|Website||Identification||Customers, Employees, Suppliers||Consent|
|Identification, Financial, Educational and employment history, Copy of ID, Contracts||Customers, Employees, Suppliers, Partners||Legitimate interest|
|Storage and exchange of documents||Identification,Financial,Educational and employment history,Copy of ID,Contracts||Customers, Employees, Suppliers, Partners||Legitimate interest|
|Delivery of goods and services||Identification, Financial, Contracts||Customers, Suppliers||Performance of a contract|
|Financial and business administration||Identification, Financial, Contracts||Customers, Employees, Suppliers||Legitimate interest|
HMD Africa SAL (Offshore) processes personal data for one or more of the following purposes:
The following business processes describe how we may collect, store or otherwise process the types of personal information set out in the table above:
We may have to share your data with third parties, including third-party service providers and other entities in the group. We require third parties to respect the security of your data and to treat it in accordance with the law.
We may transfer your Personal Data outside Lebanon. If we do, you can expect a similar degree of protection in respect of your Personal Data.
We will only share your Personal Data with third parties in accordance with the GDPR and as outlined in the legal justification table above.
We share your personal data with the following enterprise third parties. We also share your data with SME third parties, details of which are available upon request. You will be notified when we have engaged with a new third party recipient of your personal data.
- Google Workspace
|Function||Email provider, Document storage service|
|Business process||Email, Digital storage of documents|
|Data categories||Identification, Financial, Educational and employment history, Contracts|
|Data subjects||Customers, Employees, Suppliers, Partners|
|Security measures||Physical security such as access controls, clean desk policy and CCTV; Access controls and prevention of unauthorised access on the basis of roles and strong authentication methods; All data is encrypted at rest and access is only permitted via encrypted channels (e.g. SSL); Data is minimized and regularly deleted according to national retention periods.|
The third parties we have engaged for the abovementioned business process may transfer your personal information to outside of Lebanon. HMD Africa SAL (Offshore)’s third party processors take all necessary measures to ensure the confidentiality, availability and integrity of personal data and to comply with the GDPR with regards to international data transfers. The international nature of its compliance certifications, as well as far-reaching technical security measures (including but not limited to encryption of the personal data, making the data illegible to an unauthorised recipient) are sufficient to ensure that the data subjects continue to benefit from the fundamental rights they are entitled to under the GDPR.
HMD Africa SAL (Offshore) relies on processing agreements with these sub-processors that include the model clauses (or “Standard Contractual Clauses”) which have been tested on the adequacy of its protection with regards to the specific sub-processing activities carried out in this particular subprocessing relationship.
Additional security measures are taken to safeguard the international data transfers:
Your data is protected by HMD Africa SAL (Offshore) and its processors in pursuance to all legal requirements set by the relevant data processing laws. HMD Africa SAL (Offshore) has taken technical and organizational security measures to protect your data and requires its data processors to meet the same requirements. HMD Africa SAL (Offshore) has signed processing agreements with its processors to ensure an adequate level of data protection.
The following security measures are taken by HMD Africa SAL (Offshore) to protect your personal data in the course of the listed business processes:
HMD Africa SAL (Offshore) staff members are required to conduct themselves in a manner consistent with HMD Africa SAL (Offshore)’s guidelines regarding confidentiality, business ethics, appropriate usage, and professional standards.All staff members undergo appropriate background checks prior to hiring and sign a confidentiality agreement outlining their responsibility in protecting customer data.
We continuously train staff members on best security practices, including how to identify social hacks, phishing scams, and hackers.
- Access Controls
HMD Africa SAL (Offshore) maintains your data privacy by allowing only authorized individuals access to information when it is critical to complete tasks for you. HMD Africa SAL (Offshore) staff members will not process customer data without authorization.
- Data Hosting
As a rule, data is hosted within Lebanon, but it is possible that we might transfer personal data to countries within the EEA, to the UK or in exceptional circumstances outside of those areas. We ensure that we comply with the GDPR and the DPA when sending data overseas by relying on data processing agreements containing standard contractual clauses with our subprocessors or by taking additional measures to secure this data transfer, such as anonymisation.
- Physical Security
The data centres on which personal data is hosted are secured and monitored 24/7 and physical access to facilities is strictly limited to select staff.
All devices which are used to access personal data for which we are responsible are secured with antivirus software, firewalls, encryption and access management. We regularly update operating systems and software to ensure vulnerabilities cannot be exploited.
We carry out regular vulnerability scanning of our website and have engaged credentialed external auditors to verify the adequacy of our security and privacy measures.
Each data subject has the right to information on and access to, and rectification, erasure and restriction of processing of his personal data, as well as the right to object to the processing and the right to data portability.
You can exercise these rights by contacting us at the following email address: [email protected]. Each request must be accompanied by a copy of a valid ID, on which you put your signature and state the address where we can contact you. Ensure that you write “Data Request” in the subject line of your email.
Within one month of the submitted request, you will receive an answer from us. We will not charge you for submitting your request unless the request is manifestly unfounded or otherwise unreasonable in its nature. Depending on the complexity and the number of the requests this period may be extended to two months.
The collected data are used and retained for the duration determined by law. You may, at any time, request your data to be deleted from any HMD Africa SAL (Offshore) account, system or other data processing medium in accordance with the process described above.
These conditions are governed by Lebanon legislation. The court in the district where the collector has its place of business has the sole jurisdiction if any dispute regarding these conditions may arise, save when a legal exception applies.