Last Updated: February 2021
- by post, to PO Box 22525, Dubai, UAE;
- using our website contact form;
- by telephone, on the contact number published on our website from time to time; or
- by email, using the email address published on our website from time to time.
How this Privacy Statement applies
This Privacy Statement applies where we are acting as a data controller with respect to your personal data as a visitor of our website and/or user of our products or services; in other words, where we determine the purposes and means of the processing of that personal data.
We will only process your personal data in the manner set out in this Privacy Statement if you have specifically agreed or consented to us doing so (for example through your explicit acceptance of this Privacy Statement or via an electronic tick-box or other similar measures as required by applicable data protection laws) or if we have legitimate grounds to do so.
The personal data that we may collect
We may collect and process the following data about you:
- Information you give us. This is information about you that you give us by filling in forms on the Platforms or by corresponding with us by phone, e-mail or otherwise. It includes information you provide if you register to use our Platforms and when you report a problem with our Platforms. The information you give us may include your name, address, e-mail address and phone number. We will only process sensitive data if you have provided your explicit consent to do so for the specific purposes indicated therein.
- Information we collect about you. With regard to each of your visits to our Platforms we will automatically collect the following information:
- technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform.
- information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), products you viewed or searched for page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our contact centre.
- Information we receive from other sources. This is information we receive about you if you use any of the other sites we operate or the other services we provide. We may work closely with third parties (including, for example, business partners, sub- contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies).
We will combine the information that we collect automatically from you with any other information that we collect directly from you or about you (see “Aggregate data, data analytics and social media functionality” below).
The legal basis for this processing is our legitimate interests, namely; monitoring and improving our website and services; the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract; the proper administration of our website and business and communications with users; and/or the proper management of our customer relationships.
How we use personal data?
We use the information provided in the following ways:
- to answer any queries which you may send to us by email or other forms of communication, and we may keep a record of these contacts including call recordings (to the extent permitted by applicable law);
- to maintain the integrity of our network and address security issues, to investigate or take action regarding violations or suspected violations of law or our terms;
- to notify you about changes to our service;
- to ensure that content from our Platforms is presented in the most effective manner for you and for your computer;
- for recruitment purposes;
- to allow you to participate in interactive features of our service, when you choose to do so;
- to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
- to make suggestions and recommendations to you and other users of our Platforms about goods or services that may interest you or them; or
- as you may authorise or consent to additionally from time to time.
Working with other service providers and Emirates Group companies
We have summarised some rights that you may have under applicable data protection law. You should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
You (may) have the following rights:
- the right to access;
- the right to rectification;
- the right to erasure;
- the right to restrict processing;
- the right to object to processing;
- the right to data portability;
- the right to complain to a supervisory authority; and
- the right to withdraw consent.
You may exercise any of your rights in relation to your personal data by written notice to us.
Access to your personal data
Correction/updating of personal data
If your personally identifiable information changes or is inaccurate, we will provide a way to correct, update or suppress your personal data provided to us. If you are concerned that any of the information we hold about you is incorrect please contact us. These rights are without prejudice to any legal rights you may have in applicable laws, including your right to object to certain processing of data.
Unless processing is necessary for compliance with a legal obligation or for the establishment, exercise or defence of legal claims, you may have the right to the erasure of your personal data without undue delay when (i) the personal data is no longer necessary in relation to the purposes for which they were collected or otherwise processed; (ii) you withdraw consent to consent-based processing; (iii) you object to the processing under certain rules of applicable data protection law and we would not have overriding legitimate grounds for the processing; (iv) the processing is for direct marketing purposes; and (v) the personal data have been unlawfully processed.
Restriction to processing
You may have the right to restrict the processing of your personal data when (i) you contest the accuracy of the personal data; (ii) processing is unlawful but you oppose erasure; (iii) we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and (iv) you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data.
However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
Objection to processing
Unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims, you may have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: (i) the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or (ii) the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal data.
You may have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
You may have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
To the extent that the legal basis for our processing of your personal data is:
- consent; or
- that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means;
you may have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
Complaint to a supervisory authority
If you consider that our processing of your personal data infringes data protection laws, you may have a legal right to lodge a complaint with the relevant supervisory body responsible for data protection.
Withdrawing your consent
To the extent that the legal basis for our processing of your personal data is consent, you may have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
You do not have to provide us with your personal data. However, if you choose not to provide certain personal data we request and/or require, or consent to its use and disclosure, you will still be able to visit our Platforms but you may be unable to access certain options, products or services.
We will take appropriate steps to protect the personal data you share with us. We have implemented technology and security features to safeguard the privacy of your personal data. We invest significant resources to protect your personal data, from loss, misuse, unauthorised access, modification or disclosure. However, no internet-based site can be 100% secure and we cannot be held responsible for unauthorised or unintended access that is beyond our control.
Protecting your details and protecting yourself against internet fraud
Here are some simple steps you can take to ensure your information is kept securely:
- Be aware of “Phishing”, which is where someone tries to represent themselves as someone else to gain information from you – always check whether emails from any sender are actually from them, and if in doubt, go directly to their website and do not click on links in emails, as these may take you to “clone” websites which use your information illegally.
Aggregate data, data analytics and social media functionality
We may aggregate personal data and remove any identifying elements in order to analyse patterns and improve our marketing and promotional efforts, to analyse Platform use, to improve our content and product offerings, and to customize our Platforms’ content, layout, products and services, and we may appoint third parties to do this on our behalf, as set out above.
We gather certain usage information like the number and frequency of visitors to our Platforms. This information may include which webpage you just came from, which webpage you next go to, what browser you are using, your device and your IP address. We only use such data in the aggregate. This collective data helps us to determine how much our customers use parts of our Platforms, and do research on our users’ demographics, interests, and behaviour to better understand and serve you.
Cookies and other tracking technologies
See also our section on “Aggregate data, data analytics and social media functionality” above.
Do Not Track
Our Platforms may contain links to other websites. Please be aware that we are not responsible for the privacy practices of web sites not operated by us or an entity in the Emirates Group. We encourage you to read the privacy statements of each and every website that collects personally identifiable information. This Privacy Statement applies solely to information collected by our Platforms.
Transfer of your personal data
SOME PARTIES THAT PROCESS OR STORE PERSONAL DATA IN ACCORDANCE WITH THIS PRIVACY STATEMENT MAY BE LOCATED IN JURISDICTIONS OUTSIDE YOUR COUNTRY OF RESIDENCE OR OUR COUNTRY OF INCORPORATION. THEREFORE, BY GIVING YOUR CONSENT, YOU UNDERSTAND AND UNAMBIGUOUSLY AGREE THAT YOUR INFORMATION MAY BE PROCESSED AND STORED IN THESE JURISDICTIONS AND THAT DIFFERENT PRIVACY LAWS MAY APPLY IN THESE COUNTRIES WHICH MAY NOT ENSURE THE SAME LEVEL OF DATA PROTECTION AS GRANTED IN YOUR COUNTRY OF RESIDENCE.
We only make these arrangements or transfers where we are satisfied that adequate levels of protection are in place to protect any information held in that country or that the service provider acts at all times in compliance with applicable privacy laws. Where required under applicable laws we will take measures to ensure that personal data handled in other countries will receive at least the same level of protection as it is given in your home country.
Transfers will be protected by appropriate safeguards, namely the use of standard data protection clauses, a copy of which can be obtained from our legal team.
In the event your personal data is transferred to a foreign jurisdiction, it may be subject to the laws of that jurisdiction and we may be required to disclose it to the courts, law enforcement or governmental authorities in those jurisdictions but we will only do so where required by applicable laws.
Retaining and deleting personal data
Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained.
We will retain your personal data as follows:
- recruitment data will be retained for a period of twelve  months following the date the role applied for is filled.
Notwithstanding the above, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject.
Notification of changes to this Privacy Statement
If we decide to change our Privacy Statement, we will post those changes on our Platforms. If at any point we decide to use personally identifiable information in a manner materially different from that stated at the time it was collected (and/or where we are required under applicable law) we will notify you. You will have a choice as to whether or not we use your personal data in this different manner. We will use personal data in accordance with the Privacy Statement under which the personal data was collected until you agree otherwise, but if you do not accept the amended Privacy Statement, please stop using our Platforms. Each version has a version number and date so you can check this easily.
If you experience any technical problems during your interaction with the Platforms,please contact us here: firstname.lastname@example.org
Queries, concerns or complaints regarding your privacy or this Privacy Statement: If you have queries regarding this privacy statement please contact us.