1. General

• SC Holding Company Limited (hereinafter referred to as “SureCede” or “Company” or “we” or “us” or “our”) , having its registered office at Cloud Bubble B04, 15th Floor, Al Saab Tower, ADGM Square, Abu Dhabi, Al Maryah Island, UAE is engaged in the business of developing Application Programming Interface or related software solutions for Insurance Companies, Reinsurers and their authorized Brokers, collectively known as “Users”. By visiting the Website or providing your information, you expressly agree to be bound by this Privacy Policy and agree to be governed by the Data Protection Law of the Abu Dhabi Global Market ‘ADGM’ including but not limited to the laws applicable to data protection and privacy. If you do not agree please do not use or access our Website.

• The said Company’s privacy policy (hereinafter referred to as the “Privacy Policy”) is applicable to the insurance companies, reinsurers , their authorized brokers and also the subsequent end clients (“Data Subject”) that they cater to.

• The said Privacy Policy is to inform you of the said Website, about the types of information that the said Company may gather from or about you, in connection with your use of the Website. It also is intended to explain the conditions under which the Company uses and discloses that information, and your rights in relation to the collected information. Each time you use the Website, however, the current version of this Privacy Policy will apply. Accordingly, each time you use the Website you are requested to check the date of this Privacy Policy (which the Website bears at the beginning of this document) and review any changes since the last time you used the Website.

• By using the Website and/ or by providing your information, you agree and consent to us receiving , storing, processing, transferring, using the personal and identifiable information (including sensitive personal information as per the ADGM Data Protection Law and other such applicable laws) received by you.

• Personal information subject to this Privacy Policy will only be collected and retained by SureCede on the cloud. We play the role of a Data Processor as we collect and process personal information and personal data on behalf of the “Users” , who is also the Data Controller (i.e. insurance companies, reinsurers and their authorized brokers as the case may be) by means of a legally binding written agreement between us.

• It is the sole responsibility of the Users to obtain the requisite consent and inform the data subjects of the purpose for which their personal data will be collected, the circumstances under which their personal data may be disclosed and transferred and other such related tasks that may be required as per the applicable laws. Also, Users are responsible for informing the data subjects of the rules regarding the retention of personal data, as well as the precautions they have taken to ensure the security of such data. SureCede does not bear any responsibility for obtaining consent from data subjects or informing them about their rights.

2. Definitions and Interpretations

In this Privacy Policy, unless the context otherwise requires, the following expressions shall have the meanings respectively assigned to them as mentioned below:

• a. Personal Data - any information referring to an identified or Identifiable Natural Person.

• b. Data Subject - the identified or identifiable natural person to whom Personal Data pertains and who is also the end user of the Users' services

• c. Data Controller - a natural person or entity that determines the methods, approaches, criteria, and purposes for collecting and processing Personal Data, whether alone or jointly with others.

• d. Data Processor - a natural or legal entity that processes Personal Data on behalf of the Data Controller in accordance with the Data Controller's instructions and directions.

• e. Special Categories of Personal Data - Personal Data revealing or concerning (directly or indirectly) racial or ethnic origin, communal origin, political affiliations or opinions, religious or philosophical beliefs, criminal record, trade-union membership and health or sex life and including genetic data and biometric data where it is used for the purpose of uniquely identifying a natural person.

• f. Third Country - a jurisdiction other than the ADGM, whether in the UAE or elsewhere.

3. What Personal Information does SureCede collect from You?

• We collect your personal information in order to provide and continually improve our website and services. When you use our website, you are able to seek our services and other benefits provided by us. In order to develop a customised software solution, you will provide us with personal information of data subjects, received or possessed by you, which you will share with us after obtaining relevant authorisations from the data subjects. We shall then evaluate the received data, further enabling us to provide you with a customized software service.
  
  Here are the types of personal information we collect:
  Information You Give Us.
  We receive and store any information you provide in relation to Services that you avail from our website. You provide us with the following information:

1. a. Personal information such as data subject’s name, address and phone numbers, age.

2. b. Location information.

3. c. IP address.

4. d. Special categories of personal data (Eg. - health information).

5. e. E-mail addresses of your friends and other people.

6. f. Payments: When the data subject chooses to make any payments towards the Users through our software, their financial account information, such as their credit card number, may be collected by our third-party payment processors. We do not collect or store such financial account information, but we may receive information from our payment processor about the payment, such as the date and time of payment. We are not responsible for protection of any payment-related information, as it is beyond our control.

• Automatic Information
  We automatically collect and store certain types of information pertaining to use of Services from our Website. Like many websites, we may use cookies and other unique identifiers, and we may obtain certain types of information when your web browser or device accesses Services and other content served by or on behalf of SureCede on other websites. The list of such automatic information which may be collected by us are listed below:

1. a. the internet protocol (IP) address used to connect your computer to the internet;

2. b. login, e-mail address, and password;

3. c. IP address.

4. d. device metrics such as when a device is in use, connectivity data, and any errors or event failures;

5. e. purchase and website content use history, which we sometimes aggregate with similar information from other customers to create features;

6. f. the full Uniform Resource Locator (URL) clickstream to, through, and from our websites, including date and time; insurance products and content you viewed or searched for; page response times, download errors, length of visits to certain pages, and page interaction information (such as scrolling, clicks, and mouse-overs);

7. g. phone numbers used to call our customer service number;

8. h. We may also use device identifiers, cookies, and other technologies on devices, applications, and our web pages to collect browsing, usage, or other technical information.

4. For what Purposes does SureCede receive the Personal Information collected by you from the data subjects?

We use the information provided to us by you to develop a customized software solution which can be used by you to ease and fasten the process of selling your Insurance covers to your data subjects. Further, this software can be used for the following purposes as well:

• a. Easing the Purchase and delivery of insurance policies / products, issuance of quotes.

• b. Provide, troubleshoot, and improve Services: We use personal information to provide functionality, analyze performance, fix errors, and improve the usability and effectiveness of the Services.

• c. Recommendations and personalization: We use personal information to recommend new insurance policies / products that might be of interest to the data subjects, identify their preferences, and personalize their experience with Services.

• d. Communicate with you: We use your information to communicate with you in relation to Services via different channels (e.g., by phone, e-mail, chat).

• e. Fraud Prevention and Credit Risks: We use personal information to protect against and prevent fraud, claims, liabilities and to manage risk exposure.

• f. Third Party Obligations: We use personal information for processing, disclosing, transmitting, and/or sharing the data/information with our subsidiaries, affiliates, associates, partners, and other third parties which have business or contractual dealings with us.

• g. Generate aggregated data to prepare insights to enable us to understand data subject behavior, patterns and trends with a view to learning more about your preferences with respect to insurance policies / products or other such characteristics.

• h. Comply with applicable laws, regulations, codes, and industry standards and practices.

• i. Conduct facilitation for marketing and market research activities including, without limitation: (a) contacting you to participate in customer satisfaction surveys or questionnaires via telephone, email, or otherwise, and (b) soliciting your opinions or feedback on our business activities, including, without limitation, current and future products and services.

5. Does SureCede Share the Personal Information received by us from you, with any other Third Party?

Any information provided to us by you is an important part of our business and we are not in the business of selling the personal information either received by us directly or through the Users, to any other third party. We may share the personal information received by us only as described below and with our subsidiaries, affiliates, and associates that are either subject to this Privacy Policy or follow practices at least as protective as those described in this Privacy Policy.

• a. Transactions involving Third Parties: We make available to you services, insurance policies / products, or skills provided by third parties. For example, we may use WhatsApp Business API to collect some order related information from you (You can read about WhatsApp API privacy policy from here Link). We may also use Google Analytics to help us understand how our customers use the Site (You can read more about how Google uses your Personal Information here: Link. You can also opt-out of Google Analytics here: Link).

• b. Protection of SureCede: We release account and other personal information when we believe release is appropriate to comply with the law; enforce or apply our Terms of Use and other agreements; or protect the rights, property, or safety of SureCede and our Users. This includes exchanging information with other companies and organizations for fraud protection.

• c. Other than as set out above, you will receive notice when personal information about you might be shared with third parties, and you will have an opportunity to choose not to share the information.

• d. We attempt to store all of your personal information within the UAE, and will strictly store such personal information within the UAE when mandated by applicable law.

• e. We have appropriate contracts in place with our third party service providers and partners. This means that they cannot do anything with your personal information which is outside of the scope permitted by us. They hold it securely and retain it only for the period specified in our contracts with them.

• f. We may disclose your personal information for the purposes mentioned above to other parties including:

1. i. Other group companies and any subcontractors, agents or service providers who work for us or provide services to us or group companies (including their employees, sub-contractors, service providers, IT Vendors, directors and officers). The service providers are authorized to use and disclose the information only as necessary to perform and provide the services for which they were engaged. Any additional information that is directly shared by you with the Service Providers will not fall within the purview of SureCede’s liability;

2. ii. Law Enforcement Authorities, Government Authorities, courts, dispute resolution bodies, our regulators, auditors and any party appointed or requested by our regulators to carry out investigations or audits of our activities;

3. iii. Statutory and regulatory bodies and authorities (including the government) investigating agencies and entities or persons, to whom or before whom it is mandatory to disclose the personal information as per the applicable law, courts, judicial and quasi-judicial authorities and tribunals, arbitrators and arbitration tribunals;

4. iv. Anybody else that we’ve been instructed to share your personal information with by you.

6. Transfers out of ADGM

• Personal information received by us from the Users, may be transferred to a third country outside the ADGM for any of the purposes described in this Privacy Policy, as long as such transfer is in accordance with applicable law. We shall ensure that such transfer to a third country has an adequate level of data protection, general respect for individual's rights, access of a public authority to Personal Data; the existence of effective data protection law, the existence and functioning of one (1) or more independent, competent data protection or similar supervisory authorities with adequate enforcement powers; and international commitments and conventions binding on such Third Country and its membership of any multilateral or regional organizations. We shall also ensure that there are sufficient safeguards and enforceable data subject rights and effective legal remedies available for the data subjects.

• You understand and accept that these countries may have differing laws relating to the degree of confidentiality afforded to the information it holds and that such information can become subject to the laws and disclosure requirements of such countries, including disclosure to governmental bodies, regulatory agencies and private persons, as a result of applicable governmental or regulatory inquiry, court order or other similar process. In addition, a number of countries have agreements with other countries providing for exchange of information for law enforcement, tax and other purposes.

• Policy, we will use best endeavors to put in place appropriate controls and safeguards to ensure that the personal information is kept accurate, adequately protected, and processed only for specified and reasonable purposes in a manner that is fair, transparent and has a lawful basis, and is stored for no longer than is absolutely necessary.

7. How Secure is the Information shared by you?

• We design our systems with absolute security and privacy in mind. All information, including, without limitation, Personal Information, Personal Data and Special Categories of Personal Data, is stored on servers and systems located in UAE, which servers are licensed, and/or maintained by SureCede.

• We are committed to protecting the personal information in our custody. We take reasonable steps to ensure appropriate physical, technical and managerial safeguards are in place to protect the personal information from unauthorized access, alteration, transmission and deletion. We work to protect the security of the personal information during transmission by using encryption protocols. We use multi-layered controls to help protect our infrastructure, constantly monitoring and improving our applications, systems, and processes to meet the growing demands and challenges of security. We ensure that the third parties who provide services to us under appropriate contracts, take appropriate security measures to protect your personal information in line with our policies. Notwithstanding the foregoing, transmissions over the Internet and/or a mobile network are not one hundred percent (100%) secure and SureCede does not guarantee the security of transmissions. SureCede is not responsible for any errors by data subjects in submitting Personal information Personal Data and Special Categories of Personal Data to SureCede.

• We process personal information and special categories of personal data as per the applicable laws and protect your rights by following the principle of ‘data protection and by design and default’. Data processing principles such as data minimization at the time of determining the means for Processing and at the time of processing itself will be adhered to. We shall also by default only process Personal Data that is necessary for each specific purpose mentioned above. Such Personal Data of your will not be made accessible to an indefinite number of persons without your explicit consent.

• The health information of the data subject that is collected by us in order to fulfill the purposes mentioned herein shall also be governed by Federal Law No. (2) of 2019 Concerning the use of Information and Communication Technology (ICT) in Health Fields. We shall take all necessary procedures to protect and ensure safety and confidentiality. Such health information will not be disclosed without prior consent of the data subjects. The principles, standards and controls as prescribed by the health authority shall be adhered to.

• We maintain physical, electronic, and procedural safeguards in connection with the collection, storage, processing, and disclosure of personal information of data subject. Our security procedures mean that we may occasionally request proof of identity before we disclose personal information to you.

• Our devices offer security features to protect them against unauthorized access and loss of data. You can control these features and configure them based on your needs

• It is important for you to protect against unauthorized access to your password and to your computers, devices and applications. Be sure to sign off when finished using a shared computer.

8. Children’s Privacy

SureCede believes it is important to protect the online privacy of children. Accordingly, SureCede adheres to applicable laws pertaining to the protection of children’s privacy. SureCede does not knowingly collect Personal information and Special Categories of Personal Data from anyone under the age thresholds prescribed by applicable laws for the collection of Personal information and Special Categories of Personal Data from individuals without parental consent. If SureCede becomes aware that it had inadvertently collected Personal information or Special Categories of Personal Data from anyone under such age thresholds, SureCede would promptly delete such Personal information or Special Categories of Personal Data.

9. How Long Does SureCede Retain the Information shared by you?

SureCede retains personal information for 10 (Ten) Years or as long as necessary for providing the services sought by the Users, vide their customized software platform or for other essential purposes such as complying with our legal obligations, resolving disputes, enforcing our agreements and as long as processing and retaining your personal information is necessary for our legitimate interests. As these needs can vary for different data types and purposes, actual retention periods can vary significantly. In a situation where we are required to cease processing while exercising the right of a data subject then we shall immediately securely and permanently delete the personal data or anonymize the personal data so that such data is no longer considered to be personal data and the data subject cannot be traced or pseudonymised or securely encrypted.

10. What Information Can I Access?

We understand that when you interact with SureCede, the data subjects have rights over their personal information. These rights involve providing reasonable steps to allow the data subjects to access personal information, correct any errors among others. In the event that the Users are not satisfied with our response or have unresolved concerns, the Users can get in touch with us to resolve the issue by means of email at info@SureCedeinsure.tech

11. Cookies

• Cookies are small text files that are placed on the Users computer by websites that they visit. Similarly, there are other types of trackers used. These are used to make websites & apps work, or work more efficiently, as well as to provide information to the owners of the website/app.

• Depending upon the jurisdiction from where the User might be accessing our Website/software and as per applicable laws you may be served different types of cookies such as strictly necessary cookies, performance cookies etc. We use cookies, permissions and other trackers on our Website/software to collect and process data so as to provide the User a better online experience as well as improve our services.

• We use cookies, pixels, and other technologies (collectively, "cookies") to recognize the browser or device, learn more about User interests, and provide the User with essential features and services and for additional purposes, including:

1. a. Recognizing the User when they sign in to the website: This allows us to provide the User with insurance product recommendations, display personalized content, and provide other customized features and services.

2. b. Conducting research and diagnostics to improve SureCede's content, and services.

3. c. Preventing fraudulent activity.

4. d. Improving security.

5. e. Reporting: This allows us to measure and analyze the performance of our Services.

• Below are the categories of cookies used on our website along with a description of what they are used for:

1. a. Strictly Necessary: These cookies are needed to run our website/software, to keep it secure if the user is logged on and to obey regulations that apply to us. They also help us keep your details safe and private.

2. b. Functional: These cookies are used for remembering things like: User’s ID on the website; region or country; preferred language; accessibility options, etc.

3. c. Performance: These cookies tell us how you and our other customers use our website/Software. We combine all this data together and study it. This helps us to: Improve the performance of our services.

12. Terms of Use, Notices, and Revisions

• If the User chooses to use SureCede’s Services, their use and any dispute over privacy is subject to this Privacy Policy and our Terms of Use, including limitations on damages, resolution of disputes, and application of the prevailing Data Protection Law of the ADGM. If you have any concern about privacy at SureCede, please contact us with a thorough description, and we will try to resolve it.

• Unless stated otherwise, our current Privacy Policy applies to all information that we have about the User and their data subjects. We stand behind the promises we make, however, and will never materially change our policies and practices to make them less protective of customer information collected in the past without the consent of affected customers

• Our business might change in the future and our Privacy Policy will also change. We may email periodic reminders of our policies and conditions, unless you have instructed us not to, but you should check our website to see recent changes. The updated version will be effective as soon as it is accessible. Any changes will be immediately posted on our website and you are deemed to have accepted the terms of the updated Privacy Policy on your first use of our website or first purchase of the insurance products and/or services following the alterations. We encourage you to review this Privacy Policy frequently to be informed of how we are protecting your information.

13. Indemnities

You shall indemnify, defend, and hold SureCede harmless, at his/her own expense, from and against any and all losses, penalties, liability, obligations, damages, third-party claims, demands, causes of action, costs, and expenses of whatever form or nature (each a “Claim” and collectively, “Claims”), including reasonable outside attorney’s fees and other costs of legal defense, arising out of or related to: (i) any negligent acts, omissions or willful misconduct by the you; (ii) your access to and use of the Website; (iii) an actual or alleged breach of any of the duties, representations, warranties or covenants of this Agreement by you, except to the extent such indemnity is prohibited by law.

14. Need to knows

• SureCede does not solicit confidential details like your OTP/CVV/PIN/Card Number/ Bank account details through any means beyond payments. SureCede never calls the Users or their data subjects with offers, discounts on insurance products and offering free gifts.

• Scamsters/fraudsters attempt various techniques such as ‘phishing’, to contact, influence and defraud consumers. SureCede regularly cautions its User against sharing any personal or payment sensitive information with unknown persons as such sharing leads to unauthorized use and/or fraud and consequent financial loss. SureCede also from time to time, cautions the User to educate their data subjects to beware of such activities.

• SureCede shall not be liable for any loss, damage, expense incurred by anyone where the User or their data subjects have shared the personal and/or payment sensitive information with scamsters/fraudsters.

• We also request and encourage our Users to report such attempts or incidents to our Grievance officer (or Customer care) to enable us to investigate and explore legal recourse.

• SureCede relies on payment partners and banks. In certain cases involving payment/refund issues, we might see a delay as that is beyond our control once we pass the investigation to them. In case you have any questions or wish to contact us, you can reach us at: info@surecede.com

• If any court or competent authority finds that any provision of this Privacy Policy (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this Privacy Policy will not be affected.

15. Data Subject Rights

To exercise any of these rights, or if you have any questions or concerns about your data, you may contact us using the contact details provided in this privacy policy. In most cases, we will respond within one month of receiving your request. If required, we may request further information to confirm your identity before fulfilling your request.

As a data subject, you are entitled to the following rights regarding your personal data:

• Right to be Informed: You have the right to receive clear, transparent, and easily understandable information about how we collect, use, and protect your personal data. Our privacy policy aims to provide this information.

• Right of Access: You can request access to your personal data that we hold, including information about how your data is being processed, the categories of data, recipients of the data, and the purposes of processing.

• Right to Rectification: If your personal data is inaccurate or incomplete, you have the right to request its correction or completion.

• Right to Erasure ("Right to be Forgotten"): You may request the deletion of your personal data in certain circumstances, such as when the data is no longer necessary for the purposes for which it was collected, or you withdraw your consent.

• Right to Restrict Processing: You have the right to request that we restrict the processing of your personal data in specific cases, for example, when you contest the accuracy of the data or object to the processing.

• Right to Object: You can object to the processing of your personal data based on legitimate interests or for direct marketing purposes at any time.

• Rights in Relation to Automated Decision-Making and Profiling: You have the right not to be subject to a decision based solely on automated processing, including profiling, if it produces legal or similarly significant effects on you.

DPO Contact Details

Name: Shuja Noorani
Email: shuja@surecede.com