right to rectification, they may contact an employee of the controller at any time.

d) Right to erasure (right to be forgotten)

Every data subject affected by the processing of personal data has the right granted by the European legislator to obtain from the controller the erasure of personal data concerning them without undue delay, where one of the following grounds applies and insofar as the processing is not necessary:

If one of the above reasons applies and a data subject wishes to request the erasure of personal data stored by Your Mellon Group, they may contact an employee of the controller at any time. The employee of Your Mellon Group will ensure that the erasure request is complied with without undue delay. Where the personal data has been made public by Your Mellon Group and our company, as controller, is obliged pursuant to Article 17(1) GDPR to erase the personal data, Your Mellon Group shall take reasonable steps, including technical measures, taking account of available technology and the cost of implementation, to inform other controllers processing the published personal data that the data subject has requested the erasure by such controllers of any links to, or copies or replications of, that personal data, insofar as processing is not required. The employees of Your Mellon Group will arrange the necessary measures in individual cases.

e) Right to restriction of processing

Every data subject affected by the processing of personal data has the right granted by the European legislator to obtain from the controller restriction of processing where one of the following applies:

If one of the above conditions is met and a data subject wishes to request the restriction of personal data stored by Your Mellon Group, they may contact an employee of the controller at any time. The employee of Your Mellon Group will arrange the restriction of processing.

f) Right to data portability

Every data subject affected by the processing of personal data has the right granted by the European legislator to receive the personal data concerning them, which was provided by the data subject to a controller, in a structured, commonly used, and machine-readable format. They also have the right to transmit this data to another controller without hindrance from the controller to which the personal data was provided, where the processing is based on consent pursuant to Article 6(1)(a) GDPR or Article 9(2)(a) GDPR, or on a contract pursuant to Article 6(1)(b) GDPR, and the processing is carried out by automated means, provided that the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller. Furthermore, in exercising their right to data portability pursuant to Article 20(1) GDPR, the data subject has the right to have the personal data transmitted directly from one controller to another, where technically feasible and where doing so does not adversely affect the rights and freedoms of others. To exercise the right to data portability, the data subject may contact an employee of Your Mellon Group at any time.

g) Right to object

Every data subject affected by the processing of personal data has the right granted by the European legislator to object, on grounds relating to their particular situation, at any time to processing of personal data concerning them which is based on Article 6(1)(e) or (f) GDPR. This also applies to profiling based on those provisions. In the event of an objection, Your Mellon Group will no longer process the personal data unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights, and freedoms of the data subject, or for the establishment, exercise, or defense of legal claims. If Your Mellon Group processes personal data for direct marketing purposes, the data subject has the right to object at any time to processing of personal data concerning them for such marketing. This also applies to profiling insofar as it is related to such direct marketing. If the data subject objects to processing by Your Mellon Group for direct marketing purposes, Your Mellon Group will no longer process the personal data for these purposes. In addition, the data subject has the right, on grounds relating to their particular situation, to object to processing of personal data concerning them by Your Mellon Group for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest. To exercise the right to object, the data subject may contact any employee of Your Mellon Group or another employee directly. Furthermore, in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, the data subject is free to exercise their right to object by automated means using technical specifications.

h) Automated individual decision-making, including profiling

Every data subject affected by the processing of personal data has the right granted by the European legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning them, or similarly significantly affects them, unless the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and the controller, or (2) is authorized by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the rights and freedoms and legitimate interests of the data subject, or (3) is based on the data subject’s explicit consent. Where the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and a controller, or (2) is based on the data subject’s explicit consent, Your Mellon Group shall implement suitable measures to safeguard the rights and freedoms and legitimate interests of the data subject, including at least the right to obtain human intervention on the part of the controller, to express their point of view, and to contest the decision. If the data subject wishes to exercise rights concerning automated individual decision-making, they may contact an employee of the controller at any time.

i) Right to withdraw consent under data protection law

Every data subject affected by the processing of personal data has the right granted by the European legislator to withdraw consent to the processing of personal data at any time. If the data subject wishes to exercise their right to withdraw consent, they may contact an employee of the controller at any time.

Legal basis for processing

Article 6 GDPR serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is party, as is the case, for example, with processing operations necessary for the delivery of goods or the provision of any other service or consideration, the processing is based on Article 6 GDPR. The same applies to processing operations necessary for carrying out pre-contractual measures, for example in cases of inquiries about our products or services. If our company is subject to a legal obligation which requires the processing of personal data, such as for the fulfillment of tax obligations, the processing is based on Article 6 GDPR. In rare cases, the processing of personal data may be necessary in order to protect the vital interests of the data subject or another natural person. This would, for example, be the case if a visitor were injured at our company and their name, age, health insurance data, or other vital information then had to be passed on to a doctor, hospital, or other third party. In that case, the processing would be based on Article 6(1)(d) GDPR. Finally, processing operations could be based on Article 6(1)(f) GDPR. Processing operations that are not covered by any of the legal bases mentioned above are based on this legal basis if processing is necessary for the purposes of the legitimate interests pursued by our company or by a third party, provided that such interests are not overridden by the interests or fundamental rights and freedoms of the data subject. Such processing operations are permitted to us in particular because they have been specifically mentioned by the European legislator. In this respect, the legislator took the view that a legitimate interest could be assumed if the data subject is a customer of the controller (Recital 47 sentence 2 GDPR).

Legitimate interests pursued by the controller or by a third party

Where the processing of personal data is based on Article 6(1)(f) GDPR, our legitimate interest is the conduct of our business activities for the benefit of the well-being of all our employees and shareholders.

Period for which the personal data will be stored

The criterion for the duration of the storage of personal data is the respective statutory retention period. After expiry of that period, the relevant data is routinely deleted, provided it is no longer required for the fulfillment or initiation of a contract.

Statutory or contractual requirements to provide personal data

We would like to clarify that the provision of personal data is partly required by law (for example, tax regulations) or may also result from contractual provisions (for example, information about the contractual partner). In some cases, it may be necessary for the conclusion of a contract that a data subject provides us with personal data, which must subsequently be processed by us. For example, the data subject is obliged to provide us with personal data if our company enters into a contract with them. Failure to provide the personal data would mean that the contract with the data subject could not be concluded. Before personal data is provided by the data subject, the data subject must contact one of our employees. Our employee will clarify on a case-by-case basis whether the provision of personal data is required by law or contract, or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data, and what consequences the failure to provide the personal data would have.

Existence of automated decision-making

As a responsible company, we do not use automated decision-making or profiling.