Privacy Policy

How we use and look after your personal data.

Last Updated: [21 September 2023]

This website is operated by Extra Mile Strategy DMCC.

Extra Mile Strategy DMCC is a company registered in the United Arab Emirates and licensed under the rules and regulations of Dubai Multi Commodities Centre - License Number 635769.

This privacy policy relates to your use of our website: www.extramile.me and the online learning platform (the “Sites”). This privacy policy aims to give you information on how Extra Mile Strategy DMCC collects and processes your personal data through your use of our Sites, including any data you may provide through our Site when you sign up to our newsletter or register for a service.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

1. Background

Data Controller Extra Mile Strategy DMCC is the controller and responsible for your personal data (referred to as "Extra Mile", "we", "us" or "our" in this privacy policy).

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact our data privacy manager using the following email address: hello@extramile.me

You have the right to complain to the UAE Data Office at any time (https://u.ae/en/about-the-uae/digital-uae/data/data-protection-laws). We would, however, appreciate the chance to deal with your concerns before you approach the UAE Data Office, so please contact us in the first instance.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-Party Links

We may link to other websites owned and operated by certain trusted third parties. These other third-party websites may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to these other third-party websites, please consult their privacy policies as appropriate.

Customers using Extra Mile methodology, products & services

Extra Mile provides methodologies, solutions & services to its customers. If your organisation provides you with access to Extra Mile’s products, it is likely that we are acting as a data processor to your organisation. In these circumstances, you should contact your organisation directly in relation to any data protection queries you have, including any requests to exercise your data protection rights.

2. Data We Collect About You

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data includes first name, last name, username or similar identifier.
Contact Data includes email address and telephone number.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our Site.
Profile Data includes your username and password, actions completed by you on our Site, including responses in questionnaires, quizzes or surveys, your interests, preferences and feedback.
Social Media Data includes social media account details such as username, number of followers, frequency of use or activity and profile information.
Usage Data includes information about how you use our Sites, products and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and third parties and your communication preferences.

We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data, but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature or Social Media Data to produce reports for your employer. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any special categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In this case, we may have to cancel a service you have with us but we will notify you at the time if this is the case.

3. When Do We Collect Personal Data?

The information we collect depends on the context of your interactions with our Site. We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity, Contact and Social Media Data by filling in forms or by corresponding with us by post, phone, email or otherwise.

This includes personal data you provide when you:

register on, or browse our Site;
place an order for our services;
create an account on our Site;
respond to a survey, quiz, questionnaire or fill out a form;
use live chat or open a support ticket,
register to one of our events
subscribe to our newsletters or publications;
request marketing to be sent to you; or
contact us by telephone, interact with us on email or social media and when you provide us with feedback on our products or services.

Automated technologies or interactions.

As you interact with our Site, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our information on cookies at section 6 below for further details.

Third parties or publicly available sources.

We may receive Technical Data from the following third parties:

analytics providers;
advertising networks; and
search information providers.

How do we use your information?

We will only use your personal data when the law allows us to. Most commonly, we may use the information we collect from you in the following circumstances:

Where we need to perform the contract we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal obligation.

We also use software, tools or systems to make automated decisions (including profiling) based on the personal information we have, or collect from others to profile you so that we can better understand your social media needs and to provide a better service. Please note that the section on Your Rights set out below applies to profiling.

See the Glossary to find out more about the types of lawful basis that we will rely on to process your personal data.

Generally, we do not rely on consent as a legal basis for processing your personal data. You have the right to withdraw consent to marketing at any time by contacting us.

This website is not intended for use by children under the age of 13 and we do not knowingly collect or use personal information relating to children.

4. Purposes for which we will use your personal data

We may use the personal data collected for the following purposes:

To personalise your experience and allow us to deliver the type of content and product offerings you are most interested in.
To improve our Site to serve our customers better.
To allow us to better service you in responding to your customer service requests.
For statistical analysis and customer profiling to assist us in providing and improving the services (e.g. to understand digital behaviours)
To administer promotions, surveys or other site features.
To send periodic emails regarding tips, news, orders, products and services.
To follow up with you after correspondence.
To verify your identity.
To notify you of any changes to our Site or to our services that may affect you.

Our legal basis for processing your personal information

You may choose not to provide certain information, but if you do, and that information is necessary to provide a particular feature, you may not be able to use that feature. We will only use your personal data where we have a valid, lawful basis to do so. Depending on what personal information we process and why, we may rely on various legal bases.

The table below summarises what information we collect about you, explains how we intend to use it and what our legal basis is for using it.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new user of the Site	(a) Identity (b) Contact	Necessary for our legitimate interests (to performance of a contract with your organisation)
To provide the services, deliver relevant content to you and measure or understand the effectiveness of the services we provide to you	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical (g) Social Media	(a) Necessary for our legitimate interests (to performance of a contract with your organisation) (b) Necessary for our legitimate interests (to study how customers use our services, to develop them, to grow our business and to inform our marketing strategy)
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to take a survey, quiz or questionnaire	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To administer and protect our business and our Site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
To use data analytics to improve our Site, services, marketing, customer relationships and experiences	(a) Technical (b) Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our Site updated and relevant, to develop our business and to inform our marketing strategy)
Profiling and analysis. To make suggestions and recommendations to you about our Site or services that may be of interest to you	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Social Media	Necessary for our legitimate interests (to develop our services and grow our business)

5. Data Security

How do we protect your information?

Your personal information is contained behind secured networks and is only accessible by a limited number of persons who require access rights to such systems to perform their tasks. All persons with access are required to keep the information confidential.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

6. Cookies

If you agree, we may use cookies. Cookies are small files that a site or its service provider saves to your device through your Web browser (if you allow) that enables the site's or service provider's systems to recognize your browser and capture and remember certain information. Details about the cookies we use can be found here.

With your permission, we collect information about how you interact with our website. We use this information in order to improve your website experience, customize your browsing experience and for analytics and metrics about our visitors both on this website and other media.

You can choose to have your browser warn you each time a cookie is being sent, or you can choose to turn off all cookies. This can be done through your browser settings. Since all browsers are a little different, look at your browser's Help Menu to learn the correct way to modify your cookies.

If you turn cookies off or decline permission to use cookies, some of the features that make your site experience more efficient and personalised will be hidden or replaced with generic content.

For further information on cookies generally visit www.aboutcookies.org or www.allaboutcookies.org.

7. Disclosure of Your Personal Data

Third-party disclosure

We will not sell, trade, or otherwise transfer to outside parties your personal information. This excludes website hosting partners and other parties who assist us in operating our website, conducting our business, or serving our users. We require all third parties to agree to keep personal information confidential and only use it for the purpose of supporting Extra Mile Strategy DMCC. We may also share personal information with law enforcement or other authorities if required to by applicable law.

We may share personal information with third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Overseas Transfers

We may transfer to, and store the data we collect about you in, countries other than the country in which the data was originally collected, including the United States or other destinations outside the European Economic Area (“EEA”). Those countries may not have the same data protection laws as the country in which you provided the data. When we transfer your data to other countries, we will protect the data as described in this privacy policy and comply with applicable legal requirements providing adequate protection for the transfer of data to countries outside the EEA.

We will only transfer your personal data if:

the country to which the personal data will be transferred has been granted a European Commission adequacy decision;
the recipient of the personal data is located in the US and has certified to the US-EU Privacy Shield Framework; or
we have put in place appropriate safeguards in respect of the transfer, for example we have entered into EU standard contractual clauses with the recipient, or the recipient is a party to binding corporate rules.

You may request more information about the safeguards that we have put in place in respect of transfers of personal data by contacting us as described in Contact Details section above.

Whenever it is necessary to undertake such a transfer of your personal data, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

8. Data Retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us at hello@extramile.me.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9. Your Legal Rights

Under the General Data Protection Regulation (GDPR) you have a number of important rights free of charge. In summary, those include rights to:

fair processing of information and transparency over how we use your use personal information
access to your personal information and to certain other supplementary information that this privacy policy is already designed to address
require us to correct any mistakes in your information which we hold
require the erasure of personal information concerning you in certain situations
receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
object at any time to processing of personal information concerning you for direct marketing and profiling
request for a decision made by profiling to be reviewed by a human
object to decisions being taken by automated means, such as profiling, which produce legal effects concerning you or similarly significantly affect you
object in certain other situations to our continued processing of your personal information
otherwise restrict our processing of your personal information in certain circumstances

You can learn further on each of those rights, including the circumstances in which they apply, on the websites below:

Data Protection & GDPR (EU)

Personal Data Protection Law (UAE)

If you would like to exercise any of those rights, please:

Email us at hello@extramile.me
Let us have enough information to identify you (e.g. account number, user name)
Let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill)
Let us know the information to which your request relates

If at any time you would like to unsubscribe from receiving future emails, you can either:

Follow the unsubscribe link at the bottom of any automated email we send
Email us directly and request to be removed from some or all email subscriptions

We may change this privacy policy from time to time, when we do we will inform you via email.