Last updated: February 2024

1. Background

I. This Policy is addressed to individuals outside our organisation with whom we interact, including individual clients, representatives of client organisations, visitors to our https://ach-legal.com website (the “Website”), and other users of our services (together, “you”). We are committed to safeguarding the privacy of all visitors to our Website as well as the security of any Personal Data (as defined below) that you share with us through this Website. The Website is owned and operated by Anjarwalla Collins & Haidermota Legal Consultants and/or its affiliates and subsidiaries (together “we”, “us” or “AC&H”) in the United Arab Emirates (“UAE”). We want you to know how your personal information and data is collected, used, and shared when you visit the Website. Where we need to process your Personal Data, for a legitimate purpose, we do so in accordance with applicable law. In this case, “process” or “processing” means anything that is done with any Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction. For purposes of this Privacy Policy, the term Personal Data shall mean any information relating to:

a) an identified natural person; or

b) an identifiable natural person, that is, a natural person who can be identified directly or indirectly, by reference to an identifier that relates to them such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that person.

II. This Privacy Policy explains that AC&H may collect, use, share, safeguard and/or otherwise process information (including Personal Data) provided through the Website.

III. By visiting the Website or supplying information through its associated customer service channels, you are consenting to the practices described in this Privacy Policy. Please note that our Privacy Policy is updated from time to time. The date of the last revision to the Privacy Policy will be indicated by the “Last Updated” date. We reserve the right to amend the Privacy Policy at any time for any reason. You will be bound by the most recent update of the policy appearing on our Site. It is therefore your responsibility to continue to check our Privacy Policy for updates.

IV. In accordance with our legal obligations we herein inform you of the following:

a. your rights as the subject of the Personal Data which we collect from you (see section 8 below);

b. the fact that we are collecting your Personal Data from you (see sections I – 2.IV);

c. the purpose for which we intend to collect your Personal Data, including why we are collecting your Personal Data and how we plan to use it (see section 3 below);

d. the third parties to whom your personal data will be shared or transferred, including details of safeguards adopted (see sections 5 and 6 below);

e. the contacts of the data controller or data processor who will process your Personal Data (see section 9 below);

f. a description of the technical and organisational security measures taken to ensure the integrity and confidentiality of the data (see section 6 below); and

g. whether the data being collected pursuant to any law and whether such collection is voluntary or mandatory (see section IV. below); and

h. the contact information if you like to exercise your rights regarding the processing of your Personal Data (see section 8 and 9).

2. Collection of Information

I. When you interact with us, we are (or propose to be) dealing with, or providing or marketing our services to you, a client, or someone employing or engaging you, whether by using our Website or communicating with us, we may collect the following information about you:

a) Information you give us (e.g. when you fill in any form on the Website or subscribe to our publications or register to attend a seminar. If the Personal Data is intended to be collected pursuant to any law or where the collection of such Personal Data is mandatorily required, we will notify you of this directly prior to collecting such data., which can include the information set out in section 2.I. above;

b) In the course of our relationship with you (e.g. if we provide legal service to you)

c) In case you make your Personal Data public (e.g. if you make a public post on social media);

d) Information we receive from other accounts or sources (e.g. law enforcement authorities);

e) Information our IT systems collect about you which includes IP address, operating system and web browser that you use to access our website and also when you visit our Website, our server will record your IP address together with the date, time and duration of your visit. An IP address is an assigned number, similar to a telephone number, which allows your computer to communicate over the Internet. It enables us to identify which organisations have visited the Website.

II. In the course of your use of the Website or your interaction with us through the Website, we may collect Personal Data directly from you save for instances where the law permits us to collect your Personal Data from other sources. The types of Personal Data that may be collected may include your name, contact details, photo, job title or position and, particularly if you are a client or potential client or employed or engaged by one, your expertise and interests. Where relevant, we may collect other Personal Data– for example, your membership of professional associations or boards or, in rare cases, financial information.

III. If you apply for a job with us, we may certain Personal Data from you such as your name and contact details and information about your working history collect besides the Personal Data set out in section 2.I. We may also collect your Personal Data from relevant records checks, from any recruitment consultant and from your previous employers, universities and others who may be able to provide information to us to assist us in our decision on whether or not to make you an offer of employment. As part of the job application process and in every other instance where we intend to collect your Personal Data from other sources besides you, you can – in accordance with your rights set out in section 7 – request, which Personal Data we intend to collect or we already collected. In instances where you apply for any employment position with us, you agree that by so doing, you are validly consenting to our collection of your relevant Personal Data from other sources for purposes of evaluating your application.

IV. Should we ever collect your Personal Data from sources other than you, in any other context besides where you have applied for employment with us, we will, in so far as it is practicable, notify you before we collect such Personal Data from such other sources.

V. Please note that the provision of your Personal Data to us may be necessary for enabling the use or functioning of certain features of the Website or the provision of certain services through the Website. To that extent, any such features or services may not be functional or available for use or capable of being used in the absence of the provision of your Personal Data.

3. Purpose of Collection and Use of Personal Data

I. Once collected, we may use your Personal Data in a variety of ways including, but not limited to:

a) providing you with service communications such as legal advise, bill reminders, programme registrations and client service messages;

b) responding to your emails or online requests for products, services or information;

c) delivering and processing surveys;

d) personalising and improving the usability of the Website;

e) fulfilling and/or delivering our products and services;

f) tailoring content, advertising and marketing to you;

g) sharing your Personal Data with certain third parties so as to fulfil any express service requests which you make to us. We may also share such information with service providers that perform business functions for us.

II. The tracking of your IP address enables us to identify which organisations have visited the Website. We use this information to compile statistical data on the use of our Website to track how users navigate through our Website in order to enable us to evaluate and improve our Website.

4. Cookies Policy

We use the following categories of cookies on our Site:

I. Strictly necessary cookies: These cookies are essential in order to enable you to move around the Website and use its features. Without these cookies, services you have asked for cannot be provided. These cookies will also inform us, about your behaviour on our website, if we can do business with you and protect us from fraudulent activities.

II. Performance cookies: These cookies collect anonymous information on how you use our Website (e.g. we use Google Analytics cookies to help us understand how customers arrive at the Website, browse or use the Website and highlight areas we can improve such as navigation). The data stored by these cookies does not show personal details from which your individual identity can be established. You may opt-in to these cookies using your browser settings.

III. Functionality cookies: These cookies remember choices you make such as the country you visit our website from, language and search parameters. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites. You may opt-in to these cookies using your browser settings.

5. Sharing your information

I.We may on occasion be required to share your information with AC&H members, offices and affiliates and any associated firms in Africa and any third parties, who provide services on our behalf. In relation to any such disclosure of your Personal Data, we will only disclose your Personal Data where you have given your consent or where we are required or otherwise permitted to do so by any applicable law, or where it is necessary for the purpose of, or in connection with, legal proceedings or in order to exercise or defend legal rights.

II. We may also share email addresses with third parties as necessary for them to perform certain services on our behalf, such as packaging, mailing and delivering products to you and processing event registrations and responding to your service requests. Some of your Personal Data may be stored in a cloud located within or outside UAE and managed by a third-party service provider. Where we transfer your Personal Data outside UAE we will take reasonable steps to ensure that your Personal Data is treated securely and that the means of transfer provides adequate safeguards.

III. We implement commercially reasonable security measures to help protect against unauthorised access to or unauthorised alteration, disclosure, or destruction of data. Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. Accordingly, and despite our efforts, we cannot guarantee or warrant the security of any information you transmit to us, or to or from our online products or services.

6. IT Security

I. We use up to date data storage and security systems to hold your Personal Data securely in electronic and physical form to protect your personal information from unauthorized access, improper use or disclosure, unauthorized modification or unlawful destruction or accidental loss. Our IT usage and security policy is supported by various security standards, processes and procedures. Our premises are access controlled and our electronic databases require logins and password authentication.

II. All our partners, staff and third party service providers who have access to confidential information (including Personal Data) are subject to confidentiality obligations.

7. Data Retention

I. We take every reasonable step to ensure that your Personal Data are only retained for as long as they are needed.

II. The criteria for determining the duration for which we will keep your Personal Data are as follows: we will retain copies of your Personal Data in a form that permits identification only for as long as is necessary in connection with the purposes set out in this Policy, unless applicable law requires a longer retention period. In particular, we may retain your Personal Data for the duration of any period necessary to establish, exercise or defend any legal rights.

8. Your Rights

I. You have certain rights that you can exercise in relation to any of your Personal Data that we process. These are:

a) The right to be informed of the use to which your Personal Data is to be put. In case of an inquiry submitted to us other than in writing we will most probably request proof from you in such a situation in order to confirm that you are actually the person you claim to be.

b) The right to access your Personal Data and the right to object to the processing of all or part of your Personal Data.

c) The right to the correction or deletion of any false or misleading parts of your Personal Data.

d) Also, to request that we erase your Personal Data to the extent that they are no longer necessary for the purpose for which we need to keep processing them, as we have explained above, or when we are no longer legally permitted to process them.

e) The right to receive your personal Data in a structured, commonly-used and machine-readable format and to transmit it from us to another data controller or data processor without hindrance (the right to data portability);

f) The right not to be subjected to a decision based solely on automated processing which produces legal effects that concern or significantly affect you; and

g) the right to the rectification of any inaccurate, outdated, incomplete or misleading portions or parts of your Personal Data and to the erasure or destruction of any portions or parts of your Personal Data that are irrelevant, excessive, unlawfully obtained or that we are no longer authorised to retain.

h) If you have given us your consent to process your data for any purpose, you also have the right to withdraw such consent at any time.

II. In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your Personal Data for a specific purpose, you have the right to withdraw your consent for that specific purpose at any time. Once the firm has received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to unless we have another legitimate basis for doing so in law.

III. If you would like to exercise any of these rights, please contact us in writing by emailing info@ach-legal.com or by letter to: Anjarwalla Collins & Haidermota, Saaha Offices, Block C, Office W501A, The Palace Downtown, P.O. Box 58553, Dubai, United Arab Emirates.

9. Contact Information

 I. If you would like more information concerning this privacy policy and how it affects you, please contact us at

 

Anjarwalla Collins & Haidermota

Saaha Offices, Block C, Office W501A

The Palace Downtown, P.O. Box 58553

Dubai, United Arab Emirates

 

Telephone:            +971 44 52 90 91

Email:                    info@ach-legal.com