Policy
We ask that you read this website privacy policy carefully as it contains important information on who we are, how and why we collect, store, use and share personal information, your rights in relation to your personal information and on how to contact us and supervisory authorities in the event you have a complaint.
This website privacy policy is divided into the following sections:
- Who we are
- Our website
- Our collection and use of your personal information
- Cookies and similar technologies
- Marketing
- Your rights
- Keeping your personal information secure
- How to complain
- Changes to this website privacy policy
- How to contact us
- Do you need extra help?
Who we are
This website is operated by Kamal K. Jabbar, Partner at KLME LLP, a law firm registered with the Abu Dhabi Global Market (ADGM).
Our website
This privacy policy relates to your use of our website only.
Throughout our website, we may link to other websites owned and operated by certain trusted third parties to insert details (e.g., make additional products and services available to you). These other third party websites may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to these other third party websites, please consult their privacy policies as appropriate.]
Our collection and use of your personal information
We collect personal information about you when you [access our website, register with us, contact us, send us feedback, purchase products or services via our website, post material to our website and complete customer surveys or participate in competitions via our website].
We collect this personal information from you either directly, such as when you [register with us, contact us or purchase products or services via our website] or indirectly, such as your browsing activity while on our website (see ‘Cookies’ below).
[We also collect personal information about you from other sources as follows:
- insert type of personal datafrom insert full details of the source — see drafting notes
- insert additional information for each category of personal data to the extent there are differences]
The personal information we collect about you depends on the particular activities carried out through our website. This information includes:
- your name, address and contact details
- date of birth
- [bank account and payment details]
- details of any feedback you give us by phone, email, post or via social media
- information about the services we provide to you
- your account details, such as username, login details
- insert other types as appropriate
We use this personal information to:
- create and manage your account with us
- verify your identity
- provide goods and services to you
- customise our website and its content to your particular preferences
- notify you of any changes to our website or to our services that may affect you
- improve our services
- insert other actions as appropriate
This website is not intended for use by children and we do not knowingly collect or use personal information relating to children.
Our legal basis for processing your personal information
When we use your personal information we are required to have a legal basis for doing so. There are various different legal bases on which we may rely, depending on what personal information we process and why.
The legal bases we may rely on include:
- consent:where you have given us clear consent for us to process your personal information for a specific purpose
- contract:where our use of your personal information is necessary for a contract we have with you, or because you have asked us to take specific steps before entering into a contract
- legal obligation:where our use of your personal information is necessary for us to comply with the law (not including contractual obligations)
- [vital interests:where our use of your personal information is necessary to protect you or someone else’s life]
- [public interest:where our use of your personal information is necessary for us to perform a task in the public interest, or for national security or for our official functions, and the task or function has a clear basis in law]
- economic or financial interests:where our use of your personal information is necessary for protection of economic or financial interests of the state.
- legitimate interests:for our legitimate interests or those of a third party.
A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own.
Further information—the personal information we collect, when and how we use it
For further details on when we collect personal information, what we collect as well as how we use it, please read the following sections:
| When information is collected | What information we ask for | How and why we use your information |
| When you register with us | Contact details: your name and email address |
We ask for this: — to create and manage your account with us — to communicate with you about your account — insert other as appropriate We rely on insert as the lawful basis for collecting and using your personal information. [Our legitimate interests are insert if relying on legitimate interests as a lawful basis.] We will keep this information until: — you close your account with us — we close your account |
| insert next activity, e.g., a cookie or other data collection activity | State what information you collect |
Describe how the personal data will be obtained. If not collected directly from the data subject, identify the original source. Explain what will be done with the personal data. Describe the lawful basis for processing the personal data. Provide details of the third parties with whom the personal data may be shared. Provide the retention period for the personal data collected. If this data is special category personal data, specify this and explain which category of special category personal data. |
Who we share your personal information with
We routinely share insert categories of personal data shared (e.g., your name and delivery address details) with insert recipients (e.g., our third party suppliers). For a list of insert description (e.g., ‘our third party suppliers’ ) see insert link or details of where a list of such third parties can be found if possible.
This data sharing enables insert the reasons for the data sharing (e.g., ‘them to dispatch the goods you ordered directly to you)’.
We will share personal information with law enforcement or other authorities if required by applicable law.
We will not share your personal information with any other third party.
Whether information has to be provided by you, and if so why
We require you to provide insert category of personal data (e.g., name, address, delivery address etc.) to enable us to insert purpose. We will inform you at the point of collecting information from you, whether you are required to provide the information to us.
The impact of our use of your personal information
Insert details
Cookies and other tracking technologies
A cookie is a small text file which is placed onto your device (e.g., computer, smartphone or other electronic device) when you use our website. We use cookies [and insert details of any similar technologies, e.g., web beacons, action tags, single-pixel gifs] on our website. These insert details, e.g., help us recognise you and your device and store some information about your preferences or past actions.
For further information on cookies [and insert details of any similar technologies, e.g., web beacons, action tags, single-pixel gifs], our use of insert, e.g., refer to ‘cookies’ and/or to relevant similar technologies, when we will request your consent before placing them and how to disable them, please see our insert link to Cookie Policy.
Marketing
We would like to send you information about insert details, e.g., products and services, competitions and special offers, which may be of interest to you. Where we have your consent or it is in our legitimate interests to do so, we may do this by post, email, telephone, text message (SMS) or automated call.
[We would also like to share your information with selected insert name of third parties with whom you wish to share data so that they may send you information about their products AND/OR services, depending on what you agree with us.]
We will only ask whether you would like us [and other businesses] to send you marketing messages when you tick the relevant boxes when you insert details, e.g., complete our online order form for the first time. Click here insert link to see what this form looks like insert details.
If you have previously agreed to being contacted in this way, you can unsubscribe at any time by:
- contacting us at insert contact details
- using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts
- [updating your marketing preferences on our link to preference centre]
It may take up to insert figure days for this to take place.
For more information on your rights in relation to marketing, see ‘Your rights’ below.
Your rights
Under the Data Protection Laws of the United Arab Emirates, you have a number of important rights free of charge. In summary, those include rights to:
- [fair processing of information and transparency over how we use your use personal information]
- access to your personal information and to certain other supplementary information that this Privacy Notice is already designed to address
- require us to correct any mistakes in your information which we hold
- object at any time to processing of personal information concerning you for direct marketing
- object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
- object in certain other situations to our continued processing of your personal information
- otherwise restrict our processing of your personal information in certain circumstances
- [claim compensation for damages caused by our breach of any data protection laws]
If you would like to exercise any of those rights, please:
- email, call or write to us OR insert details, our Data Protection Officer
- let us have enough information to identify you (e.g., account number, user name, registration details),
- let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill), and
- let us know the information to which your request relates [including any account or reference numbers, if you have them]
Keeping your personal information secure
We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
Insert details of any specific security which the controller wishes to mention to reassure data subjects, e.g., encryption technologies (this is purely optional).
How to complain
We hope that we OR our Data Protection Officer can resolve any query or concern you raise about our use of your information.
Changes to this website privacy policy
This website privacy policy was published on insert date and last updated on insert date.
We may change this website privacy policy from time to time, when we do we will inform you via insert mechanism for informing the data subject of changes to the policy.
How to contact us
Please contact us OR insert details, our Data Protection Officer, if you have any questions about this privacy notice or the information we hold about you.
If you wish to contact us OR insert details, our Data Protection Officer,, please send an email to insert email address, write to insert address or call insert telephone number.
[Do you need extra help?
If you would like this website privacy policy in another format (for example: audio, large print, braille) please contact us (see ‘How to contact us’ above).]