Privacy Notice
References to "our", "us" or "we" within this policy is to TECOM Group.
This policy governs the collection and use of personal information by us. For more information about us please see: www.tecomgroup.ae
We are committed to protecting and respecting your privacy. This policy explains the types of personal
information we collect, how we use that personal information, who we share it with, how we protect that information,
and your legal rights in relation to your personal information. We are committed to abiding by this policy, as well
as the requirements of applicable laws, in the operation of our business.
Please read the following carefully as it explains our views and practices regarding your personal information, and
how it is handled. By accessing or browsing our website, you confirm that you have read, understood and agree to
this policy in its entirety. If you do not agree with the practices described in this policy, you should not
use our website.
Who we are
For the purpose of applicable data protection laws, the data controller is TECOM Investments FZ-LLC of Dubai Studio City, P.O. Box: 73000,Dubai, United Arab Emirates.
Information covered by this Policy
This policy covers all personal information collected and used by us. In this
policy, "personal data" or "personal information" means information that (either
in isolation or in combination with
other information held by us) enables you to be identified as an individual or recognised directly or
indirectly. This may include your name, date of birth, nationality, gender, postal address, email address,
phone number, and technical information from the devices you use to access our website.
What information do we collect from you?
We may collect information about you from different sources as detailed below.
Information you give us
You may give us information about yourself when you respond to a communication from us
or by filling in forms (both online and offline), over the telephone and through written correspondence with us.The
information you give us may include your name, postal address, email address, date of birth, landline and/or mobile
telephone number, as well as other personal information.
Information we collect about you
When you visit our website, we may use cookies and other technologies to automatically collect the following information:
- Technical information, including the Internet Protocol (IP) address used to connect your computer to the internet, your login information, browser type and version, device identifier, location and time zone setting, browser plug-in types and versions, operating system and platform, page response times, and download errors;
- Information about your visit, including the full Uniform Resource Locators (URL) click streams to, on and from our websites;
- Length of visits to certain pages, page interaction information (such as scrolling,
clicks, and mouse overs) and methods used to browse away from the page.
Information we receive and collect from other sources
We may receive information about you from other websites operated by us or from the other services that we provide. We may also collect information about you from publicly available sources, including publicly available content on social media.
Cookies
Our website uses cookies and similar technology. A cookie is a small file of letters and
numbers that our website places on your computer, or other equipment which you use to access our website. These
cookies allow us to distinguish you from other users of our website.
You can read more about cookies and how to recognise them at www.aboutcookies.org.
Cookies perform many functions, such as allowing you to navigate between pages efficiently, remembering your
preferences, and generally improving the user experience. They can also help to ensure that advertising that you see
online is more relevant to you and your interests.
Your use of our website indicates your consent to the cookies described in this policy. Please see "How you can
control cookies" below for more information on how to withdraw your consent at any time.
| Type of cookie | What does it do? |
| Strictly necessary cookies | These cookies are essential in order to enable you to move around the website and use its features, such as accessing secure areas of the website. Without these cookies services you have asked for, like room bookings or e-payment, cannot be provided. |
| Performance cookies | These cookies collect information about how you use our website, for instance which pages you go to most often, and if you receive error messages from certain web pages. These cookies do not collect information that identifies you. All information these cookies collect is aggregated and therefore anonymous. It is only used to improve how the website works. By using our website, you agree that we can place these types of cookies on your device. |
| Functionality cookies | These cookies allow the website to remember choices you make (such as your language of choice or the region you are in) and provide enhanced, more personal features. These cookies can also be used to remember changes you have made to text size, fonts and other parts of the web pages that you can customise. The information these cookies collect may be anonymised and they cannot track your browsing activity on websites operated by third parties. By using our website, you agree that we can place these types of cookies on your device. |
| Targeting or advertising cookies | These cookies are used to deliver adverts more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of our advertising campaigns. They also remember when you have visited the website before. Sometimes we share anonymised information about your browsing activity with our advertising and creative partners. They may use this information to advertise products, which may interest you, on other websites or to assist us develop future advertising campaigns. |
Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.
How you can control cookies
Your web browser includes an option that allows you to refuse the setting of all or some cookies. However, if you do so, you may not be able to access parts of our website and it may make your browsing experience less enjoyable. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies as described above when you access our website. If you would like to delete any cookies on your computer please refer to your browser manufacturer's instructions by clicking 'help' in your browser menu.
How do we use your personal information?
| We may use your personal information to: | How do we use personal information for this purpose? | What is the legal basis for us processing your information in this way? |
| Comply with legal requirements and exercise or defend legal claims. | We may sometimes need to process personal information to comply with legal requirements to which we are subject. | It is in our legitimate interests to process personal information for the purposes of exercising and defending legal claims. Processing personal information may also be necessary to ensure compliance with our legal obligations. |
| Keep an up to date suppression list where you have asked not to be contacted, so we do not inadvertently re-contact you. | We may need to process your personal information in order to keep our website safe and secure and protect against illegal or fraudulent activity such as cyber-attacks. | It is in our legitimate interests to monitor how our website is used to detect and prevent fraud, other crimes and the misuse of our website. This helps us to ensure that you can safely use our website. |
| Keep an up to date suppression list where you have asked not to be contacted, so we do not inadvertently re-contact you. | We understand that you may prefer for us not to contact you. We keep records of your preferences to ensure that we do not contact you if you have asked us not to. We may need to process certain of your personal information (such as your name and email address) in order to do this. | It is in our legitimate interests to process personal information in order to maintain an up to date suppression list and ensure that we do not contact you where you have asked us not to. |
Where we store your personal information
The personal information that we collect from you will be stored in Dubai, although it
could be transferred to any company within TECOM Group, regardless of geographic location, in the process of our
business operations.We will take all steps that are reasonably necessary to ensure that your personal information is
treated securely and in accordance with this policy and applicable data protection laws.
Security of personal information
All information you provide to us via our website is stored on our secure
servers.
We have taken steps to safeguard the integrity of our communications and computing infrastructure, which includes
implementing authentication, monitoring, auditing, and encryption technology. Security measures have been integrated
into the design, implementation, and day-to-day operations of this website as part of our continuing commitment to
the security of electronic content and the electronic transmission of information. Despite our best efforts
unfortunately the transmission of information via the internet is not completely secure. Although we have
strict procedures and security measures in place, we cannot guarantee the security of your data transmitted to our
site.
Third party websites and apps
Our websites may contain links to and from third party websites. Please note that
if you follow a link to any of these websites, these websites will have their own terms of use and privacy policies
and that we do not accept any responsibility of liability for these policies. Please check these policies
before you submit any personal data to these websites.
Your rights
You have the following rights with respect to the personal information
that we hold about you.
Your right to access the information we hold about you
You can request access to the information we hold about you by
contacting us using the contact details set out below. Our file of your information will usually be made
available to you within 30 days, although occasionally we may not be able to give you access to the personal
information we hold about you (for example, we may not be able to give you access if it would unreasonably affect
someone else's privacy or if giving you access poses a serious threat to someone's life, health or safety). Please note that we may apply an administrative charge for providing access to your information in certain
circumstances. Any such charge will be reasonable and we will advise you of the charge and obtain your consent
before providing you with access to your personal information.Please note that if you request a copy of your data
using electronic means (such as email), then we will provide a copy of your information in electronic form unless
you ask us to do otherwise.
Your right to object to us processing your personal information
You have the right to object to us processing your personal
information, even where that processing is necessary for our legitimate interests (for example, where the processing
is necessary for the legitimate commercial objectives we pursue in the course of our business). You also have the
right to object to any results of a processing activity that prejudice your rights and that are conducted
exclusively through automated systems.
You also have the right to ask us to stop processing your personal information
for direct marketing purposes, including any profiling we undertake for the purposes of direct marketing. We
will in any case only send you marketing communications if you have previously agreed to this, but if you change
your mind you can easily unsubscribe from our marketing communications at any time by following the instructions
included in these marketing communications.
Please note that, if you have consented to receive offers from our
partners, our partners are responsible for taking account of your rights, including your right to opt-out of
receiving offers from them.
Your right to have your personal information transmitted to another organisation
Where we hold personal information about you with your consent or for
the performance of a contract with you, you also have the right to ask us to provide you with the personal
information we hold about you in a structured, commonly used and machine-readable format and, where technically
feasible, to transmit that personal information to another organisation.
Making a complaint
You have the right to lodge a complaint with a local data protection
authority in the EEA if you believe that we have not complied with applicable data protection laws.
The local data
protection authority will differ depending on the country you are in.
Contacting us
If you have any questions or concerns about how we treat your personal
information, you wish to ask us to stop processing your personal information, or you would like to request a copy of
the personal information we hold about you, please contact us here or by
writing to us at:
TECOM Investments FZ-LLC
Dubai Studio City
PO Box 73000
Dubai
United Arab Emirates
Please include your reply address when you write to us.
How long do we keep your personal information?
Your personal information is stored by us and/or our Service Providers, strictly to the
extent necessary for the performance of our obligations and strictly for the time necessary to achieve the purposes
for which the information is collected, in accordance with applicable data protection laws. When we no longer need
to use your information, 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 (unless we need to keep your information to comply with legal or
regulatory obligations to which we are subject).
Changes to this Policy
We may update this policy from time to time in response to changing
legal, regulatory or operational requirements. Any changes will be updated on our website. Your continued use
of our website and/or services after any such updates take effect will constitute acceptance of those changes.
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INTRODUCTION
We are committed to protecting and respecting your privacy. This Privacy Notice (the “Notice”) governs the collection and use of personal data by DHAM LLC. It 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 DHAM LLC please see www.dubaiholding.com.
References to "our", "us" or "we" within this Notice are to DHAM LLC, P.O. Box 66000 Dubai, United Arab Emirates, privacyoffice@dham.ae.
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WHO WE ARE
DHAM 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 DHAM LLC entities, their contact details and the country in which each of these entities operates. This will enable you to identify the relevant DHAM 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@dham.ae.
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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.
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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.
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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
Description of Processing Purpose for Processing Category of Personal Data Lawful Basis Asset Management Operations We process your personal data for marketing purposes, such as personalising offers for you, as well as for analytics purposes. Advertising / Marketing Services, Analytic Services Identification Data, Contact Details, Web Data, Other Personal Information As appropriate we will process your personal data in reliance upon consent provided, or for our legitimate interest. We manage your personal data related to customer management and vendor evaluation for events and partnerships. Operations, Business Development Identification Data, Contact Details, Financial Data, Other Personal Information We process personal data in line with our contractual obligations. Where applicable, we may also rely upon your consent to do so. We process your personal data for retail operations including management of retail assets, promotional activities, security, sub-contracting, retail leasing and sponsorship. Operations, Advertising / Marketing Services Identification Data, Contact Details, Financial Data, Other Personal Information We rely upon legitimate interest to process your personal data. We process your personal data for customer services and partner relationship management. Customer Service Identification Data, Contact Details, Financial Data, Other Personal Information We process personal data in line with our contractual obligations. We process your personal data related to issuance and renewal of leases. Tenant Management Identification Data, Contact Details, Financial Data We process personal data in line with our contractual obligations. We process your personal data related to master planning of land assets and project management. Governance Identification Data, Contact Details We process personal data in line with our contractual obligations. We process your personal data for dispute management and relevant escalation where necessary. Litigation & Disputes Identification Data, Contact Details, Other Personal Information We process personal data in line with our contractual obligations. Where applicable, we may also rely upon our legal obligation to do so. We process your personal data to manage residential leasing operations. Operations Identification Data, Contact Details, Financial Data We process personal data in line with our contractual obligations. Working with Third Parties We process your personal data for all government and visa related services. Supporting Service Identification Data, Contact Details, Financial Data, Other Personal Information We process personal data in line with our contractual obligations. We process your personal data for all company establishment related services. Supporting Service Identification Data, Contact Details, Financial Data We process personal data in line with our contractual obligations. We process your personal data to manage client relations and facilitate set up of relevant business licenses. Customer Service Identification Data, Contact Details, Financial Data We process personal data in line with our contractual obligations. Internal Business Operations 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, Audit Purposes Identification Data, Contact Details, Financial Data We rely upon legitimate interest to process your personal data. We process your personal data in order to comply with legal requirements and exercise or defend legal claims. Litigation & Disputes 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. 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. Security Purposes Identification Data, Contact Details, Web Data We rely upon legitimate interest t to process your personal data. Process personal data in relation to the usage of Wi-Fi services provided at our locations. Security Purposes Identification Data, Contact Details We rely upon legitimate interest to process your personal data. We process your personal data for management of call center queries and related activities. Customer Service Identification Data, Contact Details, Other Personal Information We rely upon legitimate interest to process your personal data. We process your personal data in order to provide medical care where required. This includes COVID-19 processes and procedures Operations Identification Data, Contact Details, Other Personal Information We process personal data in line with our legal obligations. We process your personal data for sales operations including building relationships through leads and on boarding new customers. Business Development Identification Data, Contact Details, Financial Data We rely upon legitimate interest to process your personal data. We process your personal data for market research purposes. Strategy Identification Data, Contact Details We rely upon legitimate interest to process your personal data. We process your personal data in line with our corporate social responsibility commitments. Corporate Social Responsibility Identification Data, Contact Details 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 DHAM 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.
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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.
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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 DHAM 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 DHAM 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:
Category of Third-Party Purpose for Disclosure Legal and Professional Advisers Audits, Invoicing, Legal Requirements, Transaction processing Finance, Insurance and Credit Providers Invoicing, Payment Processing, Insurance, Valuation Government Bodies, Regulators Audits, Customer Queries, Invoicing, Legal Requirements, Improving our Service, Progress the Transaction IT, Digital, Technology and Telecoms Audits, Customer Queries, Application Security and Support, Improving our Service -
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.
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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. DHAM 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 DHAM 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@dham.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.
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SECURITY OF PERSONAL DATA
DHAM 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.
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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@dham.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@dham.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.
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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@dham.ae or by writing to us at: P.O. Box 66000, Dubai, United Arab Emirates. Please include your reply address when you write to us.
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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.