The Company Privacy Notice is a mandatory document for organizations operating in the UAE that collect, process, or store personal data. It is designed to comply with UAE Federal Decree Law No. 45 of 2021 and its Executive Regulations, which establish the UAE's comprehensive data protection framework. This document serves multiple purposes: it ensures regulatory compliance, provides transparency to data subjects about their rights and the organization's data handling practices, and establishes clear internal guidelines for data protection. The notice must be easily accessible to all stakeholders and should be updated regularly to reflect changes in data processing activities or regulatory requirements. For organizations operating in UAE free zones like DIFC or ADGM, additional provisions may need to be incorporated to address specific free zone regulations.
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1. Introduction: Overview of the organization and the purpose of the privacy notice
2. Scope and Applicability: Who the privacy notice applies to and what activities it covers
3. Definitions: Key terms used throughout the privacy notice, aligned with UAE law definitions
4. Types of Personal Data We Collect: Comprehensive list of personal data categories collected and processed
5. Legal Basis for Processing: Legal grounds under UAE law for collecting and processing personal data
6. How We Collect Your Data: Methods and sources of data collection, both direct and indirect
7. How We Use Your Data: Purposes and uses of collected personal data
8. Data Sharing and Disclosure: Information about third parties with whom data is shared
9. International Data Transfers: Details about cross-border data transfers and safeguards
10. Data Security: Measures taken to protect personal data
11. Data Retention: How long data is kept and criteria for retention periods
12. Your Rights: Individual rights under UAE data protection law
13. Updates to This Notice: How and when the notice will be updated
14. Contact Information: How to contact the organization about privacy matters
1. Cookies and Tracking Technologies: Required if the organization operates websites or apps using tracking technologies
2. Children's Privacy: Required if services might be used by or data collected from minors
3. Special Categories of Data: Required if processing sensitive personal data such as health information
4. Automated Decision Making: Required if using automated processing or profiling
5. Free Zone Specific Provisions: Required if operating in DIFC or ADGM with additional requirements
6. Sector-Specific Provisions: Required for regulated industries like healthcare or financial services
7. Marketing Communications: Required if personal data is used for marketing purposes
8. Employment Data Processing: Required if notice covers employee data processing
1. Schedule 1 - Categories of Personal Data: Detailed list of all personal data categories collected and processed
2. Schedule 2 - Third Party Recipients: Comprehensive list of third parties with whom data is shared
3. Schedule 3 - Technical and Organizational Security Measures: Detailed description of security measures implemented
4. Schedule 4 - Cookie Policy: Detailed information about cookies and other tracking technologies used
5. Schedule 5 - Data Retention Periods: Specific retention periods for different categories of data
6. Appendix A - Data Subject Request Form: Template form for individuals to exercise their rights
7. Appendix B - Consent Forms: Standard consent forms for specific processing activities
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