Last Updated: October 2025
Operated by: ITLS FZ-LLC (“Fast Lane / ITLS”)
Dubai Internet City, Dubai, United Arab Emirates
[email protected]
1. Introduction
IT Learning Solutions (ITLS) FZ-LLC (“Fast Lane / ITLS”) operates this Portal as an independent data controller as part of the Microsoft GCPS Exam Voucher Distribution Program (“Program”). Fast Lane / ITLS determines the purposes and means of processing personal data necessary for the operation of the Program and ensures that all processing is carried out in compliance with applicable data-protection laws. This Privacy Policy explains how Fast Lane UAE, as an independent controller, collects, uses, and protects personal data in connection with the Program. All processing is conducted in accordance with the EU General Data Protection Regulation (GDPR), the UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (PDPL), and other applicable privacy regulations.
2. Data Origin and Scope
Program data originates from authorized Microsoft distributors who nominate reseller organizations (CSP partners) for participation.
Fast Lane / ITLS collects only the minimum necessary information to manage invitation, confirmation, and voucher-distribution workflows.
3. Data Collected
Fast Lane / ITLS may collect and process the following types of data:
- Company Name: to identify invited organizations and prevent duplicate invitations (Art. 6(1)(f) GDPR – legitimate interest)
- Contact Email: to send program invitations and manage opt-in consent (Art. 6(1)(f), Art. 7(1) GDPR – proof of consent)
- Contact Name (if provided): for identification and correspondence purposes (Art. 6(1)(f) GDPR – legitimate interest)
- MPN ID: to verify Microsoft Partner Network status (Art. 6(1)(f) GDPR – legitimate interest)
- Email Domains: to verify employee eligibility for voucher claims (Art. 6(1)(f) GDPR – legitimate interest)
- Invitation Token: to facilitate secure double opt-in (Art. 6(1)(c) GDPR – legal obligation)
- IP Address and User Agent (upon acceptance): for consent verification and compliance logging (Art. 7(1) GDPR – proof of consent)
- Voucher Allocation Data: to manage the number of vouchers available per reseller (Art. 6(1)(b)/(f) GDPR – contractual or legitimate interest)
No exam results, scores, or performance data are collected.
4. Purpose of Processing
Personal data is processed solely to:
- Manage invitation and confirmation flows (double opt-in)
- Allocate and track exam vouchers
- Provide program-related communication
- Maintain an audit trail for compliance and reporting
Data is collected and processed on behalf of Microsoft to enable proper operation and monitoring of the Program.
5. Invitation Process
a) When a Distributor Adds a Reseller
- The reseller receives an invitation email with two options: Accept Invitation or Decline Invitation.
- Until the reseller confirms participation, the data remains pending and is not used for any other purpose.
b) If You Click “Accept Invitation”
- Consent is securely recorded and timestamped.
- The reseller becomes an active participant in the Program.
- The distributor who issued the invitation can view company details and voucher allocation.
- A confirmation email is sent containing next steps and a link to the voucher portal.
- Data is used exclusively for program administration – no marketing emails are sent.
c) If You Click “Decline Invitation”
- The decline is recorded for compliance.
- Personal data (contact name, email, MPN ID, and email domains) is anonymized immediately.
- Only the company name (or a hashed reference) remains to prevent duplicate invitations.
- No further communication will be sent.
d) If You Do Not Respond Within 30 Days
- Data remains pending and is not shared with the distributor.
- After 30 days, personal data fields are automatically anonymized.
- Only an anonymized company reference is retained to prevent future re-invitations.
6. Data Retention and Storage
- Pending invitations are retained for 30 days before automatic anonymization.
- Accepted reseller data is retained for the duration of the Program and up to 12 months afterward for audit purposes.
- All data is stored securely on Fast Lane-managed servers and Azure cloud servers located within the European Union (Germany) and the United Arab Emirates.
7. Access and Disclosure
Access to personal data is restricted to:
- Authorized Fast Lane / ITLS employees operating the Program
- The inviting distributor (for accepted resellers only)
- Microsoft, for audit and compliance purposes
Data is never sold or used for marketing.
8. International Transfers
Where data is transferred outside the UAE or EU, appropriate safeguards such as Standard Contractual Clauses or adequacy decisions are applied to ensure continued protection of personal data.
9. Security
Fast Lane / ITLS implements technical and organizational measures to protect personal data from unauthorized access, loss, or misuse. These include encryption, access control, secure hosting, and regular system audits.
10. Your Rights under GDPR and PDPL
You have the right to:
- Access your data (Art. 15 GDPR / Art. 13 PDPL)
- Rectify inaccurate data (Art. 16 GDPR / Art. 14 PDPL)
- Request deletion of your data (“Right to be Forgotten”)
- Restrict or object to processing (Art. 18 GDPR / Art. 15 PDPL)
- Request data portability (Art. 20 GDPR)
To exercise these rights, contact: [email protected]
11. Automated Decision-Making
No automated decision-making or profiling is used in connection with this Program.
12. Data Protection Contact
ITLS FZ-LLC (“Fast Lane / ITLS”)
Data Protection Officer: Peter Gumrich
Dubai Internet City, Dubai, United Arab Emirates
[email protected]
13. Updates to this Policy
This Privacy Policy may be updated as the Program evolves or as required by law.
The most recent version will always be available on this page and indicated by the “Last Updated” date above.