1. INTRODUCTION
We respect your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you. This privacy policy is meant to help you understand what data we collect, why we collect it and how we process it.
This privacy policy fully complies with the provisions of GDPR Regulation - Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and the free movement of such data and repealing Directive 95/46/EC (General Data Protection Regulation).

2. DEFINITIONS
the Policy means this Privacy policy (also referred below as “Privacy policy”);
the Service means W H D MARKETING L.L.C (a Limited Liability Company, Reg. number 2210263, Correspondence address: 3002-020, Plot Number 24-0, Trade Center First, AL MOOSA TOWER 2, Dubai) hereinafter referred to as “the Service”, “we”, “us” or “our” in this Privacy policy;
the User means a legal or natural person who uses analytics services (works, products, collectively referred hereinafter – “services”), collectively referred to as “you”, “your” or “yours” in this Privacy policy;
the website means the website in the Internet, located at innovate-impact.com, all rights for its administration are hold by pulsar.center/privacy ___________;
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product/Software and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Performance of the Agreement means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
FUNDAMENTAL CONDITION
The processing of your personal data in relation to your use of the website will be subject to this policy. If you disagree with any part, of this policy then you may not access the website Should you disagree with any provision of this Policy you shall cease using the ebsite immediately. If you are using the website in your own name or on behalf of any entity, you acknowledge this Policy on your or such entity’s behalf (when applicable).

3. GENERAL PROVISIONS
3.1. THE CONTROLLER
The Service is the controller, processors and responsible for User’s personal data. Being the controller, we independently determine the personal data processing purposes and means.
User’s Support: ailab@tools.whd.ae
3.2. DATA PROTECTION OFFICER (DPO)
Being the controller, We appoint a Data protection officer (DPO), who is responsible for overseeing questions in relation to User’s data protection.
If User has any questions in relation to this Privacy policy, User is entitled to contact using the details set out below:
Full name and contact details of the person authorized by the controller and responsible for personal data procession: Data protection officer (DPO), Suleymanova Kamilia, email: ailab@tools.whd.ae.
Users, being a citizens or residents of European Union, have the right to make a complaint at any time to applicable to you Data Protection Authority and can find contact details of their National Data Protection Authority online at: http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm
We would, however, appreciate the chance to deal with your concerns before you approach the DPA so please contact us or our DPO in the first instance.
3.3. THIRD-PARTY LINKS
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share User’s data. We do not control these third-party websites and is not responsible for their privacy statements. When you leave the website, we encourage you to read the privacy policy of every website you visit.

4. TYPES, PURPOSES, METHODS AND PERIODS OF PERSONAL DATA PROCESSING
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 (User) which we have grouped together follows:
Identity Data includes first name, last name, username or similar identifier, official capacity and place of employment.
Contact Data includes correspondence address, email address and telephone numbers.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, browser plug-in types and versions, device type, operating system and platform and other technology on the devices you use to access this website.
Usage Data includes information about how you use our website, as well information that you may upload into the website from time to time (if any).
We also may collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does 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. However, if We combine or connects 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 or process 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 or process any information about criminal convictions and offences.

HOW WE MAY USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, We will use your personal data in the following circumstances:
- 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 or regulatory obligation.
User is kindly asked to see information below 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 as we shall process it for the performance of the Agreement.

Methods of your personal data processing:
Collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, examination, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, sampling, erasure or destruction.

Period of your personal data processing:
(a) If you are a citizen of a European Union country, your personal data processing period ends in 5 (five) years from the termination of interaction between you and us. The personal data storage period may be extended from 5 (five) to 7 (seven) years upon the competent authority request.
(b) If you are not a citizen of a European Union country, your personal data processing period for such is unlimited.

In some circumstances you can ask us to delete your data.
Please note that if personal data is erased at your request, we will only retain such copies of the information as are necessary to protect our or third party legitimate interests, comply with governmental orders, resolve disputes, troubleshoot problems, or enforce any agreement you have entered into with us.

In some circumstances we may 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.

5. PURPOSES FOR WHICH WE MAY USE YOUR PERSONAL DATA
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity


Type of data


Lawful basis for processing including basis of legitimate interest

To register you as a new user on website.


(a)Identity Data

(b)Contact Data

Performance by us of the Agreement with you.

To manage our relationship with you which will include:

(a) Notifying you about changes to our website terms of use or privacy policy;

(b) Asking you to leave a review or take a survey, providing you with our email newsletters and other email letters in case you are subscribed;

(с) Your Identification website for our services.

(a) Identity Data

(b) Contact Data

(a) Performance of the Agreement 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 Software/services).

To administer and protect our business and website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).


(a) Identity Data

(b) Contact Data

(с) Technical data

(d) Usage data

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud)

(b) Necessary to comply with a legal obligation


To use data analytics to improve our website, Software and services, User’s relationships and experiences.


(a) Technical data

(b) Usage data

Necessary for our legitimate interests (to define types of Users for our services and Software, to keep our Website updated and relevant, to develop our business and to inform our marketing strategy)


CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please Contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

6. WHERE WE MAY STORE YOUR INFORMATION
We store your personal data on servers located within the EU. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

7. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, We limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know.

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

Numerous studies have established that data stored in the cloud is less likely to be lost, deleted or leaked than data stored on a personal computer. All our data is fully encrypted at rest and in transit, and we employ state-of-the-art firewall and back-up technology. All our data is also continuously backed up in several high security access-controlled data centers in different locations.

8. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
You have the right to:
(a) Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
(b) Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
(c) Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing, where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
(d) Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
(e) Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
(f) Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform the Agreement with you.
(g) Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us.

9. OTHER CONDITIONS
NO FEE REQUIRED
You will not have to pay a fee to access your personal data (or to exercise any of the other rights).
WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. INFORMATION ABOUT OUR USE OF COOKIES
Our website uses cookies to distinguish you from other users of our Website. This helps us to provide you with a good experience when you browse our Website and also allows us to improve our Website. By continuing to browse the website, you are agreeing to our use of cookies.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive. A cookie enables the Website to remember your actions and preferences ‒ such as login, language, font size and other display preferences ‒ over a period, so you don’t have to keep re-entering them whenever you come back to the site or browse from one page to another.

Cookies are placed on your device only if you consent, unless cookies are required for strictly technical functioning of the Website. However, note that if you do not consent to the use of cookies, certain functions of the Website may not function properly or may not function at all.

The legal basis for the use of cookies is our legitimate interest in ensuring the technical functionality of the Website. When cookies are used to remember your choices or for statistical purposes, the legal basis is your consent.
We use the following cookies:
(a) Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our Website and process identification of the User.
(b) Analytical/performance cookies. They allow us to recognize and count the number of visitors and to see how visitors move around our Website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
(c) Functionality cookies. These are used to recognize you when you return to our Website. This enables us to personalize our content for you and remember your preferences (for example, your choice of language or region).
(d) Security cookies. They are used to ensure and improve security of our Website and your warrant your secure access to the Website.

You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

Cookie

Name

Purpose

Strictly necessary cookies

test_cookie; uc_session;

These cookies enable you to log into secure areas of the Website and enables us to process identification of the User.

Analytical/performance cookies

__ddg1; _fbp; ym#_lastHit; ym#_lsid; ym#_reqNum; ym_visorc; metrika_enabled; VISITOR_INFO1_LIVE; webvisor/73298362; yabs-sid; YSC; yt-remote-cast-available; yt-remote-cast-installed; yt-remote-connected-devices; yt-remote-device-id; yt-remote-fast-check-period; yt-remote-session-app; yt-remote-session-name; yuidss; introvert_cookie; __ddgmark; __ddgid; _ym_afr

This cookie enables us to estimate our audience size and the Website usage pattern of Users.

Functionality cookies

__vw_tab_guid; _ga; _gat; _gid; _ym_d; _ym_isad; _ym_retryReqs; ym_uid; previousUr; tildasid; tildauid; visited; yandexuid; ymex;

This cookie is used to recognize you when you return to the Website. This enables us to personalize our content for you and remember your preferences (for example, your choice of language or region).

Security cookies

ipp_key; ipp_uid;ipp_uid1; ipp_uid2;

This cookie is essential for the Website to improve its security and in particular prevent attacks on the Website.


Please note that third parties (including, for example providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

You can control and/or delete cookies as you wish. You can delete all cookies that are already on your computer and you can set most browsers to prevent them from being placed. But if you do this you may have to manually adjust some preferences every time you visit the Website, while some services and functionalities may not work.

Except for essential cookies, all cookies will expire after a short term (a day, a week or a month), though in some cases they may remain valid for up to a year.

10. Version of this Privacy policy
Last updated: 25.10.2025
















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