The website www.tougly.com (Website or Site) and the Tougly online platform (Tougly) are owned, managed and operated by Tahseen Information Technology, a company registered in Dubai and licensed to operate in UAE (we, us, or our).
This privacy policy (Policy) (which is available at www.tougly.com/privacy.php) together with the terms of use (which are available at www.tougly.com/terms.php) (Terms), set out the basis on which we collect, store, use, share and process any personal data we collect from customers, visitors and users of the Site and the Platform.
Please read this Policy carefully. By accessing and continuing to use this Site, you confirm that you have read, understood and agree to be bound by this Policy in its entirety and that you give us your consent to collect and process your personal information as set out in this Policy. If you do not accept the terms of this Policy, then you must stop using or accessing this Site.
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 are complying with the latest version of the Policy. Changes are binding on users of the Site and will take effect immediately on posting of the revised policy on the Site. You agree to be bound by such changes and your access and continued use of this Site shall constitute your acceptance of such changes and your consent to us to collect, store, use, share and process your personal information as may be set out in the then current version of the Policy. We will advise you on the Site that the Policy has changed. You accept that by doing so, we will have provided you with sufficient notice of such change.
Our business has been built on trust between our customers and ourselves. We respect your right to privacy and are committed to responsible information handling practices.
Below Five privacy principles form fundamental cornerstone of our privacy policy:
By maintaining our commitment to these principles, we ensure that we respect the inherent trust that you place in us.
This Statement is intended to notify you why & how personal information is collected:
1.1. We collect your personal information to carry out and administer our services to you and in an effort to improve your customer experience. Without such data, we may be unable to open or continue accounts or establish or continue operational facilities or provide our services.
1.2. Personal Information is also collected from customers in the ordinary course of business (Credit Bureau, Feedback from other parties, algorithmic outcome etc) to continue the financial transactions.
1.3. Use of "cookies": Your visit to this site may be recorded for analysis on the number of visitors to the site and general usage patterns. Some of this information will be gathered through the use of "cookies". Cookies are small bits of information that are automatically stored on a person's web browser in their computer that can be retrieved by this site. Should you wish to disable these cookies you may do so by changing the setting on your browser. However, you will be unable to enter certain part(s) of our website.
1.4. Marketing Promotions: Occasionally we may collect personal information from visitors to this site and those individuals that participate in a contest or promotion (online or over the telephone, or at one of our branches). Such information is only collected from individuals who voluntarily provide us with their personal information. We may use this information to advise them of products, services and other marketing materials, which we think, may be of interest to them. We may also invite visitors to this site to participate in market research and surveys and other similar activities.
2.1. Data Security
2.1.1. Security is one of our top priorities. We will strive at all times to ensure that your personal information will be protected against unauthorised or accidental access, processing or erasure. We maintain this commitment to data security by implementing appropriate physical, electronic and managerial measures to safeguard and secure your personal information.
2.1.2. The secure area of our website supports the use of Secure Socket Layer(SSL)protocol and 128-encryption technology - an industry standard for encryption over the Internet to protect data.
2.1.3. Our web servers are protected behind "firewalls" and our systems are monitored to prevent any unauthorised access. As the security of ordinary email cannot be guaranteed, you should only send email to us using the secure communication facility on our website. All practical steps will be taken to ensure that personal information will not be kept longer than necessary and we will comply with all legal, statutory and regulatory requirements concerning the retention of personally identifiable information.
2.2. Security Assurance
2.2.1. Both you and us play an important role in protecting against online fraud. You should be careful that your bank account details including your User ID(s) and/or Passwords are not compromised by ensuring that you do not knowingly or accidentally share, provide or facilitate unauthorised use of it. Please do not share your User ID and/or password or allow access or use of it by others. We endeavour to put in place high standards of security to protect your interests.
2.2.2. You should safeguard your unique User ID(s) and Passwords by keeping it secret and confidential. Kindly never write them down or share these details with anyone. We will never ask you for your Passwords, in order to ensure that you are the only person who knows this information. When choosing your unique Password for the first time, do not create it using easily identifiable information such as your birthday, telephone number or a recognisable part of your name. If you think your User ID and/or Passwords have been disclosed to third party is lost or stolen and unauthorised transactions may have been conducted, you are responsible to inform us immediately.
You hereby grant to us an irrevocable, royalty-free, worldwide, assignable, sub-licensable license to use any material which you submit to us on the Website for the purpose of use of the Services or for our marketing (by any means and in any media, including, but not limited to, on our website or in our journals) our Services. You agree that you waive your moral rights to be identified as the author and we may modify your submission.
Personal Information relating to a customer may be used to:
3.1. Conduct customer/transaction level KYC/screening/credit checks
3.2. Facilitate the daily operation of the services provided to customers;
3.3. Assist other financial institutions to conduct credit checks and collect debts;
3.4. Ensure ongoing credit worthiness of customers;
3.5. Design financial services or related products for customers' use;
3.6. Market financial services or related products;
3.7. Collect amounts outstanding from customers and those providing security for customers' obligations;
3.8. Meet the disclosure requirements of any law binding on us or any of our group/associate members;
3.9. Enable an actual or proposed assignee's rights in respect of the customer to evaluate the transaction intended to be the subject of the assignment, participation or sub-participation; to meet legal, regulatory or our internal policy requirement; and to fulfil any other purposes relating thereto.
3.10. Communication via email, sms, physical mail or other communication modes.
Disclosure of personal information held by us relating to a customer will be kept confidential, but, we may provide such information to the following parties for the purposes set out in Information Usage Statement:
4.1. any agent or third party service provider who provides administrative, operational, telecommunications, computer, payment, trusteeship, escrow, custodian, clearing or other services to us in connection with the operation of its business;
4.2. any other person under a duty of confidentiality including our Group/associate company which have undertaken to keep such information confidential;
4.3. any person to whom we are under an obligation to make disclosure under the requirements of any law binding on us or any of our group/associate companies; and
4.4. any actual or proposed assignee's rights in respect of the customer.
5.1. Right to be provided with certain information : 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, 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.
5.2. Right to access your information and Right to data portability: 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 can access your personal information by login onto your dashboard or writing us via contact us form on our website . For requests by email, We aim to provide you with your information within a month.
5.3. Right to 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 deal with your request; e.g. a copy of your passport if you want to update your citizenship.
5.4. Right to human intervention : While we use automated algorithms (often machine learning), we aim to make sure that we can explain the business outcome proposed by automated algorithms. In case you aren’t happy with the outcome or proposal or recommendation, you can ask us to review our position.
5.5. Right to erasure: You can ask us to erase your personal information with valid reason and we will endeavour to delete the same within 30 days subject to regulatory guidelines.
5.6. Right to restrict processing: You can ask us to stop using your personal information with valid reason for the same and we will endeavour to delete the same within 30 days subject to regulatory guidelines.
5.7. Notification obligation : You can 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.
5.8. Right to object : We may use your personal information to further our legitimate interests; e.g., we may use information about you to improve our marketing messages because we have a legitimate interest in making sure our customers know about new products which could be of benefit to them. We will always give you a right to object whenever we intend to use your personal information for our legitimate interests.
5.9. There may be occasions 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.
6.1. The Website and any communication sent to you may also contain/display Third Party advertisements and links to other websites or products and services. You agree and acknowledge that these apps and websites are operated by Third Parties and are not controlled by, or affiliated to, or associated with us unless expressly specified. We are not responsible for any form of transmission, whatsoever, received by you from any such Third Party. Accordingly, we do not make any representations concerning the privacy practices or policies of such Third Parties or terms of use of such websites or apps, nor do we control or guarantee the accuracy, integrity, or quality of the information or other materials available on such websites or apps. The inclusion or exclusion does not imply any endorsement by us of the website, the Third Party, or the information on the website. The information provided by you to such Third Party websites shall be governed in accordance with the privacy policies of such websites and it is recommended that you review the privacy policy on any such websites and apps prior to using such websites.
6.2. These Third Party websites and apps and advertisers may use technology to send the advertisements directly to your browser. In such cases, the Third Party websites or advertisers automatically receive your IP address. They may also use cookies, JavaScript, web beacons and other technologies to measure the effectiveness of their advertisements and to personalize advertising content. We do not have access to or control over cookies or other features that such Third Party websites and apps and advertisers may use, and the information practices of these Third Party websites and apps and advertisers are not covered by this Privacy Policy. Please contact them directly for more information about their privacy practices.
6.3. We cannot assure that other Users are or will be complying with the foregoing rules or any other provisions of this T&C, and, as between you and us, you hereby assume all risk of harm or injury resulting from any such lack of compliance.
6.4. You acknowledge that when you access a link when accessing the Website, the site you will enter into is not controlled by us and different terms of use and privacy policy may apply. By assessing links, you acknowledge that we are not responsible for those sites. We reserve the right to disable links to and / or from third-party sites to the Website, although we are under no obligation to do so. If you have any queries, concerns or complaints about such third party websites or mobile applications you must direct them to the operator of that third party website or mobile application.
6.5. We have no control over and accept no responsibility for the content of any website or mobile application to which a link from the Website exists (unless we are the provider of those linked websites or mobile applications). Such linked websites and mobile applications are provided "as is" for your convenience only with no warranty, express or implied, for the information provided within them.
Any grievances relating to use or handling of your personal data may be brought to our notice by writing to us via contact us form on our website.
IMPORTANT:
Please read this Policy carefully. By accessing and continuing to use this Site, you confirm that you have read, understood and agree to be bound by this Policy in its entirety and that you give us your consent to collect and process your personal information as set out in this Policy. If you do not accept the terms of this Policy, then you must stop using or accessing this Site.
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 are complying with the latest version of the Policy. Changes are binding on users of the Site and will take effect immediately on posting of the revised policy on the Site. You agree to be bound by such changes and your access and continued use of this Site shall constitute your acceptance of such changes and your consent to us to collect, store, use, share and process your personal information as may be set out in the then current version of the Policy. We will advise you on the Site that the Policy has changed. You accept that by doing so, we will have provided you with sufficient notice of such change.