1- What is the current status of Dubarter GDPR compliance?
Dubarter intends and expects to comply with GDPR by its effective date on 25 May 2018, including having a legal basis under Article 6 GDPR for processing any personal data.
Dubarter is an electronic portal for the sale, purchase and evaluation of used and new products for helping visitors in their choices by giving them the product with all its qualities he/she needs and also to review it visible and audible, founded in 2012, contains major sections such as cars, real estate and electronics, the very special thing about us is we are allow bartering and negotiating on our website which is something unique and suits a lot of the Arab world economic status.
We are targeting more than 20 Arab countries, also we have website traffic from them but Egypt is the biggest so far.
Dubarer does not currently believe that it processes, let alone seeks or expect that it will seek to process, any personal data that is subject to Article 9 GDPR, "Processing of special categories of personal data," which, in reference to GDPR, is generally referred to as "sensitive personal data."
Dubarter currently does not believe it is a data processor for a data controller, necessitating that it enter into customary and compliant data processing agreements with data controllers. However, should that change, in order to comply with GDPR, Dubarter believes that both Dubarter as a data processor and the data controller will need to enter into a compliant data processor agreement.
6- In particular, if I am a data subject and Dubarter is a data controller to my personal data, can Dubarter comply with my request "to be forgotten"?
Yes. However, a data subject should understand the consequences of such a request.
For example, with respect to any personal data that provides the necessary contact details in order to administer a subscription for a subscriber that is an organization, Dubarter will need to replace the contact information within its system in order to manage the subscriber’s subscription and account.
For any subscribers who are individuals, complying with a request to be forgotten will of course cause a permanent termination of the subscriber’s account and subscription. Dubarter also often tries to take the participants seriously in dealing with user accounts by terminated or expired subscribers those are not have any activities on the dubarter website, and eliminating or permanently “forgetting” personal data will eliminate Dubarter ability to make any such offers to the data subject.
If you are a data subject and have requests of Dubarter under GDPR related to your individual rights in your personal data, including a "request to be forgotten/for erasure," "rectification," etc., please email firstname.lastname@example.org. Dubarter will promptly review your request and respond to you.
Most of the personal data that Dubarter collects occurs in the user or subscriber account creation process, as well as the customer care and success processes. That typically data consists of: subscriber or account-holder contact email address; display name; and data required for advertisement retargeting and analytics processes.
Dubarter does not collect or process any sensitive personal data.
Dubarter’s efforts to identify all existing and any new sources of personal data collection are ongoing toward being compliant with GDPR by 25 May 2018.
DUBARTER TRADING FZE - CORPORATE OFFICE P.O.Box 61516, Dubai - UAE
10- Are you offering data storage and all processing for your EU customers to take place within the EU?
As Dubarter is headquartered in Dubai - UAE and is not "established" anywhere in the EU, it does not see any advantage in hosting personal data in the EU, since Dubarter will have no personnel in the EU to process any of the personal data in order to perform its obligations to its subscribers.
As answered in Question 4 (above), Dubarter currently does not believe it is a data processor for a data controller, necessitating that it enter into customary and compliant data processing agreements with data controllers. However, should that change, in order to comply with GDPR, Dubarter believes that both Dubarter as a data processor and the data controller will need to enter into a compliant data processor agreement.
Updated May 14, 2018