INTRODUCTION

Ibex Financial and Management Consulting respects the privacy of our users. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website [name of website.com] [and our mobile application], including any other media form, media channel, mobile website, or mobile application related or connected thereto (collectively, the “Site”). Please read this privacy policy carefully. If you do not agree with the terms of this privacy policy, please do not access the site.

We reserve the right to make changes to this Privacy Policy at any time and for any reason. We will alert you about any changes by updating the “Last Updated” date of this Privacy Policy. Any changes or modifications will be effective immediately upon posting the updated Privacy Policy on the Site, and you waive the right to receive specific notice of each such change or modification.

You are encouraged to periodically review this Privacy Policy to stay informed of updates. You will be deemed to have been made aware of, will be subject to, and will be deemed to have accepted the changes in any revised Privacy Policy by your continued use of the Site after the date such revised Privacy Policy is posted.

This Privacy Policy was generated by Termly’s Privacy Policy Generator.

COLLECTION OF YOUR INFORMATION

We may collect information about you in a variety of ways. The information we may collect on the Site includes:

Personal Data

Personally identifiable information, such as your name, shipping address, email address, and telephone number, and demographic information, such as your age, gender, hometown, and interests, that you voluntarily give to us [when you register with the Site [or our mobile application,] or] when you choose to participate in various activities related to the Site [and our mobile application], such as online chat and message boards. You are under no obligation to provide us with personal information of any kind, however your refusal to do so may prevent you from using certain features of the Site [and our mobile application].

Derivative Data

Information our servers automatically collect when you access the Site, such as your IP address, your browser type, your operating system, your access times, and the pages you have viewed directly before and after accessing the Site. [If you are using our mobile application, this information may also include your device name and type, your operating system, your phone number, your country, your likes and replies to a post, and other interactions with the application and other users via server log files, as well as any other information you choose to provide.]

Financial Data

Financial information, such as data related to your payment method (e.g. valid credit card number, card brand, expiration date) that we may collect when you purchase, order, return, exchange, or request information about our services from the Site [or our mobile application]. [We store only very limited, if any, financial information that we collect. Otherwise, all financial information is stored by our payment processor, [Amazon Payments,] [Authorize.Net,] [Braintree Payments,] [Chargify,] [Dwolla,] [Google Checkout,] [Paypal,] [SafeCharge,] [Stripe,] [WePay,] [2Checkout,] [other], and you are encouraged to review their privacy policy and contact them directly for responses to your questions.]

Facebook Permissions

The Site [and our mobile application] may by default access your Facebook basic account information, including your name, email, gender, birthday, current city, and profile picture URL, as well as other information that you choose to make public. We may also request access to other permissions related to your account, such as friends, checkins, and likes, and you may choose to grant or deny us access to each individual permission. For more information regarding Facebook permissions, refer to the Facebook Permissions Reference page.

Data From Social Networks

User information from social networking sites, such as [Apple’s Game Center, Facebook, Google+, Instagram, Pinterest, Twitter], including your name, your social network username, location, gender, birth date, email address, profile picture, and public data for contacts, if you connect your account to such social networks. [If you are using our mobile application, this information may also include the contact information of anyone you invite to use and/or join our mobile application.]

Mobile Device Data

Device information, such as your mobile device ID, model, and manufacturer, and information about the location of your device, if you access the Site from a mobile device.

Third-Party Data

Information from third parties, such as personal information or network friends, if you connect your account to the third party and grant the Site permission to access this information.

Data From Contests, Giveaways, and Surveys

Personal and other information you may provide when entering contests or giveaways and/or responding to surveys.

Mobile Application Information

If you connect using our mobile application:

• Geo-Location Information. We may request access or permission to and track location-based information from your mobile device, either continuously or while you are using our mobile application, to provide location-based services. If you wish to change our access or permissions, you may do so in your device’s settings.
• Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device’s [bluetooth, calendar, camera, contacts, microphone, reminders, sensors, SMS messages, social media accounts, storage,] and other features. If you wish to change our access or permissions, you may do so in your device’s settings.
• Mobile Device Data. We may collect device information (such as your mobile device ID, model and manufacturer), operating system, version information and IP address.
• Push Notifications. We may request to send you push notifications regarding your account or the Application. If you wish to opt-out from receiving these types of communications, you may turn them off in your device’s settings.

USE OF YOUR INFORMATION

Having accurate information about you permits us to provide you with a smooth, efficient, and customized experience. Specifically, we may use information collected about you via the Site [or our mobile application] to:

• Administer sweepstakes, promotions, and contests.
• Assist law enforcement and respond to subpoena.
• Compile anonymous statistical data and analysis for use internally or with third parties.
• Create and manage your account.
• Deliver targeted advertising, coupons, newsletters, and other information regarding promotions and the Site [and our mobile application] to you.
• Email you regarding your account or order.
• Enable user-to-user communications.
• Fulfill and manage purchases, orders, payments, and other transactions related to the Site [and our mobile application].
• Generate a personal profile about you to make future visits to the Site [and our mobile application] more personalized.
• Increase the efficiency and operation of the Site [and our mobile application].
• Monitor and analyze usage and trends to improve your experience with the Site [and our mobile application].
• Notify you of updates to the Site [and our mobile application]s.
• Offer new products, services, [mobile applications,] and/or recommendations to you.
• Perform other business activities as needed.
• Prevent fraudulent transactions, monitor against theft, and protect against criminal activity.
• Process payments and refunds.
• Request feedback and contact you about your use of the Site [and our mobile application].
• Resolve disputes and troubleshoot problems.
• Respond to product and customer service requests.
• Send you a newsletter.
• Solicit support for the Site [and our mobile application].
• [Other]

DISCLOSURE OF YOUR INFORMATION

We may share information we have collected about you in certain situations. Your information may be disclosed as follows:

By Law or to Protect Rights

If we believe the release of information about you is necessary to respond to legal process, to investigate or remedy potential violations of our policies, or to protect the rights, property, and safety of others, we may share your information as permitted or required by any applicable law, rule, or regulation. This includes exchanging information with other entities for fraud protection and credit risk reduction.

Third-Party Service Providers

We may share your information with third parties that perform services for us or on our behalf, including payment processing, data analysis, email delivery, hosting services, customer service, and marketing assistance.

Marketing Communications

With your consent, or with an opportunity for you to withdraw consent, we may share your information with third parties for marketing purposes, as permitted by law.

Interactions with Other Users

If you interact with other users of the Site [and our mobile application], those users may see your name, profile photo, and descriptions of your activity, including sending invitations to other users, chatting with other users, liking posts, following blogs.

Online Postings

When you post comments, contributions or other content to the Site [or our mobile applications], your posts may be viewed by all users and may be publicly distributed outside the Site [and our mobile application] in perpetuity.

Third-Party Advertisers

We may use third-party advertising companies to serve ads when you visit the Site [or our mobile application]. These companies may use information about your visits to the Site [and our mobile application] and other websites that are contained in web cookies in order to provide advertisements about goods and services of interest to you.

Affiliates

We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.

Business Partners

We may share your information with our business partners to offer you certain products, services or promotions.

[Offer Wall]

Our mobile application may display a third-party hosted “offer wall.” Such an offer wall allows third-party advertisers to offer virtual currency, gifts, or other items to users in return for acceptance and completion of an advertisement offer. Such an offer wall may appear in our mobile application and be displayed to you based on certain data, such as your geographic area or demographic information. When you click on an offer wall, you will leave our mobile application. A unique identifier, such as your user ID, will be shared with the offer wall provider in order to prevent fraud and properly credit your account.]

[Social Media Contacts]

If you connect to the Site [or our mobile application] through a social network, your contacts on the social network will see your name, profile photo, and descriptions of your activity.]

Other Third Parties

We may share your information with advertisers and investors for the purpose of conducting general business analysis. We may also share your information with such third parties for marketing purposes, as permitted by law.

Sale or Bankruptcy

If we reorganize or sell all or a portion of our assets, undergo a merger, or are acquired by another entity, we may transfer your information to the successor entity. If we go out of business or enter bankruptcy, your information would be an asset transferred or acquired by a third party. You acknowledge that such transfers may occur and that the transferee may decline honor commitments we made in this Privacy Policy.

We are not responsible for the actions of third parties with whom you share personal or sensitive data, and we have no authority to manage or control third-party solicitations. If you no longer wish to receive correspondence, emails or other communications from third parties, you are responsible for contacting the third party directly.

TRACKING TECHNOLOGIES

Cookies and Web Beacons

We may use cookies, web beacons, tracking pixels, and other tracking technologies on the Site [and our mobile application] to help customize the Site [and our mobile application] and improve your experience. When you access the Site [or our mobile application], your personal information is not collected through the use of tracking technology. Most browsers are set to accept cookies by default. You can remove or reject cookies, but be aware that such action could affect the availability and functionality of the Site [or our mobile application]. You may not decline web beacons. However, they can be rendered ineffective by declining all cookies or by modifying your web browser’s settings to notify you each time a cookie is tendered, permitting you to accept or decline cookies on an individual basis.

[We may use cookies, web beacons, tracking pixels, and other tracking technologies on the Site [and our mobile application] to help customize the Site [and our mobile application] and improve your experience. For more information on how we use cookies, please refer to our Cookie Policy posted on the Site, which is incorporated into this Privacy Policy. By using the Site, you agree to be bound by our Cookie Policy.]

Internet-Based Advertising

Additionally, we may use third-party software to serve ads on the Site [and our mobile application], implement email marketing campaigns, and manage other interactive marketing initiatives. This third-party software may use cookies or similar tracking technology to help manage and optimize your online experience with us. For more information about opting-out of interest-based ads, visit the Network Advertising Initiative Opt-Out Tool or Digital Advertising Alliance Opt-Out Tool.

Website Analytics

We may also partner with selected third-party vendors[, such as [Adobe Analytics,] [Clicktale,] [Clicky,] [Cloudfare,] [Crazy Egg,] [Flurry Analytics,] [Google Analytics,] [Heap Analytics,] [Inspectlet,] [Kissmetrics,] [Mixpanel,] [Piwik,] and others], to allow tracking technologies and remarketing services on the Site [and our mobile application] through the use of first party cookies and third-party cookies, to, among other things, analyze and track users’ use of the Site [and our mobile application], determine the popularity of certain content and better understand online activity. By accessing the Site [,our mobile application,], you consent to the collection and use of your information by these third-party vendors. You are encouraged to review their privacy policy and contact them directly for responses to your questions. We do not transfer personal information to these third-party vendors. However, if you do not want any information to be collected and used by tracking technologies, you can visit the third-party vendor or the Network Advertising Initiative Opt-Out Tool or Digital Advertising Alliance Opt-Out Tool.

You should be aware that getting a new computer, installing a new browser, upgrading an existing browser, or erasing or otherwise altering your browser’s cookies files may also clear certain opt-out cookies, plug-ins, or settings.

THIRD-PARTY WEBSITES

The Site [and our mobile application] may contain links to third-party websites and applications of interest, including advertisements and external services, that are not affiliated with us. Once you have used these links to leave the Site [or our mobile application], any information you provide to these third parties is not covered by this Privacy Policy, and we cannot guarantee the safety and privacy of your information. Before visiting and providing any information to any third-party websites, you should inform yourself of the privacy policies and practices (if any) of the third party responsible for that website, and should take those steps necessary to, in your discretion, protect the privacy of your information. We are not responsible for the content or privacy and security practices and policies of any third parties, including other sites, services or applications that may be linked to or from the Site [or our mobile application].

SECURITY OF YOUR INFORMATION

We use administrative, technical, and physical security measures to help protect your personal information. While we have taken reasonable steps to secure the personal information you provide to us, please be aware that despite our efforts, no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against any interception or other type of misuse. Any information disclosed online is vulnerable to interception and misuse by unauthorized parties. Therefore, we cannot guarantee complete security if you provide personal information.

POLICY FOR CHILDREN

We do not knowingly solicit information from or market to children under the age of 13. If you become aware of any data we have collected from children under age 13, please contact us using the contact information provided below.

CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems [and our mobile applications] include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy. Most web browsers and some mobile operating systems [and our mobile applications] include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. If you set the DNT signal on your browser, we will respond to such DNT browser signals.

OPTIONS REGARDING YOUR INFORMATION

[Account Information]

You may at any time review or change the information in your account or terminate your account by:

• Logging into your account settings and updating your account
• Contacting us using the contact information provided below
• [Other]

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with legal requirements.

Emails and Communications

If you no longer wish to receive correspondence, emails, or other communications from us, you may opt-out by:

• Noting your preferences at the time you register your account with the Site [or our mobile application].
• Logging into your account settings and updating your preferences.
• Contacting us using the contact information provided below.

If you no longer wish to receive correspondence, emails, or other communications from third parties, you are responsible for contacting the third party directly.

OMANI PRIVACY RIGHTS

1. THE LAW

1.1. Overview of the privacy/data protection situation

Currently in Oman, there is no comprehensive law dealing with data protection issues. Personal data is protected in limited terms by certain provisions stipulated across a range of laws, as mentioned below.

1.2. Constitutional provisions

Royal Decree No. 101/96 Promulgating the Basic Statute of the State (‘the Basic Statute’) effectively serves as the Constitution of Oman, and grants freedom from interference of correspondence by any means of communication. The Basic Statute guarantees freedom of postal, telegraphic, telephonic, and other forms of communication and their confidentiality (subject to law). It is not permitted to monitor, inspect, or reveal the contents of such communications unless pursuant to law.

1.3. Other applicable laws (e.g. cybercrime law, privacy of communications)

Royal Decree No. 69/2008 promulgating the Electronic Transactions Law (‘the Electronic Transactions Law’) which applies to parties who have agreed to perform their transactions electronically, and safeguards the confidentiality of information or data contained in such transactions. Chapter 4 (Methods of Protecting Electronic Transactions) of the Electronic Transactions Law states at Article 18 that ciphering (i.e. encryption) is an essential means to be used for the purpose of protecting electronic transactions. This step can be efficient in keeping the information of the electronic message confidential and preventing others from infringing the data.

The Electronic Transactions Law also sets out ways of protecting private data. It states that any government body or authentication service provider may collect personal data directly from the concerned person or from others following their explicit consent, and only for the purpose of issuing certification or keeping it or facilitating such issuing or keeping. It is not permitted to collect, process, or use such data for any other purpose without the explicit consent of the person from whom such data is collected. The authentication service provider must follow the appropriate procedure to ensure confidentiality of the personal data in his/her possession.

Similarly, Royal Decree No. 12/2011 issuing the Cyber Crime Law (‘the Cybercrime Law’) was promulgated to address areas of unlawful activities in general cyberspace. The Cybercrime Law makes it a criminal offence to violate the privacy of individuals using technology. In fact, Article 3 of the Cybercrime Law states that those ‘who intentionally and illegally access an electronic site, informational system, or information technology tools or part of it or exceeded his authorised access to it or continued his existence therein after being aware of his access, shall be punished with imprisonment for a period not less than one month and not exceeding six month and a fine not less than OMR 100 (approx. €240) and not more than OMR 500 (approx. €1,200) or by either penalty.’ Other provisions namely, Articles 4 to 10 under Chapter 2 of the Cybercrime Law cover various acts in relation to privacy that constitute a cybercrime.

More, generally, Royal Decree No. 97/99 Promulgating the Criminal Procedure Law (only available in Arabic here) (‘the Criminal Procedure Law’) contemplates that correspondence and cables may not be confiscated or perused, newspapers, publications, and parcels may not be confiscated, conversations taking place at a private place may not be recorded, telephone may not be tapped and telephonic dialogues may not be recorded without the permission of the Public Prosecutor.

1.4. Case law

Not applicable.

1.5. Mention of whether there are any public sector data protection laws

In a general manner, Royal Decree No. 7/2018 Promulgating the Penal Law (‘the Penal Law’) has tackled the issue of data protection in the public sector. The Penal Law addresses the issue of forgery of reports, minutes, books, registers, records etc. and sets strict penalties for these offences. The aim is to protect the data and establish penalties to that end.

1.6. Possible amendments/draft data protection laws under discussion

At the time of writing this guidance note, there were no legislative proposals for data protection under consideration. However, suggestions have been raised by various actors in the Omani legal landscape to enact an independent data protection law in the near future.

2. SECTORAL LEGISLATION

2.1 FINANCIAL SECTOR

2.1.1. Law: Scope of application/ Key provisions

Presently there is no dedicated data protection legislation in the Omani financial sector. However, Royal Decree No. 114/2000 Issuing the Banking Law (‘the Banking Law’) sets out certain general provisions on the protection of customer information.

The Banking Law prohibits all licensed banks, their directors, officers, managers, or employees from disclosing information relating to any customer without customer consent except when such disclosure is required under the laws of Oman or if instructed by the Central Bank of Oman (‘CBO’). It clarifies that the customer may give general consent for purposes such as bank advertisements.

Customer consent to disclosure of information is not required where disclosure is instructed by the CBO. As per the Banking Law, no government agency or person may ask a licensed bank directly to disclose any information or take any action against a customer. All such requests must be submitted to the CBO to decide if action is required and instruct licensed banks to do so. Decisions of the CBO in relation to such requests are final.

2.1.2. Case law

Not applicable.

2.1.3. Presence of a regulator, its role/powers

The CBO is the supervisory authority for the financial sector in Oman. It licenses financial institutions and oversees other regulatory aspects of the industry including any data protection related issues in the financial sector.

2.1.4. Key definitions

Not applicable.

2.1.5. Data retention

See 2.1.1., above.

2.1.6. Specific provisions on data breach and data breach notification

See 2.1.1., above.

2.1.7. Specific provisions imposing limitations on data transfers

See 2.1.1., above.

2.1.8. Sanctions and penalties

The CBO has the right to instruct licensed banks to disclose information relating to customer, however, its decision may be challenged before the courts which have wide discretion in judicially reviewing such decisions.

2.2 HEALTH AND PHARMA SECTOR

2.2.1. Law: Scope of application/ Key provisions

There is no data protection law specific to the health and pharma sector in Oman. However, recently a new law, namely, Royal Decree No. 75/2019 Promulgating the Law on Governing the Practice of the Medical Profession and Allied Health Professions (‘the Healthcare Law’), was passed which repeals an earlier law (namely, Royal Decree No. 22/1996 on Issuing the Practice of Human Medicine and Dentistry Law (only available in Arabic here)).  The Healthcare Law aims to bring existing Omani healthcare legislation in line with international standards in healthcare, including standards of professional ethics, the use of patient information, and the circumstances in which medical research on humans is permitted. The Healthcare Law addresses the issue of disclosing patient information, and states that patient information may not be disclosed to any person without the patient’s express written consent. Exceptions to this rule permit disclosure in certain circumstances, including where disclosure is necessary to prevent a crime, where a patient is subjected to a condition that threatens public health and safety, or where disclosure is required for health insurance companies.

2.2.2 Case law

Not applicable.

2.2.3 Presence of a regulator, its role/powers

The Ministry of Health is responsible for ensuring the availability of healthcare to the people of Oman. It regulates all matters pertaining to the healthcare sector.

2.2.4. Key definitions

Not applicable.

2.2.5. Data retention

See 2.2.1., above.

2.2.6. Specific provisions on data breach and data breach notification

See 2.2.1., above.

2.2.7. Specific provisions imposing limitations on data transfers

See 2.2.1., above.

2.2.8. Sanctions and penalties

The Healthcare Law mandates that anyone who violates obligations related to the disclosure of patient information, may be punished with imprisonment for a period of no less than one month and not exceeding one year, or a fine of no less than OMR 500 (approx. €1,200) and no more than OMR 1,000 (approx. €2,400), or both.

2.3 TELECOMMUNICATIONS SECTOR

2.3.1. Law: Scope of application/ Key provisions

There is no sector-specific data protection law in relation to the telecommunications sector in Oman. The general provisions on the protection of information over telecommunications networks are contained in Royal Decree No. 30/2002 for Issuing the Telecommunications Regulatory Act (‘the Telecommunications Regulatory Act’).

The Telecommunications Regulatory Authority (‘TRA’) is responsible for establishing controls that guarantee the protection of user data and ensure its confidentiality and privacy.

2.3.2. Case law

Not applicable.

2.3.3. Presence of a regulator, its role/powers

The TRA regulates all matters pertaining to the telecommunications sector including licensing and other issues.

2.3.4. Key definitions

See 2.3.1., above.

2.3.5. Data retention

See 2.3.1., above.

2.3.6. Specific provisions on data breach and data breach notification

See 2.3.1., above.

2.3.7. Specific provisions imposing limitations on data transfers

See 2.3.1., above.

2.3.8. Sanctions and penalties

The Telecommunications Regulatory Act stipulates that penalties may include imprisonment for a period not exceeding one year, a fine not exceeding OMR 1,000 (approx. €2,400), or both. In all cases, the penalty may be doubled in the case of repeat offences.

Terms and Conditions

CONTACT US

If you have questions or comments about this Privacy Policy, please contact us at:

Ibex Financial and Management Consulting

P.O.Box:952

P.Cl: 116 Mina Al Fahal

+968 91744799

Email