Privacy & Cookie Policy
This Privacy and Cookie Policy explains how Delta International Management Development Training (“Delta”, “we”, “our” or “us”) collects, uses, discloses and protects personal data, and how we use cookies and similar technologies on our website.
General Provisions
1. Introduction
Delta International Management Development Training, a civil company duly incorporated under the laws of the United Arab Emirates, and holding Professional License No. 1005182 issued by the Department of Economy and Tourism (DET) ("Delta", "we", "our" or "us") is committed to protecting the privacy and personal data of every individual who interacts with our website, educational platforms, learning management systems, mobile applications (if any), customer support channels, training programmes, seminars, webinars and other services.
We recognise that personal data is valuable and that its collection, use, disclosure and protection must be carried out responsibly, transparently and in accordance with applicable laws.
This Privacy Policy explains how we collect, use, disclose, transfer, retain and otherwise process personal data relating to students, prospective students, website visitors, clients, instructors, speakers, business partners and other individuals who interact with us.
Our objective is to ensure that every individual understands:
what information we collect;
why we collect it;
how we use it;
who we may share it with;
how long we retain it;
the security measures implemented to protect it; and
the rights available to individuals in relation to their personal data.
We encourage you to read this Privacy Policy carefully before using our website or submitting any personal data to us.
2. Scope of this Privacy Policy
This Privacy Policy applies to all personal data processed by Delta in connection with its business operations, whether such processing is carried out through or in relation to our website, online course registration portals, learning management systems (LMS), student portals, webinar and virtual classroom platforms, classroom registration processes, mobile applications (where available), customer support channels, marketing communications, surveys, feedback mechanisms, social media pages administered by us, certification and examination services, or any other products, services, platforms or activities that expressly refer to or incorporate this Privacy Policy.
This Privacy Policy applies irrespective of the method by which personal data is collected or processed, including information obtained through electronic systems, written documentation, verbal communications, audiovisual means, or any other lawful method of collection or processing.
Unless expressly stated otherwise, this Privacy Policy governs all personal data processed by Delta in its capacity as a data controller and, where applicable, as a data processor under applicable data protection laws.
This Privacy Policy does not apply to the processing of personal data by third parties that operate independently of Delta and determine their own purposes and means of processing. This includes, without limitation, third-party websites that may be accessible through links on our website, payment service providers and payment gateways operating under their own privacy notices, independent instructors, consultants or business partners acting as separate data controllers, and third-party software, applications or online services that users choose to access independently of our Services.
Where our website or Services contain links to external websites, platforms or applications operated by third parties, such links are provided solely for convenience and informational purposes. Delta does not own, operate or control such third-party services and is not responsible for their privacy practices, security measures, content or the manner in which they collect, use, disclose or otherwise process personal data. Users are encouraged to review the applicable privacy policies and terms of use of any third-party service before providing personal data or using such services.
Nothing in this Privacy Policy shall be construed as extending Delta's responsibilities or liabilities to the processing activities of independent third parties, except to the extent required under applicable law or where Delta expressly states otherwise.
3. Definitions
For the purposes of this Privacy Policy, unless the context otherwise requires:
"Applicable Law" means all laws, regulations and legally binding requirements governing the processing of personal data, including the laws of the United Arab Emirates, as amended from time to time.
"Cookies" mean small text files placed on a user's device to enable website functionality, improve user experience and collect analytical information.
"Data Controller" means the person or organisation that determines the purposes and means of processing personal data.
"Data Processor" means a person or organisation that processes personal data on behalf of the Data Controller.
"Personal Data" means any information relating to an identified or identifiable natural person, whether directly or indirectly, including any information that can reasonably be used to identify that individual.
"Processing" includes collecting, recording, organising, storing, adapting, retrieving, consulting, using, transmitting, disclosing, combining, restricting, erasing or destroying personal data.
"Services" means all educational programmes, training courses, seminars, workshops, webinars, certifications, consulting services, digital content and related services offered by Delta.
"Student" includes any individual who registers, applies for, attends or participates in any of our educational services.
"Website" means the official website operated by Delta together with all associated webpages, student portals and online platforms.
4. About Us
Delta is an educational services provider specialising in professional training, skills development and educational programmes in the fields of financial markets and other professional disciplines. As part of its educational activities, Delta develops and delivers courses, workshops, seminars, webinars, certification programmes and related learning services designed to enhance participants' knowledge and professional competencies.
Depending on the programmes offered from time to time, our educational services may include training in foreign exchange (Forex), securities and capital markets, stock market investing, commodities, derivatives, portfolio management concepts, financial analysis, risk management, financial technology (FinTech), wealth management concepts, cryptocurrency and blockchain education (where legally permissible), and other educational or professional development programmes that are introduced as part of our curriculum.
All programmes, materials and Services provided by Delta are intended solely for educational, informational and training purposes unless expressly stated otherwise. Nothing contained in our courses, educational materials, presentations, publications, webinars, communications or other content should be interpreted as constituting investment advice, financial advice, legal advice, tax advice, portfolio management services, brokerage services or any other regulated financial or professional service. Participation in our programmes does not create an adviser-client, fiduciary or other professional relationship between Delta and any participant, nor should any educational content be relied upon as a substitute for obtaining independent professional advice appropriate to an individual's circumstances.
For the purposes of applicable data protection laws, including the UAE Personal Data Protection Law, Delta acts as the Data Controller in relation to the personal data it collects and processes in connection with its Services where it determines the purposes and means of such processing. In circumstances where Delta processes personal data on behalf of another organisation in accordance with that organisation's documented instructions, Delta shall act as a Data Processor to the extent provided under the applicable contractual arrangements and governing law
5. Acceptance of this Privacy Policy
By accessing or using our Website or Services, submitting information through our registration forms, enrolling in any course, communicating with us, or otherwise providing us with personal data, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein, where consent is the applicable legal basis.
Where the processing of personal data is based on your consent, you may withdraw such consent at any time by contacting us using the details provided in this Privacy Policy. Withdrawal of consent shall not affect the lawfulness of any processing carried out before such withdrawal and may affect our ability to provide certain Services.
If you do not agree with the terms of this Privacy Policy, you should refrain from using our Website or Services or providing us with your personal data.
If you are providing personal data on behalf of another individual, you represent and warrant that you are authorised to do so and have obtained any necessary permissions or consents required under applicable law.
Collection Of Personal Data
6. Categories of Personal Data We Collect
Delta collects and processes only such personal data as is adequate, relevant and reasonably necessary for the purposes described in this Privacy Policy, including providing and administering our Services, managing our educational programmes, fulfilling contractual and legal obligations, protecting our legitimate interests, maintaining the security of our systems, and improving the quality and functionality of our Website, platforms and Services. The categories of personal data that we may collect vary depending on the nature of your interaction with us and the Services you use.
6.1 Identity Information
We may collect personal information that identifies or relates to you as an individual. Depending on the circumstances, this may include your full name, date of birth (where required), gender (where voluntarily provided or required for administrative purposes), nationality, country of residence, and photograph where submitted by you or required for certification, identification or educational purposes. Where reasonably necessary, we may also collect government-issued identification details, including information contained in an Emirates ID, passport, visa or other official identification document.
Government-issued identification documents are not ordinarily required for general enquiries or routine interactions with Delta. Such information will be requested only where it is reasonably necessary for identity verification, certification, compliance with applicable legal or regulatory obligations, fraud prevention, security, or other legitimate purposes connected with the provision of our Services.
6.2 Contact Information
We may collect contact information necessary to communicate with you and administer our Services. This may include your email address, mobile telephone number, alternative contact number, residential or postal address, country, city or emirate of residence, and your preferred language of communication.
We use this information to communicate with you regarding course registrations, schedules, examinations, certification, payment confirmations, customer support enquiries, administrative matters, service updates and other matters relating to our educational programmes and Services.
6.3 Professional Information
Where relevant to a particular programme or service, we may collect information relating to your professional background, including your current occupation, employer, industry, job title, years of professional experience, areas of expertise, professional qualifications, licences and certifications.
Such information enables us to assess eligibility for certain programmes, tailor educational content to participants' professional backgrounds, understand the experience of our participants and improve the quality and relevance of our educational offerings.
6.4 Educational Information
We may collect information relating to your educational background and learning history where relevant to the Services you request. This may include your academic qualifications, previous certifications, training history, examination or assessment results, attendance records, course completion records and continuing professional education records.
This information assists us in administering our educational programmes, maintaining academic records, verifying eligibility for courses or certifications, evaluating learning outcomes and issuing certificates where applicable.
6.5 Financial Markets Experience
As Delta provides education and training relating to financial markets, we may request information regarding your existing knowledge or experience in trading or investing. This may include information concerning your previous trading experience, familiarity with foreign exchange, equities, commodities, derivatives or digital assets, preferred financial markets, investment education history, trading objectives and educational goals.
Such information is collected solely for educational and administrative purposes, including understanding participants' existing knowledge, delivering learning content appropriate to different experience levels and improving the overall educational experience. It is not collected for the purpose of assessing your suitability for any investment, providing investment recommendations or delivering regulated financial or investment advisory services.
6.6 Payment Information
Where you purchase or register for our Services, we may collect information necessary to process and administer the transaction. This may include invoice details, billing information, payment reference numbers, transaction amounts, payment status, payment dates and the applicable currency.
For the avoidance of doubt, Delta does not store complete credit or debit card details or other sensitive payment credentials. Payment transactions are processed securely through authorised third-party payment service providers in accordance with their applicable security standards and privacy practices. Accordingly, complete payment card information will not be stored, sold, rented, leased or otherwise disclosed by Delta except where required by applicable law.
6.7 Communications
We may collect and maintain records of communications exchanged with you in connection with our Services. This includes communications made through email, website enquiry forms, live chat, customer support channels, telephone calls, messaging platforms such as WhatsApp, webinar interactions, surveys, complaints, feedback submissions and testimonials voluntarily provided by you.
Communication records may be retained where reasonably necessary for customer support, quality assurance, staff training, service improvement, dispute resolution, compliance with legal obligations, the protection of our legitimate interests or the establishment, exercise or defence of legal claims.
6.8 Technical Information
When you access or use our Website or other digital platforms, certain technical information may be collected automatically through our systems or through cookies and similar technologies. Depending on your device and browser settings, this information may include your Internet Protocol (IP) address, browser type and version, operating system, device identifiers, device type, screen resolution, language settings, referring URLs, pages visited, date and time of access, session duration, clickstream information and system or error logs.
This information is used to operate, secure and maintain our Website, improve performance and functionality, identify technical issues, detect fraudulent or malicious activity and enhance the overall user experience.
6.9 Website Usage Information
We may collect information regarding your interactions with our Website and online platforms, including the pages you visit, educational content accessed, downloads, navigation behaviour, search queries, links selected, session frequency, time spent on particular pages and course registration activity.
We use this information to understand how our Website and Services are used, evaluate user engagement, improve accessibility and functionality, develop educational content and enhance the performance and effectiveness of our digital platforms.
6.10 Marketing Preferences
Where you choose to receive marketing or promotional communications from us, we may maintain records of your communication preferences, subscription status, preferred communication channels, consent records and interactions with our marketing communications.
You may withdraw your consent or unsubscribe from marketing communications at any time by using the unsubscribe mechanism included in the relevant communication or by contacting us using the contact details provided in this Privacy Policy. Withdrawal of your marketing preferences will not affect the lawfulness of any processing carried out prior to such withdrawal and will not prevent us from sending communications that are necessary for the administration of our Services or the performance of our contractual or legal obligations.
7. Personal Data You Voluntarily Provide
Certain personal data is provided directly by you when you choose to interact with Delta or use our Services. This may occur when you submit an enquiry, create or register an account, enrol in a course, request information about our programmes, subscribe to newsletters or other communications, attend webinars, seminars or training sessions, complete surveys or feedback forms, download educational materials, communicate with our instructors or customer support team, submit assignments or assessments, participate in competitions, promotional campaigns or events, or voluntarily provide testimonials, reviews or other content.
You are responsible for ensuring that any personal data you provide to us is accurate, complete and up to date. Where your personal data changes, you should notify us as soon as reasonably practicable so that we may update our records and continue to provide our Services effectively.
If you provide personal data relating to another individual, you represent and warrant that you are authorised to disclose such information to Delta and, where required under applicable law, that the individual concerned has been informed of the processing of their personal data in accordance with this Privacy Policy or has otherwise provided any consent or authorisation required for such disclosure. Delta reserves the right to request evidence of such authority where it is reasonably necessary to do so.
8. Information Collected Automatically
When you access or use our Website, learning platforms or other digital Services, certain information may be collected automatically through cookies, server logs and similar technologies. Depending on your device, browser settings and the technologies employed, this information may include browser and device characteristics, operating system details, approximate geographic location derived from your Internet Protocol (IP) address, referring websites, pages visited, links selected, session duration, navigation patterns, diagnostic information, performance metrics and other technical information relating to your interaction with our digital platforms.
We process this information for a variety of legitimate operational purposes, including maintaining the security and integrity of our Website and systems, identifying and resolving technical issues, monitoring and improving the performance, functionality and accessibility of our digital platforms, understanding how users interact with our Services, detecting and preventing fraudulent, malicious or unauthorised activities, and enhancing the overall user experience.
Where technically feasible and appropriate, information collected automatically may be aggregated, anonymised or otherwise processed in a manner that does not directly identify individual users. The collection and processing of such information is carried out in accordance with applicable law and, where required, subject to your consent or cookie preferences.
Further information regarding our use of cookies and similar technologies, including the categories of cookies we use and the choices available to you, is set out in the Cookie Policy forming part of this Privacy Policy.
9. Information Received from Third Parties
In certain circumstances, Delta may receive personal data relating to you from third parties where such disclosure is lawful, appropriate and reasonably necessary for the provision of our Services, the administration of our educational programmes, the performance of contractual obligations or compliance with applicable legal requirements.
Where educational programmes are delivered in collaboration with educational institutions, training partners or other organisations, we may receive personal data necessary to administer the programme, including registration details, attendance records, assessment information or other academic and administrative records relevant to your participation.
Where your participation in one of our programmes is sponsored, arranged or facilitated by your employer or another organisation, we may receive personal data reasonably necessary to process your registration, manage your enrolment, administer the programme, monitor attendance, issue certificates or communicate with you regarding the relevant educational services.
If you are referred to Delta through an authorised business partner, educational consultant, referral partner or marketing partner, we may receive limited personal data required to respond to your enquiry, process your registration or facilitate the provision of our Services.
Where payments are made through authorised third-party payment service providers, we may receive transaction-related information necessary to confirm, administer and reconcile payments. Such information may include payment confirmations, transaction status, payment authorisation details, refund information and chargeback notifications. Delta does not receive, access or store your complete payment card details through these providers.
Where you choose to interact with Delta through social media platforms or use any available social sign-in functionality, we may receive personal data that you have authorised the relevant platform to share with us, subject to your privacy settings and the terms governing your use of that platform.
In limited circumstances, we may also obtain personal data from publicly available sources where reasonably necessary to verify information you have provided, prevent or investigate fraud, comply with applicable legal or regulatory obligations, protect our legal rights or otherwise safeguard our legitimate business interests. Any information obtained from publicly available sources will be processed in accordance with applicable law and only to the extent necessary for the relevant purpose.
10. Information We Generally Do Not Collect
Delta follows the principle of data minimisation and does not intentionally collect categories of personal data that are not reasonably necessary for the provision of our Services or the fulfilment of our legal and operational obligations.
Accordingly, unless required by applicable law or necessary for a specific and lawful purpose, we do not intentionally collect or request the following categories of information:
biometric information
health or medical records
political opinions or political affiliations
religious or philosophical beliefs
trade union membership
information relating to criminal convictions or offences
genetic data
precise geolocation data
complete payment card numbers
CVV or other card security codes
banking passwords or authentication credentials; or
passwords for online accounts or other digital services
Where the collection of any such information becomes necessary for a specific lawful purpose, Delta will collect and process it only to the extent permitted or required by applicable law and will implement appropriate technical, organisational and administrative safeguards commensurate with the sensitivity of the information
11. Accuracy of Information
You are responsible for ensuring that the personal information you provide to us is accurate, complete and up to date.
Where your personal information changes, you should notify us as soon as reasonably practicable so that our records remain accurate.
Failure to provide accurate information may affect our ability to provide certain Services or fulfil our contractual or legal obligations.
12. Purposes of Processing Personal Data
Delta processes personal data only for specific, explicit and legitimate purposes that are necessary for the provision, administration, improvement and protection of its Services. We process personal data only to the extent permitted or required by applicable law and only where an appropriate legal basis exists for such processing.
Depending on the nature of your relationship with Delta and the Services you access, your personal data may be processed for one or more of the following purposes.
12.1 Providing Educational Services
We process personal data to administer and deliver our educational programmes and related Services. This includes registering students and participants for courses, workshops, seminars and webinars, verifying enrolment details, creating and managing student accounts, providing access to learning management systems and educational materials, delivering classroom and online training, communicating course schedules and administrative updates, monitoring attendance and participation, assessing course completion, issuing certificates and other educational records, and providing academic and administrative support throughout your participation in our programmes.
12.2 Student Administration and Relationship Management
We process personal data to manage our relationship with current, prospective and former students throughout the lifecycle of our educational Services. This includes responding to enquiries, providing information regarding our programmes, processing applications and registrations, maintaining student records, monitoring course progress, responding to requests, complaints and feedback, and maintaining appropriate records of our communications to facilitate the effective administration of our Services.
12.3 Personalisation and Improvement of Educational Services
Where appropriate, we may process information relating to your professional background, educational objectives and financial markets experience to better understand your learning requirements, recommend suitable educational programmes or learning pathways, improve the design and delivery of our courses, develop educational materials, evaluate the effectiveness of our programmes and analyse student engagement and learning outcomes.
Any assessment of your prior trading, investing or financial markets experience is conducted solely for educational and curriculum development purposes. Such information is not used to assess your financial suitability, provide investment recommendations or otherwise deliver regulated financial advisory, brokerage or portfolio management services.
12.4 Certification and Academic Records
We process personal data to administer certification processes and maintain accurate academic records. This includes verifying eligibility for certificates, maintaining records of attendance and course completion, issuing certificates and other educational documents, responding to certificate verification requests and preserving historical academic records where appropriate.
Where certificates are issued, certain information, including your name, course title, completion date, certificate number and other relevant certification details, may be retained for verification, record-keeping, audit and administrative purposes.
12.5 Payments and Financial Administration
Where payment is required for our Services, we process personal data to administer financial transactions and fulfil our accounting obligations. This includes processing course fees, issuing invoices and receipts, maintaining payment records, confirming transactions, administering refunds, resolving payment disputes, preventing fraudulent transactions and complying with applicable accounting, taxation and financial record-keeping requirements.
Payment transactions may be processed through authorised third-party payment service providers in accordance with their own security standards, contractual obligations and applicable legal requirements.
12.6 Customer Support and Communications
We process personal data to communicate with you and provide effective customer support throughout your interaction with Delta. This includes responding to enquiries, providing technical and administrative assistance, investigating issues, handling complaints, issuing service-related notifications and maintaining appropriate records of communications.
Where communications are recorded or retained, such records may be used for customer support, quality assurance, staff training, dispute resolution, regulatory compliance, the protection of our legitimate interests and the establishment, exercise or defence of legal claims.
12.7 Website Management and Security
We process technical and usage information to operate, administer, secure and improve our Website, online learning platforms and other digital Services. This includes monitoring system performance, identifying and resolving technical issues, improving functionality and accessibility, preventing unauthorised access, detecting fraudulent, abusive or malicious activity, maintaining the integrity of our systems and protecting our users, networks and information assets.
12.8 Marketing and Promotional Activities
Subject to applicable law and your communication preferences, we may process personal data to inform you about our educational programmes, courses, workshops, seminars, webinars, events, promotional offers and other information that may be relevant to your interests. We may also analyse the effectiveness of our marketing activities and improve our communication strategies to ensure that our communications remain relevant and appropriate.
Marketing communications may be sent through various communication channels, including email, SMS, WhatsApp, telephone or other electronic communication methods permitted by applicable law. Where your consent is required for direct marketing, you may withdraw such consent or opt out of receiving marketing communications at any time without affecting the lawfulness of any processing undertaken prior to such withdrawal.
12.9 Business Analysis and Service Development
We may process aggregated, statistical or anonymised information to better understand participant demographics, evaluate demand for educational programmes, improve business operations, develop new courses and services, conduct market research, monitor operational performance and enhance the overall quality of our educational offerings and user experience.
Where reasonably practicable, such analysis will be carried out using information that has been anonymised or aggregated so that it does not identify individual participants.
12.10 Compliance with Legal and Regulatory Obligations
We may process personal data where necessary to comply with applicable laws, regulations, court orders or lawful requests from competent governmental, judicial or regulatory authorities. We may also process personal data where necessary to maintain legally required records, investigate suspected fraud, misconduct or misuse of our Services, protect our legal rights and interests, establish, exercise or defend legal claims, and fulfil any other legal or regulatory obligations applicable to Delta.
13. Legal Basis for Processing Personal Data
Delta processes personal data only where there is a lawful basis for doing so under the applicable provisions of the UAE Personal Data Protection Law and any other applicable data protection legislation. The legal basis relied upon will depend on the nature of the personal data concerned, the purpose for which it is processed, and the circumstances in which it is collected.
13.1 Performance of a Contract
We process personal data where such processing is necessary to enter into, perform or administer a contract with you, or to take steps at your request prior to entering into a contract. This includes processing personal data to register you for educational programmes, administer course enrolments, deliver classroom and online training, provide academic and administrative support, issue certificates and educational records, process payments, and otherwise fulfil our contractual obligations in connection with the Services you have requested.
13.2 Consent
Where required by applicable law, or where no other lawful basis is appropriate, we will process personal data based on your freely given, specific, informed and unambiguous consent. Depending on the circumstances, this may include sending direct marketing communications, facilitating your participation in promotional campaigns or competitions, publishing testimonials or photographs, conducting optional surveys, or processing personal data for other purposes where your consent is required.
Where processing is based on your consent, you may withdraw that consent at any time by contacting us or by using the withdrawal mechanisms made available through the relevant communication or service. Withdrawal of consent will not affect the lawfulness of any processing carried out before such withdrawal, nor will it affect any processing undertaken on another lawful basis permitted by applicable law.
13.3 Compliance with Legal Obligations
We may process personal data where such processing is necessary to comply with applicable legal, regulatory or statutory obligations. This includes maintaining accounting and financial records, complying with taxation requirements, responding to lawful requests from competent governmental, judicial or regulatory authorities, complying with court orders or other legal processes, fulfilling statutory record retention obligations, and meeting other legal or regulatory requirements applicable to our business operations.
13.4 Legitimate Interests
Where permitted by applicable law, we may process personal data where such processing is necessary for our legitimate interests or those of a third party, provided that those interests are not overridden by your rights, freedoms or legitimate interests as a data subject.
Our legitimate interests may include improving and developing our educational programmes and Services, maintaining the security, integrity and availability of our Website and information systems, preventing fraud and other unlawful activities, protecting our business operations and assets, managing customer and participant relationships, responding to complaints and disputes, conducting internal administrative activities, enforcing our contractual rights, and establishing, exercising or defending legal claims.
Before relying on legitimate interests as the basis for processing, Delta will consider the nature of the personal data involved, the reasonable expectations of the data subject, the purpose of the processing, and the potential impact on the rights and freedoms of the individuals concerned, and will implement appropriate safeguards where necessary.
13.5 Other Lawful Grounds
Where permitted or required under applicable law, Delta may also process personal data on any other lawful basis recognised under the UAE Personal Data Protection Law or other applicable legislation, including where processing is necessary to protect vital interests, for reasons of public interest, or in other circumstances expressly authorised by law.
14. Consent and Withdrawal of Consent
Where Delta relies on your consent as the legal basis for processing personal data, we will obtain such consent using clear, transparent and appropriate mechanisms before commencing the relevant processing activities, unless applicable law provides otherwise. Depending on the nature of the processing, consent may be obtained through our Website, online registration portals, electronic forms, written documentation, electronic communications, learning platforms or other documented methods that clearly record your decision.
Where appropriate, requests for consent will be presented separately from other contractual terms and conditions and in a manner that enables you to make an informed and voluntary decision. We will provide sufficient information regarding the purpose of the processing, the categories of personal data involved and, where applicable, the consequences of refusing or withdrawing consent.
You have the right to withdraw your consent at any time where processing is based on consent. Withdrawal of consent may be exercised by contacting us using the contact details provided in this Privacy Policy or through any other withdrawal mechanism made available by Delta for the relevant processing activity.
The withdrawal of consent shall not affect the lawfulness of any processing carried out before the withdrawal became effective, nor shall it affect any processing undertaken on another lawful basis permitted under applicable law.
Please note that withdrawing your consent may affect our ability to provide certain optional features, services or communications. For example, if you withdraw your consent to receive marketing communications, we will cease sending promotional emails, newsletters and similar communications. If you withdraw your consent for participation in optional surveys, promotional activities or the publication of testimonials or photographs, we will discontinue such processing to the extent reasonably practicable. Where you seek to withdraw consent in circumstances in which the relevant processing is necessary for the performance of a contract or is otherwise authorised or required under applicable law, we may be unable to provide the relevant Service or continue the affected aspect of our relationship with you. In such cases, we will inform you of the consequences of your request before taking any action, where reasonably practicable.
Delta maintains appropriate records of consents obtained and, where applicable, withdrawals of consent, in order to demonstrate compliance with applicable data protection laws and to ensure that your preferences are respected in future processing activities.
15. Processing of Sensitive Personal Data
Certain categories of personal data require a higher level of protection because of their sensitive nature. Delta does not intentionally collect or process sensitive personal data unless such processing is necessary for a lawful and specific purpose, is authorised or required under applicable law, or is otherwise carried out in accordance with this Privacy Policy and the applicable provisions of the UAE Personal Data Protection Law.
Where appropriate and permitted by law, sensitive personal data may be processed where it is necessary to provide a particular Service, fulfil a legal or regulatory obligation, protect the rights or legitimate interests of Delta or another person, or where you have voluntarily provided such information and the processing is otherwise lawful. Where required by applicable law, Delta will obtain your explicit consent before processing sensitive personal data.
If the collection or processing of sensitive personal data becomes necessary, Delta will limit such processing to the minimum information reasonably required for the relevant purpose and will implement appropriate technical and organisational measures designed to protect the confidentiality, integrity and security of the information. Access to such information will be restricted to authorised personnel who have a legitimate business need to access it and who are subject to appropriate confidentiality obligations.
Where reasonably practicable, Delta will avoid requesting sensitive personal data unless it is genuinely required for the provision of our Services or to comply with legal, regulatory or contractual obligations. We request that you do not provide sensitive personal data to us unless we have specifically requested it or unless its disclosure is otherwise necessary in connection with your use of our Services.
For the purposes of this Privacy Policy, sensitive personal data includes any category of personal data that is afforded enhanced protection under applicable law, including information revealing an individual's racial or ethnic origin, religious beliefs, health information, biometric or genetic data, and any other category of personal data designated as sensitive under the UAE Personal Data Protection Law or other applicable legislation.
16. Identity Verification and Government Identification Documents
In certain circumstances, Delta may request government-issued identification documents where such information is reasonably necessary to verify an individual's identity, comply with applicable legal or regulatory requirements, prevent or investigate fraud, confirm eligibility for particular educational programmes or certifications, protect the security and integrity of our Services, or fulfil other legitimate operational or compliance purposes. Depending on the circumstances, the documents requested may include an Emirates ID, passport, visa documentation or other government-issued identification.
Delta adheres to the principle of data minimisation and will request, collect and retain government-issued identification documents only where there is a legitimate, specific and documented business, legal or regulatory requirement to do so. Such documents will not ordinarily be requested for general enquiries or routine interactions with our Services where identity verification is unnecessary.
Where government-issued identification documents are collected, Delta will process them solely for the purpose for which they were obtained and only for as long as is reasonably necessary or required by applicable law. Access to such information will be restricted to authorised personnel who have a legitimate business need to access it and who are subject to appropriate confidentiality obligations. Appropriate technical and organisational measures will be implemented to safeguard the confidentiality, integrity and security of such information against unauthorised access, disclosure, alteration, loss or misuse.
Government-issued identification documents will not be used for purposes that are incompatible with those for which they were originally collected, nor will they be disclosed to third parties except where such disclosure is authorised by the data subject, required or permitted by applicable law, necessary for the establishment, exercise or defence of legal claims, or otherwise required to protect the legitimate rights, interests or security of Delta or another person.
Where it is no longer necessary to retain government-issued identification documents, Delta will securely delete, destroy or anonymise such information in accordance with its data retention and disposal practices, unless a longer retention period is required or permitted under applicable law.
17. Financial Education Disclaimer and Processing of Trading-Related Information
As part of providing educational programmes relating to financial markets, Delta may collect information regarding your trading knowledge, investment experience, financial market interests, educational objectives and preferred areas of learning. Such information is collected solely for educational and administrative purposes, including understanding participants' existing knowledge and experience, designing and delivering educational programmes appropriate to different levels of expertise, improving learning outcomes, developing educational content, and enhancing the quality and effectiveness of our Services.
Any information relating to your trading or investment experience is processed exclusively in connection with the provision of our educational Services and shall not be used to evaluate your financial suitability, risk tolerance or investment objectives for the purpose of recommending, arranging or facilitating any investment or financial product.
Delta does not use such information to provide investment recommendations, financial advice, portfolio management services, brokerage services or any other regulated financial service. The collection and processing of trading-related information should not be interpreted as an assessment of your suitability to engage in trading or investing, nor as an endorsement or recommendation of any particular financial product, strategy or transaction.
Participation in any course, workshop, seminar, webinar or other educational programme offered by Delta does not create an adviser-client, fiduciary, brokerage or portfolio management relationship between Delta and any participant. All educational content is provided solely for general educational and informational purposes and should not be relied upon as a substitute for obtaining independent financial, legal, tax or other professional advice appropriate to your individual circumstances.
18. Automated Decision-Making and Profiling
Delta does not make decisions that produce legal effects or similarly significant consequences for individuals solely through automated processing of personal data. Decisions relating to enrolment, certification, customer support, complaints, disciplinary matters or other matters that may materially affect an individual are not based exclusively on automated decision-making without appropriate human review and involvement.
In the course of operating our Website, learning platforms and other digital Services, we may use limited automated processing technologies to support routine operational and administrative functions. Such processing may include analysing website usage and performance, administering communication preferences, recommending educational content or courses based on users' interactions with our Services, detecting technical issues or security risks, preventing fraudulent or unauthorised activities, and facilitating the efficient administration of our educational programmes.
Where profiling or similar analytical techniques are used, they are intended solely to improve the functionality, security and quality of our Services, personalise user experiences where appropriate, and better understand the educational needs and interests of our participants. Such activities are not designed or intended to evaluate an individual's personal characteristics in a manner that produces legal effects or other similarly significant consequences.
Should Delta introduce automated decision-making or profiling activities that are subject to additional legal requirements under applicable data protection laws, we will implement appropriate safeguards, provide any notices required by law and, where applicable, ensure that individuals are afforded the rights and protections available to them under the UAE Personal Data Protection Law and other applicable legislation.
19. Payment Processing
Certain educational programmes and Services offered by Delta may require the payment of course fees, registration fees, certification fees or other applicable charges. Where you purchase or register for a paid Service, we may collect and process the personal data reasonably necessary to administer the transaction, including your name, contact details, billing information, transaction and payment reference details, invoice information, payment status and, where applicable, information relating to refunds or adjustments.
Delta does not process or retain complete credit card, debit card or other sensitive payment credentials on its own systems unless expressly required for a specific lawful purpose and permitted by applicable law. Payment transactions are processed through authorised third-party payment service providers, banks, financial institutions or payment gateway providers that have been appointed to facilitate secure payment processing on our behalf or independently provide payment services in connection with our Services.
These third-party providers process payment information in accordance with their own privacy policies, contractual obligations, security standards and applicable legal and regulatory requirements. Depending on the payment method selected, your payment information may be collected directly by the relevant payment service provider rather than by Delta. We encourage you to review the privacy notices and terms of use of the relevant payment provider before submitting payment information.
Delta receives only such payment-related information as is reasonably necessary to confirm, administer and record transactions, issue invoices and receipts, manage refunds, resolve payment enquiries or disputes, comply with applicable accounting and taxation requirements, prevent fraudulent transactions, and fulfil other legitimate business, contractual or legal obligations. We do not sell, rent, lease or otherwise disclose payment-related personal data except where such disclosure is authorised by you, necessary for the processing of a transaction, required by applicable law, or otherwise permitted under this Privacy Policy.
Delta implements appropriate technical and organisational measures to protect payment-related information within its possession and requires, where appropriate, that third-party payment service providers engaged by us maintain appropriate security measures and comply with applicable legal and contractual obligations relating to the protection of personal data.
20. Credit and Debit Card Information
Delta is committed to protecting the security and confidentiality of payment card information. As a general practice, Delta does not directly collect, access, process or store complete credit or debit card information on its own systems unless such processing is specifically required for a lawful purpose and is permitted under applicable law.
Where payment is made through our Website or other authorised payment channels, payment card information is entered directly into secure systems operated by authorised third-party payment service providers or payment gateway operators. Such providers are responsible for processing payment card information in accordance with their own privacy policies, contractual obligations, applicable legal requirements and recognised payment security standards.
Accordingly, Delta does not ordinarily retain complete payment card numbers, card verification values (CVV), card security codes, personal identification numbers (PINs), online banking credentials or other sensitive authentication data required to authenticate payment transactions.
Where limited payment-related information or transaction records are retained by Delta, such information will be restricted to that which is reasonably necessary for legitimate business, contractual and legal purposes. This may include maintaining accounting and financial records, reconciling payments, issuing invoices and receipts, administering refunds, responding to customer enquiries, resolving payment disputes, preventing fraudulent or unauthorised transactions, complying with applicable legal and regulatory obligations, and establishing, exercising or defending legal claims.
Delta implements appropriate technical and organisational measures to safeguard payment-related information within its possession and requires, where appropriate, that third-party payment service providers engaged in connection with our Services maintain appropriate security controls and comply with applicable data protection, payment security and regulatory requirements. However, the processing and security of payment card information submitted directly to a third-party payment provider remain subject to that provider's own privacy practices, security measures and legal obligations.
21. Payment Security
Delta is committed to maintaining appropriate safeguards to protect payment-related information processed in connection with its Services. Where payments are made through our Website or other authorised payment channels, we take reasonable technical, organisational and administrative measures to facilitate secure payment transactions and to reduce the risk of unauthorised access, misuse, alteration or disclosure of payment-related information within our control.
Depending on the nature of the payment transaction, these measures may include the use of reputable and authorised payment gateway providers, encrypted communication channels, appropriate access controls, transaction monitoring mechanisms, fraud prevention and detection measures, and internal administrative procedures designed to protect payment-related information and maintain the integrity of payment processes.
While Delta implements reasonable security measures and exercises due care in selecting payment service providers, no method of electronic transmission, online payment processing or electronic storage can be guaranteed to be completely secure or free from risk. Accordingly, Delta cannot warrant or guarantee the absolute security of information transmitted over the internet or through third-party payment networks.
Payment transactions processed through banks, payment gateway providers or other independent payment service providers remain subject to the security practices, operational controls and privacy policies of those organisations. To the extent permitted by applicable law, Delta shall not be responsible for any unauthorised access, security incident, system failure or personal data breach occurring solely within the systems or infrastructure of an independent third-party payment service provider that is outside Delta's reasonable control. Nothing in this Privacy Policy excludes or limits any responsibility or liability that cannot lawfully be excluded or limited under applicable law.
Users are encouraged to take appropriate precautions when making online payments, including accessing our Services only through trusted networks, safeguarding their devices and account credentials, and promptly notifying both the relevant payment service provider and Delta if they suspect any unauthorised or fraudulent payment activity.
22. Payment Verification and Fraud Prevention
Delta processes certain payment-related and technical information where reasonably necessary to verify transactions, protect its payment systems, prevent fraud and safeguard the legitimate interests of its students, customers and business operations. Depending on the circumstances, such processing may include information relating to payment history, transaction records, account activity, communications with Delta, unusual or suspicious payment patterns, and technical information such as Internet Protocol (IP) addresses, device identifiers or other information relevant to the security of a transaction.
Such information may be processed for purposes including verifying the authenticity of payment transactions, preventing fraudulent registrations, identifying suspicious or unauthorised activities, investigating payment irregularities, responding to chargebacks or payment disputes, preventing misuse of payment facilities, enforcing our contractual rights, protecting our information systems, and complying with applicable legal or regulatory obligations.
Where Delta reasonably suspects that a payment transaction is fraudulent, unauthorised or otherwise presents a material security or compliance risk, we may suspend, decline or delay the relevant transaction, registration or Service pending appropriate verification or investigation. Any such action will be taken in accordance with applicable law and our contractual rights and obligations.
23. Refund Processing
Refund requests are administered in accordance with Delta's applicable Refund and Cancellation Policy, which forms part of the terms governing the relevant Service. Where a refund is approved, Delta will process the refund using the original payment method used for the relevant transaction unless another method is required or permitted by applicable law, directed by the relevant payment service provider, or otherwise authorised by Delta in exceptional circumstances.
To protect against fraud, money laundering and unauthorised payment activity, Delta generally does not process refunds to unrelated bank accounts, third-party payment accounts, alternative payment methods or cash payments where such refunds are prohibited by law or inconsistent with our internal payment verification procedures.
The time required for a refund to be completed may vary depending on the payment method used, the relevant payment gateway provider, the issuing or acquiring bank, financial institution processing times and other factors outside Delta's reasonable control. While Delta will use reasonable efforts to process approved refunds promptly, we are not responsible for delays attributable solely to banks, payment service providers or other third parties involved in the payment process.
24. Chargebacks and Payment Disputes
Where a payment dispute, chargeback request, payment reversal or similar claim is initiated, Delta may process and, where reasonably necessary, disclose relevant personal data to payment gateway providers, payment processors, acquiring or issuing banks, payment networks, fraud prevention service providers, professional advisers, insurers and competent governmental, judicial or regulatory authorities, to the extent necessary to investigate, respond to and resolve the dispute.
The information disclosed may include transaction records, registration details, proof of enrolment or service delivery, attendance records, course access logs, communication history, refund records and any other information reasonably necessary to establish the validity of the transaction, defend Delta's legal or contractual rights, investigate suspected fraud or comply with applicable legal or regulatory requirements.
Delta will ensure that any disclosure made in connection with a payment dispute or chargeback is limited to the information reasonably necessary for the relevant purpose and is carried out in accordance with applicable data protection laws, contractual obligations and appropriate confidentiality safeguards.
Cookies And Tracking Technologies
25. Use of Cookies
Delta uses cookies and similar technologies on its Website and digital platforms to support their operation, enhance functionality, improve user experience, analyse Website usage, strengthen security and deliver certain features and services. Cookies are small text files that are stored on your device when you visit a website. They enable the Website to recognise your browser or device, remember certain information relating to your visit and facilitate the efficient operation of online services.
Cookies and similar technologies may be placed directly by Delta or, where appropriate, by authorised third-party service providers acting on our behalf. Depending on the services being used, these may include providers of website hosting, analytics, payment processing, security services, content delivery, marketing technologies or other service providers that support the operation and improvement of our Website and Services.
The information collected through cookies may constitute personal data where it can identify, or be linked to, an identifiable individual. In such circumstances, the information will be processed in accordance with this Privacy Policy and applicable data protection laws.
26. Types of Cookies We Use
Delta uses different categories of cookies for different operational purposes. The cookies used on our Website may change from time to time as our Services evolve, and the categories described below are intended to provide a general explanation of the types of cookies that may be used.
26.1 Strictly Necessary Cookies
Strictly necessary cookies are essential for the operation, security and administration of our Website and cannot ordinarily be disabled through our cookie management tools. These cookies enable core Website functionality, including user authentication, secure login sessions, session management, payment security, fraud prevention and other features required for the proper operation of our Services. Without these cookies, certain parts of the Website may not function correctly or may become unavailable.
26.2 Functional Cookies
Functional cookies enable the Website to remember information that improves your browsing experience and provides enhanced functionality. These cookies may remember your preferred language, user settings, previously entered information and other preferences so that you are not required to re-enter the same information each time you visit our Website or access particular features.
26.3 Analytics and Performance Cookies
Analytics and performance cookies help us understand how visitors interact with our Website and digital platforms. These cookies may collect information relating to visitor numbers, pages viewed, navigation patterns, time spent on individual pages, Website performance, technical errors and other usage statistics.
The information generated by these cookies assists Delta in monitoring the performance of the Website, identifying technical or usability issues, improving accessibility and functionality, evaluating the effectiveness of our educational content and enhancing the overall user experience. Where reasonably practicable, analytics information is processed in an aggregated, anonymised or de-identified form so that it does not directly identify individual users.
26.4 Marketing and Advertising Cookies
Where applicable, marketing and advertising cookies may be used to better understand user interests, measure the effectiveness of advertising campaigns, provide communications that are more relevant to users and evaluate the performance of our marketing activities. These cookies may be placed by authorised third-party advertising, marketing or social media partners that provide services on our behalf or independently operate their own technologies.
Where required under applicable law, Delta will obtain your consent before placing or activating non-essential marketing, advertising or similar cookies on your device. You may manage or withdraw your cookie preferences at any time through our cookie management tools or by adjusting your browser settings, subject to the limitations described in our Cookie Policy.
27. Third-Party Cookies and Similar Technologies
Certain features of our Website and Services rely upon technologies provided by independent third-party service providers. As a result, these third parties may place cookies or use similar technologies when you interact with our Website or access particular Services. Depending on the functionality being used, such third parties may include payment service providers, learning management system providers, analytics providers, video conferencing platforms, email communication service providers, social media platforms and other technology partners that support the operation of our Services.
These technologies may be used to facilitate payment processing, deliver educational content, analyse Website usage, provide communication services, improve system performance, enhance security or support other legitimate operational functions. Where information collected through such technologies constitutes personal data, it will be processed in accordance with applicable data protection laws and, where appropriate, this Privacy Policy.
Each independent third-party service provider operates in accordance with its own privacy policy, cookie policy and terms of use. Delta does not own or control the cookies or similar technologies placed by such third parties, nor does it determine the purposes or means by which those third parties process personal data collected through their own technologies. We encourage users to review the privacy and cookie policies of any third-party services with which they interact through our Website or Services.
28. Managing Cookies
You may manage your cookie preferences at any time through your web browser settings or, where available, through the cookie preference management tools provided on our Website. Most modern web browsers allow users to delete existing cookies, block the storage of future cookies, receive notifications before cookies are placed on their devices, or restrict particular categories of cookies and tracking technologies.
Please note that restricting or disabling certain cookies, particularly those that are strictly necessary for the operation of the Website, may affect the availability, functionality or performance of our Services. Depending on the cookies disabled, you may experience limitations in accessing secure areas of the Website, signing into your account, registering for courses, completing payment transactions, using certain interactive features or receiving a personalised user experience.
Where your consent is required for the use of non-essential cookies under applicable law, you may withdraw or modify your consent at any time through the cookie preference settings made available on our Website. Any changes to your cookie preferences will apply prospectively and will not affect the lawfulness of processing carried out before your preferences were updated.
Additional information regarding our use of cookies, including the categories of cookies used and the options available for managing your preferences, may be provided in our Cookie Policy or through our cookie consent banner.
29. Cookie Consent
Where required under applicable law, Delta will obtain your consent before placing or activating non-essential cookies or similar technologies on your device. Our Website may display a cookie consent mechanism that enables you to accept all cookies, reject non-essential cookies or manage your cookie preferences according to the categories of cookies used.
Your cookie preferences may be recorded to ensure that your choices are respected during future visits to our Website, unless you subsequently modify your preferences, delete your browser cookies or otherwise reset your browser settings. You may review, update or withdraw your cookie preferences at any time through the cookie management tools provided on our Website, subject to the limitations described in this Privacy Policy and our Cookie Policy.
30. Disclosure of Personal Data
Delta recognises the confidential nature of personal data and does not sell, trade, rent, lease or otherwise commercially exploit personal data belonging to students, participants, Website users or other individuals whose personal data we process.
Personal data will be disclosed only where such disclosure is necessary for the provision of our Services, the operation of our business, compliance with applicable legal or regulatory obligations, the protection of our legitimate interests, the establishment, exercise or defence of legal claims, or any other lawful purpose permitted under applicable law.
In all cases, Delta seeks to ensure that any disclosure of personal data is limited to the minimum information reasonably necessary for the relevant purpose and is made subject to appropriate contractual, organisational or legal safeguards designed to protect the confidentiality and security of the information disclosed.
31. Categories of Third Parties with Whom We May Share Personal Data
Depending on the nature of your relationship with Delta, the Services you access and the purposes for which your personal data is processed, we may disclose personal data to the following categories of recipients.
31.1 Service Providers and Data Processors
Delta engages carefully selected third-party service providers and data processors to support the delivery, administration and security of our Services. These providers may perform functions including website hosting, cloud storage, learning management systems, customer relationship management (CRM), email delivery, communication services, customer support, cybersecurity, information technology support, document management, analytics and other operational services necessary for our business.
Such service providers process personal data only on Delta's documented instructions or as otherwise permitted by applicable law and are required by contract or other legally binding arrangements to implement appropriate technical and organisational measures to protect personal data, maintain confidentiality and process personal data only for authorised purposes.
31.2 Payment Service Providers
Where payment is required for our Services, relevant personal data may be shared with authorised payment gateway providers, banks, financial institutions, payment processors and fraud prevention service providers to facilitate payment processing, verify transactions, prevent fraudulent activity, administer refunds and comply with applicable financial, regulatory and legal requirements.
The information disclosed will be limited to that reasonably necessary for the relevant transaction and may include transaction details, payment confirmation information, billing information and limited personal identification information required to complete, verify or investigate a payment transaction. Except where required by applicable law or legitimate payment dispute procedures, Delta does not disclose complete payment card information.
31.3 Educational Technology Providers
To deliver online learning and related educational services, Delta may utilise educational technology providers, including learning management systems, virtual classroom platforms, webinar platforms, examination systems and student portals. These platforms may process personal data necessary for the administration and delivery of educational programmes, including student names, contact details, attendance information, participation records, course progress, assessment results and other information reasonably required to provide the relevant educational Services.
31.4 Instructors, Trainers and Academic Personnel
Where necessary for the effective delivery and administration of our educational programmes, personal data may be disclosed to instructors, trainers, mentors, academic coordinators, programme administrators and other authorised personnel involved in the provision of our Services. Access will be restricted to the information reasonably necessary for educational delivery, student support, assessment, certification and programme administration.
31.5 Certification Partners and Educational Institutions
Where a programme involves third-party certification, accreditation, examination, verification or academic partnership arrangements, Delta may disclose personal data reasonably necessary to facilitate the administration of the relevant programme. Such disclosures may include information required to verify eligibility, issue certificates, confirm attendance, administer examinations, validate academic records or otherwise support the certification or accreditation process. Delta will limit such disclosures to the minimum information reasonably necessary for the relevant purpose.
31.6 Employers and Corporate Clients
Where an employer, corporate client or other organisation sponsors, funds or arranges your participation in one or more of our educational programmes, Delta may disclose information relating to your registration, attendance, course participation, completion status, assessment outcomes or certification, to the extent reasonably necessary to administer the relevant programme or fulfil contractual obligations owed to the sponsoring organisation. Such disclosures will be made in accordance with applicable law, contractual arrangements and, where required, your consent or other appropriate lawful basis.
31.7 Professional Advisers
Delta may disclose personal data to external professional advisers where reasonably necessary to obtain legal, accounting, auditing, taxation, compliance, cybersecurity, insurance or other professional services relating to our business operations. Such disclosures will be limited to the information reasonably required for the relevant engagement and will be subject to appropriate duties of confidentiality and, where applicable, contractual data protection obligations.
31.8 Government Authorities and Regulators
Delta may disclose personal data to competent governmental authorities, courts, regulators, law enforcement agencies or other public authorities where such disclosure is required or permitted under applicable law. Such disclosures may be made for the purpose of complying with legal or regulatory obligations, responding to lawful requests or legal process, investigating suspected unlawful or fraudulent activities, protecting public safety, safeguarding the rights or legitimate interests of Delta or others, establishing, exercising or defending legal claims, or otherwise fulfilling obligations imposed by applicable law.
Where reasonably practicable and not prohibited by law, Delta will assess the scope of any request for personal data and disclose only the information reasonably necessary to satisfy the relevant legal or regulatory requirement.
32. Internal Access to Personal Data
Delta adopts the principle of least privilege and need-to-know access in the management of personal data. Access to personal data is restricted to authorised personnel whose roles and responsibilities reasonably require such access for the performance of their duties or for other legitimate business, contractual, operational or legal purposes.
Depending on the nature of the information and the purpose of the processing, authorised access may be granted to personnel responsible for student administration, academic operations, customer support, finance and accounting, information technology, legal affairs, compliance, management oversight or other functions that require access in connection with the provision and administration of our Services.
All employees, officers, contractors and other authorised representatives who are granted access to personal data are expected to handle such information responsibly, maintain its confidentiality and comply with applicable laws, internal policies and contractual confidentiality obligations. Delta implements reasonable administrative, technical and organisational measures to ensure that access to personal data is appropriately controlled, monitored and periodically reviewed.
33. Third-Party Service Provider Management
Where Delta engages third-party service providers to process personal data on its behalf, we take reasonable steps to assess whether such providers are capable of protecting personal data in accordance with applicable legal and contractual requirements. As part of this assessment, we may consider the provider's information security practices, confidentiality commitments, technical and organisational safeguards, regulatory compliance, data handling procedures, operational reliability and overall suitability for the services to be provided.
Where appropriate, Delta enters into contractual or other legally binding arrangements requiring third-party service providers to process personal data only for authorised purposes and in accordance with our documented instructions, maintain the confidentiality of personal data, implement appropriate technical and organisational security measures, restrict unauthorised access, assist Delta in meeting applicable legal obligations where required, and notify Delta without undue delay of actual or suspected security incidents affecting personal data, to the extent required under the applicable agreement or law.
Delta does not permit third-party service providers to use personal data for their own independent purposes except where they act as separate data controllers under applicable law or where such processing is otherwise authorised or required by law.
34. International Transfer of Personal Data
As part of operating a modern digital education business, Delta may transfer, store, access or otherwise process personal data outside the United Arab Emirates where this is reasonably necessary for the provision of our Services, the operation of our business or the use of trusted third-party service providers. Such transfers may occur where we utilise cloud hosting services, email and communication platforms, learning management systems, customer relationship management (CRM) platforms, analytics services, cybersecurity solutions, payment service providers or other technologies that support our operations.
Where personal data is transferred to another jurisdiction, Delta will take reasonable and appropriate steps to ensure that the transfer is carried out in accordance with the UAE Personal Data Protection Law and any other applicable data protection legislation. Where required, we will implement appropriate safeguards designed to ensure that personal data continues to receive an adequate level of protection, which may include contractual safeguards, assessments of the recipient's technical and organisational security measures, reliance on recognised legal transfer mechanisms, or any other measures permitted or required under applicable law.
Regardless of the location in which personal data is processed, Delta requires persons processing personal data on its behalf to maintain appropriate standards of confidentiality, security and data protection consistent with the requirements of applicable law and our contractual obligations.
35. Cloud-Based Services
Delta may utilise cloud-based technologies and software-as-a-service (SaaS) solutions to support the secure operation and administration of its business and educational Services. Such technologies may include cloud storage platforms, email hosting services, student information systems, learning management systems, business applications, collaboration platforms and other cloud-based services that facilitate the efficient delivery of our operations.
Where cloud service providers process personal data on Delta's behalf, they do so in accordance with applicable contractual arrangements and only to the extent necessary to provide the relevant services. Delta remains responsible, to the extent required under applicable law, for implementing appropriate technical, organisational and contractual safeguards designed to protect personal data processed through such services and for exercising reasonable oversight over the service providers engaged to support our operations.
36. Social Media Platforms
Delta may maintain official pages, profiles or accounts on third-party social media platforms for the purpose of communicating with students, prospective participants and the public. If you choose to interact with Delta through these platforms, including by posting comments, sending direct messages, reacting to content, following our accounts, sharing our content or submitting reviews, the relevant social media platform may collect, use and otherwise process your personal data in accordance with its own privacy policy, terms of service and applicable practices.
Information that you voluntarily publish on publicly accessible areas of social media platforms may be visible to other users and, depending on the platform, may become publicly available. Delta encourages users to exercise appropriate caution when sharing personal information through social media channels.
Delta does not own or control third-party social media platforms and is not responsible for their privacy practices, security measures or processing activities. We encourage you to review the applicable privacy policies of any social media platform through which you interact with us.
37. Student Communities and Group Communications
To facilitate the administration and delivery of our educational programmes, Delta may establish or participate in communication channels such as WhatsApp groups, Telegram groups, online discussion forums, learning management system discussion boards, student portals or other collaborative platforms.
Participation in such communication channels may make certain information visible to other participants, including your name, profile information, messages, comments and other information that you voluntarily choose to share. The visibility of such information will depend upon the functionality and privacy settings of the relevant platform.
Students are encouraged to exercise discretion when sharing personal information in group communications. Except to the extent required by applicable law, Delta is not responsible for personal information voluntarily disclosed by participants to other members of a group or community, nor for the subsequent use of such information by those participants.
38. Public Display of Information
Delta may publish or otherwise make certain information publicly available where such publication is necessary for legitimate educational or business purposes, where you have provided your consent, or where the information has been anonymised or de-identified so that it no longer identifies an individual.
Such publications may include student testimonials, course completion announcements, event photographs, educational achievements, success stories or similar promotional or informational content relating to our educational activities.
Where photographs, videos, testimonials or other identifiable personal information are used for promotional, marketing or public relations purposes, Delta will obtain your consent where required under applicable law and will process such information in accordance with this Privacy Policy.
39. Data Breach Notification and Cooperation
Delta maintains policies and procedures designed to identify, assess, contain and respond to actual or suspected personal data breaches. A personal data breach may include any accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or unauthorised access to, personal data processed by Delta.
Where Delta becomes aware of a personal data breach, we will take reasonable and proportionate steps to investigate the incident, contain its effects, mitigate potential risks, restore affected systems where appropriate, preserve relevant evidence and assess our legal and regulatory obligations, including any obligation to notify competent authorities or affected individuals.
Where required under applicable law, Delta will cooperate with competent governmental or regulatory authorities in connection with the investigation, management and resolution of personal data breaches.
40. Data Security
Delta is committed to protecting personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access, misuse or other forms of unlawful processing. We implement appropriate technical, organisational and administrative measures designed to safeguard personal data, taking into account the nature, sensitivity and volume of the information processed, the purposes of processing, the potential risks to individuals, available technologies, industry practices and the operational requirements of our business.
40.1 Technical Security Measures
Depending on the nature of the processing activities, Delta may implement appropriate technical safeguards including secure communication protocols, encryption technologies where appropriate, authentication mechanisms, password protection, multi-factor authentication where available, firewalls, endpoint protection, malware detection, security monitoring, system updates and security patches, secure backup procedures, vulnerability management and restrictions on privileged administrative access.
40.2 Organisational Security Measures
Delta also implements organisational measures designed to support the effective protection of personal data. These measures may include confidentiality obligations applicable to employees and contractors, role-based access controls, documented internal policies and procedures, employee awareness and training programmes, secure information handling practices, vendor due diligence processes, incident response procedures, business continuity measures and periodic reviews of our information security practices.
40.3 Employee and Contractor Confidentiality
Employees, trainers, consultants, contractors and other authorised persons who are granted access to personal data are expected to comply with applicable confidentiality obligations and internal data protection requirements. Personal data may be accessed only where necessary for authorised business purposes, and authorised personnel are expected to use such information solely for legitimate purposes, protect it against unauthorised disclosure or misuse and promptly report any actual or suspected security incidents in accordance with Delta's internal procedures.
41. Personal Data Breach Management
In addition to the general principles described above, Delta maintains operational procedures for managing actual or suspected personal data breaches. These procedures are intended to facilitate the prompt identification, assessment, documentation, containment and remediation of incidents involving personal data.
Where a suspected or confirmed personal data breach occurs, Delta may investigate the circumstances of the incident, identify the categories of personal data affected, assess the potential impact on affected individuals, implement corrective and preventive measures, enhance existing security controls, document the incident and maintain appropriate records of the response undertaken.
Where required under applicable law, Delta will notify the competent supervisory authority and affected individuals within the applicable statutory timeframes and in accordance with the notification requirements prescribed by law. Nothing in this section shall require Delta to provide notifications where an exemption or other lawful exception applies.
42. Data Retention
Delta retains personal data only for as long as is reasonably necessary to fulfil the purposes for which it was collected, to provide and administer our Services, comply with applicable legal, regulatory and contractual obligations, maintain appropriate business records, resolve disputes, establish, exercise or defend legal claims, protect our legitimate interests and satisfy applicable audit or compliance requirements.
The appropriate retention period will depend upon factors including the nature and sensitivity of the personal data, the purposes for which it was collected, applicable statutory limitation periods, contractual commitments, regulatory record retention requirements, operational needs, information security considerations and any actual or anticipated legal proceedings or investigations.
Once personal data is no longer required for the purposes for which it was collected and there is no legal or legitimate basis requiring its continued retention, Delta will take reasonable steps to securely delete, anonymise, de-identify or otherwise irreversibly dispose of the information in a manner appropriate to its nature and sensitivity and consistent with applicable legal and regulatory requirements.
43. Categories of Records and Retention Periods
Delta retains different categories of personal data for different periods depending on the nature of the information, the purposes for which it was collected, applicable legal or regulatory requirements, contractual obligations and legitimate business needs. The retention periods described below are intended to provide general guidance only and may be extended or shortened where required or permitted by applicable law, regulatory requirements, ongoing investigations, legal proceedings or other legitimate operational considerations.
43.1 Student Registration Records
Delta maintains records relating to student registration and participation for the purpose of administering educational programmes and maintaining accurate institutional records. Such records may include information relating to student identity, contact details, course enrolment, attendance and communications with Delta.
These records are generally retained for the duration of the student's relationship with Delta and for a reasonable period thereafter to facilitate academic verification, respond to student enquiries, provide customer support, resolve disputes, comply with legal obligations and maintain appropriate business records.
43.2 Course Completion and Certification Records
Delta may retain records relating to course completion, assessments and certification for extended periods where necessary to verify qualifications or maintain permanent educational records. Such records may include the student's name, programme or course title, completion date, certificate number, attendance records, assessment results and other information reasonably required to verify academic achievement.
Longer retention periods may be appropriate to enable certificate verification, respond to requests from former students or authorised third parties, maintain institutional records, satisfy audit requirements and comply with applicable legal or regulatory obligations.
43.3 Payment and Financial Records
Records relating to payments, accounting and financial administration are retained for the periods required under applicable accounting, taxation, financial reporting and other legal or regulatory requirements. Such records may include invoices, payment confirmations, transaction references, refund records, financial correspondence and other documentation reasonably necessary to demonstrate or administer financial transactions involving Delta.
43.4 Identity Verification Documents
Where Delta collects identity verification documents, including Emirates ID, passport, visa documentation or other government-issued identification, such information will be retained only for as long as is reasonably necessary to fulfil the purpose for which it was collected or to comply with applicable legal or regulatory requirements.
Once the relevant purpose has been fulfilled and there is no continuing legal basis requiring retention, Delta will take reasonable steps to securely delete, anonymise or otherwise irreversibly dispose of such information in accordance with its data retention and information security procedures.
43.5 Marketing and Communication Records
Delta may retain records relating to marketing preferences, communication consents, subscription status and opt-out requests for as long as reasonably necessary to demonstrate compliance with applicable legal requirements, maintain accurate suppression lists, respect individual communication preferences and administer our marketing activities in accordance with this Privacy Policy.
43.6 Legal and Dispute Records
Records relating to complaints, disputes, investigations, legal proceedings, regulatory matters and similar issues may be retained for as long as reasonably necessary to establish, exercise or defend legal claims, comply with legal or regulatory obligations, cooperate with competent authorities, preserve evidence or otherwise protect Delta's legal rights and legitimate interests.
44. Data Minimisation
Delta applies the principle of data minimisation throughout the lifecycle of personal data processing. We seek to collect, use and retain only such personal data as is adequate, relevant and reasonably necessary for the specific purposes identified in this Privacy Policy or otherwise permitted under applicable law.
Individuals are not required to provide personal data that is unrelated or disproportionate to the Services requested. Where the provision of particular information is optional rather than mandatory, Delta will identify this where reasonably practicable and will not require optional information as a condition for accessing Services unless there is a lawful basis for doing so.
45. Accuracy of Personal Data
Delta takes reasonable steps to ensure that the personal data we process is accurate, complete and, where necessary, kept up to date, having regard to the purposes for which the information is processed.
Individuals are encouraged to notify Delta promptly if their contact details or other personal information changes, if previously provided information becomes inaccurate or incomplete, or if corrections are required. Unless Delta has reasonable grounds to believe that information provided by an individual is inaccurate, incomplete or misleading, we may rely upon the accuracy of information supplied by that individual.
46. Student Records Management
As part of providing educational services, Delta maintains records relating to student registration, participation and academic administration. Depending on the programme undertaken, these records may include registration information, attendance records, course participation, assessment results, submitted assignments, academic feedback, certificates issued, communications with students and other information reasonably necessary for the effective administration of educational programmes.
These records are maintained for purposes including administering courses, monitoring student participation, verifying course completion, providing academic and administrative support, maintaining institutional records, responding to legitimate verification requests and complying with applicable legal, regulatory and accreditation requirements.
47. Examination and Assessment Records
Where educational programmes include examinations, assessments or other forms of evaluation, Delta may collect and retain information relating to examination registration, submitted responses, assessment outcomes, evaluator comments, grading records and completion status.
Such information is processed for purposes including assessing learning outcomes, administering examinations, issuing certificates or qualifications, maintaining academic records, improving the quality of educational programmes, responding to academic appeals or disputes and complying with applicable accreditation or regulatory requirements.
48. Learning Platform Records
Where students access Delta's online learning platforms or other digital educational technologies, Delta or its authorised service providers may process information relating to user authentication, login activity, course access, content viewed, learning progress, participation statistics, system usage and technical or security events associated with the operation of the platform.
This information is processed for purposes including delivering educational content, monitoring course participation, providing technical and academic support, improving learning outcomes, troubleshooting technical issues, maintaining platform security, protecting the integrity of our systems and supporting the ongoing development and enhancement of our educational Services.
49. Backup and Recovery Systems
To support business continuity, disaster recovery and cybersecurity resilience, Delta maintains secure backup and recovery systems as part of its information security programme. Personal data that has been deleted from active systems may continue to exist temporarily within secure backup media until the relevant backup retention cycle expires or the backup data is securely overwritten or otherwise disposed of in accordance with Delta's backup management procedures.
Backup copies are maintained solely for legitimate operational purposes, including disaster recovery, business continuity, system restoration and information security. Access to backup data is restricted to authorised personnel with a legitimate operational need and remains subject to the same confidentiality, technical and organisational security measures applicable to personal data stored in active systems.
50. Your Rights Regarding Personal Data
Delta respects the rights of individuals in relation to their personal data and is committed to facilitating the exercise of those rights in accordance with the UAE Personal Data Protection Law and other applicable legislation. The availability and scope of certain rights may depend upon the legal basis for processing, the nature of the personal data concerned and any applicable statutory exceptions or limitations.
50.1 Right to Information and Transparency
You have the right to receive clear and transparent information regarding how Delta collects, uses, stores, discloses and otherwise processes your personal data. This Privacy Policy is intended to assist you in understanding the categories of personal data we process, the purposes for which such data is processed, the categories of recipients with whom it may be shared, the applicable retention periods and the rights available to you under applicable law.
50.2 Right of Access
Subject to applicable legal requirements and appropriate identity verification, you may request confirmation as to whether Delta processes your personal data and, where applicable, obtain access to such personal data together with information regarding the categories of personal data processed, the purposes of processing, the sources from which the information was obtained, the categories of recipients to whom it has been disclosed and the applicable retention periods.
50.3 Right to Rectification
You may request that Delta correct, update or complete personal data that you believe is inaccurate, incomplete or no longer current. Where appropriate, Delta may request reasonable supporting information before making any amendments in order to ensure the accuracy and integrity of our records.
50.4 Right to Erasure
Where permitted under applicable law, you may request the deletion of your personal data where it is no longer necessary for the purposes for which it was collected, where processing is based solely on your consent and that consent has been withdrawn, or where deletion is otherwise required by law.
This right is not absolute. Delta may retain personal data where continued retention is necessary to comply with legal or regulatory obligations, maintain financial or accounting records, verify educational qualifications or certificates, establish, exercise or defend legal claims, investigate suspected misconduct or fraud, or otherwise protect our legitimate interests as permitted by applicable law.
50.5 Right to Withdraw Consent
Where personal data is processed on the basis of your consent, you may withdraw that consent at any time by contacting Delta using the details provided in this Privacy Policy or by using any available consent management mechanism.
Withdrawal of consent will not affect the lawfulness of processing carried out prior to its withdrawal, prevent processing based on another lawful basis or require Delta to delete records that we are legally required or otherwise entitled to retain. Depending on the circumstances, you may withdraw consent relating to promotional communications, marketing activities, optional surveys, testimonials, photographs or other optional processing activities.
50.6 Right to Object
Where applicable law provides such a right, you may object to certain processing activities, particularly where processing is carried out on the basis of Delta's legitimate interests or for direct marketing purposes. Upon receiving a valid objection, Delta will consider the circumstances of the request and determine whether the processing should cease or whether compelling lawful grounds exist to continue the processing.
50.7 Right to Restrict Processing
Where permitted by applicable law, you may request that Delta temporarily restrict the processing of your personal data in circumstances such as where the accuracy of the information is contested, the lawfulness of the processing is disputed, or the information is required for the establishment, exercise or defence of legal claims. During any period of restriction, Delta may continue to store the relevant information where permitted by law but will otherwise limit its processing to the extent required by applicable legislation.
50.8 Right to Data Portability
Where applicable and technically feasible, you may request that personal data processed by automated means and based upon your consent or a contract with Delta be provided to you, or to another controller where legally required, in a structured, commonly used and machine-readable format. The availability of this right is subject to the requirements and limitations prescribed by applicable law.
50.9 Rights Relating to Automated Decision-Making
Delta does not make decisions producing legal or similarly significant effects solely through automated processing. Where automated technologies are used to support operational or administrative activities, you may request additional information regarding such processing where required by applicable law.
51. How to Exercise Your Rights
Requests concerning your personal data or the exercise of your privacy rights may be submitted using the contact details provided in this Privacy Policy. Requests should include sufficient information to enable Delta to understand the nature of the request, verify the identity of the requester and locate the relevant personal data.
Privacy Contact Email: [info@deltainstitutions.com]
52. Identity Verification
To protect personal data against unauthorised access or disclosure, Delta may take reasonable steps to verify the identity of any person submitting a privacy request before taking action on that request. Depending on the nature of the request, verification may include confirmation of the registered email address, account information or other identification reasonably necessary to establish the requester's identity.
Delta will request only such verification information as is reasonably necessary for the relevant purpose and will not require excessive or unrelated information solely for identity verification.
53. Response to Requests
Delta will review and respond to valid privacy requests within the timeframes required by applicable law. Where additional time is reasonably required due to the complexity of the request, the volume of information involved or technical or operational considerations, Delta may extend the response period where permitted by law and will, where appropriate, notify the requester of the reasons for the extension.
Where Delta is unable to comply with a request, whether wholly or in part, we will provide an explanation to the extent required or permitted under applicable law.
54. Fees for Requests
Delta does not ordinarily charge individuals for exercising their privacy rights. However, where permitted by applicable law, we reserve the right to charge a reasonable administrative fee or decline to act upon requests that are manifestly unfounded, excessive, repetitive, abusive or otherwise inconsistent with applicable legal requirements.
55. Marketing Communications
Delta may send educational, informational and promotional communications relating to our courses, workshops, webinars, educational resources, events, industry developments and other services that may be of interest to you. Such communications may be delivered by email, SMS, WhatsApp, telephone or other electronic communication channels, subject to your communication preferences and applicable legal requirements.
56. Marketing Consent and Communication Preferences
Where required by applicable law, Delta will obtain your consent before sending direct marketing communications. You may withdraw your consent or update your communication preferences at any time by using the unsubscribe facility contained within our communications, following any available opt-out mechanism or contacting Delta directly using the contact details provided in this Privacy Policy.
Please note that opting out of marketing communications does not affect Delta's ability to send communications that are necessary for the administration of our Services, including course confirmations, payment receipts, account notifications, examination information, administrative updates, security notifications or other service-related communications.
57. WhatsApp and Other Messaging Platforms
Delta may communicate with students and prospective students through messaging platforms such as WhatsApp or other similar communication services for legitimate educational and operational purposes. Such communications may include course reminders, class schedules, registration assistance, student support, administrative updates, examination notifications and other information relating to the Services requested by you.
Where you provide your telephone number and consent to receive communications through such platforms, you acknowledge that these services are operated by independent third-party providers whose collection and processing of personal data are governed by their own privacy policies and terms of service. Delta is not responsible for the independent privacy practices of such providers.
58. Complaints Regarding Personal Data Processing
If you believe that Delta has processed your personal data in a manner that is inconsistent with this Privacy Policy or applicable data protection laws, you may submit a complaint using the contact details provided in this Privacy Policy. To assist us in investigating your concerns efficiently, your complaint should include sufficient information to identify you, describe the nature of your concern and provide any supporting information that may be relevant.
Delta will acknowledge and investigate complaints fairly, objectively and within a reasonable period, taking appropriate steps to address any substantiated concerns. Where required by applicable law, you may also have the right to submit a complaint to the competent supervisory authority responsible for data protection.
59. Regulatory Complaints
Without prejudice to any other rights or remedies available under applicable law, individuals may, where permitted, submit complaints relating to the processing of their personal data to the competent supervisory authority or other regulatory body responsible for overseeing personal data protection matters in the relevant jurisdiction.
Delta encourages individuals to contact us in the first instance so that we may investigate the matter, address any concerns and, where appropriate, resolve the issue promptly and amicably before regulatory intervention becomes necessary.
60. Privacy Governance
Delta is committed to maintaining an effective privacy governance framework designed to support compliance with applicable data protection laws and promote the responsible handling of personal data throughout our organisation. To support these objectives, Delta may designate appropriate personnel, departments or committees with responsibility for overseeing privacy-related matters, including the management of privacy enquiries, the implementation and periodic review of data protection practices, the coordination of responses to data subject requests, the monitoring of compliance initiatives and the continuous improvement of our privacy programme.
Privacy governance forms part of Delta's broader corporate governance and information security framework and may be reviewed periodically to reflect changes in legal requirements, business operations, technology or recognised industry practices.
61. Contact Details for Privacy Matters
If you have any questions, requests or concerns regarding this Privacy Policy or the manner in which Delta processes personal data, you may contact us using the details below:
Delta International Management Development Training
Privacy Department / Data Protection Contact
Email: [info@deltainstitutions.com]
Delta will make reasonable efforts to respond to legitimate privacy-related enquiries within an appropriate timeframe and in accordance with applicable legal requirements.
62. Children's Privacy
Delta's educational programmes and Services are intended primarily for individuals who are legally capable of entering into contractual arrangements and making independent decisions regarding educational services. Unless expressly stated otherwise for a particular programme, our Services are not directed towards individuals under the age of eighteen (18) years.
Delta does not knowingly collect personal data relating to children without obtaining the consent, authorisation or other lawful basis required under applicable law. If we become aware that personal data relating to a child has been collected without the required authorisation, we will take reasonable steps to investigate the circumstances, determine whether continued processing is lawful and, where appropriate, securely delete or otherwise cease processing the relevant information.
Parents or legal guardians who believe that a child has provided personal data to Delta without appropriate authorisation are encouraged to contact us using the details provided in this Privacy Policy.
63. Student Photographs, Videos and Recordings
During the delivery of educational programmes, workshops, seminars, conferences, webinars and other events, Delta may capture photographs, video recordings, audio recordings or other media for legitimate educational, administrative, documentation or promotional purposes.
Such recordings may include classroom activities, educational sessions, webinars, events, student testimonials or other aspects of our educational programmes. Where required by applicable law, Delta will obtain the appropriate consent before using identifiable photographs, recordings, testimonials or similar materials for marketing, promotional or other public-facing purposes.
Where an individual has previously provided consent for the use of identifiable media, that individual may request that such consent be withdrawn in relation to future uses. Any withdrawal of consent will apply prospectively and will remain subject to practical, contractual, archival and legal limitations, including circumstances where materials have already been lawfully published or incorporated into historical records.
64. Online Classes, Webinars and Virtual Learning Sessions
Where educational programmes are delivered through online learning platforms, virtual classrooms or webinar technologies, Delta and its authorised technology providers may process personal data reasonably necessary for the administration and delivery of those programmes. Depending on the platform used, such information may include participant names, email addresses, profile information, attendance records, chat messages, questions submitted during sessions, participation activity and other information generated through the use of the relevant platform.
Where online sessions are recorded, recordings may be retained for purposes including providing access to registered participants, supporting educational review, quality assurance, instructor training, dispute resolution, institutional record-keeping and other legitimate educational or operational purposes. Where recording is taking place, Delta will provide appropriate notice to participants in accordance with applicable law.
65. Third-Party Websites and External Links
Our Website or Services may contain links to websites, applications, platforms or other online services operated by independent third parties. Such links are provided for convenience only and may include payment service providers, educational technology platforms, social media platforms, partner organisations or other external resources.
Delta does not own or control third-party websites or services and is not responsible for their privacy practices, content, security measures or the manner in which they collect, use or otherwise process personal data. Access to and use of third-party websites are governed by the terms, conditions and privacy policies of the relevant third party. We encourage users to review those documents carefully before providing any personal data.
66. Student Reviews, Testimonials and Feedback
Delta welcomes feedback from students and participants as part of our commitment to continually improving the quality of our educational programmes and Services. Where you voluntarily submit reviews, testimonials, feedback, success stories or similar comments, Delta may process such information to evaluate and improve our Services, respond to enquiries, monitor service quality and, where appropriate, promote our educational programmes.
Where testimonials or other identifiable information are intended to be published or otherwise used for promotional purposes, Delta will obtain any consent required under applicable law before such use.
Participation in Delta's educational programmes does not guarantee any particular financial, professional, academic or personal outcome. Any testimonials, reviews or success stories published by Delta represent the individual experiences of those persons and should not be interpreted as guarantees or representations regarding the results that may be achieved by other participants.
67. Financial Markets Education Disclaimer
Delta provides educational and professional training services relating to financial markets and associated disciplines. All courses, educational materials, presentations, webinars, publications and communications are provided solely for educational and informational purposes.
Nothing provided by Delta constitutes investment advice, financial advice, trading advice, securities recommendations, portfolio management services, brokerage services, tax advice, legal advice or any other regulated financial service. References to financial markets, trading strategies, foreign exchange, securities, commodities, digital assets or similar subjects are intended exclusively for educational purposes and should not be interpreted as recommendations or invitations to buy, sell or otherwise deal in any financial instrument.
Participants remain solely responsible for conducting their own independent research and obtaining advice from appropriately qualified and licensed professional advisers before making any financial, investment or trading decisions.
Participation in any programme offered by Delta does not guarantee trading profits, investment returns, financial success, employment opportunities, professional advancement or any other particular outcome. Any historical examples, case studies, simulations, demonstrations or references to past performance are provided solely for educational purposes and should not be regarded as indicative of future results.
68. No Financial Suitability Assessment
Where Delta collects information relating to an individual's trading experience, investment knowledge, financial interests or learning objectives, such information is collected solely for educational, administrative and programme development purposes.
Delta does not use such information to determine whether an individual should invest, assess the suitability or appropriateness of any investment or financial product, recommend investment strategies or provide any regulated financial advisory, brokerage or portfolio management services. The collection of such information does not create a client-adviser relationship or any fiduciary relationship between Delta and the participant.
69. Intellectual Property and Educational Materials
Delta may process personal data where reasonably necessary to administer, deliver, protect and enforce its rights in relation to educational materials, learning platforms and other intellectual property owned or licensed by Delta.
Educational materials are provided exclusively for the personal educational use of authorised participants unless otherwise expressly agreed in writing. Delta may process information relating to user authentication, account activity, access logs, downloads, system usage and other relevant information for purposes including protecting intellectual property rights, preventing unauthorised access or distribution, enforcing contractual terms and maintaining the security and integrity of our educational platforms.
70. Fraud, Misuse and Security Monitoring
To protect students, instructors, employees, educational materials and business systems, Delta may monitor the use of its Website, learning platforms and other Services for legitimate security, fraud prevention and operational purposes.
Such monitoring may include reviewing unusual account activity, suspicious registrations, unauthorised access attempts, misuse of educational platforms, suspected intellectual property infringements, fraudulent payment activity or other conduct that may threaten the security, integrity or lawful operation of our Services.
Monitoring activities are conducted only to the extent reasonably necessary to protect Delta's legitimate interests, maintain a secure learning environment, comply with applicable legal obligations and safeguard the rights and interests of our students, employees and business partners.
71. Changes to this Privacy Policy
Delta may amend, revise or otherwise update this Privacy Policy from time to time to reflect changes in applicable legislation, regulatory guidance, judicial decisions, business operations, technology, security practices, industry standards or the Services that we provide.
Any revised version of this Privacy Policy will be published on our Website together with the updated effective date. Unless otherwise stated, amendments will become effective from the date on which they are published. Where required by applicable law, Delta will provide additional notice or obtain consent before implementing changes that materially affect the processing of personal data.
We encourage users to review this Privacy Policy periodically to remain informed of our current privacy practices.
72. Governing Law and Jurisdiction
This Privacy Policy shall be governed by and construed in accordance with the laws of the United Arab Emirates.
Subject to any mandatory rights or remedies available under applicable law, any dispute, claim or proceeding arising out of or relating to this Privacy Policy, the processing of personal data by Delta, the use of our Website or the provision of our Services shall be subject to the jurisdiction of the competent courts of the United Arab Emirates, unless otherwise required by applicable law or agreed in writing between the parties.
73. Language
This Privacy Policy may be made available in multiple languages for convenience.
In the event of any inconsistency or conflict between translated versions, the English version shall prevail unless otherwise required by applicable law.
74. Severability
If any provision of this Privacy Policy is determined to be invalid, unlawful or unenforceable, such provision shall be interpreted or modified to the minimum extent necessary to make it enforceable.
The remaining provisions shall continue to remain valid and enforceable.
75. Entire Privacy Statement
This Privacy Policy, together with any additional notices or policies referenced herein, represents the complete statement regarding Delta's handling of personal data.
It replaces any previous privacy statements relating to the Website or Services unless otherwise stated.
76. Contact Information
For questions, requests, concerns or complaints relating to this Privacy Policy or the processing of personal data, please contact:
Email: info@deltainstitutions.com
Contact
For questions, requests or concerns regarding this Privacy and Cookie Policy, please contact us at info@deltainstitutions.com.