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1. Introduction

GHAYA is a company incorporated in the Emirate of Dubai, United Arab Emirates.

This policy describes how GHAYA collects, processes uses and discloses your personal information as a data controller, when you contact us, use our services or interact with our platforms including websites and mobile apps (together “Platforms”).

WHAT THIS POLICY COVERS?

We are committed to adopting the highest standards when it comes to how we collect, use and protect your personal information, and have accordingly developed this privacy policy (the “Policy”), which:

  • Sets out the types of personal information we collect;
  • Explains how and why we collect and use your personal information;
  • Explains when and why we may share personal information within GHAYA and with other organisations;
  • Explains how we protect the personal information we collect; and
  • Explains the rights and choices you have in relation to your personal information.

 

This Policy applies if you use our services (referred to in this Policy as “our Services”). Using our Services means:

  • Using any of our platforms, including websites (“our Websites”)
  • Being the recipient of our consultancy services.

This Policy also applies if you contact us or we contact you about our Services.

 

 

PERSONAL INFORMATION WE COLLECT

When you register to our services, we may collect:

  • Your personal details, including your postal and billing addresses, email address(es), phone number(s), date of birth, gender, and passport or ID number
  • Your account login details, such as your username and the password (encrypted) that you have chosen; and
  • Your interests, preferences, income, and other profiling information.

WHY AND HOW WE USE YOUR PERSONAL INFORMATION

Personalise your experience

We may use your personal information to personalise the marketing messages we send to you and to make them more relevant and interesting, as this is in our legitimate business interests. Where necessary we will obtain your consent first. We may use your personal information for this purpose in the following ways:

  • Providing you with relevant marketing communications (including by email, post, telephone, SMS, or online advertising), relating to services we offer, and those of our suppliers and partners. As part of this, online advertising may be displayed on Our Websites and on other organisations’ websites and online media channels. We may also measure the effectiveness of our marketing communications and those of our suppliers and partners;

Contact and interact with you

We may use your personal information when we communicate with you, in order to:

  • Contact you about our Services, for example by phone, email or post or by responding to social media posts that you have directed at us;
  • Invite you to take part in and manage customer surveys, questionnaires and other market research activities carried out by GHAYA and by other organisations on our behalf.

It is in our legitimate business interests that we are able to provide you with appropriate responses and provide you with notice about our services.

Manage and improve our day-to-day operations

We analyse information about how you use our services to:

  • Manage and improve our Websites;
  • Help to develop and improve our services, information technology systems, know-how and the way we communicate with you;
  • Detect and prevent fraud or other crime.

It is in our legitimate business interests to use the information provided to us for this purpose, so we can understand any issues with our Services to improve it.

SHARING PERSONAL INFORMATION

We may share your personal information with third parties under the following circumstances:

GHAYA Subsidiaries

We may share the personal information collected by any of our subsidiaries with our other subsidiaries for the purposes listed above.

Service Providers

We work with carefully selected Service Providers that carry out certain functions on our behalf. These include, for example, companies that help us with technology services, storing and combining data, and processing payments.  We only share personal information that enables our Service Providers to provide their services.

SHARING PERSONAL INFORMATION WITH OTHER ORGANISATIONS

We may share personal information with other organisations in the following circumstances:

  • if any applicable law or a public authority says we must share the personal information;
  • if we need to share personal information in order to establish, exercise or defend our legal rights (this includes providing personal information to others for the purposes of preventing fraud and reducing credit risk);
  • to an organisation we sell or transfer (or enter into negotiations to sell or transfer) any of our businesses or any of our rights or obligations under any agreement we may have with you to. If the transfer or sale goes ahead, the organisation receiving your personal information can use your personal information in the same way as us
  • to any other successors in title to our business; or
  • to anyone to whom we transfer or may transfer our rights and duties under our agreement with you.

TRANSFER OF YOUR PERSONAL INFORMATION

Your personal information may be transferred to, stored, and processed in a country that is different from your country of residence or our country of incorporation. In any case, we have put in place appropriate safeguards in accordance with applicable legal requirements to ensure that your data is adequately protected.

In the event your personal information 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.

HOW WE PROTECT PERSONAL INFORMATION

We maintain physical, technical, and organisational safeguards to secure your personal information from unauthorized access, use, alteration and destruction. 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.

SOCIAL MEDIA

We operate channels, pages and accounts on some social media sites to inform, assist and engage with customers. We monitor and record comments and posts made on these channels about us so that we can improve our services.

GHAYA is not responsible for any information posted on those sites other than information we have posted ourselves. We do not endorse the social media sites themselves or any information posted on them by third parties.

RETENTION

We keep records for as long as required to a) manage Services anticipated by this Privacy Policy, including keeping you up-to-date with our marketing b) personalise the services and communications with you c) comply with the applicable record retention legal requirements. When deciding how long to keep your personal information after our relationship with you has ended, we take into account our legal obligations and regulators’ expectations.

If you wish to request that we no longer use your information to provide you services, contact us at Analytics Office, GHAYA, P.O. Box 9919, Dubai, United Arab Emirates. You can also email us at ghaya@ghaya.ae.

However, we will retain and use your registration information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

MARKETING COMMUNICATIONS

All marketing communications we send to you will provide you with a way to withdraw your consent to future marketing. If you no longer wish to receive promotional materials you may opt-out from receiving these communications or change your account settings, this will remove you from marketing lists.

Please note that if you unsubscribe from marketing communications you will still receive operational and service messages from us regarding the services and responses to enquiries made to us, and that we may hold your details on a suppression list so we don’t send you marketing communications in the future.

COOKIES AND SIMILAR TECHNOLOGIES

We use cookies and similar technologies, such as tags and pixels (“Cookies”), to personalise and improve your customer experience as you use our Websites and Mobile Apps and to provide you with relevant online advertising. Cookies are small data files that allow a website or Mobile App to collect and store a range of data on your desktop computer, laptop or mobile device.

Cookies help us to provide important features and functionality on our Websites Apps, and we use them to improve your customer experience. 

YOUR RIGHTS

You have the right to see or access the personal information we hold about you. To receive a copy, please write to the Analytics Office, GHAYA, P.O. Box 9919, Dubai, United Arab Emirates. You can also email us at ghaya@ghaya.ae.

In addition, you have certain rights regarding your personal information, subject to local law. These include the following rights to:

  • rectify the information we hold about you;
  • erase your personal information;
  • restrict our use of your personal information;
  • object to our use of your personal information;
  • withdraw any consents you have provided for our use of your personal information;
  • receive your personal information in a usable electronic format and transmit it to a third party (right to data portability); and
  • lodge a complaint with your local data protection authority.

If you would like to discuss or exercise such rights, please contact us at the details below.

If you are concerned that any of the information we hold about you is incorrect, or out of date, please write to the address above to report your concerns and we will take appropriate steps to amend our records.

Please note that we will likely require additional information from you in order to honour your requests.

PRIVACY CONCERNS

If you have any concerns about our compliance with applicable privacy laws or this Privacy Policy please write to the Corporate Compliance Office, GHAYA Management Services, P.O. Box 91100, Abu Dhabi, United Arab Emirates or email us at ghaya@ghaya.ae. We will endeavour to respond to your concerns as soon as possible.

NOTIFICATION OF CHANGES TO THIS PRIVACY POLICY

We update this Privacy Policy when needed and place updates on our platforms. If we are going to use your personal information in a manner different from that stated at the time of collection, we will notify you. All changes will become effective when posted unless indicated otherwise. Please review this Privacy Policy periodically for changes.

LINKS

Our Websites may contain links to other websites operated by other organisations that have their own privacy policies. Please make sure you read the terms and conditions and privacy policy carefully before providing any personal information on a website as we do not accept any responsibility or liability for websites of other organisations.