1. Introduction
1.1 Qabas (referred to as “we,” “us,” or “our”), a legal entity registered under the jurisdiction of Libyan law, located at the Tatanaki Building, Independence Street, Tripoli, Libya, recognizes the importance of privacy for our clients and website users (“you” or “your”). This Privacy Notice formalises our commitment to protecting your privacy in accordance with the laws of Libya and relevant international privacy standards. It delineates the manner in which your personal information is collected, used, and safeguarded when you engage with our website (the “Website”).
1.2 In compliance with our transparency obligations, we may provide specific notices at the point of collecting personal information from you. These notices are intended to complement this Privacy Statement by elucidating specific uses of your personal data, thereby granting you the ability to make informed decisions regarding the sharing of your information with us.
1.3 It is noteworthy that our Website contains links to third-party websites. Such external websites operate independently from us, and we assume no responsibility for their privacy practices. We encourage you to review the privacy policies of any third-party websites before submitting your personal information to them.
1.4 Our adherence to the Libyan legal framework concerning data protection, coupled with our commitment to international data privacy principles, underpins our approach to privacy and data protection. This Privacy Statement has been crafted to ensure full compliance with the statutory requirements of Libya, reflecting our dedication to the secure and responsible handling of your personal information.
1.5 By accessing and utilizing our Website, you signify your acceptance of the practices set forth in this Privacy Statement. Your continued use of the Website after any modifications to this Privacy Statement constitutes your acceptance of such changes, thus, we encourage regular review of the statement to stay informed about how we are protecting your information.

      2. Information We Collect About You
2.1 In the course of our operations, Qabas collects a comprehensive array of personal information to facilitate user interaction, improve our services, and maintain the security of our digital platforms. The scope of data collection is outlined as follows:
(a) Information Provided by You: This category encompasses the personal details you actively submit through our website. Whether you’re filling out contact forms, subscribing to our services, or applying for a position through our career portal, we collect information such as your name, email address, contact details, and any other data you choose to provide. For job applicants, this includes all the details submitted via our careers site, from resumes to cover letters, which are processed in accordance with the specific privacy guidelines detailed on that portal.
(b) Correspondence Records: Any time you reach out to us, whether through email, phone, or other communication channels, we retain records of these interactions. This documentation helps us to track your inquiries, respond effectively, and improve our customer service protocols.
(c) Survey Data: On occasion, we may invite you to participate in surveys aimed at gathering insights for research purposes. Participation is voluntary, but should you choose to engage, we collect the responses and information you provide within these surveys.
(d) Digital Footprint and Usage Data: As you navigate our website, we collect detailed information on your digital engagement patterns through cookies and similar tracking technologies. This data includes, but is not limited to, your IP address, domain name, browser type, operating system, and detailed interaction metrics such as traffic patterns, location data, web logs, and the specific resources you access on our site. The collection of this data serves multiple purposes, from enhancing website functionality and user experience to securing our web environment and tailoring our digital content to better meet your preferences and needs.

      3. How We Use Your Personal Information
3.1 This section outlines the specific purposes for which we collect and use personal information obtained through our website, in alignment with our commitment to comply with Libyan data protection regulations:
(e) Business Communications and Operations: Our primary use of your information is to facilitate effective communication and conduct our business operations. This includes responding to your inquiries, fulfilling our obligations under any agreements with you, and possibly sharing your data with third parties such as agents, contractors, or advisors to enhance our services.
(f) Marketing Communications: With your consent, we aim to keep you informed about our latest offers and updates. Your information allows us to tailor these communications to your preferences. We adhere to legal requirements by obtaining your consent for marketing communications and offer straightforward mechanisms for you to opt-out at any time.
(g) Research and Development: To continuously improve our offerings, we analyze your personal information to gain insights into your needs and preferences. This research helps us to develop our products and services in alignment with client expectations.
(h) Monitoring for Quality and Security: We monitor transactions and interactions with our services to ensure quality, compliance with our procedures, and to deter and investigate fraudulent activities.
(i) Notifications of Changes: We use your information to notify you about significant changes to our services or products, ensuring you are always up-to-date with our latest developments.
(j) Content Optimization: To ensure that our website’s content is presented in the most effective manner for you, we may use your information to adjust and tailor our digital presence, which might involve collaboration with third parties.
(k) Business Reorganization: In the event of a sale, merger, or re-organization of our business, it may be necessary to transfer your personal information to a third party as part of any due diligence process or the subsequent transfer to a new entity to ensure continuity of service.
(l) Legal and Regulatory Compliance: We process your personal information to meet our legal and regulatory obligations, which may include disclosing your information to legal, regulatory, and law enforcement agencies as required.

      4. Transmission, Storage, and Security of Your Personal Information
4.1 The nature of the Internet means that data transmission is not immune to security breaches. However, Qabas is committed to upholding the integrity of your personal information by implementing robust physical, electronic, and procedural safeguards. These measures are in strict compliance with data protection laws applicable in Libya, ensuring a high level of security for your data.
4.2 Personal information collected from you is securely stored on our own or our subcontractors’ servers. Access to this information is tightly controlled and conducted in accordance with our stringent security protocols. If we provide you with (or you choose) a password for accessing certain parts of our site, you are responsible for maintaining its confidentiality. We urge you not to share your password with anyone, adhering to the security practices we outline.
4.3 In the course of our operations, personal information may be transferred to, and stored in, countries outside of Libya. These countries may have data protection laws that differ from those in Libya. Regardless of these differences, Qabas ensures that your personal information is protected with a high standard of security, consistent with our privacy policy.
4.4 When transferring personal information internationally, we take necessary measures to ensure that your data is handled securely and in accordance with our privacy policy. This includes entering into agreements with foreign service providers that obligate them to adhere to privacy standards comparable to those of Libya.
4.5 Qabas retains your personal information only for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements. Our retention periods reflect the nature of the information and the purposes for which it is processed. Information that is no longer needed is securely destroyed or anonymized, so it cannot be associated with you. Our data retention policies are designed to ensure that your information is securely maintained while in our possession and responsibly disposed of when no longer needed.

      5. Your Rights and Contacting Us
We recognize and respect your rights regarding your personal information. Our practices are designed to ensure your data is handled transparently, securely, and in compliance with Libyan data protection laws.
5.1 You have the unequivocal right to opt-out of receiving marketing communications from us. This can be done at any time by selecting the “unsubscribe” link provided in any electronic marketing material we send you or by directly contacting us.
5.2 We are committed to maintaining the accuracy of your personal information. Should there be any changes to your personal data, or should you notice any inaccuracies in the information we hold about you, we encourage you to inform us. This ensures that our records remain up-to-date and reflective of your current information. Corrections or updates can be communicated to us via our website form.
5.3 If you have inquiries or concerns regarding our use of your personal information, or if you wish to exercise any of your rights as outlined below, please reach out to us through the form of our website. You are entitled to:
(a) Request more detailed information on how we use your personal data.
(b) Obtain a copy of the personal information you have provided to us.
(c) Correct inaccuracies in the personal information we hold about you.
(d) Request the deletion of personal information for which we no longer have a lawful basis to use.
(e) Object to certain processing activities if you believe your data protection rights outweigh our legitimate interests in that processing.
(f) Withdraw your consent for processing activities based on consent.
(g) Restrict how we use your information while we review your inquiry or objection.
Your requests will be handled with the utmost consideration, ensuring compliance with legal requirements and our internal policies. Responses to such requests will be provided in a timely manner, typically within one month.
5.5 Should you be dissatisfied with our handling of your personal information or our response to your exercise of these rights, you have the right to lodge a complaint with the Libyan data protection authority.
5.6 For any questions regarding this Privacy Statement or your personal information under our care, please contact our Data Protection Officer thought the form available in our website. Our dedicated officer is committed to addressing your privacy concerns and ensuring the respectful treatment of your data in line with our privacy commitments and legal obligations.

      6. Cookies Policy
6.1 Our use of cookies is designed to enhance your browsing experience on our website. Cookies are small data files placed on your device to collect standard internet log information and visitor behaviour information in an anonymous form.
6.2 Opting Out: You have control over the use of certain cookies. Our Cookie Management Tool, accessible at the bottom of our website, allows you to manage your cookie preferences. For more detailed information on the types of cookies we use, their purpose, and how you can manage or delete them, please refer to our comprehensive Cookies Policy available through the provided link on our site.

      7. Changes to Our Privacy Statement and/or Cookies Policy
7.1 Updates and Modifications: Due to the evolving nature of our services and the broader digital environment, it’s natural for our practices, including those related to cookies and privacy, to undergo changes. Whenever we make significant updates to our Privacy Statement or Cookies Policy, we will revise the publication date and take proactive steps to notify you. These measures are part of our commitment to transparency and ensuring that you are always aware of how we collect, use, and safeguard your personal information.
7.2 Last Revision Date: Please note that the current version of our Privacy Statement was last updated on 10 April 2024. We encourage you to regularly review this section to stay informed about the most up-to-date practices and policies governing your personal data.
7.3 Data Subject Requests (DSR): For those looking to exercise their data privacy rights, we have established an online privacy rights portal accessible through our website. This platform is designed to facilitate the efficient handling of your requests in accordance with relevant data protection regulations. For any inquiries or to manage your data privacy preferences, please utilize the contact form available on our website. This method ensures direct communication with our team, enabling us to address your concerns promptly and effectively.

      8. Legal Grounds for Processing Your Information

8.1 Aligned with Qabas’s commitment to uphold stringent transparency, legal compliance, and respect for privacy within the Libyan legal framework, we meticulously process your personal information based on established legal grounds. These principles ensure that our processing activities are both justified and in strict adherence to the nuances of Libyan data protection regulations, alongside universally respected privacy principles:
(a) Consent: We rely on your explicit consent for processing your personal information. This foundational principle empowers you to freely grant, refuse, or withdraw your consent at any stage, thereby controlling the extent to which we can utilize your data. This right is fundamental to our privacy operations, reflecting our respect for your autonomy and privacy preferences.
(b) Contract Performance: Essential for the execution and fulfilment of contracts, your data is processed as necessary to deliver the services or products you have engaged us for. This ensures that we can meet our contractual obligations effectively, providing you with the services or information you have rightfully expected from us.
(c) Legal Obligation: Adhering to the Libyan legal statutes, we may process your information to comply with various legal obligations. These obligations ensure that both you and we operate within the legal frameworks established by Libyan authorities, contributing to a transparent and lawful business environment.
(d) Legitimate Interests: In certain instances, your data is processed to safeguard legitimate interests pursued by Qabas or by a third party, provided these interests do not override your fundamental rights and freedoms. This basis for processing is carefully balanced to ensure that our legitimate business activities do not encroach upon your privacy rights.
(e) Legal Claims: Your personal information may be processed in the context of establishing, exercising, or defending against legal claims. This could involve court proceedings, administrative processes, or other legal contexts, ensuring that both your and our legal rights are preserved and respected.
8.2 For further information, inquiries, or to exercise your rights in relation to your personal data, we encourage you to use the dedicated contact form on our website. This method ensures that your queries are addressed promptly and securely, respecting the privacy and security measures upheld by Libyan laws and Qabas’s commitment to your data protection.