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Policy

 

Last Updated: 05/12/2021

 

INTRODUCTION

We are committed to protecting and respecting your privacy. This Privacy Notice (the “Notice”) governs the collection and use of personal data by 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.

 

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.

 

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

Description of ProcessingPurpose for Processing Category of Personal DataLawful 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 ServicesIdentification 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 DevelopmentIdentification 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 PurposesIdentification 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.

 

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-PartyPurpose for Disclosure
Legal and Professional AdvisersAudits, Invoicing, Legal Requirements, Transaction processing
Finance, Insurance and Credit ProvidersInvoicing, Payment Processing, Insurance, Valuation
Government Bodies, RegulatorsAudits, 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.

 

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.

 

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.

 

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.

 

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 orby writing to us at: P.O. Box 66000, 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.