Last updated on December 2022
Please read this Privacy Policy carefully. This policy describes the way Kema FZ-LLC and its affiliates, subsidiaries and vendors (collectively “Kema”, “kema”, “we”, “us” or “our”) collect, protect, use and store your personal information ("Personal data"). By using our products and services through any means, you accept this Privacy Policy. If you do not accept the terms of this policy, you must stop using or accessing this website or platform.
Respect for the privacy of your personal and other information is important to us.
We are the Controller for the purposes of the Data Protection Law of the personal information that we collect or receive from you as more fully described in this policy.
This website (www.kema.co, or any successor site) and its related sub-domains, sites, online applications, services and tools (“Platform”) are owned and operated by Kema FZ-LLC.
1. How does Kema collect your information?
We collect personal information via different means, including:
- When you visit or use our website or platforms;
- When you submit information to us;
- When you perform transactions via our website or platforms;
- When you perform transactions via third party websites connected to the Platform;
- When you contact us and/or interact with us;
- Automated technology and digital services;
- Third party databases, websites or platforms; and
- Publicly available sources.
2. What personal information does Kema collect?
We may collect, store, use and transfer your personal information, this includes:
- Personal identification information: such as name, title, marital status, official identification data, address, contact information, username, job title, employer, date of birth and gender;
- Profile data: such as username and password, your preferences, feedback and responses;
- Transactions data: such as details about payments you make or receive, including all the information related to such transactions;
- Financial data: such as details about your income, bank account and payment card details and financial details, credit agencies scores, details and financial behaviour, fraud prevention agency scores, details and financial behaviour;
- Technical information: such as IP (internet protocol) address, browser type and version, browser plug-in types and versions, operating system and platform, login information, time zone setting and location, and other information on the devices you use to access our websites or platforms, services you accessed or searched for, page response times, download errors, length of visits to pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page;
- Usage information: such as how you use our website, products and services; and
- Marketing and Communications information: such as your preferences in receiving marketing content and your communication preferences.
We may also collect, use and share anonymised aggregated data about visitors to the website or platform for reporting purposes. However, no single individual will be identifiable from the aggregated data we collect or disclose by us for these purposes.
Kema’s website and platforms are not targeted, intended or expected to be of use by children and we do not knowingly collect data related to children.
3. How does Kema use your information?
We may use the information we obtain about you for the following purposes:
- To perform the service intended as part of your utilisation of Kema’s services;
- To verify your identity;
- To administer and operate your Kema account;
- To update the records we hold about you;
- To comply with a legal and/or regulatory obligation;
- To prevent and detect crime and/or misuse of our services;
- To improve our services;
- To ensure that the content presented to you is tailored to your needs;
- To serve relevant marketing content to you; and
- To contact you.
4. How does Kema disclose and transfer your information?
We may share your personal information with third parties in order to provide you with our services. This may include:
- Internal third parties, such as subsidiaries and affiliates of the Kema group;
- External third parties to provide you with the service you requested through a partnership or promotional offering made by/with a third party or us;
- External third parties whom you choose to let us share your personal data;
- Professional advisers including lawyers, IT support, bankers, auditors and insurers who provide consultancy, banking, legal, insurance, IT and accounting services;
- Credit reference agencies who use information about your application, your business, you and your business partners;
- Tax authorities, regulators, courts, tribunals, law enforcement officers and other governing authorities who require reporting of processing activities or as required by applicable laws, including situations in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights;
- Potential investors who might be interested in financing your transactions; and
- Potential purchasers of or investors in our business.
We will not disclose, rent or sell your personal information to any third party other than as set out in this policy unless you have consented to this. If you give us your consent for processing your personal information in a certain way but later change your mind, you may contact us to proceed with such changes (see “How to contact us?”).
We might share your transactional information with other Kema users, but only when strictly necessary (eg: the company you are buying from).
Your information may be transferred to and stored in locations outside of the United Arab Emirates (“UAE”) . When we do this, we will ensure appropriate safeguards are in place to ensure a similar degree of protection is afforded to it and that the transfer is lawful.
This website may include links to third party websites, plug-ins and/or applications. Clicking on those links or enabling those connections may allow third parties to collect or share information about you. We do not control these third party websites and are not responsible for their privacy statements.
5. What are your rights?
You have a number of rights when it comes to your personal information. This includes:
- Information disclosure: we must provide you with certain information at the time we collect your personal information, including how we use it and the legal basis for doing so, who we share it with, and how long we intend to keep it, where we got the information from and your rights in relation to it. You find this information in this Privacy Policy;
- Request access: we must provide you with a copy of your information unless providing some or all of it would adversely affect the rights and freedoms of others, or the law allows us not to comply with your request. You may contact us to request access to your information (see “How to contact us?”);
- Preference changes: you have the right to change your preferences related to the way we contact you and the content we send you. This includes the right to opt-out of receiving marketing communications from us. You have the option to ask us not to process your personal information for direct marketing purposes;
- Request correction: you can ask us to correct any information which you believe is inaccurate. We will update your information as soon as we can. You may need to provide supporting evidence before we can proceed with your request;
- Withdraw consent: after having given your consent to anything we do with your personal information, you have the right to withdraw your consent;
- Request erasure: you can ask us to erase your personal information where there is no good reason for us to continue to keep your information. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing, where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local laws. We may not be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. However, if you exercise this right we will not be able to provide you with our services. Please also note that we are not required to delete information where we have a compelling reason or duty to retain it;
- Right to object processing or restrict processing: in some circumstances, you have the right to object to our use of your personal data or to ask us to restrict certain processing activities;
- Data portability: if we are using your information on the basis of your consent or because we need it to carry out our contractual obligations, you have the right to ask us to give you your personal information in a structured, commonly used and machine-readable format or have it transmitted to another data controller;
- Human intervention: in situations where an automated process or technology decides to proceed or block any transaction, you have the right to request to review our decision;
- Notification obligation: you have the right to ask us to notify everyone to whom we have given your personal information whenever we amend, delete or agree to restrict our use of it; and
- Lodge a complaint: you have the right to lodge a complaint about the way we handle or process your personal information with the relevant authorities.
There may be situations when you wish to exercise one of your rights and we are unable to agree to your request (e.g. because we have compelling legitimate grounds for using your information, or because we need to keep your information to comply with a legal and/or regulatory obligation).
You will not ordinarily have to pay fees to access your personal data (or to exercise any other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights).
We try to respond to all legitimate requests within 30 working days. Occasionally it could take us longer if your request is complex or you have made several requests. In this case, we will notify you and keep you updated.
6. How does Kema use cookies?
Cookies are files that websites put on your device to provide you with a better, more personal and relevant experience online. Some cookies are essential for websites to work and others are there to give you a better, more enjoyable experience online. By continuing to use our websites or platforms, you are agreeing to our use of cookies. Alternatively, you can manage them in your browser settings.
7. How do we keep your information secure?
Kema has put in place appropriate security measures to prevent your personal data from being accidentally used or accessed in an unauthorised way, altered or disclosed. We store and process your information maintaining physical, electronic and procedural safeguards. We maintain physical security measures to guard against unauthorised access to systems and use safeguards such as firewalls and data encryption. We enforce physical access controls to our buildings, and we authorise access to personal information only for those employees or agents who require it to fulfil the responsibilities of their jobs.
While we aim to protect your personal data, we cannot ensure or guarantee the security of any personal data you transmit to us. Any transmission of your personal information is done at your own risk.
8. How do we keep this privacy policy updated
We reserve the right to modify or amend this policy from time to time. You are advised to check this policy periodically to ensure that you are aware of and comply with the current version of the policy. Changes are binding on users of the website or platform and will take effect immediately on posting of the revised policy on the website. You will always be able to find the most recent version on Kema’s websites.
9. How to contact us?
If you have any questions or requests, or if you want to exercise any of your rights related to Kema’s Privacy Policy, please contact us at support@kema.co