This Privacy Policy (hereinafter referred to as the Policy) applies to all information that "TORRION RIVER – FZCO” (hereinafter referred to as the Company) can receive about the User during the use of the Company’s Website, programs and products.
This Policy regarding the processing of personal data compiled in accordance with the Personal Data Protection Law, Federal Decree Law No. 45 of 2021, the Legal Affairs Department is governed by the laws of the Emirate of Dubai and the other applicable federal laws of the United Arab Emirates.
This Policy defines the procedure for processing personal data, conditions and principles for the processing of personal data, information on the implemented measures to protect the processed personal data.

1. DEFINITION OF TERMS
1.1. The following terms are used in this Policy:
1.1.1. “Personal data” means any information recorded on electronic, paper and (or) other tangible media relating to a specific individual or making it possible to identify him;
1.1.2. “Personal data processing” means any implementation of one or more steps to collect, systematize, store, enhance, supplement, offer, provide, distribute, transfer, depersonalize and neutralize vegetation;
1.1.3. "Confidentiality of personal data" is a mandatory requirement for compliance with Company or other persons who have access to personal data not to allow its distribution without the consent of the subject of personal data or other legal foundation;
1.1.4. "Website" (hereinafter referred to as the Company’s Website) refers to the website https://torrionriver.com/ subject to all levels of domain names owned by the Company.
1.1.5. "Website Company’s User" (hereinafter referred to as the User) is a person who has access to the Website through the Internet and using the Website.

2. GENERAL PROVISIONS
2.1. The use of the Company’s Website by the User means a specific and conscious consent to this Policy and the terms of processing of the User's personal data.
2.2. In case of disagreement with the terms of the Policy the User should stop using the Company’s Website. The further use by the User of the Website will be considered as the User's consent to these terms.
2.3. This Policy applies only to the Company’s Website. The Company does not control and is not responsible for the Websites of third parties, which the User can visit using the links available on Company’s Website.
2.4. The Company does not verify the authenticity of the personal data provided by the User to the Company’s Website.
2.4.1. In this regard, the Company proceeds from the fact that when submitting personal data User:
— is a competent (a capable) person. In case of incapacity of the person using the Website, consent to the processing of personal data is provided by the legal representative.
— indicates reliable information about himself (or about the incompetent person represented by him person). The User independently maintains the submitted personal data in up to date.
2.5. The Company processes personal data based on the following principles:
2.5.1. legality;
2.5.2. restrictions on the processing of personal data by achieving specific in advance certain legitimate purposes;
2.5.3. preventing the processing of personal data incompatible with the purposes of collection and/or storage of data received from the User;
2.5.4. compliance of the content and volume of personal data being processed with the purposes of their processing;
2.5.5. preventing the processing of data that is excessive in relation to the purposes of processing;
2.5.6. ensuring the accuracy, sufficiency and relevance of personal data in relation to the purposes of their processing;
2.5.7. destruction or depersonalization of personal data in order to prevent their disclosure upon achievement of the purposes of data processing, loss of the need for such processing or upon receipt from the User of a request for the destruction of personal data or receipt statements about the withdrawal of consent to the processing of personal data.

3. POLICY SUBJECT
3.1. This Policy provides the obligations of the Company for non-disclosure and security of the confidentiality of personal data that the User provides upon request of Company when sending a question to the Company address.
3.2. Personal data permitted for processing under this Policy is provided by the User by filling out the form on the Company’s Website and includes the following information:
3.2.1. surname, first name, patronymic of the User;
3.2.2. e-mail address of the User;
3.2.3. The name of the Company represented by the User;
3.2.4. the phone number of the User;
3.2.5. Country of the User.
3.3. Company protects the data provided by the User.
3.4. The provision of User's personal data by entering them into the form on the Website is his consent to the processing of personal data in accordance with the terms and objectives indicated below.

4. PURPOSES OF COLLECTION OF THE USER'S PERSONAL DATA
4.1. Personal data will be processed (including (but not limited to) collection, storage, depersonalization, distribution, accumulation, systematization, copying, update) for the following purposes:
4.1.1. Establishing feedback connection with the User, including sending information about the activities of the Company, provided the Company services, publications on the Company’s Website and for processing requests from the User.
4.1.2. Identification of the User for the purpose of the subsequent conclusion of the Agreement with the person whose interests the User represents when making a request to the Company.

5. METHODS AND TERMS OF PERSONAL DATA PROCESSING
5.1. The User's personal data processing is carried out without any time limit, in any legal way, including in personal data information systems using automation tools or without using such tools.
5.2. The User's personal data can be transferred to the competent public authority of the United Arab Emirates only on the grounds and in the order provided by the legislation of the United Arab Emirates.
5.3. The processing of personal data of Users is carried out using databases data on the territory of the UAE.
5.4. The Company takes necessary organizational and technical measures to protect the User's personal data from unauthorized or accidental access, destruction, modification, copying, distribution, as well as from other wrongful acts of third parties.
5.5. For the purposes of data processing the Company can transfer Personal data exclusively to its employees. Personal data may be communicated to other persons only subject to the mandatory anonymization of personal data and only in a statistically processed form, excluding the possibility of identifying the User as the person to whom the data relates.
5.6. If the User wishes to clarify personal data in the event that personal the data is incomplete, inaccurate or out of date, or wishes to withdraw their consent to processing of personal data, the User must send an official request to the Company.

6. AUXILIARY TERMS
6.1. In order to improve the convenience of providing information, the Company’s Website and/or information systems of the third parties can automatically collect and process data during the use of Company’s Website using the software installed on user's device including IP address, file data cookies, information about User's browser (or other program used to access the Website), specifications of the equipment and software used by the User, access date and time to the Website, addresses of requested pages and other similar information.
6.2. If the User wishes to receive information about the personal data relating to him or to change the information provided by him or does not agree with the processing terms or the fact of its implementation, as well as with the intention of the Company to send informational materials to the User, the User may send his objections to the Company.
6.3. The Company has the right to make changes to this Policy without the consent of the User.
The new Policy comes into force from the moment of its posting on the Company’s Website, unless otherwise provided for by a new edition of the Policy.
6.4. Continued use of the Website or its services after the publication of a new edition Policy means acceptance of the Policy and its terms by the User.
6.5. The handling of all personal information by the Legal Affairs Department is governed by the laws of the Emirate of Dubai and the applicable federal laws of the United Arab Emirates.
6.6. All proposals or questions regarding this Policy and/or the processing of personal data are directed to the Company’s email address: info@torrionriver.com.
6.7. The current Policy is posted at: https://torrionriver.com/.