Introduction
Data and information is at the heart of what Elite Way does to enable us to serve you better and continue to connect and advance the healthcare industry

We take the privacy and protection of data and information seriously and are committed to handling the personal information of all those we engage with in a way that meets the legal requirements for data protection laws.

As part of using Elite Way products and services and contacting us, data and information are collected. This privacy policy (the “Privacy Policy”) sets out our approach to maintaining the privacy of your personal information collected. It also explains what data is collected, how it is used, the legal basis for its use, and the rights individuals have over that data.

What we collect
This section explains the personal information that may be collected when using our products and services, and the other personal data we may receive from other sources.

In this Privacy Policy, the term “personal information” refers to the types of information we may collect and use, which includes:

• Contact details, such as your name, e-mail address, postal address and telephone number
• Country of Residency and professional background information
• Comments, feedback, posts and other content you submit
• Interests and communication preferences

How & why personal information is used
This section explains in detail how and why we use personal information.

Product enquires, sales and administration
As part of a purchase, product enquiry, request for information and for account administration, we collect information such as your name, country, job title, company information, postal address, e-mail address, telephone number as well as details about your company and business role.

If you provide registration/login details for one of our online services, once registered your details may be retained to identify you and remove the need for repeated logins on/across our sites.

If you have made an enquiry about us or our products or services, either online, face to face or over the phone, we will use your personal information to respond to the enquiry or to take other steps at your request, before you enter into a contract. For example, we collect the e-mail addresses and additional contact details of those who send e-mails to request information. Where a sales representative speaks to you over the phone, the calls may be recorded for training and monitoring purposes only.

If you have registered for or purchased a product or service, including on a trial basis, your personal information will be used to provide that product or service, communicate about it and handle payments, as is necessary for the performance of the contract entered into.

For purchases, payment information, including credit/debit card number/bank details and billing addresses are also collected. Where payment card processors are used to facilitate payment card transactions on our website, your data will be collected and used according to that data processors’ privacy policy. We take steps to ensure that any payment processor we use will provide a high standard of privacy and security controls.

If your personal information is relevant to certain products and is freely available through public sources, such as on a website related to your work or profession, we may use this personal information to promote our products, as part of our legitimate interests as a commercial organisation.

Event and exhibition management
If you have agreed to participate in one of our events as a speaker, sponsor, exhibitor or visitor, personal information is used in connection with the organisation of the event, to handle payments or for other purposes, as is necessary for performing the contract entered into. We will also use your personal information to maintain our databases, assess your qualities as a speaker or sponsor/exhibitor, promote events and encourage further engagement at our events, as part of the legitimate interests we have as a commercial organisation.

In addition, we sometimes take photos and videos at our events, which may feature visitor, speakers, sponsors or exhibitors. Where photos and videos are taken that feature you as a visitor, speaker, sponsor or exhibitor, we may use those photos and videos for promotional purposes.

Marketing
We will use your personal information to send you newsletters, offers or other marketing e-mails to keep you up to date with our news, events and products and services that may be of interest. Depending on the nature of your interaction with us and the laws of the country where you live, you may have actively given your consent for this by opting in, or we may be entitled to rely on your implied consent or our legitimate interests.

The opportunity to opt out of future marketing e-mails will be provided on every marketing email and we will provide information on how to opt out when your personal information is collected. You have the right to amend your marketing preferences at any time.

To make a request to amend your details/preferences, please send an e-mail to: info@eliteway-sa.com or to write us at: Database Team Manager, Elite Way, 29th floor, Olaya Towers, Tower B, Prince Mohammed bin Abdul-Aziz Street - Riyadh, 12213, Saudi Arabia

Customer and prospects management (including analytics and product management)
We may use your personal information, combined with publicly available data and your demographic data, to deliver products and services, to choose relevant offers that may be of interest to you, to improve our existing products and services, and to develop new products and services, as part of our legitimate interests as a commercial organisation.

We may also use your data in advertising campaigns on Social Media platforms such as Linked In, Instagram and Facebook in order to provide information about upcoming events/new products and to ensure that you only receive relevant advertising about our products and services.

Analytics – websites, emails and database (including location data)
We may combine visitor session information, or other information collected through tracking technologies with personally identifiable information, to understand and measure your online experiences and determine what products, promotions and services are likely to be of interest.

Technical methods are also used in HTML e-mails, for purposes including: (i) to determine whether recipients have opened or forwarded e-mails and/or clicked on links in those e-mails, (ii) to customise the display of banner advertisements and other messages after closing an e-mail, and (iii) to determine whether a visitor has made an enquiry or a purchase in response to a particular e-mail.

In compliance with the California Online Privacy Protection Act (CalOPPA) (e.g. Browsers Do Not Track Signals), while we strive to offer you choice when using our website and mobile applications, we do not promise that we will be able to receive or honour web browser Do Not Track signals.

Bulletin boards or chat areas
When you disclose personal information on any public bulletin board or chat areas of this website, or any other website used as a result of use of this website, such personal information can be collected and used by anyone who views that board or area. This may result in unsolicited messages from other participants or other parties, which we are not responsible for.

Where you engage on our customer enquiry chat areas, we will use any information provided to help recommend our products and services and/or assist with confirming any order you wish to place.

Automated decision-making (including profiling)
We use algorithm-based technologies to personalise dynamic web content based on your stated and/or inferred interests. We carry out general profiling such as segmentation, non-automated and automated decision-making based on profiling for the purpose of providing you with a more relevant experience and for the purposes of our legitimate interests as a commercial organisation. Solely automated decision making is never used in any way that produces a legal or similarly significant effect. This automated decision-making is never based on sensitive personal data and we make efforts to ensure any profiling is non-discriminatory.

Depending on the laws of the country where you live, you may have rights related to our decision. For example, if you live in the European Union, you may have the right not to be subject to automated decision-making, or you may have the right to insist on human intervention in the process, express your point of view or contest the decision. If you wish to exercise any such right, please contact us via one of the methods set out in the ‘Contacting us’ section below. In some cases, we may have the right to continue with our decision, in accordance with applicable laws. This will be explained if it is the case. Otherwise, we will respond to your request as promptly as reasonably possible.

Compliance with our legal obligations
To ensure compliance with international trade sanction laws and regulations, we screen customers, vendors and other business partners against US, OFAC, BIS, UN, EU, UK and other applicable sanctions lists. Should any screening checks flag an issue where we cannot continue in a contract or other interaction with a customer, vendor or other business partner, they will always be informed.

How we protect personal information
Any personal information given to us will be treated with the utmost care and security. This section sets out some of the security measures in place.

A variety of physical and technical measures are used to keep data safe and prevent unauthorised access to, or use or disclosure of personal information. Electronic data and databases are stored on secure computer systems and we control who has access to information, using both physical and electronic means. Our colleagues receive data protection training, and we have detailed security and data protection policies that colleagues are required to follow when handling personal data.

All reasonable steps are taken to ensure that your personal information is kept secure from unauthorised access, but we cannot guarantee it will be secure during the transmission process to this website because this transmission is not controlled by us. We make use of HTTPS (HTTP Secure) whereby the communication protocol is encrypted via Transport Layer Security for secure communication over a computer network. The website is loaded via HTTPS, represented by the lock icon in your web browser, which ensures the transmission is secure and is demonstrated by a certificate issued by an official security certificate authority to Elite Way.

International transfer of personal information
As an international business and because of the technologies we use, personal information may be accessed by our colleagues and third-party service providers from locations outside of the European Economic Area, whose data protection laws may not be as extensive as those in Europe.

To ensure the same level of protection is in place when processing is conducted outside the European Economic Area, we use appropriate safeguards approved by the European Commission.

We apply appropriate protection to make sure your personal data remains adequately protected and is treated in line with this Privacy Policy. Elite Way’s international data transfer agreements between its group companies and with relevant third-party service providers based on standard contractual clauses approved by the European Commission.

Cookies
A cookie is a small text file containing a user ID that is automatically placed on a user’s computer or other device when visiting a website. Cookies record the pages visited and the actions taken on a website, but do not contain any personal information. From time to time, we may use cookies for purposes including administering the website; tracking your activity on the website; gathering broad demographic information for aggregate use to improve the website; and offering time-saving or personalised features on the website.

Third-party links
This website contains links to websites of other businesses, including potentially websites of other businesses within Elite Way. These businesses will have their own privacy policies, tailored to their particular business practices and the sectors in which they operate, and if following those links, we recommend reviewing the privacy policy of each website to understand how personal data is used in that instance. The inclusion of links to these websites does not imply an endorsement or validation of their content, and we are not responsible for their privacy practices, nor do we accept any liability in connection with the content on such websites.

Who we share personal information with
As an international company, to provide you with products and services we may share your information for specific reasons. This section explains how and why we share personal data with other companies within Informa, suppliers and other third parties.

Sharing with Elite Way Group companies
We may share your personal information with certain other companies within Elite Way for specific purposes. For example, other Elite Way companies may assist in providing products and services to you, carry out internal analysis of the usage of products and services, or offer relevant products and services which may be of interest.

Sharing with service providers
We may share personal information with third parties to assist in providing products and services to you and/or to offer ancillary add-ons that are complementary to such products and services. These third party data processors are bound to compliance with data protection legislation through contracts that protect the personal information shared with us. They may include: IT and marketing technology host suppliers, web and data hosting providers, mailing houses, ad servers, logistics and general service contractors, hotel/housing partners, freight forwarders, onsite health and safety partners, event registration partners, sales platform providers, communication tool providers, stand designers/builders/fitters, suppliers of sponsorship/marketing/PR collateral and other event collaboration partners.

Sharing with other organisations
We may share your personal information with our trusted partner organisations for their marketing purposes in accordance with local data laws and where appropriate your permissions.

If you use one of our virtual products, e.g. Virtual Exhibitions, Directory Sites, Webinars etc., or choose to allow your badge to be scanned at an event, we may pass the information you provide to third parties. Generally, this will be via a process whereby you, as the user, visit or interact with a third party, e.g. visit a stand at an online exhibition, have your badge scanned or click on an asset branded and provided by a third party. In some instances, for example, a products listing site, you may reach out directly to a supplier or exhibitor, who may contact you in return. In other instances, our virtual products are sponsored and, in such cases, the data you provided to us will be given to the sponsor. Generally, we will let you know at the time of collection if a product is sponsored.

We may share your personal information with third parties outside Elite Way including the Securities Exchange in the event of a sale, merger, acquisition, partnership, joint venture, collaboration, or negotiations related to the same with respect to all or part of our business.

Sharing with government departments or agencies
In some circumstances, we may be legally required to disclose your personal information because a court, the police, another judicial or law enforcement body or government entity has asked us for it.

For events specifically held in regions of the Middle East, we are required by law to supply your personal information (full name, DOB, nationality and e-mail address) to the Dubai Department of Tourism and Commerce Marketing (DTCM) and Abu Dhabi Municipality. These government bodies state they will not disclose data to any third parties. Elite Way cannot accept any liability in this regard.

How long information is kept
We will only retain your personal information for as long as is necessary and as permitted by applicable laws.

We will retain your personal information while we are using it, as described in the section above, and may continue to retain it after these uses have ended where we have a legitimate business purpose. For example, if you have opted out of marketing communications from us, we will retain limited details about you to ensure the opt out request is honoured. We may also continue to retain your personal information to meet our legal requirements or to defend or exercise our legal rights. The length of time for which we will retain personal information will depend on the purposes for which it is retained. After we no longer need to retain your personal information, it will be deleted or securely destroyed.

How to update your information and marketing preferences
We want to ensure you remain in control of your personal information. We try to ensure that the personal information held about you is accurate and up-to-date, and will always give the opportunity to opt out of future marketing communications.

Information on how to opt out will be given to you when we collect your personal information and specified on every marketing e-mail sent to you. If at any stage you would like to update or correct such personal information, or opt out of future marketing communications, e-mail: info@eliteway-sa.com

Your rights
Elite Way operates in countries with data protection laws that may provide individuals the right to be able to access and control their information. We will always enable you to exercise the rights provided by data protection laws.

EU data protection laws give individuals a number of rights, where their data and information is collected and used by companies that are active and operating in Europe. Under the General Data Protection Regulation, these are:

• The right to confirmation of whether or not we have your personal data and, if we do, to obtain a copy of the personal information we hold. This is known as a subject access request;
• The right to have inaccurate data rectified;
• The right to have your data erased. This does not however apply where it is necessary for us to continue to use the data for a lawful reason;
• The right to request the restriction or suppression of your personal data (such as, we will stop using the data but we may continue storing it);
• The right to obtain your personal data that you have provided to us, on the basis of consent or performance of a contract, and where technically feasible, transmitted in a common electronic format to you or directly to another company;
• The right to object to the use of your data. Specifically, you have the right to object to our use for marketing and in relation to automated decision making, including profiling where there may be legal or similarly significant effects.

There are exceptions to the rights above. Where you make a request to us as part of these rights, we will always try to respond to your satisfaction, although there may be situations where we are unable to do so.

Depending on the laws of the country where you live, you may have other rights in respect of your personal information. If you wish to exercise any legal right in respect of your personal information, please contact us via one of the methods set out in the ‘Contacting us’ section below.

In some cases, we may be entitled to decline a request you have made regarding your personal information, in accordance with applicable laws. We will explain if that is the case. Otherwise, we will meet your request as promptly as we reasonably can. If you have requested that we stop sending you marketing messages, please note that you may still receive them for a short period while the request is processed. If you would like further information on your rights or wish to exercise them, please write to the Elite Way info@eliteway-sa.com

Contacting us
If you have any questions about this Privacy Policy or our use of your information, e-mail info@eliteway-sa.com

We hope to resolve any privacy concerns you may have. If you are not happy with our response, or you believe that your data protection or privacy rights have been infringed, you can complain to any supervisory authority or other public body with responsibility for enforcing privacy laws. In the UK, the UK Information Commissioner’s Office regulates and enforces data protection law.

Changes to this Privacy Policy
To keep up with changing legislation, best practice and changes in how we process personal data, this Privacy Policy may be revised at any time without notice by posting an updated version on this website. Checking back periodically will mean you are aware of any changes.

What we collect
The information that we collect is set out in the main body of the Privacy Policy. We further detail it below in accordance with Californian privacy requirements in the section below.

How we share your personal information is set out in the main body of the Privacy Policy
We further detail it below in accordance with Californian privacy requirements:

The categories of personal information that we used, transferred, exchanged, or disclosed  (including to third parties as set out in the Who do we share your personal information with section of the Privacy Policy) about consumers during the preceding 12 months were:  (a)  identifiers; (b) personal information; (c) classification data; (d) commercial information; (e) internet activity; (f) geolocation data; and (g) inferences.

The categories of personal information that we disclosed about consumers for a business purpose (including to secure our network and our websites, to conduct audits related to our current interactions with you, to debug the site and service, to perform services on behalf of ourselves, including servicing your account and providing you customer service and as set out in the How and why we use personal information section of the Privacy Policy) during the preceding 12 months were:  (a)  identifiers; (b) personal information; (c) classification data; (d) commercial information; (e) internet activity; (f) geolocation data; and (g) inferences.

Tracking
Please note that the do not track disclosures are covered in the main body of the privacy policy.  For information on how we and our partners use cookies and online tracking technologies when you visit our sites please visit our Cookie Policy link on the bottom of the website.

Your rights
EU data protection laws give individuals a number of rights, where their data and information is collected and used by companies that are active and operating in Europe. Under the General Data Protection Regulation, these are:

• To request access to the personal information we have about you; 
• To request that we delete personal information about you;
• To opt-out of our use, transfer, exchange or disclosure (including to third parties) of personal information about you; 
• Not to be discriminated against based upon whether you decide to opt-out.

To exercise the access, deletion, and opt-out rights described above, please submit a verifiable consumer request to us by info@eliteway-sa.com

You have the right to request that Elite Way disclose to you what information it collects, uses, discloses, and sells.  You also have the right to request that a business delete any personal information about you which the business has collected about you. 

Please note for your protection, any request sent to Elite Way will be subject to the following verification procedure requiring you to provide sufficient information that allows us to reasonably identify you are the person about whom we collected personal information including details of products/services you have previously taken with us and also we will ask you to provide some evidence that you are a California resident (e.g utility bill).  We reserve the right to deny your request if we cannot verify your identify.  Where we deny your request in whole or in part, we will endeavor to inform you of the denial, provide an explanation of our actions, and provide the reasons for the denial.

You have the right to direct Elite Way to not sell your information.  To exercise this right to opt-out of the sale of personal information, please email info@eliteway-sa.com

Elite Way shall not discriminate against you for exercising any of your above rights. Please note we will continue to communicate with you directly and send you information about your product/service and promotional materials that may be relevant to you.

You may designate an authorized agent to make a request to exercise your rights on your behalf.  Your authorized agent must be able to provide to Elite Way proof that you have authorized the agent to act on your behalf.  For your protection, we reserve the right to deny any request from an agent who does not submit proof that they have been authorized to act on your behalf.

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.