Privacy Policy

ACM Limited (the ‘Firm’) and its affiliates are committed in providing the highest level of protection regarding the processing personal data based on applicable data protection laws and regulations.

We provide this Privacy Policy (the ‘Policy’) to inform you of our Privacy Policy and practices, and of the choices, you can make about what information is collected, the manner in which that information is collected and how that information is used. This policy describes how the Firm as head office in the United Arab Emirates (UAE) and its concerned affiliate(s) – when you are dealing with Firm’s Affiliate - may collect, use, store, data transfer on a legal basis or otherwise process your personal data including personal data provided when using Firm’s websites (the ‘Websites’).

Personal data comprises all the details that Firm collects and processes directly or indirectly about you as a Firm’s website visitor, individual client or representative of a corporate client, for instance information about your identity and contact details (such as name, email id, contact number), your transactions, your financial information, interactions or dealings with the Firm and its affiliates, including information received from third parties and information collected through use of Affiliate Websites, cookies.


Processing Personal Data

The Firm may process your Personal Data as an individual client or a representative of a corporate client, job candidates, and employees for the following purposes:

  1. Persons of the business line(s) concerned by the products and services provided;
  2. Persons of the marketing department;
  3. Persons of the legal and compliance department(s) concerned;
  4. Persons of the accounting department(s) concerned;
  5. Persons of the IT department(s) concerned;
  6. Persons of selected service providers who support the Firm in the provision of adequate and qualitative products and services.

When you are in a relationship with an Affiliate entity within the European Economic Area (EEA), your personal data may be transferred to the Firm in THE United Arab Emirates or any affiliate located outside the EEA, including Switzerland, Russia, for the purposes mentioned above only or to their local service providers for support in the pursuance of such purposes.


Data Subject Rights

Subject to applicable law, regulations and/or industry guidelines, you may have the right to invoke a data subject right in relation to your personal data being processed by the Firm.

The Firm may be allowed by law, in particular in case of excessive or manifestly unfounded request, to charge a fee for fulfilling your request, subject to applicable conditions. The rights that you can invoke as a data subject can be:

1 — Right of Access

You have the right to obtain from the Firm confirmation as to whether or not personal data concerning you is being processed, and, where that is the case, access to the personal data and the following information:

  1. The purposes of the processing;
  2. The categories of personal data concerned;
  3. The recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
  4. Where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
  5. The existence of the right to request from the Firm rectification or erasure of your personal data or restriction of the processing of such data or to object to such processing;
  6. The right to lodge a complaint with a supervisory authority;
  7. Where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
  8. The existence of automated decision-making, including profiling, and meaningful information about the logic involved; and
  9. Where applicable, the transfer of personal outside United Arab Emirates and appropriate safeguards implemented.

The Firm shall provide a copy of the personal data undergoing processing. For any further copies requested, please note that the Firm may charge a reasonable fee based on administrative costs.

2 — Right to Rectification

You shall have the right to obtain from the Firm without undue delay the rectification of inaccurate personal data concerning you.

3 — Right to Erasure

Except in very specific cases where provided by law, you have the right to obtain from the Firm the erasure of personal data concerning you without undue delay where one of the following grounds applies:

  1. the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
  2. you withdraw your consent on which the processing is based and there is no other legal ground for the processing;
  3. you object to the processing and there are no overriding legitimate grounds for the processing;
  4. the personal data have been unlawfully processed;
  5. the personal data have to be erased for compliance with a legal obligation to which the Firm is subject;
  6. the personal data have been collected in relation to the offer of information society services directly to a child.

4 — Right to Restriction of Processing

You have the right to obtain from the Firm restriction of processing where one of the following applies:

  1. you contest the accuracy of your personal data (in such a case, the restriction will be for a period enabling the Firm to verify the accuracy of said data); the processing is unlawful;
  2. the Firm no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims;
  3. you object to processing pending the verification whether the legitimate grounds of the controller override those of the data subject.

5 — Right to Data Portability

You have the right to receive or to transmit those data to another controller in a structured, commonly used and machine-readable format, the personal data concerning you that you have provided to the Firm without hindrance from the Firm where the processing is based on your consent or on a contract and the processing is carried out by automated means.

6 — Right to Object to the Processing

You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you. The Firm shall no longer process said personal data unless it demonstrates compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims.

Such right can be exercised at any time where your personal data is processed for direct marketing purposes

Security

The security and confidentiality of your Personal Data is important to us and the Firm has invested significant resources to protect the safekeeping and confidentiality of your personal data. When using external service providers acting as processors, we require that they adhere to the same standards as r the Firm regardless of where your personal information is transferred or stored, we take all steps reasonably necessary to ensure that personal data is kept secure.

Complaint with the Competent Data Protection Authority

Finally, note that you are entitled to lodge a complaint with a competent Data Protection Authority where existing, concerning Firm’s compliance with the applicable data protection laws and regulation. If you have any questions and or need any assistance please visit the official website of Office of Data Protection - https://www.adgm.com/operating-in-adgm/office-of-data-protection/for-individuals. If you have any questions regarding this data protection policy or the protection of your personal data, please contact Firm’s Data Protection Officer and data protection team at the following:

Data Protection Officer

Dimitrios Kanias

Dimitrios.Kanias@acmgroup.ae

The Firm may in its absolute discretion update this policy from time to time, and you are responsible to visit from time to time this policy in order to familiarize yourself with the applicable provisions.

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