Effective Date: 1 October 2024
Be.-LLC (hereinafter “Be.”, “we” or “us” or “our”) values your security and privacy. Be. operates out of Delaware, USA and abides by the US data protection laws and regulations (as amended from time to time) and for personal data processing, we are subject to this jurisdiction.
A. As such, it is the policy of Be. to respect the privacy of our website users. In accordance with US legislation and as applicable, Be. collects information about you when you use or access our websites and other web-based products, information, or services (collectively, the “Website”) as well as through other interactions and communications you have with us. This data protection policy (the “Policy") sets out the basis on which any information, including any personal data we collect from you, or you provide to us, will be processed by Be. Each time you access or use the Website Services or provide us with information, by doing so you are accepting and, where possible, consenting to the practices described in this Policy.
You can visit our home page and our website without giving us your personal data. The portion of our website that is accessible to all Site Users (the “General Site”) is designed to provide General Visitors with a range of information concerning (i) home; (ii) services; (iii) contact details (iv) team etc. Through our General Site, for example, Site Users can request or be provided newsletters, alerts, e-announcements and other communications from our team. Our Website also provides Site Users with an online appointment booking option and with a membership registration option, where we require you to provide us with some personal data. Our Website also provides Registered Users with a gateway to the password-protected areas to which they have access, to make online payments for our services.
B. By using our website, you explicitly declare that you agree with our privacy policy, and you agree to us collecting and processing your personal data according to the methods and principles described in this privacy policy.
C. The website www.be.today (“Website” or “Site”) is the property of The Boardroom, duly represented by Vic Barreto, its CEO.
D. The Boardroom is committed to maintaining the privacy of information that you might share with us while visiting our website and interacting with us online. This ONLINE DATA PROTECTION & PRIVACY POLICY (“Privacy Policy” or “Policy”) covers how we collect and use any personal information that you provide through our website.
E. This Policy applies to all visitors of the Website (collectively, “Site Users” or “Users”),including (i) casual Site Users who visit the Site to learn more about our services (“General Visitors”); and(ii) registered users to whom we have granted access to certain password- protected areas and features of our Site, consisting of our E-Commerce Online Payment Facility (for registering as a ‘Registered User’ and using our services) (“Registered Users”).The term “you”, “your”, and “User”, or similar terms in this Policy means both General Visitors and Registered Users. The terms “us” refer to the Boardroom.
F. Please read this Policy carefully. By accessing and using our Website, you are acknowledging that you have read and understood this Policy and agree to be legally bound by it. If you do not agree with the terms of this Policy, please refrain from using our Site. This Policy should be read in conjunction with our General Terms &Conditions which govern the use of our Website.
1. Scope and Application This Policy applies to persons anywhere in the world who access or use Be.’s Website, as Site Users.
2. Collection of Information
This is information you give us about you by providing information or filling in forms, or by corresponding with us (for example, by telephone, e-mail or any other digital or electronic form). It includes for example information you provide when you share your data and register for an appointment using Be.’s provided appointment app, and when you report a problem with our Website. If you contact us, Be. will keep at least an electronic record of such correspondence, including personal information shared at that time. The personal information you give us may include your name, address, e-mail address and phone number, certain device information, and other registration information you choose to provide (“Personal Information” or "Personal Data”). The Website collects and processes Personal Data for specific, lawful purposes only, or for the performance of tasks carried out in the interests of Be.. The Website and its services are not targeted, intended or expected to be of use to children. Apart from providing information for specific services or purposes, as directed by Be. processes, User-provided contributions of content or contact information regarding or about children are expressly prohibited. Information we collect about you and your device. Each time you use our Website, we will automatically collect the following information: technical information, including the type of mobile device you use, a unique device identifier (for example, mobile network information, your mobile operating system, the type of mobile browser you use, device token, device type, time zone setting (“Device Information”); details of your use of our Website including, but not limited to traffic data, weblogs and other communication data, and the resources that you access (“Log Information”). location information, if the Website uses GPS technology to determine your current location. If you wish to use the particular feature, you may be asked to consent to your data being used for this purpose. You can alter your consent and sharing selections at any time via your mobile device settings. Other Information We May Collect Through Your Use of the Website When you use any Website pages, we may collect Personal Information as well as demographic information, for example information that you submit, or that we collect, which may include, but is not limited to, mobile network information, your mobile operating system, the type of mobile browser you use, time zone setting, device location, IP address, SMS data, browsing history information, searching history information, and registration history information (“Demographic Information”).
3. Use of Personal Data
We may use Personal Data which you provide to us or we collect from you to: Provide, maintain, and improve Website Services, including, for example, to facilitate payments, send receipts, facilitate access to our offline services (and send related information about them), develop new features, provide customer support to Users, authenticate users, and send administrative messages, whether information or required by applicable law; Perform internal administration and operations, including, for example, to prevent fraud and abuse of our Website; to troubleshoot software bugs and operational problems; to conduct data analysis, testing, and research; and to monitor and analyse usage and activity trends; Send you communications we think will be of interest to you, including information about our services, news, and events, only a) if you consented to such communication to be submitted to you, b) where permissible under UAE Laws and regulations; and to c) process contest, sweepstake, or other promotion entries and fulfil any related awards; Notify you about changes to our Website; Allow you to participate in any interactive features of our Website Keep our Website safe and secure; and Personalize and improve the Website, including to provide or recommend features, content, social connections, referrals, and advertisements. Specifically, we collect, or receive, information from General Visitors at different points on our Website, and use this information as follows:
a) Registrations. In order to access the Registration section of our Website (for potential/existing members) and make use of our services on the password-protected areas of our Site, we require that you provide certain information, such as (i) name; (ii) phone number; (iii) physical/e-mail address; (iv) date of birth; (v) gender; and (vi) nationality. The registration process for certain portions of the Site may require a Registered User to provide additional Personal Information, as specified in the registration process. We use the information provided by a Registered User during the registration process to provide him or her with a username and a password, and to allow the Registered User to gain access to password-protected areas of the Site. We also use contact information Registered Users provide during the registration process as further detailed below.
b) E-mail Communication. We use your e-mail address to send alerts/newsletters, e-announcements and other communications concerning the website, the company, our and third-party legal developments, notifications, and other information relating to our website. In addition, we may use your e-mail address to invite you to events, or other functions we believe may be of interest to you. You have the ability to opt-out of receiving these materials (Removing Information, Opting-Out).
c) Information Notices and Bulletins. Periodically, we may choose to send news, bulletins, seminar and information announcements, and other information to General Visitors, and will use Personal Information to send such communications. If we choose to undertake such communications, you will have the ability to opt-out of receiving these communications as provided in Section 8 (Removing Information, Opting-Out).
d) Surveys. Periodically, we may initiate surveys on our website, and we may request Personal Information from you in connection with such surveys. You are free to choose whether to participate in this type of survey. Survey information will be used for purposes of monitoring or improving our Site and our services. By submitting information to us when registering as a Site User, you consent to the use of your information for these purposes.
e) Data Transmitted During Payments: Your visit to our Website may result in the use of our E-Commerce Internet Payment Services. Any credit card or debit card details and related personally identifiable information will not be stored, sold shared, rented or leased to any third parties.
4. Processing, Storage and Transfer of Personal Data
We will take all steps reasonably necessary to ensure your data is processed fairly and lawfully, in accordance with the UAE legislation and this Policy. By submitting your Personal Data (including Log, Device and / or Demographic Information), you agree to such transfer, storing or processing in order for The Boardroom to provide you with information regarding our entire range of services (in person and online), including but not limited to responding to enquiries you raise via Website, and maintaining contacts for future informational or promotional activities. Unless otherwise notified, The Boardroom does not ordinarily engage in automated decision making when processing your Personal Data. You agree that we have the right to transfer the Personal Data described in this Policy to and from, and process and store it in, the United Arab Emirates and (where applicable or required) with processors in other countries, some of which may have less protective privacy laws than those where you reside. Where this is the case, we will take appropriate security measures to protect your Personal Data in accordance with this Policy and the applicable UAE legislation. To preserve the integrity of our databases, to carry out on-going Website services on behalf of all Users, for research, analytics, and statistics purposes and to ensure compliance with applicable laws and regulations, we retain Personal Data submitted by Registered Users for a reasonable length of time unless otherwise prescribed by applicable law. The Boardroom is not responsible for the accuracy of the information you provide and will modify or update your Personal Data in our databases upon your request, as further outlined below. We will erase or archive from active use your Personal Data upon request unless we are required to retain it in accordance with applicable regulations and laws. By accessing or using the Website, you do hereby represent and warrant that you understand that all information submitted by you through the Website or otherwise to The Boardroom may be used by The Boardroom in accordance with applicable laws and its policies.
5. Sharing of Personal Data
We may share Personal Data which we collect about you as described in this Policy or as described at the time of collection or sharing, including as follows:
5.1. Through Our Website We may share your Personal Data: As an exception to the policies set out here above, we will disclose your Personal Information to third parties without your express consent in the following circumstances:
a) Site Vendors. We may employ other companies to perform functions on our behalf, such as maintaining the Website, providing services related to the Site, collecting information, responding to and sending electronic mail, or other functions related to our mandate and services. In order to obtain these services, we may need to share your Personal Information with these companies (collectively, “Site Vendors”). We will provide Site Vendors with only the information necessary to perform their duties with respect to our Website, and we obligate our Site Vendors to safeguard your Personal Information and refrain from using your Personal Information for any other purpose.
b) Affiliates. We may disclose your Personal Information to our affiliates and entities under common control of the company.
c) Harm Mitigation. We may reveal your Personal Information to third parties such as law enforcement or investigative agencies if we believe it is necessary in order to prevent, or take action against illegal activities, fraud, or situations involving the potential threats to the rights, property, or personal safety of any person, or that you are violating these Terms, or other legal obligations. d) Legal. We will reveal Personal Information to the extent required to do so by law.
5.2. Other Types of Data SharingWe may share your Personal Data:
a) With Boardroom subsidiaries and affiliated entities (under Boardroom’s control);
b) With vendors, consultants, marketing and advertising partners, and other service providers who need access to such Personal Data to carry out work on our behalf or to perform a contract we enter into with them;
c) In response to a request for information by a competent authority or government entities if we determine that such disclosure is in accordance with, or is otherwise required by, any applicable law, regulation, or legal process;
d) With law enforcement officials, government entities or authorities, or other third parties as required by applicable law;
e) If we otherwise notify you and you explicitly consent to the sharing;
f) With third parties in an aggregated and/or anonymized form which cannot reasonably be used to identify you.
6. Your Rights and Choices
6.1 Marketing and and Opting Out Boardroom supports Users’ legal rights to opt-out of receiving communications from us and our partners. You have the option to ask us not to process your Personal Data for marketing purposes and to remove it from our database, to not receive future communications or to no longer receive our Website related information. You may change your preferences at any time. Please note that if you elect to opt-out of receiving promotional e-mails from us, we shall unsubscribe you from, and we will remove your individual contact information from, our professional contacts database.
6.2 Access to and Correction of Your Personal Information have the right to access information held about you. Your right of access can be exercised in accordance with UAE laws and regulations. Any access request generally comes at no cost to you, but may, where permissible, be subject to a fee to meet any extraordinary administrative costs in providing you with details of the information we hold about you. When you contact us about a potential Personal Data error, we will endeavor to confirm or verify the information in question, then correct verified inaccuracies and respond to the original inquiry. You may also request that we restrict, erase or otherwise process your Personal Data in line with the relevant articles providing for such rights set out in the UAE legislation.6.3 Changes to this may change this Policy from time to time and without notice. If we make significant changes in the way we treat your Personal Data, or to the Policy, we will endeavor to provide you notice through the Website or by some other means, such as email. Your continued use of the Website after such notice constitutes your acceptance of the changes. We encourage you to periodically review this Policy for the latest information on our privacy practices. We provide links to it through:
a) The Website
b) Referencing it in our Terms of Use
c) Incorporating it into our Letters of Engagement, contracts, agreements, and other documents as necessary or appropriate.
7. Security Precautions
The Boardroom makes every effort to ensure that your Personal Data is secure on its system. The Boardroom has staff dedicated to maintaining our data protection and security policies, periodically reviewing them and making sure that The Boardroom employees are aware of our data protection and security practices. Unfortunately, no data transmission over the internet can be guaranteed to be 100% secure. As a result, The Boardroom cannot warrant or guarantee the security of any Personal Data you transmit to us, and you do so at your own risk. The Boardroom has established policies and procedures for securely managing information and protecting Personal Data against unauthorized access. We continually assess our data privacy, information management and security practices.
We do this in the following ways:
a) Establishing policies and procedures for securely managing information;
b) Limiting employee access to viewing only necessary information in order to perform his or her duties;
c) Protecting against unauthorized access to Personal Data by using data encryption, authentication and virus detection technology, as required;
d) Requiring service providers with whom we do business to comply with relevant data privacy legal and regulatory requirements;
e) Monitoring our websites through recognized online privacy and security organizations;
f) Conducting background checks on employees and providing training to our employees. If you have any further questions about our security and processing activities, please contact us. To the extent permitted by applicable law, Be. expressly disclaims any liability that may arise should any other third parties obtain the Personal Data you submit.
8. Cookies
A cookie is a small text file that is unique to the web browser on your computer or mobile device, which is used to retain User preferences, and enhance browsing experience ("Cookie"). Be. uses Cookies to track over all site usage and enables us to provide a better User experience. We do not use Cookies to “see” other data on your computer or determine your email address. Types of cookies we drop, and the information collected using them include: Essential Google Analytics - gives website owners the digital analytics tools needed to analyse data from all touchpoints in one place, for a deeper understanding of the customer experience. Site Analytics DoubleClick - a subsidiary of Google which develops and provides Internet ad serving services. Twitter Advertising - enables website owners to track and measure the actions users take after viewing or engaging with ads on Twitter. Facebook Advertising - lets website owners measure, optimise and build audiences for advertising campaigns. LinkedIn Analytics – enables website owners to promote their company updates to targeted audiences on desktop, mobile, and tablet. Most browsers accept and maintain Cookies by default. Check the ‘Help’ or ‘Settings’ menu of your browser to learn how to change your Cookie preferences. You can choose to alter Cookies settings related to the use of our Website, but this may limit your ability to access certain areas of the Website. Alternatively, you may wish to visit an independent source of information, www.aboutcookies.org, which contains comprehensive information on how to alter settings or delete Cookies from your computer as well as more general information about Cookies. For information on how to do this on the browser of your mobile phone you will need to refer to your handset manual or network operator for advice. Advertising "). These links are provided solely as a convenience to you and not as an endorsement by Be. of the contents of or reliability on such External Sites. You acknowledge that Be. is not responsible for the availability of, or the information and content of any External Site. You should contact the site administrator or webmaster for those External Sites if you have any concerns regarding such links or the content located on such external Sites. If you decide to access linked third-party websites, you do so at your own risk. The Boardroom does not accept liability and shall not be liable to you for any loss or damage arising from or as a result of your acting upon the content of another website to which you may link from the Website.
9. External Links
These links are provided solely as a convenience to you and not as an endorsement by Be. of the contents of or reliability on such External Sites. You acknowledge that Be. is not responsible for the availability of, or the information and content of any External Site. You should contact the site administrator or webmaster for those External Sites if you have any concerns regarding such links or the content located on such external Sites. If you decide to access linked third-party websites, you do so at your own risk. Be. does not accept liability and shall not be liable to you for any loss or damage arising from or as a result of your acting upon the content of another website to which you may link from the Website. External Sites"). These links are provided solely as a convenience to you and not as an endorsement by Be. of the contents of or reliability on such External Sites. You acknowledge that Be. is not responsible for the availability of, or the information and content of any External Site. You should contact the site administrator or webmaster for those External Sites if you have any concerns regarding such links or the content located on such external Sites. If you decide to access linked third-party websites, you do so at your own risk. Be. does not accept liability and shall not be liable to you for any loss or damage arising from or as a result of your acting upon the content of another website to which you may link from the Website.
10. Contact Us
If you have any questions, comments and requests related to this Policy, or if you have any complaints related to how Be. processes your personal data, please contact us at: hello@be.today,
Phone: +971 56 1820384
