EJADAH ASSET MANAGEMENT GROUP LLC – PRIVACY NOTICE
Last Updated: 21/11/2021
INTRODUCTION
We are committed to protecting and respecting your privacy. This Privacy Notice (the “Notice”) governs the
collection and use of personal data by Ejadah Asset Management Group LLC. This notice explains how and why
we
use your personal data and applies to the personal data that you provide us directly, or which we may obtain
from other sources.
We may use your personal data for any of the purposes described in this Notice, or as otherwise stated at
the
point of collection. For more information about the Ejadah Asset Management Group LLC please see
https://ejadah.com/.
References to "our", "us" or "we" within this Notice are to the Ejadah Asset Management Group LLC, 7th
Floor,
Vision Tower, Business Bay, P.O. Box: 500272, Dubai, United Arab Emirates,
privacyoffice@dhre.ae, Contact
Number: 800 5465.
WHO WE ARE
Ejadah Asset Management Group LLC is the data controller of your personal data. We decide how and why your
personal data is processed, either alone or jointly with others.
If you use our facilities and services, the entity which manages the relevant facility or service will also
be a
data controller in respect of your personal information. You can access a ‘Data Controller List’
here , which sets out all of the different Ejadah Asset
Management
Group LLC entities, their contact details and the country in which each of these entities operates. This
will
enable you to identify the relevant Ejadah Asset Management Group LLC entity that holds, processes and
secures
your personal data and is the data controller in relation to your personal data.
If you have any questions about this Notice, the use of your data, or would like to be directed to our Data
Protection Officer, please contact
privacyoffice@dhre.ae.
INFORMATION COVERED BY THIS PRIVACY NOTICE
In this notice we refer to “processing” your “personal data”.
Processing is taken to mean anything that is done to or with personal data (including simply collecting,
storing, or deleting that data).
Personal data is any information relating to an identified or identifiable living person. When “you” or
“your”
are used in this statement, we are referring to the relevant individual who is the subject of the personal
data.
COOKIES POLICY
Where we use cookies, you can also control the data stored by cookies and withdraw consent to cookies by
using
the browser-based cookie controls described in our Cookie Policy available on our websites.
WHAT WE COLLECT FROM YOU AND HOW WE USE IT
We process different categories of personal data to enable us to provide services to you as further
described
below:
Contact Details: Includes, but is not limited to, home address, home / personal mobile number and personal
email
address, emergency contact number.
Identification data: Includes but is not limited to name, your photo, citizenship, nationality, passport
data,
Visa information, drivers' licence information, the resident country`s ID, marriage certificate, birth
certificate and education certificates, national/social insurance number (if applicable), health insurance,
government retirement plan information and tax reference/ID (if applicable).
Special categories of data: Includes data that reveals the following about a data subjects: racial or ethnic
origin, political opinions, religious and philosophical beliefs, trade union membership, genetic data,
biometric
data for the purpose of uniquely identifying a natural person, and data concerning health.
Web Data: Includes, but is not limited to, cookies, user activity logs, and website visitor interaction
data.
Financial Data: Includes, but is not limited to, card details and bank details.
Other Personal Information: Includes but is not limited to date and place of birth, emergency contact
details
(if applicable), gender and marital status.
The reason these categories of personal data are processed, along with our Lawful basis for doing so, are
set
out in the table below:
Personal Data Directly Obtained from You
We process your personal data for service and quality monitoring purposes. |
Customer Service . |
Identification Data, Contact Details |
We process your personal data in line with our contractual obligations. We may also rely
upon
our
legitimate interests where we are required to do so
|
We process your personal data to provide integrated facilities management services.
|
Customer Service |
Identification Data, Contact Details |
We rely upon legitimate interest to process your personal data. |
We process your personal data to provide integrated facilities management
services.
Customer Service Identification Data, Contact Details We rely upon legitimate interest to
process
your personal data.
|
We process your personal data for procurement purposes, such as vendor management and
contract
management.
|
Supporting Service |
Identification Data, Contact Details, Financial Data |
We process
personal data in line with our contractual obligations.
|
We process your personal data for invoicing purposes. |
Account Management |
Identification Data,
Contact Details, Financial Data
|
We process your personal data in line with our contractual
obligations. We may also rely upon legal obligation where we are required to do so.
|
For management and audit of our business operations including accounting |
Financial Management |
Identification Data, Contact Details, Financial Data |
We rely upon legitimate
interest to process your personal data. We may also rely upon legal obligation where we are
required
to do so.
|
We process your personal data in order to comply with legal requirements and exercise or
defend
legal claims.
|
Identification Data, Contact Details, Financial Data, Other
Personal Information
|
We rely upon legitimate interest to process your personal data. We may also
rely upon legal obligation where we are required to do so.
|
Litigation & Disputes |
We process your personal data for security purposes, and to ensure secure backup and
archival of
IT
Systems.
|
Security Purposes |
Identification Data, Contact Details, Financial Data, Web Data, Other
Personal Information
|
We rely upon legitimate interest to process your personal data. |
We process your personal data for application management and support purposes, and to
respond to
customer requests.
|
Identification Data, Contact Details, Financial Data, Web Data,
Other Personal Information
|
We rely upon legitimate interest to process your personal data. |
Security Purposes |
Process personal data in relation to the usage of Wi-Fi services provided at our locations.
|
Security
Purposes
|
Contact
Details, Web Data
|
We rely
upon legitimate interest to process your personal data.
|
We process your personal data to facilitate application integration within our systems.
|
Security
Purposes
|
Identification Data, Contact Details, Financial Data, Web Data, Other Personal Information
|
We rely upon legitimate interest to process your personal data. |
Personal Data Indirectly Obtained from Others
To the extent necessary, we will also receive your personal data from other entities within the Dubai
Holding
LLC group of companies, including the Ejadah Asset Management Group LLC’s subsidiaries and holding
companies.
Legitimate Interest
Where we rely upon legitimate interest as a lawful basis, we have balanced your rights and freedoms against
our
interests, or those of any third parties, and determined your rights are not infringed. Legitimate Interest
is
where your personal data is processed for either our own interests or the interests of third parties. This
can
include commercial interests, individual interests or broader societal benefits.
HOW LONG DO WE KEEP YOUR PERSONAL DATA?
Your personal data will not be kept longer than necessary to meet the purposes detailed above. The criteria
that
we use to determine how long we will keep your personal data includes the period of time during which we
have an
ongoing relationship with you, and whether we have a legal obligation to store it (for example, for
accounting
purposes or for litigation, or regulatory investigations purposes).
Should retention of your personal data no longer be required we will remove it from our systems and records
and/or take steps to properly anonymise it so that you can no longer be identified from it.
WHO DO WE SHARE YOUR PERSONAL DATA WITH?
Where necessary to fulfil the purposes described in this Notice, we shall disclose your personal data to
certain
third-parties, vendors and service providers or affiliated employees, contractors and entities as described
below.
The Ejadah Asset Management Group LLC forms part of Dubai Holding LLC and its subsidiaries. To the extent
necessary, and where we have a lawful basis to do so, we will also share your personal data with other
entities
within Dubai Holding LLC’s group of companies, including to the Ejadah Asset Management Group LLC’s
subsidiaries
and holding companies, as well as with Dubai Holding LLC’s group of companies, including Dubai Holding LLC’s
subsidiaries and holding companies.
Where we share personal data, we do so with the following parties for the following purposes:
IT, Digital, Technology and Telecoms |
Audits, Customer Queries, Application Security and Support, Improving our Service |
Legal and Professional Advisers |
Audits, Invoicing, Legal Requirements, Transaction processing |
Finance, Insurance and Credit Providers |
Invoicing |
Government Bodies, Regulators |
Audits, Customer Queries, Invoicing, Legal Requirements, Improving our Service, Progress the
Transaction
|
PROFILING
Where we have a lawful basis to do so, we will use your personal data to evaluate certain personal aspects
about
you, such as to analyse or predict aspects concerning your economic situation, personal preferences,
interests,
reliability, behaviour, location or movements. This is known as “Profiling”. We only conduct profiling where
it
will not have a legal or other significant effect on you. We undertake profiling to help tailor our
marketing to
you.
WHERE WE STORE/TRANSFER YOUR PERSONAL DATA
When processing your personal data, we may transfer this to third parties based in other countries, to the
extent necessary to fulfil the purposes described in this Notice. Ejadah Asset Management Group LLC forms a
part
of Dubai Holding LLC and its subsidiaries. Your personal data may be transferred within this group of
companies,
as well as to the Ejadah Asset Management Group LLC ‘s subsidiaries and holding companies. Such transfers
shall
always be done in compliance with relevant data protection laws.
For transfers of personal data from the UK and European Economic Area (“EEA”) we transfer personal data to
entities outside the EEA, under the EU Standard Data Protection Clauses. Further information about transfers
can
be obtained by contacting us using the following email address
privacyoffice@dhre.ae
To the extent required, we will also transfer your personal data to third parties in connection with a
reorganization, restructuring, merger, acquisition or transfer of assets, provided that the receiving party
agrees to treat your personal data in a manner consistent with applicable laws and requirements.
SECURITY OF PERSONAL DATA
Ejadah Asset Management LLC has implemented technology and operational security measures in order to protect
personal data from loss, misuse, alteration or destruction. Only authorised persons are provided access to
personal data, such individuals have agreed to maintain the confidentiality of this personal data.
YOUR RIGHTS
You have certain rights relating to your personal data. However, these rights can differ depending upon the
country in which you are located. That country’s law will determine which rights apply and in what
instances.
Right to withdraw consent
Where you have provided your consent to us, you will always have the right to withdraw this at any time. You
can
do this by either following the information provided at the time you provided your consent, or by contacting
us
using the following email address
privacyoffice@dhre.ae. The withdrawal of consent will not affect any
processing that was based on consent before its withdrawal.
Right to request correction of your personal data
You will always have the right to request that we correct any personal data that we process about you that
is
inaccurate or incomplete. You can do this by contacting us
privacyoffice@dhre.ae.
European Data Protection Rights
Where the General Data Protection Regulation applies, you are also provided with additional rights. This
allows
you, subject to certain conditions, to:
- upon request, be provided access to, or copies of, your personal data that we process;
- upon request, restrict the processing of your personal data;
- upon request, delete your personal data which we process;
- object to our processing of your personal data;
-
or, upon request, obtain a copy of your personal data which we process in a commonly used and
machine-readable
format.
It is important to understand that these rights are not absolute (e.g. their application may depend upon the
lawful basis we rely upon to process your personal data) and that we may require further information from
you
(e.g. to confirm your identity) in order to action your request.
If the General Data Protection Regulation applies, you also have the right to lodge a complaint with the
supervisory authority in your country of residence, place of work or the country in which an alleged
infringement of data protection law has occurred within the EU.
CONTACTING US
If you want to exercise any of the rights set out above or have any questions or concerns about how we treat
your personal data, please contact us at
privacyoffice@dhre.ae or by writing to us at: Ejadah Asset
Management
Group LLC, 13th Floor, The Galleries 4, Downtown Jebel Ali, Dubai, United Arab Emirates. Please
include
your reply address when you write to us.
CHANGES TO THIS PRIVACY NOTICE
We keep this Notice under regular review. We reserve the right, at our discretion, to change, modify, add or
remove sections of this Notice at any time. You are also encouraged to review this Notice from time to time
for
updates. We will notify you of any changes (including when they will take effect) if we are required to do
so by
data protection laws.