Al Ghurair Collection & Its Portfolios ("we”, “our”, or “us”) are committed to respecting your personal information and complying with the relevant laws including, without limitation, the UAE FEDERAL Decree Law № (45) of 2021 on Personal Data Protection, DIFC Data Protection Law and EU General Data Protection Regulations (“applicable legislation”).

This Data Privacy Policy contains information on what Personal Data we and our related Group companies collect, what we do with that information, and what rights you have. This Data Privacy Policy has been prepared with reference to applicable legislation considerations and will be augmented by jurisdictional specific addendums from time to time.

We are committed to safeguarding the privacy of the personal information that we process in the course of our business, including the personal information we receive from you (“you” or “your”). This Data Privacy Policy describes how and why we collect, store and use personal information, and provides information about the rights of the individuals to whom such personal information relates.

For the purposes of applicable data protection law, Al Ghurair Collection & Its Portfolios are typically the “Data Controller” of any personal information provided to us. Specifically, the data that you have provided and communicated to us will be controlled, collected and processed by Al Ghurair Collection & Its Portfolios. Very occasionally, we will act on specific retainers as a

“Processor”

(meaning that we process Personal Data only in accordance with the directions of a Data Controller, or as otherwise permitted by law).

Please read the following information carefully to understand our views and practices regarding how we handle personal information. If you have any queries about our approach to data protection that are not already addressed in this Data Privacy Policy, please contact our Data Protection Officer, as per the contact details set out at the end of this Data Privacy Policy.

1. Scope and Application

This policy applies globally to individuals who access or use our websites, mobile applications, or other digital platforms owned and operated by Al Ghurair Collection & Its Portfolios.

2. Collection of Personal Data

We may collect personal information from you by electronic and/or physical means in the course of our business, when you contact us or request information from us, when you use our website or mobile app (or other digital platforms), or as a result of your relationship with any of our personnel or clients. The personal information that we process (“Personal Data”) includes:

• basic details, such as your first & last name, nationality, date of birth, role/title, employer/s, your relationship to a person, your contact information (such as your email address, physical address, contact details, mobile number & landline number, office number, fax number, P.O. Box Number) and other information related to the emergency contact person, such as:
  • Name of Emergency contact person related to the client
  • Mobile Number of Emergency contact person related to the client
  • landline Number of Emergency contact person related to the client
  • Email Id of Emergency contact person related to the client.
• identification information to enable us to check and verify your identity (e.g. your birthdate; your passport details, Resident Visa, Emirates ID), information collected from publicly available resources to verify the same; any other supporting documents such as:
  • Marriage certificate
  • salary certificate
  • Employment contract
  • Bank account details
  • Dewa account details
  • Gas account details
• bank account or other financial information, if relevant to our engagement with you;
• technical information (including your location, IP address, browser details, traffic data, location data), such as information from your visits to our website or mobile app (page interaction information, length of visits, etc.), or in relation to marketing emails we send to you;
• information relating to your visits to our offices or our meetings and events, including appointment details (e.g. time, location, participants) or photographic and video images;
• call recording if you reach out to us by phone, for the quality and training purposes;
• personal information provided to us by or on behalf of our clients/customers, or generated by us in the course or providing services to them, which may include special categories of Personal Data;
• any other information relating to you which you may provide to us.

We may collect your personal information:

as part of our new business intake and client on-boarding or client maintenance activities;

when you seek employment from us, as part of our new employee on-boarding and maintenance of the employment relationship;

when you provide (or offer to provide) services to us, either yourself or on behalf of your employer;

when we are acting on a matter where you or your employer are a party to the same;

when you interact with our website or mobile app (or other digital platforms), or use any of our online services;

when you interact with us in respect of any of our marketing communications or events.

We collect most of this information directly from you, through your use of our website or any other websites operated by Al Ghurair Collection & Its Portfolios business, or any service provided by Al Ghurair Collection & Its Portfolios Our company works closely with third parties (including, business partners, vendors, suppliers, sub-contractors, advertising networks, analytics providers, search information providers, customer survey providers, etc.) and may receive information about you from them. Where we obtain your information from a third party, we may ask them to provide you with a copy of this Data Privacy Policy to ensure that you know we are processing your information and the purpose for such processing. The information you provide may be confidential, and we will maintain such confidentiality and protect your information in accordance with our professional obligations and applicable legislation

3. Use of Personal Data

Whether we receive your Personal Data directly from you or from a third party, we will only use your personal information if we have obtained your consent, or if we have another lawful basis upon which to do so. Depending on the purpose of the processing activity, the legal basis for the processing of your Personal Data will be one of the following:

• necessary to perform our contractual obligations towards you or to take pre-contractual steps at your request;
• necessary to meet our legal or regulatory obligations in accordance with the applicable legislation;
• necessary to public interest;
• necessary to protect the vital interests of the relevant individual or of another natural person, such as providing disability access to places of work where applicable;
• necessary for the legitimate interests of Al Ghurair Collection & Its Portfolios, without unduly affecting your interests or fundamental rights and freedoms and to the extent such Personal Data is strictly necessary for the intended purpose; or
• in some cases, and as may be requested from you from time to time, we have obtained prior consent (for instance where required by law) or processed with your explicit consent in the case of special category of Personal Data (i.e. your medical information).

We always process your Personal Data for a specific purpose and only process the Personal Data which is relevant to achieve that purpose. The purposes for which we process your personal information are as follows:

• providing professional services where this is necessary or appropriate;
• processing your orders;
• communicating with you in connection to your request;
• verification your identity and information in your job application, and
• managing the accounts, you hold with us.

We may also 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. According to the applicable legislation, we will obtain your consent first. We may use your personal information for this purpose in the following ways:

• using your online browsing behavior to help us better understand you as a customer and provide you with personalized offers and services;
• providing you with relevant marketing communications (including by email, post, telephone, SMS, or online advertising), relating to products and services we offer, and those of our suppliers and partners;
• to help us to better understand you and provide you with services and marketing communications, that are relevant to your interests, we combine personal information we collect with personal information collected from our websites, mobile apps and other sources.

4. Consent

We process your Personal Data based on your consent or another lawful basis stated in Section 3 of this Data Privacy Policy. Where we do process your Personal Data based on your consent, you have the right to withdraw your consent at any time. To withdraw your consent, please contact us using the contact details stated at the end of this Data Privacy Policy.

5. Sharing of Personal Data

We may share Personal Data with other Al Ghurair Collection & Its Portfolios for the purposes indicated in section 3 to ensure a consistently high service standard across our group, and to provide services and products to you. We may disclose your Personal Data to third parties only:

• where you have given your prior written consent,
• where we are required to do so by applicable legislation (such as to relevant regulators or other authorities),
• when it is necessary for a purpose of legitimate interest, or
• where it is necessary for the purpose of or in connection with legal proceedings or in order to exercise or defend legal rights.

We do not sell, rent, distribute, or otherwise make, personal information commercially available to any third party. Where we transfer your data to third parties, we take steps to ensure they meet our data security standards, so thar your Personal Data remains secure.

6. Storage and Transfer of your Personal Data

The Al Ghurair Collection & Its Portfolios website will be managed and operated from the United Arab Emirates (“UAE”). The information collected from you via the website will be processed internally and stored on servers based in the UAE. It is not transferred outside the UAE in the usual course of our business. We will only transfer your data outside of the UAE if:

• the country or location we are transferring your data has adequate levels of protection for data subjects’ rights and freedoms.
• we have appropriate safeguards in place to ensure that your data is protected;
• we have your explicit consent to the proposed data transfer after being informed of any potential risks; or the transfer is necessary for one of the other reasons under the applicable legislation, including to allow us to perform any contracts we have with you, to protect your interests, and in limited cases, for our legitimate interest.

By providing your personal data to the Al Ghurair Collection & Its Portfolios website, you agree to this transfer, storing or processing. The Company will take all steps reasonably necessary to ensure your data is treated securely, to prevent unauthorised access or disclosure and in accordance with this Data Privacy Policy. If some transfers of your Personal Data may be made to the countries or jurisdictions with data protection or privacy laws that are not adequate (non-adequate jurisdictions) in comparison with the applicable legislation, we will take appropriate measures to protect Personal Data in accordance with the applicable legislation.

7. Your data protection rights

Various rights may be available to you, depending on the circumstances and the applicable legislation. We summarise key rights likely to be available to most data subjects:

• to access your personal information – you can request access to your personal information and, further details about how it is handled;
• to rectify your personal information– if the personal information we hold about you is inaccurate or incomplete, you are entitled to request to have it rectified;
• to request your personal information is erased – you can ask us to delete or remove your personal information where the processing is not necessary for the legitimate interests of Al Ghurair Collection & Its Portfolios;
• to restrict processing or object to the processing of your personal data – you have the right to restrict or to object to the processing of your personal information unless the processing of your personal information is necessary for the legitimate interests of Al Ghurair Collection & Its Portfolios;
• data portability - you have the right, in certain circumstances, to obtain personal information you have provided to the Al Ghurair Collection & Its Portfolios in a structured, commonly used and machine-readable format and to reuse it elsewhere or to ask us to transfer this to a third party of your choice
• to withdraw your consent- at any time you have the right to withdraw your consent for Al Ghurair Collection & Its Portfolios to process your personal information.
• to lodge a complaint - if you have a complaint or concern about our privacy practices or how we have used or processed your personal information, you can report it to the relevant authority.

If you:

• would like to discuss or exercise above-mentioned rights;
• would like to see or access the personal information we hold about you;
• concerned that any of the information we hold about you is incorrect, or out of date,

please write to the address stated at the end of this Data Privacy Policy to report your concerns and we will take appropriate steps to fulfil your request. Please note that some of the rights listed above may be limited where we have an overriding interest or legal obligation to continue to process your personal data or not disclose the same.

8. Children’s Privacy

Al Ghurair Collection & Its Portfolios does not knowingly collect the information of, or make contact with, children, including to participate in customer research activities. If you are aged 18 or under, please get your parent/guardian’s permission before you provide any personal information via the Al Ghurair Collection & Its Portfolios website. Users aged 18 or under without such consent are not allowed to provide us with personal information.

9. Data Retention

We will retain your personal information for the length of time needed to fulfil the purposes for which it was collected, unless we specifically agree a longer retention period with you, or a longer retention period is required or permitted by applicable legislation. At any time, you can ask for your stored information to be deleted from the company’s database using the contact details below. However, some of your information may be retained in some circumstances, such as to resolve disputes, troubleshoot problems, enforce terms and conditions or as required by regulators. Further, in some circumstances such information is never entirely removed from databases due to technical constraints and systems back-ups.

10. How we protect your Personal Data

We have implemented reasonable administrative, technical, and physical measures to protect your personal information against loss, misuse and alteration. 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.

11. Cookies

Cookies are text files containing small amounts of information which are downloaded to your computer’s hard drive when you visit a website and are used to distinguish your device but cannot identify you personally. We use cookies to distinguish you from other users, personalise content and provide you with an improved user experience. By clicking the “I agree” button on the pop-up when you first use the Al Ghurair Collection & Its Portfolios website you are agreeing to the use of cookies by Al Ghurair Collection & Its Portfolios website. You can control and manage cookies using your browser. Please note that removing or blocking cookies can impact your user experience and some functionality may no longer be available. We only set a few cookies ourselves, but when we include content from other websites, they also get the opportunity to set cookies, to help them serve their content better. We cannot guarantee that we will have listed every cookie you might get from a third party, as they can change them at any time as their needs change. The main categories of cookies used by our website are set out below. Categories of cookies:

• Strictly Necessary Cookies: These cookies are fundamental to website functionality and cannot be switched off without blocking features on the website. They are usually set in response to your actions on the website, such as filling in forms, setting preferences, or recognize the user as valid and authenticated while accessing protected areas of the website.
• Analytics cookies: we collect information about how you use our website including details such as the website that referred you (e.g. search engines, marketing campaigns, referring domains), the content you viewed, the website path you navigated and the links that you clicked on. This is in order to understand your interests on our website and the number of times you visit our website. We use this information to improve our website and enhance visitor experience. We share this information with analytics and search engine providers that assist us in improving and optimising our website.
• reference cookies: we use preference cookies also known as “functionality cookies,” to allow our website to remember the choices you have made in the past (such as your username, language or the region you are in) and provide you with an enhanced more personalized experience.
• Advertising cookies: we may present ads to you on websites that are not owned or operated by Al Ghurair Collection & Its Portfolios to promote our services. The cookies are used to make advertising messages more relevant to you and your interests. They also perform functions like preventing the same ad from continuously re-appearing. These advertisements are solely intended to make you aware of relevant Al Ghurair Collection & Its Portfolios promotions. We do not sell your data to any third parties.

Once you have given us your consent to the use any categories of cookies, we shall store cookies on your computer or device. If you do not wish to have non-permanent cookies (analytics, preference and advertising) placed on your computer you should not agree to proceed when you see the cookie ribbon on the homepage. Most web browsers allow some control of most cookies through the browser settings. If you change your mind about permitting the use of cookies on your computer, you can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. If you use your browser settings to block all cookies (including strictly necessary cookies) you may not be able to access and/or use all or parts of the Al Ghurair Collection & Its Portfolios website.

12. Changes to the Data Privacy Policy

We update this Data 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 Data Privacy Policy periodically for changes.

13. Contact Details

If you have any concerns about our compliance with applicable legislation or this Data Privacy Policy, please use the contact details below:

Data Protection Officer (Group Risk Assurance Services Department)
Al Ghurair Collection & Its Portfolios – Corporate Office
United Arab Emirates, Dubai
Post Box No. 6999
E-mail: DataProtection.Officer@al-ghurair.com

We will endeavour to respond to your concerns as soon as possible.