Website privacy policy and privacy notice

Introduction This is Dubai Global Connect DWC-LLC (DGC) privacy policy and related privacy notice. DGC respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we deal with your personal data when you visit our website (regardless of where you visit it from).

By accessing DGC’s website you:

(i) agree to be bound by the following terms and conditions, including any modifications made to them from time to time, and each time you receive any information as a result of such access; and

(ii) confirm that your agreement provided above is (i) freely given and confirmed by your continued access to the DGC website and/or by you providing your personal and sensitive data to DGC in the ways envisaged by this privacy notice.

1. Purpose of this privacy notice This privacy notice aims to give you information on how DGC may collect and process your personal data through your use of this website, including any data you may provide through this website. This privacy notice supplements our terms of use and any other notices and is not intended to override them.
   
   Controller and Processor DGC may be the controller and processor and responsible for your personal data (collectively referred to as “DGC”, “we”, “us” or “our” in this privacy notice). We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about or requests relating to this privacy notice, please contact the data privacy manager using the details set out below.
   
   Contact details Our full details are: Dubai Global Connect DWC-LLLC
   Email address: [email protected]
   For the attention of: Data Privacy Manager
   Postal address: 6th Floor, Gate Village 7, DIFC, Dubai
   You have the ability to contact certain supervisory authorities who deal with data protection issues.
   
   Changes to the privacy notice and your duty to inform us of changes Data protection laws are constantly evolving, the General Data Protection Regulations of the European Union came into force on 25 May 2018, and the Dubai International Financial Centre’s Data Protection Law No. 5 of 2020 came into force on 1 July 2020. It is important that the personal data we hold about you, if any, is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
2. Third-party links This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements.
   
   The data which may be collected
   
   Personal data, or personal information, generally means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows: Identity Data, Contact Data, Financial Data, Transaction Data, Technical Data, Profile Data, Usage Data, Marketing and Communications Data, and Aggregated Data. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice. We do not seek to collect any Special Categories of Personal Data about you nor do we collect any information about criminal convictions and offences.
   
   If you fail to provide personal data Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, in relation to the provision of goods or services). In this case, we may have to cancel a product or service.
3. How is your personal data collected? We may use different methods to collect data from and about you including through:
   
   
   • Direct interactions. You may give us your personal data (including sensitive personal data) by filling in forms, by corresponding with us by post, phone, email, or by visiting our offices or otherwise.
   • Automated technologies or interactions. As you interact with (i) our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns; and/or (ii) our offices, we may automatically collect personal (including sensitive personal data) about you. We collect this personal data by using cookies, server logs and other similar technologies, including those introduced in connection with limiting the spread of COVID-19.
   • Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources.
4. How we use your personal data We will only use your personal data when the law that is applicable to us allows us to. Most commonly, we will use your personal data in the following circumstances:
   
   
   • Where we need to perform the contract we are about to enter into or have entered into with you.
   • Where it is necessary for our legitimate interests (or those of a third party) (including measures introduced in connection with limiting the spread of COVID-19) and your interests and fundamental rights do not override those interests.
   • Where we need to comply with legal or regulatory obligations.
   Purposes for which we will use your personal data We have set out below a description of the ways we may use your personal data, which of the legal bases we rely on to do so, and have also identified what our legitimate interests are where appropriate. The below is not intended to be, and is not, exhaustive and we do rely on the consent you have provided as a basis for the collection and processing of your personal and sensitive data.
   
   

   Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
   To register you as a new customer	(a) Identity(b) Contact	(a) Performance of a contract with you(b) Consent
   To process and deliver your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) (c) Consent
   To manage our relationship with you which will include:(a) Notifying you about changes to our terms or privacy policy(b) Asking you to leave a review or take a survey	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)(d) Consent
   To enable you to partake in a prize draw, competition or complete a survey	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)(c) Consent
   To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity(b) Contact(c) Technical	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)(b) Necessary to comply with a legal obligation(c) Consent
   To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical	(a) Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)(b) Consent
   To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	(a) Technical (b) Usage	(a) Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)(b) Consent
   To make suggestions and recommendations to you about goods or services that may be of interest to you	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile	(a) Necessary for our legitimate interests (to develop our products/services and grow our business)(b) Consent
   To comply with laws, regulations and safety measures related to the COVID-19 pandemic	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile	(a) Necessary to comply with a legal obligation(b) Necessary for our legitimate interests (limiting the spread of COVID-19)(c) Consent

   Contact by us We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). You may receive marketing communications from us if you have requested information from us or purchased from us or if you provided us with your details and, in each case, you have not opted out of receiving that marketing. We will get your express opt-in consent before we share your personal data with any company outside the DGC group of companies for marketing purposes.
   
   Opting out and Cookies You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see https://www.DGC.gov.ae/cookie-policy.
   
   Change of purpose We will only use your personal data and/or sensitive personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may collect and process your personal data and/or sensitive personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. Disclosure of your personal data We may have to share your personal data and/or sensitive personal data with Internal Third Parties, External Third Parties or third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets or where we seek to acquire other businesses or merge with them (if a change happens to our business, then the new owners may use your personal data and/or sensitive personal data in the same way as set out in this privacy notice). We seek to ensure that all relevant third parties respect the security of your personal data and/or sensitive personal data and treat it in accordance with the law.
6. Data security We seek to ensure that appropriate security measures are in place to prevent any of your personal data and/or sensitive personal data that we may hold from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We have put in place procedures to deal with any personal data breach and will seek to notify you and any applicable regulator of a breach where we are legally required to do so.
7. Data retention By law we have to keep basic information for certain periods of time. In some circumstances you can ask us to delete your data: see below for further information. In some circumstances we may anonymise your personal data and/or sensitive personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
8. Your legal rights Under certain circumstances, you may have rights under data protection laws that apply to us in relation to your personal data. You may find certain information about your rights on the internet. You may, in certain circumstances and subject to certain conditions, have the right to: Request access to your personal data (commonly known as a “data subject access request”). Request correction of the personal data that we hold about you. Request erasure of your personal data. We may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. Request restriction of processing of your personal data. Request the transfer of your personal data to you or to a third party. Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you wish to exercise any of the rights, please contact us in writing detailing your specific concern and legal right you are seeking to exercise. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. We try to respond to all legitimate requests within three months. Occasionally it may take us longer than this if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.