Privacy Policy
Last Updated: February 1, 2026
1. Introduction
Gentium Incentives (“we,” “us,” or “our”) is a division of Gentium International. We provide incentive risk management and reward fulfillment services globally. We are committed to protecting the privacy and security of your personal data in accordance with Bahrain Law No. 30 of 2018 (the Personal Data Protection Law or "PDPL").
2. Data Controller Information
For the purpose of the PDPL, the Data Controller is:
Entity Name: Gentium Advisers WLL
Local Office (Bahrain): 4253, Building 2004, Road 1527, Block 115, Hidd, Kingdom of Bahrain
Phone: +973 3743 8211
3. The Data We Collect
As an incentive risk management service, we collect personal data to verify eligibility and fulfill rewards. This includes:
Identity Data: Full name, nationality, and government ID (CPR/Passport) where legally required for high-value disbursements.
Contact Data: Email address, telephone number, and physical mailing address.
Financial Data: Bank account details or digital wallet addresses for incentive payment.
Verification Data: Proof of purchase or participation data provided by the brand partner.
4. Legal Basis for Processing
In accordance with Article 4 of the PDPL, we process your data under the following grounds:
Contractual Necessity: To fulfill the reward promised to you by our clients.
Legal Obligation: To comply with Bahraini tax laws and Anti-Money Laundering (AML) regulations.
Legitimate Interest: To detect and prevent fraud, and to manage the financial risks (over-redemption) of promotional campaigns.
5. Data Subject Rights
Under the PDPL, you have the following rights regarding your personal data:
Right to Access: You may request a copy of the personal data we hold about you.
Right to Object: You may object to your data being used for direct marketing or where processing causes you unwarranted damage.
Right to Rectification/Erasure: You can request that we correct inaccurate data or delete data that is no longer necessary.
Right to Withdraw Consent: Where we rely on your consent, you may withdraw it at any time.
6. International Data Transfers
To fulfill global incentives, your data may be processed in jurisdictions outside of Bahrain (such as the UK or EU). We ensure these transfers comply with Articles 12 and 13 of the PDPL by using Standard Contractual Clauses (SCCs) or ensuring the recipient country provides an adequate level of data protection.
7. Data Security
We implement strict technical and organizational measures to prevent unauthorized access, loss, or destruction of your data. This includes end-to-end encryption for financial transmissions and multi-factor authentication for data access.
8. Data Retention
We retain personal data only for as long as necessary to fulfill the incentive program's purpose and to satisfy legal, accounting, or reporting requirements (typically 10 years as per Bahraini Commercial Law).
9. Contacting the Authority
If you have concerns about how we handle your data, you have the right to lodge a complaint with the Bahrain Personal Data Protection Authority (PDPA) via the Ministry of Justice.