Privacy Policy

1.         THIS NOTICE AND INFORMATION ABOUT US

1.1 This Privacy Notice sets out how Abu Dhabi Global Market (ADGM, we or us) and its group of affiliates and third party service providers use and protect your personal information through your use of the ADGM application (which was last updated on 04/12/2024) (our Application or the Application). The Application is owned and operated by ADGM and we are the controller, and responsible for, your personal data.

1.2 This Privacy Notice, together with the terms of use accessible at terms of use and any additional terms and conditions incorporated by reference into the terms of use apply to your use of our Application and the services you receive or connect to via the Application (the Services).

2.         CHANGES TO THIS NOTICE

2.1 We keep this Privacy Notice under regular review. This version was last updated on 04/12/2024, but we may revise this Privacy Notice from time to time. If this Privacy Notice changes, the changes will be posted on this page, and where appropriate, we will provide an in-Application notification to you. The new Privacy Notice may be displayed on-screen and you may be required to read and accept the changes to continue your use of our Application or any of the Services.

3.         WHAT TYPE OF PERSONAL INFORMATION DO WE COLLECT?

3.1 Once you submit or upload information through our Application, we will know who you are and your activities on this Application and information about you and/or your company may be recorded on our systems. For example, we may ask for the following types of personal data when you complete an online form on our Application or sign up as a registered user:

• your name;
• your phone number;
• your employer’s company name;
• the country where you are based; location is tracked if opted in.
• marketing and sales information (e.g. newsletters, documents received, invitations to and participation at events, personal preferences and interests, opt-in and opt-out declarations); and
• your comments/questions.

If you are a Community User or Authorised User of our Application, we may ask for the following additional types of personal data:

• your work permit ID
• your work permit expiry date;
• your registry ID;
• your PIN;
• your interests; and
• your favourites.

3.2 We do not collect any “Special Categories” of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data).

3.3 In providing certain Services via the Application, we may also receive personal data about you from third party providers of the Services and/or social media platforms integrated within our Application, including basic information about you (including, without limitation, your name, gender, account information, date of birth and email address), together with any other personal data you have made publicly available on such third party sites or platforms (which may include photos).

4.         HOW DO WE COLLECT YOUR PERSONAL DATA?

4.1 We will collect and process your personal data in the following ways:

• (a) Information you provide us. This is personal data you consent to giving us about you by populating forms on the Application or by corresponding with us (for example, by email or chat). This includes personal data you provide when you: (i) register as a user of the Application; (ii) download the Application; (iii) upload documents or data onto the Application or via any Service; (iv) share your data via the Application’s social media functions; (v) register to attend events hosted in ADGM; (vi) contact us (for instance, to report a problem with the Application or the Services, share feedback about the Application or request a call back); and/or (viii) subscribe to, search for or use the Services on the Application.
• (b) Location data. Some of the location-enabled Services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. Where you consent to sharing your data for this purpose, we will use location-tracking technology within your device to determine your current location. You can withdraw your consent at any time by disabling location data in your settings.
• (c) Information we receive from other sources, including third parties and publicly available sources. We will receive personal data about you from various third parties, including providers of social media platforms integrated with our Application, the ADGM Registration Authority and other providers of Services or advertisers on the Application who you elect to contact. We may also collect personal data about you from publicly-available sources integrated within our Application.

5.         HOW DO WE USE YOUR PERSONAL INFORMATION?

5.1 We use your personal data for various reasons, including:

• installing our Application on your device and registering you as a user of our Application;
• establishing and maintaining a responsible commercial and legal relationship with you;
• delivering the Services to you or making available the Services for you to connect with via the Application;
• making recommendations to you about goods or services which may interest you;
• notifying you of products and events which may be of interest to you;
• notifying you with any changes to the Application and/or the Services;
• answering your queries or complaints;
• internal record keeping; and
• meeting our legal and regulatory requirements.

6.         ON WHAT LAWFUL BASIS WILL WE PROCESS YOUR PERSONAL DATA?

6.1 We use and process your personal data on the following lawful bases:

• (a) Where we have your consent. We will process your personal data with your consent for a specific purpose, including: (i) installing our Application on your device and providing you with the Services; (ii) delivering content and advertisements to you; (iii) responding to queries you have raised; and (iv) sending you updates and information that you have requested. You may withdraw your consent at any time by changing the relevant settings on the Application or contacting us in accordance with Section 15 below, although if you do so, it does not mean that anything we have done with your personal data with your consent up to that point is unlawful and we may be able to continue to process your personal data to the extent required or permitted by law, including in order to comply with our legal or regulatory obligations. This includes your right to withdraw consent to us using your personal information for marketing purposes.
• (b) To provide a requested service or product, or to carry out a contract with you. We will process your personal data where such processing is necessary for the performance of a contract, such as to provide you with our Application and the Services.
• (c) For a legitimate purpose. We will process your personal data where it is relevant and necessary for our legitimate interests, including: (i) developing our services; (ii) ensuring compliance with applicable laws; (iii) preventing loss and misuse of our proprietary materials; (iv) maintaining the security of our Application, network and systems; (v) detecting unauthorised, excessive or inappropriate use of our Application; and (vi) keeping our records updated and to analyse how our customers and users use our Application and the Services.
• (d) Where we have a legal obligation. We will process your personal data in order to comply with our legal and regulatory obligations, including responding to requests from supervisory or regulatory authorities and law enforcement agencies.

6.2 Whenever we process your personal data, such processing shall be conducted in accordance with applicable laws and regulations and with the use of appropriate security measures

6.3 It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.

7.         WHAT HAPPENS IF YOU DO NOT PROVIDE US WITH THE PERSONAL DATA WE REQUEST OR ASK THAT WE STOP PROCESSING YOUR PERSONAL INFORMATION?

If you do not provide the necessary personal data, or you refuse or withdraw your consent at any time for the processing of your personal data, we may be unable to provide certain services, products or information to you, and you may not be able to make use of certain products, services and information offered by us.

8.         WHO DO WE SHARE PERSONAL DATA WITH?

8.1 We share your personal data with trusted third parties where we have retained them to perform functions on our behalf and who also provide services to us, such as professional advisors, cloud service providers, managed service providers and IT consultants carrying out testing and development work on our business technology systems, research and mailing houses and function coordinators and, to the extent necessary in connection with the Application and our products and services, sub-processors, suppliers and subcontractors. We may also share your personal data with third parties who provide products and/or Services that you have requested. These third parties comply with similar and equally stringent undertakings of privacy and confidentiality.

8.2 We may also share your personal data with our other group companies for internal reasons, primarily for business and operational purposes. If another entity acquires us or merges with us, your personal data may be disclosed to such entity. Also, if any bankruptcy or reorganization proceeding is brought by or against us, all such information will be considered an asset of ours and as such it is possible it will be sold or transferred to third parties.

8.3 Where required, we may share your personal data with other third parties, including: (a) to comply with a legal or regulatory obligation; (b) when we believe in good faith that an applicable law requires it; (c) with governmental, public or regulatory authorities and institutions insofar as a statutory or regulatory obligation exists; (d) with auditors or dispute resolution bodies; (e) to verify or enforce our applicable policies; (f) to detect and protect against fraud, or any technical or security vulnerabilities; (g) to respond to an emergency; or (h) otherwise to protect the rights, property, safety, or security of third parties, visitors to our website, our business or the public.

9.         WILL YOUR PERSONAL DATA BE TRANSFERRED TO ANOTHER JURISDICTION?

Your personal data may be processed by ADGM and the third parties described above, outside of the country in which you are based. Where the data protection regulator in your home country has not issued an adequacy decision in relation to the jurisdiction where your personal data is to be processed, we will ensure that there are adequate mechanisms in place to protect your personal data in accordance with applicable data protection and privacy laws, including, where applicable, through use of data transfer agreements implementing standard data protection clauses published or approved by a data protection regulator. At all times we will transfer your personal data in accordance with applicable laws and regulations and employ appropriate security measures for the transfer of your personal data, which are technically and reasonably possible. Please contact us in accordance with Section 15 below if you would like more information about the specific mechanisms we use when transferring your personal data outside of your jurisdiction.

10.         HOW DO WE SAFEGUARD YOUR PERSONAL DATA?

We use various technical and organizational methods to help protect and safeguard your personal data. The nature of the safeguards we implement varies depending on the nature and sensitivity of the personal data, the scope of the personal data, whether that personal data will be transferred outside of the country in which you are based and the method of storage of that information. More sensitive types of personal data will be safeguarded by a higher level of protection, such as encryption. If you would like more information about the safeguards we have in place, please contact us by using the contact form set out below

11.         HOW LONG DO WE RETAIN YOUR PERSONAL DATA?

11.1 The personal data we collect will be retained for such periods as necessary to fulfil the purposes set out in this Privacy Notice, or for longer periods in accordance with applicable data protection laws. Otherwise, we will only keep your personal information for no more than six years thereafter.

11.2 We will irretrievably delete your personal data upon the expiry of the applicable retention period described in Section 11.1 above.

12.         WHAT ARE YOUR RIGHTS?

12.1 By law you have a number of rights when it comes to your personal data, as further detailed below. Further information and advice about your rights can be obtained from the ADGM data protection regulator.

• (a) The right to object to processing. You have the right to object to certain types of processing, including processing for direct marketing (i.e. if you no longer want to be contacted with potential opportunities).
• (b) The right to be informed. You have the right to be provided with clear, transparent and easily understandable information about how we use your personal data and your rights. This is why we are providing you with the information set out in this Privacy Notice.
• (c) The right of access. You have the right to obtain access to your personal data (if we are processing it), and certain other information (similar to that provided in this Privacy Notice). This is so you are aware and can check that we are using your personal data in accordance with data protection law.
• (d) The right to rectification. You are entitled to have your personal data corrected if it is inaccurate or incomplete.
• (e) The right to erasure. This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your personal data where there’s no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions.
• (f) The right to restrict processing. You have rights to ‘block’ or suppress further use of your personal data. When processing is restricted, we can still store your personal data, but may not use it further. We keep lists of people who have asked for further use of their personal data to be ‘blocked’ to make sure the restriction is respected in future.
• (g) The right to data portability. You have rights to obtain and re-use your personal data for your own purposes across different services. For example, if you decide to switch to a new provider, this enables you to move, copy or transfer your personal data easily between our IT systems and theirs safely and securely, without affecting its usability.
• (h) The right to lodge a complaint. You have the right to lodge a complaint about the way we handle or process your personal data with your national data protection regulator.

12.2 You may exercise any of the above rights by contacting us to submit a request in accordance with Section 15 below.

12.3 We will usually act on requests and provide information free of charge, but may: (a) charge a reasonable fee to cover administrative costs for providing information; or (b) refuse to act on request in respect of:

• unreasonable or excessive or repeated requests; or
• requests for further copies of the same information.

12.4 We will respond to requests as soon as we can, which will generally be within one month from our receipt of your request. We will inform you if we expect that our response to your request will exceed this period.

12.5 In certain circumstances and in accordance with applicable data protection laws, we may not be able to provide you with access to all your personal data we hold, for example, if the personal data in question relates to information to be disclosed by applicable law (including by court order) or in connection with legal proceedings, obtaining legal advice or establishing, exercising or defending legal rights, or relates to information in respect of which a claim to legal professional privilege could be maintained in legal proceedings or in respect of which a duty of confidentiality is owed by a legal professional advisor is owed to its client.

13.         YOUR ROLE IN PROTECTING YOUR PERSONAL DATA

13.1 Please remember that this Privacy Notice and our use of your personal data only applies to the personal data you provide directly to us by accessing and using our Application and receiving our products or the Services. Our Application and the Services may sometimes include links to other websites which are not within our control. Please note that these websites and any services that may be accessible through them are outside of our control and we do not accept any responsibility or liability for any personal data that may be collected through those websites or services. You should exercise caution and look at the privacy statement applicable to the website or service in question before you provide any information to these websites or use these services.

14.         HOW CAN I MAKE COMPLAINTS OR ASK QUESTIONS?

14.1 You may direct any questions or inquiries with respect to the privacy principles outlined above or about the privacy practices described in this Privacy Notice by contacting us in accordance with Section 15 below.

14.2 We will investigate all complaints and respond to all questions asked by you. If a complaint is found to be justified, we will take appropriate measures to resolve the complaint, which may include amending its policies and procedures.

15.         CONTACT

15.1 We may contact you by email or by in-app notifications, based on the information you provide us with.

15.2 If you have any enquiries about the processing of your personal data, you may contact us by email at: dpo@adgm.com or by populating a general enquiry form on the Application.