Privacy Policy

We are committed to protecting and respecting the privacy of your personal information.

Last updated: November 1, 2022

This Privacy Policy (hereinafter referred to as the “Privacy Policy”) applies to the website https://mircare.com/en-gb/ and/or any subsidiary website and/or corresponding domains (and/or subdomains) https://mircare.com/en-gb/ (hereinafter referred to as the “website” or “site”), the services provided by Mircare (the owner and operator of the Site), and any related software applications (“Applications”) , in which your personal data is processed (through the Site, any of Our applications or otherwise).

Mircare is an international group of companies that provides clients with services in the field of planning for obtaining residence permits and citizenship.

Mircare includes a number of legal entities, details of which can be found here. This Privacy Policy is issued on behalf of Mircare and its affiliates, so when this Privacy Policy refers to “Mircare”, “We”, “Us” or “Our”, we mean the relevant Mircare entity responsible for the processing your data. We will provide information about which organization handles personal data when a customer uses any of our services. In limited circumstances, where customer personal data is provided to, stored and processed by us in countries where local data protection laws additionally apply, our customers may refer to the relevant jurisdiction below for further information on relevant local data protection laws in relation to the policy notice privacy.

In the Privacy Policy, the words “You”, “Your” and “User” refer to an identified or identifiable individual who is a User of the Site and/or a client (or potential client) recipient of any of Our Services. Full details, including contact details, can be read below.

This Policy describes the ways in which Mircare processes information and personal data that you provide to us and which allows us to effectively manage your relationship with us.

1. Purpose of this Privacy Policy

We respect and value the privacy of our clients. Mircare does not sell, transfer or otherwise make available to third parties any information about any person visiting our Website, except as expressly provided in this Privacy Policy.

The purpose of this Privacy Policy is:

• - Identification of the type of personal information that Mircare collects about customers and how we use your personal information.
• - Identification of the basis on which Mircare processes any personal data.
• - Bringing to your attention information about how Mircare processes your personal data
• - Clarification of Mircare's obligation under data protection regulations to process our customers' personal data lawfully and responsibly.
• - Informing you of your data protection rights

2. Legal issues regarding the processing of personal data

All processing of Personal Data carried out by Mircare is carried out in accordance with this Privacy Policy, and:

• Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/. EC (General Data Protection Regulation - hereinafter referred to as "Regulation" or "GDPR")

We comply with local data protection laws in the jurisdictions in which we operate.

This Privacy Policy should be read in conjunction with Our Cookie Policy and any other privacy notices We may provide on certain occasions when We collect or process personal data about you to ensure that you are fully aware of how and why we use your data.

3. Data controller

We control the personal data that we collect or receive and process in the course of providing our services and/or operating the website. Our affiliated entities may become data controllers, either jointly or as separate data controllers.

Contact information

Full name of the legal entity: Mircare FZE LLC.

Mailing address: Suite 04, office 1801,18 floor, Burlington Tower, Business Bay, Dubai, PO BOX 127907.

Phone: +971586883270

4. Personal data received from our Users

Personal data or personal information is any information about an individual from which that person can be identified. Personal data does not include information where there is no mention of an individual (anonymous data). Our website is structured so that our users can access our online site without identifying themselves or revealing any personal information. If you choose to provide us with personal information, We will protect this information and use it only in the ways described below.

We collect and process the following personal data about you:

a) Identification dataincluding first name, maiden name, last name after marriage, position, identity document number, gender, nationality, employment status, organization, occupation, email address and phone number.

If you use our services or apply for a position, you may be required to provide additional information. If you are a user of our services, we may also require additional information before we enter into a commercial relationship with you.

We may also ask you for information that may be necessary to verify your identity and serve as proof of your identity, such as copies of your passport or national ID card. If you are a job seeker, you will be required to provide a copy of your current resume.

If we need to obtain certain personal data in accordance with legal requirements or in accordance with the terms of a contract concluded with you, and you are unable to provide this data upon request, this results in the impossibility of providing the service in accordance with the agreement or the impossibility of concluding a contract with you , but we will inform you about this in advance. As a result of our inability to provide certain data, the contractual relationship with you may have to be terminated.

b) Contact informationincludes billing address, mailing address, email address and contact telephone numbers.

c) Compliance Data(AML and KYC) includes the following information and documentation related to the checks carried out in relation to Our clients or their representatives, shareholders, founders, beneficiaries, directors, if the client is a legal entity person: a copy of the identity document, a KYC check report (database) and any other documentation that may be required from time to time under the Prevention of Money Laundering Act ("PMLA"), the Prevention of Money Laundering and Terrorist Financing Regulations ( "PMLFTR"), Financial Intelligence Analysis Unit ("FIAU") and/or as required by any other competent authority or relevant legislation.

d) Supporting Dataincludes the following information about Our clients:

• The client’s current situation, plans, interests, goals or objectives;
• Services requested and provided to the client.

e) Financial dataincludes the customer's bank account details and details of any payment methods used by the customer to pay Our invoices and, if required in the particular circumstances, the financial position and client's creditworthiness.

e) Transaction dataincludes details of invoices issued to the customer (including due date and payment methods), payments to and from the customer, and any outstanding invoices due to the customer.

g) Technical Dataincludes Internet Protocol (IP) address, your login information, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, as well as other information about your experience with the Website, such as page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs) and the methods used to go to pages.

Location Information: We may receive location information about you and may determine your location from your IP address and, when accessing the Website through a mobile device, using data we collect from that device. This includes information about wireless networks or cell towers near your mobile device at the time of access.

Our website uses cookies to distinguish you from other users of our website. This helps us provide a quality browsing experience on our website and allows us to improve our site. For detailed information about the cookies we use and the purposes for which we use them, please see our cookie policy.

h) Marketing and Communications Data – your preferences in receiving marketing materials from us and our third parties or their affiliates, as well as preferences regarding communication methods. This may include information about whether you have subscribed or unsubscribed to any of our newsletters, attended any of our events or accepted any of our invitations.

We also collect, use and process any other personal information that you voluntarily provide or disclose to us where appropriate and necessary to provide the services you have requested from us.

5. How is your personal data collected

Personal data may be provided by you in the following cases:

• Filling out the request form on the website
• Correspondence with us by mail, telephone, email or otherwise in the course of applying for our services
• Subscribe to our services or publications,
• Request a quote to send to you,
• Reviews about our services
• Starting negotiations or concluding an agreement.
• Whenever you visit our website, we automatically collect technical data.
• We may also receive personal information about our visitors from various third parties and publicly available sources (Google Analytics advertising features including Google AdWords, Facebook Pixel, Google Tag Manager, LinkedIn and other special paid media partnerships).
• Identity, contact and reference data from publicly available sources, audit databases, and/or audit data service providers in the EU and outside the EU so that we can verify that you are a suitable customer or supplier for us.

6. How we use your personal data

We use personal data:

• To simplify the format for providing the requested services under the contract that we enter into or have entered into with you,
• When our legitimate interests (or those of third parties) require it and your interests and rights do not override those interests,
• When necessary to comply with legal or regulatory obligations,
• To resolve any problems you report and to provide support services
• To manage our relationship with you as a supplier,
• To administer our website and internal operations, including troubleshooting, and to maintain the security of our website
• To improve the performance of our website to ensure that content is presented to you in the most effective manner
• To ensure that all information on the site is presented in a user-friendly form.

7. Legal basis for data processing

We process your personal data only to the extent necessary to enable us to provide our services and/or for the purposes specified in this Privacy Policy.

We may also process your personal data on the basis of any legitimate interests or to comply with any legal obligations. These interests and obligations may include the exercise or defense of legal claims or compliance with the order of any court, tribunal or authority, and disclosure of information to a government or regulatory authority.

As a rule, we do not require separate legally verified consent to process your personal data. However, if your consent is required, we will provide you with a personal data processing request form.

8. Marketing

If you request, you will receive promotional communications by providing us with your information through this website and your consent to receive such information. If we have entered into a business relationship (namely signed a contract) with you, we may inform you about our activities, offers or other information that we believe will be useful to you in accordance with our legitimate interests.

We do not share your personal data with third parties for marketing purposes without your consent.

You have the right to revoke your consent or unsubscribe to receive promotional information at any time by writing to office@mircare.com or by clicking the unsubscribe button. Once you withdraw your consent, or if you object to any of the items listed here, we will stop sending you any marketing communications. If you choose not to consent or choose to unsubscribe, We will be able to provide our services to the extent possible without the information required to provide the full range of services. This may affect the efficiency with which we provide the services you request.

9. Disclosure of your personal data

We reserve the right to disclose your personal data to any of our international offices or Mircare member companies who may act as joint data controllers or data processors for our company. These offices or companies become the responsible controllers of your data in providing our services and/or they provide administration, control and reporting services. All Mircare companies respect and protect the security of your personal data in accordance with applicable laws (including GDPR) and take all measures to protect data.

We may need to share personal data with government agencies and authorities in the country in which you plan to obtain residence permit or citizenship. We provide such information only to the extent necessary to provide services in accordance with our contract with you.

We may be required to provide your data to local agents or other third parties (for data processing) in order to provide the services you have requested. These local agents and suppliers store and process your data in strict confidence and with appropriate security measures and safeguards.

We may also share your data with other third parties who act as data controllers, such as legal, tax, real estate, immigration or other consultants and agents, (international) banks for payment details or third parties providing other or additional services or products to you, such as estate agents, owners or developers, with whom you may wish to interact on separate terms. These third parties will process your data under their own rules and their data protection policies and processes will apply.

We may also disclose or share your data if we are required to do so to comply with any legal requirement, court order or order of a court, tribunal or authority. We may also disclose your information to enforce our terms of use or to protect our rights, property or safety of our partners or other users of our website. This includes sharing information with other companies and organizations for anti-money laundering or due diligence purposes, compliance with anti-bribery or corruption laws, and/or fraud protection.

10. Transfer of data to third countries

When we share your personal data with third parties, this may involve transferring your data outside the EEA. We share your personal data in accordance with standard contractual clauses to ensure that your personal data is protected and transferred securely in accordance with applicable laws, including the GDPR.

All Mircare divisions act as the EU data processing representative for other divisions located outside the EEA. You can ask any questions or concerns you may have regarding Mircare by sending an email with the subject “Data Protection” to the following address: office@mircare.com

11. Third party access to your personal data

We work closely with third parties to provide services. These third parties include cloud storage providers, analytics providers and search engine information providers. We only work with third party providers if they comply with applicable laws in the jurisdictions in which we operate and who follow the GPL to ensure a high level of security and protection for your personal data.

12. Data security

We take all necessary security measures against illegal or unauthorized processing of personal data, as well as against accidental loss or damage to personal data. In addition, we restrict access to your personal information to those employees, agents, service providers and other professional third parties who have a need to know that information. They handle your personal data strictly in accordance with our instructions and maintain confidentiality. All of our employees and agents have received appropriate data protection training.

The transmission of information between our website and your device is protected by Transport Layer Security (TLS) certificates. When the website is accessed using compatible browsers, this technology protects personal information by using both server authentication and data encryption to ensure the security of personal information during transmission.

All personal data is stored on a secure server that uses a firewall and other advanced technologies to protect against tampering or unauthorized access. Usernames and passwords are issued to persons authorized to access personal data, Our employees, who are required to maintain confidentiality and are not entitled to disclose any personal data.

No method of data transmission is 100% secure and, accordingly, absolute security cannot be guaranteed.

13. Data storage

We only retain your data for as long as strictly necessary for the purposes for which it was collected (that is, to provide you with our services or to satisfy any legal, accounting or reporting requirements).

We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected (providing services and continuing our professional relationship with you), and further to satisfy any legal or security claims. for accounting, tax, anti-money laundering purposes, for required reporting purposes, or for the purposes of obligations imposed on us. We may need to retain your personal data in order to be able to assert, exercise or defend against possible future legal claims against or otherwise involving you.

In general, the period for which we retain your personal data should not exceed six (6) years from the date of termination of our relationship. This retention period allows us to use your personal data for potential AML/CFT reporting obligations to the FIAU (legal obligation) and/or to assert, bring or defend against potential legal claims involving you.

14. Data minimization

По возможности, мы обезличиваем хранящиеся у нас данные о вас, когда больше нет необходимости идентифицировать вас по этим данным.

15. Your rights as a data subject

You have the right to exercise the following rights in accordance with the PDA:

1. Right to access information

You have the right to request information about whether your personal data is processed by Mircare, as well as information about how and why it is processed by sending an email to office@mircare.com You will receive the information electronically free of charge by email in a single case. We reserve the right to charge a reasonable fee if your request is manifestly unfounded, repetitive or excessive, and we reserve the right to refuse your request.

2. Right to object

You can contact us at any time by sending an email to office@mircare.com to ask us not to use your personal data, where our lawful basis for using your personal data is that it is necessary for the legitimate interests pursued by us or a third party, or for marketing purposes (for example, receiving information from us about upcoming events, newsletters and publications). If you object in writing, your data will no longer be used for these purposes.

3. Right to make changes

You have the right to amend and correct any inaccuracies in your personal data used by us, update any out-of-date data and complete any incomplete personal data, including by means of an additional statement.

4. Right to erasure

You have the right to request the deletion of your personal data transferred to Us when it is no longer required in the following cases:

• you withdraw your consent to our processing of your personal data originally provided to us, or where there are no other legal grounds for processing
• your personal data is no longer needed for the purpose for which it was originally collected
• you object to the use of data and in the absence of overriding legal grounds for sending commercial communications,
• your personal data was used illegally
• Your personal data must be deleted to comply with a formal legal requirement to which we are subject.

Please note that we may not always be able to comply with your deletion request for specific legal reasons, which we will notify you of at the time we process your request. This may include where retaining your personal data is necessary to comply with a legal or regulatory obligation to which we are subject; or in case of litigation.

5. Right to restriction of processing of personal data

You have the right to restrict our right to use your personal data if:

• you contest the accuracy of this personal data during the period in which Mircare verifies the accuracy of this personal data
• our processing of personal data is unlawful and you object to the erasure of your personal data and instead request a restriction of its use
• we no longer need your personal data for the purposes set out in this Privacy Policy, but you will need it in the event of legal proceedings
• you object to our processing of your data and are awaiting a decision on the legal basis for using the data.

6. Right to receive data

We will provide you or a third party you choose with your personal data in a structured, commonly used, electronic format.

7. Right to withdraw consent

If you have consented to the collection, processing and transfer of your personal information for a specific purpose (for example, advertising purposes), you have the right to withdraw your consent to that specific transaction at any time, or you may withdraw your consent from this Privacy Policy. To withdraw your consent, please write to office@mircare.com This will not affect the lawfulness of any data use we made based on such consent prior to your consent. review. Once we receive notice that you have withdrawn your consent, we will no longer use your information for that purpose unless we have another lawful basis to do so under the law. Withdrawal of consent to this Privacy Policy will result in us having to immediately stop providing our services to you.

16. Legislation regulating controversial issues

The Privacy Policy and any dispute arising out of its application are governed by the laws of Malta. You hereby agree that the courts of Malta shall have exclusive jurisdiction over any claim, dispute or controversy relating to the Letter of Engagement and any matters arising therefrom. Each party irrevocably waives any right it may have to object to the filing of an action in these courts, to claim that an action has been brought in an inconvenient forum, or to allege that these courts lack proper jurisdiction.

17. Changes to this Privacy Policy

Any changes we may make to this Privacy Policy in the future will be posted on this page and, where appropriate, emailed to you.

18. How to contact us

If you have any questions or comments regarding this Privacy Policy, please contact us today using the contact information (see Section 3, Data Controller).