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PRIVACY POLICY

Privacy Policy

Middle East Cloud and Digital Transformation Company Limited respects your privacy and is committed to striving to protect it. We take confidentiality and security of your personal data seriously and will ensure that your personal data is processed according to the Kingdom of Saudi Arabia (KSA)’s Personal Data Protection Law (PDPL). This Privacy Policy is designed to help you understand the types of personal data that we will collect and how we use your personal data when you visit our Website.

For the purposes of this Privacy Policy “CNTXT”, “we”, “our” and “us” refer to Middle East Cloud and Digital Transformation Company Limited, a company established in the KSA having its head office address at Rubeen Plaza, Northern Ring Rd, Hittin, Riyadh 13512, Saudi-Arabia under commercial registration number 1010796728. "This website" refers to the website at www.cntxt.com (the Website) and "you" and "your" refers to a specific individual accessing the Website.

Except as otherwise set out at the end of this Privacy Policy, defined terms in this Privacy Policy have the same meaning as the corresponding terms in the PDPL. 

Please read this Privacy Policy carefully if you are a customer or partner of CNTXT. It provides important information about how we use your personal data and your legal rights under the PDPL. 

On what basis we use your personal data

We use your personal data on the following basis, where available under applicable data protection laws:

  • because you have given your consent (if we expressly ask for consent to process your personal data, for a specific purpose); or
  • for our legitimate interests, to the extent that it does not affect your rights and where the data does not include sensitive data as defined under the PDPL. This requires us to carry out an assessment by understanding what you may reasonably expect from the processing and balance your rights and interests. Using your personal data helps us to operate, improve and minimize any disruption to our Website. We also have a legitimate interest in sending you information on the products, services and offerings we believe will be of interest to you; or
  • to comply with legal, regulatory and risk management obligations. 

We will not process your personal data in a manner that is inconsistent with the purpose for which we have collected the personal data or the basis on which we have relied to collect your personal data without obtaining your consent and will strive to process your personal data in a manner compliant with the PDPL. If you fail to provide certain information when requested, we may not be able to provide you with information about our services and products. 

Collection and use of your personal data

In order to provide you with our services and in connection with the operation of our Website, we will need to process your personal data from time to time. Therefore, we will process your personal data obtained via the Website in our capacity as a Data Controller. This means that we are responsible for ensuring that we comply with relevant data protection laws when processing your personal data. In some cases, we may also act as a Data Processor.  

The sections below highlight the different scenarios where we might process your personal data. This includes the types of personal data we process about you and the purposes for which we process the personal data. 

  • CNTXT Data Fusion Onboarding

When we process personal data as part of our onboarding process, we act as a Data Controller and Data Processor. We act as a Data Controller when we provide customers and partners with technical support and account management services.

For the purposes of onboarding, we will process personal data that we receive from you, including: full name, job title, position, IP address, email address and telephone number - this information is obtained from the identity provider used to authenticate you for the use of CNTXT Data Fusion.

The collection and use of personal data as described above takes place pursuant to PDPL and our obligations under our Data Processing Agreement with you.

We act as a Data Processor whenever we process any personal data you place into CNTXT Data Fusion (CDF). In such instances, our obligations are regulated by the Data Processing Agreement (DPA). CDF strives to provide customers and partners with secure storage and processing of their personal data.

Customers and partners have full autonomy to control the processing of personal data and related security. 

  • Customer management system (CRM) and operations

We may use the personal data we have on you in our Customer Management System in order to provide you with consultancy, billing, compliance with the law, support & technical support, management of our service such as data analytics, benchmarking, product development and in order to notify you of any changes that may affect the services we provide to you.

For the purposes of CRM, service level and general operations, we will process information that we already have about you, including: name, position, IP address, email address and telephone number. 
​​The collection and use of personal data as described above takes place pursuant to PDPL and our obligations under our Data Processing Agreement with you.

  • Robotics

CNTXT Robotics uses Twilio Programmable Video API for relaying video streams from robots to InRobot users.

For the purposes of Robotics, we will process the video stream captured by the Robots. The video is streamed live from Twilio to the customer. The video is never stored by CNTXT or Twilio.

​​The collection and use of personal data as described above takes place pursuant to the PDPL and our obligations under our Data Processing Agreement with you.

  • Newsletter and CNTXT conferences  

We may use your personal data in order to send you our newsletters, tell you about our products and services, and invite you to our events.

For the purposes of newsletters and invitations to CNTXT conferences, we will process information that we already have about you, including: name, position, email address and telephone number.
If you no longer wish to receive our newsletters, information about our products or invitation to our conferences, you can use the opt-out link provided in the communication. Alternatively, you can also contact us on [email protected].

The collection and use of personal data as described above takes place pursuant to art. 6 (1) (a) of the PDPL.

  • CNTXT Academy

CNTXT Academy is CNTXT's e-learning portal where CNTXT's on-demand and instructor-led training offerings are available to gain CDF skills and upskill on industrial digitalization. CNTXT Academy is available to everyone. When we process personal data as part of CNTXT Academy, we act as a Data Controller and Data Processor.

For the purposes of providing you with e-learning we act as a Data Controller and we process the following information about you: name, email address and activities and courses taken on CNTXT Academy.

The collection and use of personal data as described above takes place pursuant to Art. 6(1)(a) of the PDPL.

We act as a Data Processor if we share personal data with customer and partners employees course trajectory on CNTXT Academy. In such instances, our obligations are regulated by the Data Processing Agreement (DPA).

  • Third party products

Additional onboarding may be required to use any third-party products that we resell. The processing of any personal data for the purpose of onboarding on or using third-party products shall be subject to separate terms and will be governed by the relevant subscription order form, master services agreement, and specific terms and conditions, including the third-party seller’s relevant privacy policies, which you must review and agree to before onboarding.

  • Customer Survey

We may use your personal data in order to survey you for feedback. The information collected will be used to improve our services and processes. 
For the purposes of the customer survey, we will process personal data that we already have about you, including: name, position and email address.
The collection and use of personal data as described above takes place pursuant to the PDPL. 

With whom do we share your personal data

CNTXT is committed to protecting personal data and does not disclose users’ personal data, which they voluntarily provide, to third parties without his or her personal consent, except in certain cases (and upon reliance of another lawful basis) to:

  • third party service providers and sub-contractors who provide a service to us and help us run our business efficiently (including but not limited to marketing and advertising, data processing, IT and office services); 
  • any member of our group; and
  • any competent authorities if we are legally required to comply with a request for data. 

A complete list of processors and third parties is available at: https://content.cntxt.com/subprocessor_list

Cookies

We may obtain information about your usage of our Website by using cookie files stored on your computer or device. Cookies are text files containing small amounts of information which are downloaded to your computer or device when you visit a website. Cookies help us to improve our Website and to deliver a better and more personalised service.

We use cookies to help you navigate efficiently and perform certain functions.

The cookies that are categorised as “necessary” are stored on your browser as they are essential for enabling the basis functionalities of the Website. These cookies do not collect personal data.

We also use third-party cookies that help us analyse how you use this Website, store your preferences, and provide the content and advertisements that are relevant to you. These cookies will only be stored in your browser with your prior consent. 

For some of the functions within our Websites we may use third party suppliers, for example, when you visit a page with videos embedded from or links to YouTube. These videos or links (and any other content from third party suppliers) may contain third party cookies, and we encourage you to consult the privacy policies of these third-party vendors on their websites for information regarding their use of cookies.

We use Google Analytics to analyse the use of this website. Google Analytics generates statistical and other information about website use by means of cookies, which are stored on users’ computers. The information generated relating to our Website is used to create reports about the use of the Website. Google will store this information. Google’s privacy policy is available at https://www.google.com/privacypolicy.html.

You can find more information about cookies and how to manage them at https://www.allaboutcookies.org/. You may disable cookies by changing the settings on your browser. However, if you do so, this will affect your enjoyment of our site and we will no longer be able to offer to you a personalized service.

List of cookies:

  • Google Analytics
  • HubSpot
  • WPML
  • WPML SEO
  • WordPress
  • Advanced Custom Fields Pro 
  • Gravity Forms  
  • Hotjar
  • Google Ads
  • Caching plugins

Google Analytics We use Google Analytics to understand how our media campaigns work and how you interact with our Website in order to improve the user experience. https://tools.google.com/dlpage/gaoptout

Google tracking cookies enable us to understand if you complete certain actions on our Website(s) after you have seen or clicked through one of our adverts served via Google. Based on the content you have engaged with on our Websites Google is able to deliver some targeted adverts across other Google partner websites. https://support.google.com/ads/answer/2662922?hl=en

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

We will only use personal data that we obtained directly from you for marketing purposes and will obtain your consent before using your personal data to send marketing communications to you.  You have the right to withdraw consent to marketing at any time by contacting us.

Countries to which we transfer your personal data

The personal information you submit may be transferred, stored and hosted outside of the country from which you may be accessing the Website. We will strive to ensure that these and all other transmissions are compliant with the PDPL and any other applicable laws and remain secure and under our control. 

A list of processors and third parties, and their locations, is available at: https://content.cntxt.com/subprocessor_list

If you would like further details of how your personal data is protected when transferred from one country to another then please email us at [email protected]. 

Retention

We aim to only store your personal data for as long as is necessary for the purposes described above, to respond to any queries or complaints, to improve our Website or to comply with any legal obligations to which we may be subject. 

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve such purposes through other means, and the applicable legal requirements. For example, personal data related to our service will be stored for 3 years after the customer relationship ends. Newsletters, marketing and CNTXT conference invitations will be sent out until you opt-out or end your customer relationship with CNTXT.

We will destroy or anonymise your personal data as soon as the purpose of collecting it, or the legal requirement for which are required to keep the personal data, has expired.

Your rights under the PDPL

Under certain conditions, you may have the right to: 

  • be informed which includes requesting additional information from us about the legal basis of collecting your personal data and how we process your personal data;
  • request for us to correct your personal data if you locate any errors and complete or update your personal data; 
  • access all the personal data we have stored about you;
  • delete your personal data; 
  • obtain your personal data in a structured, commonly used, machine-readable format, including the right to request the transfer of your personal data to another controller (if this is technically possible); and 
  • withdraw your consent at any time. 

If you wish to exercise your rights, then please contact us at [email protected].  We will require that you confirm your identity by providing additional information, such as a copy of your National ID, residence permit, or passport.

Subject to any overriding legal obligations, requirements and/or exemptions, we will endeavor to respond to your request promptly in compliance with applicable laws, and at the latest within 30 days, unless we require further information from you. This period may be extended by an additional 30 days in the event of multiple requests or if the request requires disproportionate effort. We will notify you in advance if we anticipate a delay. 

If any request is repetitive, manifestly unfounded, or requires disproportionate efforts, we reserve the right to refuse it, in which case we will notify you of the refusal and the reason behind it.

If you are not satisfied with our use of your personal data in respect of this Website or our response to any request by you to exercise your rights, or if you think that we have breached any relevant data protection laws, then please contact us at [email protected]. You may, in addition, have the right to complain to any regulatory authority that supervises our processing of your personal data including, where you are based in KSA, the Saudi Data & Artificial Intelligence Authority (SDAIA) and/or the National Data Management Office (NDMO).

Data security

We take security issues seriously. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you within 72 hours and any applicable regulator of a breach where we are legally required to do so.

Hyperlinks

Our Website may provide links to third party websites for your convenience, including those third party websites which are applicable to the products that we resell. If you access those links, you will leave our Website. We do not control those websites or their privacy practices, which may differ from ours.

This Privacy Policy does not cover the personal data you choose to give to unrelated third parties. We encourage you to review the Privacy Policy of any company before submitting your personal data. Some third-party companies may choose to share personal data with us; that sharing is governed by that third party company's privacy policy.

Notification of changes

We may update or change our Privacy Policy from time to time. In such case, we will upload an updated Privacy Policy on the Website and it will be effective from the time of posting. 

This Privacy Policy was last updated on 11th October 2023.

Contacting us

This Privacy Policy sets out in broad terms how we handle your personal data and safeguard your privacy. If you have any questions relating to our data processing activities or this Privacy Policy, please send an email to the following address [email protected].

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Definitions

"CDF'' means CNTXT Data Fusion, a software system made and implemented by or on behalf of CNTXT, the core functionality of which is to collect, process, and store personal data and to make such personal data available for consumption. The term "CDF'' shall include CDF API and Extractors. A further description of CDF shall be maintained at https://www.cognite.com/en/product/cognite_data_fusion_industrial_dataops_platform

“Personal data” means data that relates to you or allows us to identify you. This includes data such as your name, address and telephone number, but can also include data such as analysis of your use of our Website.

“PDPL” means the Saudi Arabia Personal Data Protection Law implemented by Royal Decree M/19 of 9/2/1443H (16 September 2021) and amended by Royal Decree No. M147 of 5/9/1444H (27 March 2023), and its executive regulations as issued by the relevant body from time to time.