Software Developer (Market Setup)

Eqvilent Investments Ltd (“Eqvilent”) respects the privacy of Personal Data and is committed to protecting Personal Data for which Eqvilent is a Controller.
This Policy describes how the Personal Data must be collected, handled, disclosed, shared and stored to meet the Eqvilent’s data protection standards — and to comply with the Data Protection Laws.
Why this Policy exists
The Policy ensures Eqvilent:
complies with Data Protection Laws and follows good practice;
protects the rights of staff, customers and partners;
is open about how it stores and Processes Personal Data;
and protects itself from the risks of a Personal Data breach.
Data protection risks
This Policy helps to protect Eqvilent from some very real data security risks, including:
Breaches of confidentiality. For instance, information being given out inappropriately.
Failing to offer choice. For instance, all individuals should be free to choose how the company uses data relating to them.
Reputational damage. For instance, the company could suffer if hackers successfully gained access to sensitive data.
2. TERMS AND DEFINITIONS
"Controller" means a natural or legal person, public authority, agency, or other body that, independently or jointly with others, determines the purpose and means of Processing Personal Data, as defined in Data Protection Laws. Controller shall refer to Eqvilent, and with regard to certain Processes, Eqvilent may act as joint Controller with a third-party.
"Compliance Manager'' means Eqvilents employee Vitalii Kulikov accountable for data protection compliance under this Policy. The Compliance Manager is not considered to be in a data protection officer position for the purposes of Data Protection Laws.
"Cookies" means a small text file that a website stores on a Users computer or mobile device when he or she visits the Eqvilents website and which includes unique identifiers that web servers send to browsers. Cookies help Eqvilent to determine the path the visitor took on our Website. Eqvilent uses Cookies in order to anonymously identify repeated users of the Website and most popular pages. It allows Eqvilent to keep our Website user-friendly and efficient by identifying the information most valued by users.
"Data Protection Laws" means The Data Protection Law DIFC Law No. 5 of 2020, the DIFC Data Protection Regulations 2020.
"User" means a natural person who can be identified, directly or indirectly, by reference to their Personal Data.
"Personal Data" or "Personal Information" means any information attributable to an identified or identifiable natural person (a User), as defined in Data Protection Laws. Personal Data does not include data where the identity has been removed (anonymous data). Personal Data shall encompass Special Category Data.
"Process" or "Processing" means, as applicable, any operation or set of operations performed upon Personal Data, whether or not by automatic means, such as collecting, recording, using, organizing, structuring, storing, adapting or altering, retrieving, disclosing by transmission, disseminating or otherwise making available, aligning or combining, restricting, erasing, or purging.
"Processor" means a natural or legal person, public authority, agency, or other body that Processes Personal Data on behalf of a Controller, as defined in Data Protection Laws. Processors may include third-party service providers, applications, or agencies utilized by Eqvilent in the course of business.
"Special Category Data" means Personal Data revealing racial or ethnic origin, criminal history, political opinions, religious or philosophical beliefs, sexual orientation, trade union membership, or health, genetic, or biometric data, financial data or data pertaining to a child or minor or other categories of Personal Data pursuant to the applicable Data Protection Laws
3. COMPLIANCE MANAGER
The Compliance Managers responsibilities include:
informing and advising Eqvilent and its employees about their obligations to comply with the Data Protection Laws;
monitoring compliance with the Data Protection Laws, including managing internal data protection activities, advise on data protection impact assessments; train staff and conduct internal audits;
and acting as the first point of contact for supervisory authorities and for individuals whose data is Processed (employees, customers etc).
4. AUTOMATICALLY COLLECTED INFORMATION
Users device automatically transmits to Eqvilent its technical characteristics when User uses Eqvilents Website. Eqvilent uses the information about location (a set of parameters that determine regional settings of interface, namely, residence country, time zone and the interface language), IP address, cookie files, browser and operating system, date and time of access to the website and the pages requested in order to provide the efficiency, usability and security of Eqvilents Website.
The Cookies are used exclusively for the purposes stated hereof. The Users may provide a consent for the use of their Cookies in accordance with the principles provided hereof or refuse in the use of their Cookies.
5. PROCESSING PERSONAL DATA
Grounds for Processing Personal Data
Eqvilent will only use Personal Data when Data Protection Laws allow Eqvilent to do so. Eqvilent’s basis for Processing Personal Data may include:
User giving consent to the Processing of his or her Personal Data for a specific purpose(s);
Processing is necessary for the performance of a contract to which the User is party or in order to take steps at the request of the User prior to entering into a contract;
Processing is necessary for compliance with a legal obligation to which Eqvilent is subject;
Processing is necessary to respond to public health emergencies, or protect the life, health, and property safety of natural persons in emergencies;
Processing is necessary in order to protect the vital interests of the User or of an other natural person;
or Processing is necessary for the purposes of the legitimate interests pursued by Eqvilent or a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the User which require protection of Personal Data, in particular where the User is a child
Personal Data Eqvilent collects
Examples of Personal Data Eqvilent may collect include:
personal details (such as full name, nationality, gender, photograph and IP address);
identification details (such as passport or identification card, photo ID, national identification number and social security number);
education details (information about schools attended, degrees awarded and academic status);
contact information (such as phone number and postal address);
information in order to comply with our regulatory obligations (such as know your counter party information due diligence checks and anti-money laundering checks);
records of contact you have with us via phone calls, video calls, video conference calls and e-mail and video surveillance for the security of our buildings and systems;
location data includes details about visitor's current address;
or technical data which includes internet protocol IP address, login data, browser type and version, time zone setting and location, browser plug-in type and versions, operating system and platform, and other technologies on the devices visitors use to access the Website and use of Cookies stored on visitor's device
How Personal Data are collected
The Personal Data Eqvilent collects and Processes is directly provided by User or obtained from other third party sources. Eqvilent may use Personal Data collected from third party sources, such as:
regulatory authorities that contain Users Personal Data;
public sources such as newspapers and the internet;
and data files from other parties that have collected Personal Data about User who contact Eqvilent regarding business activities who may provide Eqvilent with information that relates to User.
Consent
Consent provided by Users