This Privacy Notice applies to anyone whose Personal Data is provided to us. It sets out how and why we collect, store, use and share your Personal Data. It also tells you about the privacy rights and how the law protects you.
“We” “us” or “our” means VentureSouq Management Limited. We explain in this Privacy Notice what is considered Personal Data, methods of collection, the purposes for which it is used, the third parties to whom it may be disclosed and how individuals can exercise their rights in relation to their Personal Data. Pursuant to our obligation(s) under the Abu Dhabi Global Market (“ADGM”) Data Protection Regulations 2021 (referred herein as “Applicable Data Protection Law”). It is important that you read and retain this notice, together with any other Privacy Notice we may provide on specific occasions so that you are aware of how and why we are using your Personal Data.
VentureSouq Management Limited and affiliates shall usually be the controller of your Personal Data. We may engage third parties service providers to process Personal Data on our behalf and those third parties act as processors.
This Privacy Notice applies to the following individuals (“you”):
Applicable Data Protection Law requires us to demonstrate that any Personal Data we hold about you is:
We obtain your Personal Data as follows:
“Personal Data” means data related to an identified natural person, or related to a natural person that can be identified directly or indirectly by linking the data, through the use of identification elements such as his name, voice, image, identification number, or electronic ID, geographic location, or one or more of its morphological, physiological, economic, cultural or social characteristics, including sensitive Personal Data and biometric data.
|Personal Data Type
Personal details such as:
|Residence ID details, previous ID and new ID details (ID number, name, expiry date)
Biographical information which may confirm your identity including:
Information relating to your financial situation such as:
|An understanding of your goals and objectives in procuring our services
|Information about your employment, education, family or personal circumstances, and interests, where relevant
Data contained in identification documents such as:
|Education certificate photocopy
Recruitment information such as:
|Compensation history, or performance information
|Results of background check
|Know our customer data as part of customer due diligence and to prevent fraudulent conduct or behavior that contravenes sanctions and to comply with regulations against money laundering, terrorist financing, and tax fraud
|Information about criminal convictions and offenses
The above list is by no means exhaustive and should be used merely as a point of reference from which a working definition of business purposes can be established and further developed.
“Special Categories” of particularly sensitive Personal Data require higher levels of protection. We have justification for collecting, storing, and using this type of Personal Data. We have in place an appropriate policy document, where necessary, and safeguards in compliance with the Applicable Data Protection Law. We are likely to process Special Categories of Personal Data in the following circumstances where:
We may process this Personal Data where it is required by law where it is needed to protect your interests (or someone else's interests) and you are not capable of giving your consent, where you have already made the information public, where it is required for the purposes of preventative or occupational medicine (such as the assessment of the working capacity of an employee or medical diagnosis).
We will only disclose your Personal Data to third parties if we are legally obliged to do so or where there is a need to comply with our contractual obligations to you, for instance we may need to pass on certain information to any external Service Providers including consultants or third party screening platform provider.
To comply with our regulatory obligations, we may also disclose Personal Data to the relevant government, supervisory and judicial authorities such as:
Where there is a requirement to use an intermediary, we will ensure that the Personal Data is exported to one who is either located in a jurisdiction that is deemed by the Commissioner of Data Protection as an adequate jurisdiction or we have a safeguard in place such as standard contractual clauses or a legal derogation. You may request further information on this from our Data Protection Representative.
We may be required by law to retain and use Personal Data to meet our internal and external audit requirements, for data security purposes and as we believe to be necessary or appropriate:
We will maintain clear and accessible records of all data processing activities. Your Personal Data will only be kept for as long as is necessary to fulfil the purpose we collected it for or as required by law. Where there is a legal requirement to keep the data, we will comply with the statutory retention periods.
In the case of unsuccessful candidate CV’s, we will only retain these for a period of one year after receiving, in case a suitable position arises.
As a data subject, you have a number of rights with regard to your Personal Data. You have the right to request to access and rectify your data as well as for it to be erased and to restrict the processing of your data in certain circumstances.
You also have the right to lodge a complaint with the Commissioner of Data Protection if you feel that we have not complied with our obligations under applicable data protection law regarding how we deal with your Personal Data.
Your rights pursuant to Applicable Data Protection Law amongst others:
We do not generally rely on consent as our processing reason. However, if we do so, we will provide you with full details of the information that we would like and the reason we need it so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your relationship with us that you agree to any request for consent from us.
To withdraw your consent, please contact us using the email provided below. Once we have 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 under an applicable law.
It is important that the personal information we hold about you is accurate and, where necessary, kept up to date. Please keep us informed if your personal information changes during your working relationship with us and respond promptly to our request for updates of your data.
In some cases, we are legally required to collect Personal Data, or your Personal Data may be needed before we may perform certain services and provide certain products. We undertake to request only the Personal Data that is strictly necessary for the relevant purpose. Failure to provide the necessary Personal Data may cause delays or lead to refusal of certain products and services.
We have implemented reasonable administrative, technical, and physical measures to protect your personal information against loss, misuse and alteration.
You can contact our Data Protection Representative by any of the following means for any privacy-related questions, including regarding how we collect, store, and use your Personal Data:
You have the right to make a complaint at any time to the ADGM Commissioner of Data Protection, which is the relevant authority that safeguards your interests.
We may amend this Privacy Notice to remain compliant with any changes in law or to reflect how our business processes Personal Data. This version was created and published on 18 September 2023 and enters into force on 11 September 2023. The most recent version is available on our website.