Effective Date: February 2020
The Dubai International Financial Centre and/or its affiliates and entities (collectively “DIFC”, “we” or “us”) values your security and privacy. DIFC has its own data protection law, Data Protection Law DIFC Law No. 1 of 2007, and its successor tentatively effective from July 1, 2020, Data Protection Law, DIFC Law No. 5 of 2020 (the “DP Law”), and may for certain types of personal data processing, be subject to laws from other jurisdictions.
1. Scope and Application
This Policy applies to persons anywhere in the world who access or use DIFC’s Website Services or the App (“Users”).
2. Collection of Information
This is information you give us about you by providing information or filling in forms on the App or any DIFC-owned Website Services, or by corresponding with us (for example, by telephone, e-mail or any other digital or electronic form). It includes for example information you provide when you register using the DIFC-provided online client portal, or download and register to use the App, search for the App in app stores (including but not limited to Apple App Store and Google Play Store), share data via the App's social media functions, and when you report a problem with the App, or any of our Website Services. If you contact us, DIFCA will keep at least an electronic record of such correspondence, including personal information shared at that time. The personal information you give us may include your name, address, e-mail address and phone number, certain device information, username, password, residential building, work address, photograph and other registration information you choose to provide (“Personal Information” or “Personal Data”).
The Website Services or App collect and process Personal Data for specific, lawful purposes only, or for the performance of tasks carried out in the interests of the DIFC.
The Website Services or App are not targeted, intended or expected to be of use to children. Apart from providing information for specific services or purposes, as directed by DIFC processes, User-provided contributions of content or contact information regarding or about children are expressly prohibited.
Information we collect about you and your device
Each time you use our Website Services or App we will automatically collect the following information:
- technical information, including the type of mobile device you use, a unique device identifier (for example, mobile network information, your mobile operating system, the type of mobile browser you use, device token, device type, time zone setting (“Device Information”);
- details of your use of our Website Services or App including, but not limited to traffic data, weblogs and other communication data, and the resources that you access (“Log Information”).
- location information, if the Website Services or App uses GPS technology to determine your current location. If you wish to use the particular feature, you may be asked to consent to your data being used for this purpose. You can alter your consent and sharing selections at any time via your mobile device settings.
Other Information We May Collect Through Your Use of the Website Services or the App
When you use any Website Services or the App, we may collect Personal Information as well as demographic information, for example information that you submit, or that we collect, which may include, but is not limited to, post code, hometown, gender, username, mobile network information, your mobile operating system, the type of mobile browser you use, time zone setting, device location, IP address, SMS data, transaction information, age/birth date, browsing history information, searching history information, and registration history information (“Demographic Information”).
3. Use of Personal Data
We may use Personal Data which you provide to us or we collect from you to:
- Provide, maintain, and improve our App and Website Services, including, for example, to facilitate payments, send receipts, provide products and services you request (and send related information about them), develop new features, provide customer support to Users, authenticate users, and send administrative messages, whether information or required by applicable law;
- Perform internal administration and operations, including, for example, to prevent fraud and abuse of our Website Services; to troubleshoot software bugs and operational problems; to conduct data analysis, testing, and research; and to monitor and analyze usage and activity trends;
- Send you communications we think will be of interest to you, including information about products, services, promotions, news, and DIFC events, where permissible under DIFC Laws and according to any other applicable laws; and to process contest, sweepstake, or other promotion entries and fulfill any related awards;
- Notify you about changes to our App and Website Services;
- Allow you to participate in any interactive features of our App or Website Services;
- Keep our App and Website Services safe and secure; and
- Personalize and improve the Website Services, including to provide or recommend features, content, social connections, referrals, and advertisements.
4. Processing, Storage and Transfer of Personal Data
We will take all steps reasonably necessary to ensure your data is processed fairly and lawfully, in accordance with the DP Law, other applicable laws and this Policy. By submitting your Personal Data (including Log, Device and / or Demographic Information), you agree to such transfer, storing or processing in order for DIFC to perform its general administrative and regulatory functions, including but not limited to responding to enquiries you raise via the App or Website Services, oversight of the business entities registered in DIFC’s jurisdiction and maintaining contacts for future informational or promotional activities. Unless otherwise notified, DIFC does not ordinarily engage in automated decision making when processing your Personal Data.
You agree that we have the right to transfer the Personal Data described in this Policy to and from, and process and store it in, the United Arab Emirates and (where applicable or required) with processors in other countries, some of which may have less protective privacy laws than those where you reside. Where this is the case, we will take appropriate security measures to protect your Personal Data in accordance with this Policy. DIFC is ISO 27001 certified and all information security policies are strictly enforced. Please see section 7 below for further details.
To preserve the integrity of our databases, to carry out on-going Website Services on behalf of all Users, for research, analytics and statistics purposes and to ensure compliance with applicable laws and regulations, we retain Personal Data submitted by Users for a reasonable length of time unless otherwise prescribed by applicable law. DIFC is not responsible for the accuracy of the information you provide, and will modify or update your Personal Data in our databases upon your request, as further outlined below. We will erase or archive from active use your Personal Data upon request, unless we are required to retain it in accordance with DIFC or other applicable laws or to perform agreed services. By accessing or using the App or Website Services, you do hereby represent and warrant that you understand that all information submitted by you through the App or Website Services or otherwise to DIFC may be used by DIFC in accordance with applicable laws and its policies.
5. Sharing of Personal Data
We may share Personal Data which we collect about you as described in this Policy or as described at the time of collection or sharing, including as follows:
Through Our Website Services or the App
We may share your Personal Data:
- With third parties to provide you a service you requested through a partnership or promotional offering made by a third party or us;
- With third parties with whom you choose to let us share your Personal Data, for example other apps or websites that integrate with our API or Website Services, or those with an API or Service with which we integrate; and
Other Types of Data Sharing
We may share your Personal Data:
- With DIFC subsidiaries and affiliated entities;
- On the DIFC Public Register, in accordance with Article 153 of the Companies Law, DIFC Law No. 5 of 2018, and Section 9.2 of the Companies Regulations;
- With vendors, consultants, marketing and advertising partners, and other service providers who need access to such Personal Data to carry out work on our behalf or to perform a contract we enter into with them;
- In response to a request for information by a competent authority or government entities if we determine that such disclosure is in accordance with, or is otherwise required by, any applicable law, regulation, or legal process;
- With law enforcement officials, government entities or authorities, or other third parties as required by applicable law;
- With third parties in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company;
- If we otherwise notify you and you consent to the sharing;
- With third parties in an aggregated and/or anonymized form which cannot reasonably be used to identify you
All sharing of Personal Data aligns to the extent possible with the DIFC Government Data Sharing Policy, which is an internal DIFC policy that governs fair and lawful sharing of Personal Data requested by government entities within the UAE and elsewhere.
6. Your Rights and Choices
Marketing and Opting Out
DIFC supports Users’ legal rights to opt-out of receiving communications from us and our partners. You have the option to ask us not to process your Personal Data for marketing purposes and to remove it from our database, to not receive future communications or to no longer receive our App or Website Services.
You may change your preferences at any time.
Please note that we may continue to send you transactional or service-related e-mails despite your desire to not receive promotional or marketing e-mail messages. Additionally, please note that if you elect to opt-out of receiving promotional e-mails from one of our Website Services or the App, you may continue to receive promotional emails from our other websites, providers or other, non-affiliated marketers whose services you may have accessed via the DIFC Website Services or App.
Finally, while we may remove your individual contact information from our professional contacts database, please be aware that if such information is in a different third party's marketing directory through your request or election, you will need to request removal with such third party directly.
Access to and Correction of Your Personal Information
You have the right to access information held about you. Your right of access can be exercised in accordance with DIFC and other applicable laws. Any access request generally comes at no cost to you, but may, where permissible, be subject to a fee to meet any extraordinary administrative costs in providing you with details of the information we hold about you.
When you contact us about a potential Personal Data error, we will endeavor to confirm or verify the information in question, then correct verified inaccuracies and respond to the original inquiry. We will endeavor to send a correction notice to businesses or others whom we know to have received the inaccurate data, where required and / or appropriate. However, some third parties and third party sites may continue to process inaccurate data about you until their databases and display of data are refreshed in accordance with their update schedules, or until you contact them personally to ensure the correction is made in their own files.
You may also request that we restrict, erase or otherwise process your Personal Data in line with the relevant articles providing for such rights set out in the DP Law.
Changes to this Policy
We may change this Policy from time to time and without notice. If we make significant changes in the way we treat your Personal Data, or to the Policy, we will endeavor to provide you notice through the App or Website Services or by some other means, such as email. Your continued use of the App or Website Services after such notice constitutes your acceptance of the changes. We encourage you to periodically review this Policy for the latest information on our privacy practices. We provide links to it through:
- The App or Website Services
- Incorporating it into our contracts, agreements, and other documents as necessary or appropriate
7. Security Precautions
DIFC makes every effort to ensure that your Personal Data is secure on its system. DIFC has staff dedicated to maintaining our data protection and security policies, periodically reviewing them and making sure that DIFC employees are aware of our data protection and security practices. Unfortunately, no data transmission over the internet can be guaranteed to be 100% secure. As a result, DIFC cannot warrant or guarantee the security of any Personal Data you transmit to us, and you do so at your own risk.
DIFC has established policies and procedures for securely managing information and protecting Personal Data against unauthorized access. We continually assess our data privacy, information management and security practices. We do this in the following ways:
- Establishing policies and procedures for securely managing information;
- Limiting employee access to viewing only necessary information in order to perform his or her duties;
- Protecting against unauthorized access to Personal Data by using data encryption, authentication and virus detection technology, as required;
- Requiring service providers with whom we do business to comply with relevant data privacy legal and regulatory requirements;
- Monitoring our websites through recognized online privacy and security organizations;
- Conducting background checks on employees and providing training to our employees.
Types of cookies we drop and the information collected using them include:
- Google Tag Manager - helps make tag management simple, easy and reliable by allowing marketers and webmasters to deploy website tags all in one place.
- Google Analytics - gives website owners the digital analytics tools needed to analyse data from all touchpoints in one place, for a deeper understanding of the customer experience.
- Pingdom - monitors sites and servers on the internet, alerting the website owners if any problems are detected.
- Hotjar - by combining both analysis and feedback tools, Hotjar helps website owners understand what users want, care about and interact with on their website by visually representing their clicks, taps and scrolling behavior.
- Salesforce Chat Solution - lets website owners chat with customers and give them real-time support.
- DoubleClick - a subsidiary of Google which develops and provides Internet ad serving services.
- Twitter Advertising - enables website owners to track and measure the actions users take after viewing or engaging with ads on Twitter.
- Facebook Advertising - lets website owners measure, optimise and build audiences for advertising campaigns.
- LinkedIn Analytics – enables website owners to promote their company updates to targeted audiences on desktop, mobile, and tablet.
Most browsers accept and maintain Cookies by default. Check the ‘Help’ or ‘Settings’ menu of your browser to learn how to change your Cookie preferences. You can choose to alter Cookies settings related to the use of our Website Services, but this may limit your ability to access certain areas of the Website.
Alternatively you may wish to visit an independent source of information, www.aboutcookies.org, which contains comprehensive information on how to alter settings or delete Cookies from your computer as well as more general information about Cookies. For information on how to do this on the browser of your mobile phone you will need to refer to your handset manual or network operator for advice.
9. External Links
The Website and the App may contain links to other websites on the Internet that are owned and operated by third parties (the "External Sites"). These links are provided solely as a convenience to you and not as an endorsement by DIFC of the contents of or reliability on such External Sites. You acknowledge that DIFC is not responsible for the availability of, or the information and content of any External Site. You should contact the site administrator or webmaster for those External Sites if you have any concerns regarding such links or the content located on such external Sites. If you decide to access linked third party websites, you do so at your own risk. DIFC does not accept liability, and shall not be liable to you for any loss or damage arising from or as a result of your acting upon the content of another website to which you may link from the Website Services or the App.
10. DIFC Buildings Security
Building security records containing sign in and sign out information collected at the time of visiting and departing a DIFC-owned building will be maintained in accordance with this Policy. Buildings within the DIFC free zone that are not owned and operated by the DIFC Authority or its subsidiaries are not bound by this Policy.
If you have any questions, comments and requests related to this Policy, or if you have any complaints related to how DIFC processes your personal data, please contact the Commissioner of Data Protection’s Office at:
Dubai International Financial Centre Authority
Level 14, The Gate Building
+971 4 362 2222
DIFCA has appointed a Data Protection Officer in accordance with Article 16 of the DP Law. She may be contacted using the above address or telephone number, or via email at firstname.lastname@example.org