Data Policy
How we collect, use and protect personal data through this website.
Defy Consortium ("Defy", "we", "us") is a private initiative of XCUBE.CO W.L.L. ("xcube.co"), a company incorporated in the Kingdom of Bahrain under commercial registration no. 181289-1, with its registered office at 3rd floor, Arcapita Building, Bahrain Bay, BH 346, Bahrain. Defy designs inclusive finance ecosystems with governments, regulators and industry. xcube.co is responsible for the personal data collected through defyconsortium.org.
This Data Policy explains what personal data we collect through this website, why we collect it, and the choices you have. We handle personal data in line with the Kingdom of Bahrain's Law No. (30) of 2018 with Respect to Personal Data Protection.
This policy applies to this website and the forms on it.
01What we collect
We only collect what you give us through the forms on this website. Depending on the form, this includes:
- your name and professional email address, when you subscribe to our briefing;
- the details you enter when you ask to join the consortium, such as your name, organisation, role, professional email address and LinkedIn profile, and how you would like to contribute;
- the details you enter when you propose a national pilot, such as your name, institution, its website and country, your role, professional email address and LinkedIn profile, and your national priorities;
- the details you enter when you contribute to our research or propose a topic, such as your name, organisation, role, professional email address and LinkedIn profile, and your contribution or topic;
- your consent to this Data Policy, with the date and time you gave it.
If you email us directly, we receive the details in your email.
Our hosting provider also processes standard technical data, such as your IP address and browser type, to deliver and secure the website. We do not use this data to identify you.
02Why we collect it
To send you our monthly briefing, if you subscribed to it.
To reply to you about membership of the consortium, a national pilot or a collaboration on our research.
To understand which organisations and roles are interested in Defy. Your LinkedIn profile helps us confirm your professional context.
To keep a record of your consent, and to comply with the law.
We will not sell your personal data, and we will not share it with third parties for their own marketing.
03Consent
We collect and use your personal data on the basis of the consent you give by ticking the box on our forms. The box is never pre-ticked, and you cannot submit a form without it. Your consent covers only the purposes described in this policy.
Withdrawing your consent. You can withdraw your consent at any time by emailing our Data Protection Officer, Julia Chin, at julia@jfourthsolutions.com, or by using the unsubscribe link in any briefing we send you. Once your withdrawal is processed, we will stop using your data for the purposes you consented to.
Withdrawing consent does not affect processing that took place before it, or processing the law permits or requires without consent.
04Service providers
We use trusted service providers to host the website, receive the forms, host our email and send the briefing. They process data on our behalf, only for the purposes in this policy and under written contracts. We remain responsible for your personal data.
| Provider | Purpose |
|---|---|
| Web3Forms | Receives the forms and forwards them to our inbox |
| Infomaniak | Email hosting, where your submission is stored, and the monthly briefing, where your subscription is stored (Switzerland) |
| Vercel | Website hosting and delivery |
05Transfers outside Bahrain
Some of our service providers are located outside the Kingdom of Bahrain. We transfer your data only to countries that the Personal Data Protection Authority recognises as offering sufficient protection, or with your consent, which you give when you submit a form.
06How long we keep it
We keep briefing subscriptions until you unsubscribe or withdraw consent.
We keep requests to join, to propose a national pilot or to contribute to our research for as long as we need them to follow up on your interest.
Where we go on to work together, we keep your data for as long as needed for legal, tax, accounting and contractual purposes.
We keep consent records for as long as we hold the related data.
We do not keep personal data in a form that identifies you for longer than the purpose requires. If you withdraw consent or ask us to delete your data, we will do so unless the law requires us to keep it.
07Your rights
You can ask us to:
- confirm whether we hold personal data about you, and tell you what it is, where it came from, why we use it and who receives it;
- correct, block or erase personal data that is inaccurate, incomplete or no longer needed;
- stop sending you our briefing or any other direct communication;
- review a decision about you that was made only by automated means. We make no such decisions.
Email our Data Protection Officer, Julia Chin, at julia@jfourthsolutions.com. We may ask you to confirm your identity. Requests are free of charge. We answer requests for access within 15 working days, and requests to correct, erase or stop direct communication within 10 working days.
Accuracy. We rely on the information you give us. If your details change, please let us know so that they stay current, complete and accurate.
If you are not satisfied with how we have handled your personal data, please contact us first. You may also lodge a written complaint with the Personal Data Protection Authority of the Kingdom of Bahrain at pdp.gov.bh.
08Security
This website is served only over encrypted HTTPS connections. Access to form submissions is limited to the people who need it, protected by sign-in controls, and bound by confidentiality. No method of transmission or storage over the internet is completely secure, so we cannot guarantee absolute security, but we review our measures regularly.
If a breach affects your personal data, we will notify the Personal Data Protection Authority as Bahraini law requires, and we will inform you where it affects your rights.
09Cookies and trackers
This website does not use analytics or advertising cookies or trackers. We do not build profiles of visitors.
10Minors
Defy is intended for professionals and institutions. We do not knowingly collect personal data from minors. If we learn that we have, we will delete it.
11Changes to this policy
We may update this Data Policy from time to time, for example in response to changes in the law or in how we run the site. The "Last updated" date at the top shows when it last changed. If we ever want to use your data for a new purpose, we will ask for your consent first.
12Contact us
For any question about this policy or your personal data, email our Data Protection Officer, Julia Chin, at julia@jfourthsolutions.com. For general enquiries, email info@defyconsortium.org.