VSQ Privacy Policy

Overview

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.

Recitals

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.

Scope

This Privacy Notice applies to the following individuals (“you”):

our prospective employees (job applicants);
anyone involved in any transaction or interaction with us, whether it is in your personal capacity or as a representative of a legal entity (for example, director, a company manager, agent, legal representative, operational staff, other authorised representative, etc.);
our customers;
our business partners;
our suppliers, advisors, consultants and/or secondees; and
website visitors.

Data Protection Principles

Applicable Data Protection Law requires us to demonstrate that any Personal Data we hold about you is:

processed lawfully, fairly and transparently;
processed for specified, explicit and legitimate purposes;
adequate, relevant and limited to what is necessary;
accurate and, where necessary, kept up to date;
kept for no longer than is necessary; and
kept securely.

Obtaining Personal Data

We obtain your Personal Data as follows:

from the information you provide to us when you meet or interact with us;
from information about you provided to us by your company or an authorised intermediary;
when you visit our website, we collect cookie data;
when you communicate with us by telephone, email or other forms of electronic communication; in this respect, we may monitor, record and store any such communication;
when you complete (or we complete on your behalf) client on-boarding or application or other forms; or
from publicly available sources or from third parties, most commonly where we need to conduct background checks about you.

Processing Personal Data

“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	Purpose
Personal details such as: Name Last name Identification number (ex: Emirates ID) Date of birth Gender Contact details (phone number(s), email address(es)) Residential and/or business address(es)	In order to enter into a contract with you at your request or to perform our contract with you. In order to meet our obligations under applicable law. For our legitimate interest in using your details to share information for the efficiency of business communications. Where we need to share your information in a life-or-death situation. Pre-employment purposes.
Residence ID details, previous ID and new ID details (ID number, name, expiry date)	For our legitimate interest in using your details to share information for the efficiency of business communications. Where we need to share your information in a life-or-death situation. Pre-employment purposes.
Biographical information which may confirm your identity including: Date and place of birth Tax identification number Passport number or national identity card Visa details Country of domicile and/or nationality	In order to enter into a contract with you at your request or to perform our contract with you. In order to meet our obligations under applicable law. Where we need to share your information in a life-or-death situation. Pre-employment purposes.
Information relating to your financial situation such as: Income Expenditure Assets and liabilities Sources of wealth Bank account details	In order to enter into a contract with you at your request or to perform our contract with you. To meet our obligations under applicable law. Pre-employment purposes.
An understanding of your goals and objectives in procuring our services	In order to enter into a contract with you at your request or to perform our contract with you. To meet our obligations under applicable law.
Information about your employment, education, family or personal circumstances, and interests, where relevant	In order to enter into a contract with you at your request or to perform our contract with you. To meet our obligations under applicable law. Pre-employment purposes.
Data contained in identification documents such as: Passport Residence visa National identity card Labor card Other similar documents	In order to enter into a contract with you at your request or to perform our contract with you. To meet our obligations under applicable law. Pre-employment purposes.
Personal photograph	In order to enter into a contract with you at your request or to perform our contract with you. To meet our obligations under applicable law. Pre-employment purposes.
Education certificate photocopy	In order to enter into a contract with you at your request or to perform our contract with you. To meet our obligations under applicable law. Pre-employment purposes.
Recruitment information such as: Copies of right to work documentation references Other information included in a CV or cover letter or as part of the application process.	In order to enter into a contract with you at your request or to perform our contract with you. To meet our obligations under applicable law. Pre-employment purposes.
Compensation history, or performance information	In order to enter into a contract with you at your request or to perform our contract with you. Pre-employment purposes.
Results of background check	To meet our obligations under applicable law. In order to enter into a contract with you at your request or to perform our contract with you. Pre-employment purposes.
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	To meet our obligations under applicable law. In order to enter into a contract with you at your request or to perform our contract with you.
Non-disclosure agreement	To meet our obligations under applicable law. In order to enter into a contract with you at your request or to perform our contract with you.
Information about criminal convictions and offenses	In order to enter into a contract with you at your request or to perform our contract with you. For our legitimate interest - Where it is necessary to share such information to protect the public against dishonesty, malpractice, or other improper behavior. To meet our obligations under applicable law. Pre-employment purposes.

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 Personal Data

“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:

in limited circumstances, we have your explicit written consent;
it is necessary to comply with the applicable law in relation to anti-money laundering or counter-terrorist financing obligations or the prevention, detection, or prosecution of any crime;
it is required for the performance of a contract or prior to entering into a contract; and
it is necessary for the compliance with specific requirements pursuant to applicable law.

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).

Sharing and Transferring Personal Data

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:

Public authorities, regulators and supervisory bodies in the countries in which we operate.
Tax authorities may require us to report customer assets or other Personal Data such as your name and contact details and other information about your organisation; for this purpose, we may process your identification data such as national identifier in accordance with applicable law.
Judicial/investigative authorities such as the police, public prosecutors, courts and arbitration/mediation bodies on their express and legitimate request.

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.

Data Retention

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:

to comply with our obligations under applicable laws and regulations;
to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include such authorities outside your country of residence;
to carry out anti-money laundering, sanctions or Know Your Customer checks as required by applicable laws and regulations; or
to protect our rights, privacy, safety, property, or those of other persons. We may also be required to use and retain Personal Data after you have doing business with us for legal, regulatory and compliance reasons, such as the prevention, detection or investigation of a crime; loss prevention; or fraud prevention.

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.

Your Rights as a Data Subject

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:

Request access to your personal information (commonly known as a "data subject access request"), this enables you to receive a copy of the personal information we hold about you and to check that we are lawfully Processing it.
Request correction of the personal information 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 information; this enables you to ask us to delete or remove personal information where there is no good reason for us to continue to Process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to Processing (see below).
Object to Processing of your Personal Data; you have the right to object where we are Processing your personal information for direct marketing purposes.
Request the restriction of Processing of your personal information; this enables you to ask us to suspend the Processing of personal information about you, for example, if you want us to establish its accuracy or the reason for Processing it.
Data portability enables you to receive or request transfer of the data you have provided us in a structured, commonly used and machine-readable format.
Object to automated Processing, including profiling which produces legal or other seriously impactful consequences concerning you.

Consent

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.

To Inform Us of Changes

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.

Are You Obliged to Provide Us With Your Personal 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.

How Do We Protect Your Personal Data?

We have implemented reasonable administrative, technical, and physical measures to protect your personal information against loss, misuse and alteration.

Contact Us

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:

Email: support@venturesouq.com
Address: DD-14-122-053, 14, WeWork Hub 71, Al Khatem Tower, Adgm Square, Al Maryah Island, Abu Dhabi, United Arab Emirates

Complaints

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.

Email: data.protection@adgm.com
Telephone: +971 23338888
Address: ADGM Commissioner of Data Protection, ADGM Authorities Building, ADGM Square, Al Maryah Island, PO Box 111999, Abu Dhabi, UAE

Changes to This Privacy Notice

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.