Privacy Policy
1. Data Controller
The data controller responsible for processing your personal data is First Numismatic Tech Consultants FZCO (hereinafter, the "Company"), a company incorporated in Dubai, United Arab Emirates. Our identification and registration details are:
- Address: Dubai Digital Park, Building A1, Dubai Silicon Oasis, Dubai, UAE
- DSO Commercial License: 54413
- DSO-FZCO Registration No: 52060
- TRN (Tax Registration Number): 104868001900001
- Data Protection Officer (DPO): Olga Reyes
- DPO Email: dpo@firstnumismatic.tech
2. Data Collected
The Company collects only the data necessary to provide its technology consulting services and to ensure optimal browsing on our website. This data includes:
- Basic contact data: Name, email address, company name, and service of interest, provided directly through our contact form.
- Browsing data: IP address, browser type, operating system, and usage statistics collected via analytical cookies (subject to the user's consent).
3. Purpose of Processing
The personal data provided will be processed for the following purposes and legal bases in compliance with the UAE Federal Decree-Law No. 45 of 2021 on Personal Data Protection (PDPL):
| Purpose of Processing | Types of Data Used | Legal Basis (PDPL Art. 5/6) |
|---|---|---|
| Responding to inquiries and pre-contractual requests | Name, email, company, service of interest | Execution of pre-contractual measures or legitimate interest. |
| Sending commercial communications and newsletters | Name, email address | Explicit consent (active opt-in check). |
| Web performance analysis and optimization (Google Analytics) | IP address, metadata, analytical cookie data | Explicit consent granted via the banner settings. |
| IT security and fraud prevention | Access logs, network data, IP addresses | Compliance with legal obligations and security standards (DSO). |
4. Legal Basis for Processing
The legal basis that legitimizes the processing of your data is:
- The unequivocal and informed consent provided by actively and manually checking the acceptance boxes on the contact form and/or accepting the cookie policy.
- The execution of pre-contractual or contractual measures to deliver the services requested from the Company.
5. Recipients of the Data
The data provided will not be transferred or communicated to third parties outside the Company, unless legally required by court order or government mandate of the United Arab Emirates. Only our trusted technology service providers may have access to the data, under strict confidentiality and data processing agreements.
6. International Transfers
Due to our international presence and operations headquartered in Dubai (UAE) and alignment with DSO regulations, the personal data collected through the website may be transferred to secure servers located in the United Arab Emirates. In accordance with Chapter III of the UAE Personal Data Protection Law (PDPL), international transfers of data are carried out under mechanisms that guarantee an adequate level of protection, including standard contractual clauses and end-to-end encryption.
7. Retention Period
We will retain your personal data for the time strictly necessary to fulfill the purpose for which it was collected, i.e., responding to your query or commercial request. Subsequently, the data will be kept blocked for the legal periods required by local UAE legislation, after which it will be completely and securely deleted or anonymized.
8. Rights of the Data Subject
As the owner of the data, you have the following rights under the UAE PDPL:
- Access: The right to know what data we process about you and obtain a copy of it.
- Rectification: The right to correct inaccurate or incomplete data.
- Erasure: The right to request the deletion of your data when it is no longer necessary.
- Restriction of processing: The right to temporarily restrict how your data is processed.
- Portability: The right to receive your data in a structured, readable format.
- Objection: The right to object to processing for commercial purposes.
The Data Protection Officer (DPO) will respond to your rights requests within a maximum period of 30 business days, which may be extended in case of special complexity in accordance with the applicable articles of the UAE PDPL.
To exercise any of these rights, you may submit a written request enclosing a copy of your identity document to our DPO Olga Reyes at privacy@firstnumismatic.tech or dpo@firstnumismatic.tech.
9. Data Security
The security of your data is our priority. We implement advanced technical, physical, and organizational measures (such as SSL/TLS encryption, firewalls, and restricted access controls) designed to protect your personal information against unauthorized access, loss, alteration, or unauthorized disclosure. If you detect any vulnerability or have security questions, you can contact our security team at security@firstnumismatic.tech.
10. Changes to the Privacy Policy
The Company reserves the right to modify or update this Privacy Policy to adapt it to new legislative developments or technical improvements to the website. Changes will be published on this page with the date of the last update reflected in the header.