Privacy Policy1. Personal Data Controller1.1 The personal data controller is
TIME OF HEROES FZCO, License Number 63 815, located at: Building A1, Dubai Digital Park, Dubai Silicon Oasis, Dubai, United Arab Emirates. Contact:
ceo@thetimeofheroes.com.
The controller declares that all personal data processed is strictly confidential and handled in accordance with national UAE legislation and applicable international regulations on personal data protection. This includes, where applicable, the UAE Federal Decree-Law No. 45 of 2021 regarding the Protection of Personal Data (PDPL) and, for data subjects in the EEA, the EU General Data Protection Regulation (GDPR).
1.2 The controller collects, stores, and uses your personal data in compliance with applicable laws and regulations, including GDPR where relevant. The purposes for which personal data is processed are defined below. Where required by law, we may also be subject to specific data protection regimes of free zones (such as DIFC or ADGM).
1.3 The controller may collect personal data via the website
thetimeofheroes.com ("Website"), as well as via mobile applications, affiliated platforms, and official social media pages linking to this Privacy Policy.
1.4 This policy informs you about what personal data is processed, the purpose, retention periods, who may access it, and your rights as a data subject. This policy applies to all personal data collected by the controller in connection with contractual obligations, legal requirements, legitimate interests, or explicit consent. Where this Policy conflicts with mandatory law, such mandatory provisions prevail.
1.5 If you are located in the EU/EEA and we are required to appoint a representative under Article 27 GDPR, we may do so. You may contact either us or our EU representative if applicable.
1.6 Where required by applicable law, the Company may appoint a Data Protection Officer (DPO). If appointed, their contact details will be published on our Website.
2. Processed Data2.1 We may process the following categories of personal data:
(a) Performance of contract and provision of services- Data: name, surname, username, contact details, payment details (masked card data, wallet address, transaction identifiers), VAT/ID where required, account settings, communication history.
- Legal basis: performance of contract or pre-contractual steps.
- Retention: duration of contract + 3−10 years (depending on jurisdiction).
- Recipients: hosting providers, payment providers, support tools, professional advisers, affiliates where necessary.
(b) Accounting, tax, and legal compliance- Data: identification and transaction data necessary for invoicing, accounting, AML, sanctions screening.
- Legal basis: legal obligations.
- Retention: 5−10 years, depending on law.
- Recipients: tax authorities, auditors, financial institutions, public authorities.
© Marketing and promotions- Data: name, email, phone, social media identifiers (if provided), interaction preferences.
- Legal basis: consent or legitimate interest (where permitted).
- Retention: until withdrawal of consent + reasonable documentation period.
- Recipients: CRM tools, email services, marketing agencies.
(d) Analytics, statistics, and service improvement- Data: cookies, IP address, device identifiers, usage logs, aggregated behavioural statistics.
- Legal basis: legitimate interest; in EEA — consent for non-essential cookies.
- Retention: up to 24 months (or anonymised longer).
- Recipients: analytics and performance monitoring providers.
(e) Advertising and personalization- Data: cookies, tracking identifiers, behavioural and device data, approximate location.
- Legal basis: consent where required; legitimate interest where permitted.
- Retention: according to cookie lifespan and purpose.
- Recipients: ad networks, retargeting and anti-fraud providers.
(f) IT security, fraud prevention, enforcement- Data: technical logs, IP address, device fingerprints, login data, security incident evidence.
- Legal basis: legitimate interest in protecting systems and legal rights.
- Retention: as needed for investigations, compliance, or legal claims.
- Recipients: security vendors, legal advisers, law enforcement.
2.2 Definitions of processing purposes:
Performance of contract — using services/registration.
Marketing — newsletters and communications.
Compliance — tax, AML, and legal obligations.
Statistics — service improvement.
Ads display — tailored advertising.
Legitimate interest — fraud prevention, administration, IT security.
Legal obligation — required disclosures.
2.3 Data is retained only as required by law or purpose duration, then securely deleted or irreversibly anonymised.
2.4 Data may be processed manually or automatically with minimal personal data use and anonymisation where possible.
2.5 Recipients include:
IT and hosting providers, payment institutions, communication tools, analytics/advertising vendors, professional advisers, affiliates, and authorities when required.
2.6 Sources of data:
Directly from you, from social media where interacted with us, business partners, payment/KYC providers, and public sources where allowed.
3. Data Processed by Consent3.1 Consent applies to marketing. Consent must be explicit and may be withdrawn anytime via unsubscribe link, account settings (if available), or email.
3.2 Withdrawal is valid going forward and does not affect prior lawful processing. We may retain limited data to document your opt-out or meet legal obligations.
4. Your Rights4.1 You may exercise:
— Access (GDPR Art.15)
— Rectification/Erasure
— Restriction
— Explanation
— Complaint
— Portability (GDPR Art.20)
— Objection
— Withdrawal of consent
4.2 EEA: you may complain to local supervisory authorities.
4.3 We may verify identity before fulfilling requests. We aim to respond within legal time limits.
4.4 In some cases, your request may be restricted (e.g., rights of others, legal obligations). We will explain where possible.
5. Cross-Border Data Transfers5.1 Data may be transferred outside your jurisdiction due to our UAE location and global infrastructure.
5.2 For transfers from EEA to non-adequate countries, we implement safeguards:
— Standard Contractual Clauses
— Approved protections
— Statutory derogations where necessary
5.3 For UAE transfers, we comply with PDPL requirements and UAE Data Office guidance.
5.4 You may request information about applied safeguards (with redactions).
6. Cookies and Similar Technologies6.1 We use cookies for core functionality, preferences, analytics, and advertising.
6.2 Essential cookies: legitimate interest.
Non-essential cookies: consent where required.
6.3 Details are in our Cookie Policy; you may update preferences anytime.
7. Automated Decision-Making and Profiling7.1 Profiling may be used for personalization and fraud detection.
7.2 We do
not currently use solely automated decision-making producing legal or similarly significant effects. If this changes, we will update this Policy and provide rights information.
8. Data Security8.1 Measures include encryption, access controls, secure development, regular testing, and monitoring.
8.2 Access limited to authorised personnel bound by confidentiality.
8.3 If a high-risk personal data breach occurs, we will notify you and authorities where required.
9. Changes to This Policy9.1 The Policy may be updated periodically. "Last updated" date will be changed accordingly.
9.2 For significant changes, additional notice will be provided.
9.3 Continued use of services constitutes acknowledgment of changes.
10. Contact and Further InformationFor inquiries and rights requests:📧
ceo@thetimeofheroes.com📍 Building A1, Dubai Digital Park, Dubai Silicon Oasis, Dubai, UAE
🌐 thetimeofheroes.com