AZRAQ Member and Event Attendee Privacy Notice

 

 

AZRAQ Member and Event Attendee Privacy Notice

AZRAQ (“we”, “us”, “our”) respects your privacy and is committed to protecting your Personal Data
(as defined under Section ( 3 ) (What Personal Data we collect), below).
The purpose of this Privacy Notice is to provide the following individuals with information about how
and why we process their Personal Data:
a. members of the public who have paid an annual membership fee and who have agreed to our
Membership Terms and Conditions (see [AZRAQ TO INSERT HYPERLINK]), including their
family members where such individuals apply for our “Family Membership” (“Members”); and
b. members of the public who attend events we organise (“Event Attendees”).
This Privacy Notice does not apply to our staff members (whether full time or part time), volunteers
(whether paid or unpaid), directors and / or contractors.
Important notes:
 This Privacy Notice is intended to meet our duties of transparency under the United Arab
Emirates (“UAE”) Personal Data Protection Law (“PDPL”).
 It is important that you read this Privacy Notice so that you are aware of how and why we are
using your Personal Data, your rights and how the PDPL protects you.
We may update this Privacy Notice from time to time. If we do so, we will communicate the updated
version to you using your registered email address.

1. Who We Are And How To Contact Us
Who we are.
AZRAQ is the Controller (as defined in the PDPL) for the purposes of the processing of your Personal
Data described in this Privacy Notice.
Our address is:
Level 41, Emirates Towers
Sheikh Zayed Road
Dubai, UAE
PO Box 31303
How to contact us.
To contact us in connection with this Privacy Notice, you can either:
 Email our Data Protection Officer at maz.fletcher@azraqme.org; or
 write to us at the postal address noted above.
Our Data Protection Officer
We have appointed a “Data Protection Officer”. This is a person who is responsible for overseeing
and advising us in relation to our compliance with PDPL (including compliance with the practices
described in this Privacy Notice).
If you want to contact our Data Protection Officer directly, you can email: maz.fletcher@azraqme.org.

2. Your Rights Relating To Your Personal Data

Your rights in connection with your Personal Data
Under certain circumstances, pursuant to the PDPL, you have the right to:
 Obtain information relating to our processing of your Personal Data. Whilst we have
endeavoured to provide as much information as possible within this Privacy Notice, you
may under certain circumstances be entitled to request additional information.
 Request access to your Personal Data. Subject to certain limitations and restrictions,
this right enables you to receive a copy of the Personal Data we hold about you and to
check that we are lawfully processing it.
 Request correction of the Personal Data that we hold about you. This enables you to
have any incomplete or inaccurate information we hold about you corrected.
 Request erasure of your Personal Data. You have the right to request that we delete
your Personal Data under certain circumstances.
 Object to processing of your Personal Data. You can request that we stop using your
processing your Personal Data under limited circumstances.
 Request the restriction of processing of your Personal Data. This enables you to ask
us to suspend the processing of Personal Data about you under certain circumstances,
for example if you want us to establish its accuracy or the reason for processing it.
 Request the transfer of your Personal Data. We will provide to you, or a third party
you have chosen, your Personal Data which you have provided to us, in a structured,
commonly used, machine-readable format. Note that this right only applies to Personal
Data we process by automated means which you initially provided consent for us to use
or where we used your Personal Data to perform a contract with you.

How to exercise your rights
If you want to exercise any of the rights described above, please contact us using the contact details
shown at Section ( 1 ) (Who We Are and How to Contact Us) above.
We may need to request specific information from you to help us confirm your identity and verify your
right to access your Personal Data (or to exercise any of your other rights). This is a security measure
to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may
also contact you to ask you for further information to assist us in responding to your request.
Please also note that in certain circumstances the rights above will not apply and/or in certain
circumstances some categories of Personal Data will be exempt from the scope of those rights. We
will notify you where this is the case.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than
a month if your request is particularly complex or you have made several requests. In this case, we
will notify you and keep you updated.
3. What Personal Data We Collect
The information from which you can be identified, directly or indirectly, and which we may collect (both
from you and from third parties), is outlined in the table below (“Personal Data”).
Category of
Personal
Data
collected

What this means

Membership
Data

We collect the following Personal Data from our Members:
– Full name
– Address
– Email Address
– Phone number

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– Emirates ID copy
– Date of birth
– Occupation
– Communications between you and us (including and communications
within any AZRAQ online chat groups we make available to our Members)

Event Data We collect the following Personal Data from our Event Attendees:

– Name
– Phone number
– Email address
– Photographs and / or video footage from AZRAQ events

4. Personal Data from Third-Party Sources
We do not collect Personal Data with respect to our Members and Event Attendees from third-party
sources.
5. How We Use Your Personal Data and Lawful Basis for Processing
We may use your Personal Data for the following purposes:
Members
– Administering your membership with us (i.e. Processing your application and any renewals)
– To add you to our community chat groups(s) (where you have indicated to us that you wish to
be added)
– Making you aware of our upcoming AZRAQ events
– Communicating with you in connection with your membership with us (including, without
limitation, informing you of updates with respect to our partners and any associated
membership benefits)
Event Attendees
– Providing you with information ahead of AZRAQ events you have signed up for via our
website
Most commonly, we will rely on one of the following legal bases under the PDPL to lawfully process
your Personal Data:
 Where we need to perform a contract we are about to enter with you, or have entered with
you (i.e. Our Membership Terms and Conditions, see [INSERT] and / or our Event Attendance
Terms and Conditions, see [INSERT])
 Where we need to comply with a legal or regulatory obligation
 Where it is necessary to initiate or defend against any actions to claim rights or legal
proceedings
 Where it is necessary to protect the interests of the individual to whom the personal data
relates (for example, we may share your Personal Data in the case of a medical emergency at
one of our events)
 Your consent, only if and to the extent to which an alternative lawful basis for processing is
not available
6. Who We Share Your Personal Data With

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Provided that we have suitable contractual assurances from such third parties, we may share, or grant
access to, your Personal Data (or limited elements of your Personal Data, depending upon the
context) with certain third parties, such as:
Service Providers. For example, we may store your Personal Data on IT databases operated by third
party providers. Third parties who provide us with IT support in managing our website may also have
temporary and limited access to your Personal Data. We may also share your Personal Data with
third parties who support in organising and delivering AZRAQ events.
Professional advisers. We may, under limited circumstances be required to share your Personal
Data with our accountants, auditors, lawyers, insurers, bankers, and other professional advisors (each
of which would be subject to appropriate professional confidentiality obligations)
Compliance and protection related sharing. Under certain limited circumstances we may need to
share your Personal Data with entities that regulate, or have jurisdiction over, us (such as regulatory
authorities, public bodies, and judicial bodies). We may also share your Personal Data in the context
of protecting our, your or others’ rights, privacy, safety, or property (including by establishing, making,
and defending legal claims).

7. International Data Transfers
We may share your Personal Data with third parties, such as our IT database provides, who are
based outside the UAE in connection with the processing of Personal Data described in this Privacy
Notice.
We do so pursuant to contractual commitments from such third parties with respect to their processing
of your personal data securely and lawfully.
You can contact us if you want further information with respect to any international transfers of your
Personal Data.

8. How We Keep Your Personal Data Secure
We have put in place appropriate security measures to prevent your Personal Data from being
accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed.
We limit access to your Personal Data to those staff members who have a clearly defined need to
have such access to perform their function. All such individuals are subject to a contractual duty of
confidentiality.
We have put in place procedures to deal with any actual or suspected Personal Data breach. In
addition, in certain circumstances (e.g., where we are legally required to do so) we may notify you of
breaches affecting your Personal Data.

9. How Long We Store Your Personal Data
We retain your Personal Data for as long as is necessary for the processing purpose(s) for which it
was collected, as set out in this Privacy Notice, and any other permissible, related purposes. For
example, we may retain certain information to comply with regulatory requirements regarding the
retention of such data, or in the event a litigation hold is imposed.
When Personal Data is no longer needed, we either irreversibly anonymise the data (and we may
further retain and use the anonymised information) or securely destroy the Personal Data.

10. No Automated Decisions
AZRAQ does not envisage that you will be subject to decisions or profiling that will have a significant
impact on you using an electronic program or system that is automatically operated, completely
independently either without any human intervention, or partially independently with limited human
supervision and intervention.