Privacy

DUBAI AEROSPACE ENTERPRISE

Privacy Statement

The Dubai Aerospace Enterprise group of companies (“DAE Group”, “we” or “us”) will collect and process your Personal Data and other information in relation to your dealings with us, including through your use of the DAE Group website, Dubaiaerospace.com (the “Website”). This Privacy Statement explains how the DAE Group will manage your Personal Data, why we use it, and how you may contact the DAE Group in relation to the use of your Personal Data.

Types of Information We Collect
We collect information, which includes Personal Data, about directors, officers, employees, agents, guarantors and / or authorised signatories of the DAE Group’s customers, suppliers, service providers, vendors and other commercial partners, and media contacts (“Individuals”) for the purposes of and in connection with the DAE Group’s dealings with those relevant commercial and other entities. You may be such an Individual.

Personal Data means any information which the DAE Group has or obtains, or which you provide to the DAE Group, and specifically your name, address, email address, phone number(s), title or position, from which you can be directly or indirectly personally identified.

We may also collect certain statistical and other analytical information collected on an aggregate basis relating to all visitors to the Website. This Non-Personal Data comprises information that cannot be used to identify or contact you, such as demographic information regarding browser types, mobile device equipment, mobile network and other anonymous statistical data involving the use of the Website. We collect this information to help us monitor traffic and enhance your experience of the Website. Please see further detail on this in our Cookie Policy.

How We Obtain Your Information
We will obtain some of your Personal Data directly from you where we interact directly with you in the course of our business. We may also obtain Personal Data directly from you through the Website, such as (i) when you sign up to our mailing list, (ii) when you sign up to receive financial results, or (iii) when you apply for a position with the DAE Group.

This information may be collected indirectly from a variety of sources, such as the commercial entity which you represent, publicly available sources including media reports and social media, such as LinkedIn, and from any of the companies within the DAE Group with which you interact.

Use of Personal Data and Basis of Processing
The DAE Group will use the Personal Data where necessary:

1. where use is for a legitimate purpose of the DAE Group or any member of the DAE Group, including:

(a) for the purposes of “know your customer” (“KYC”) and sanctions screening due diligence checks which we undertake relating to our customers, trading counterparties, consignment partners and their guarantors (where applicable);

(b) for the purposes of managing its contracts and relationships with its customers, suppliers, service providers, vendors and other commercial partners;

(c) for day to day operational and business purposes, including recruitment purposes;

(d) board reporting and management purposes;

(e) in the event of a merger, reorganisation or disposal of, or a proposed merger, reorganisation or disposal of (all or part of) the DAE Group;

(f) to take advice from the DAE Group’s external legal and other advisors;

2. for compliance with the DAE Group’s legal obligations, including:

(a) compliance with applicable tax and regulatory reporting obligations;

(b) where the DAE Group is ordered to disclose information by a court with appropriate jurisdiction; and / or

3. where necessary to establish, exercise or defend its legal rights or for the purpose of legal proceedings; and / or

4. where you have consented to the use of your Personal Data for a particular purpose. If you give consent for the DAE Group to use your Personal Data for a particular purpose (e.g., when signing up to the DAE Group mailing list or to receive DAE Group financial results through the Website) you have the right at any time to withdraw consent to the future use of your Personal Data for some or all of those purposes by writing to the address specified below.

Know Your Customer
We may collect certain documentation (which contains Personal Data) from you for KYC purposes. This documentation includes proof of identity (e.g. copy passport / driving licence) and proof of address (e.g. copy utility bill). We are not under a legal obligation to collect this documentation. However, we consider it a legitimate business interest of the DAE Group to verify the identity of our customers, trading counterparties, consignment partners and their guarantors (where applicable) for anti-money laundering and counter-terrorist financing and for sanctions screening purposes.

Applicants for jobs
Where you, or a third-party recruitment agent acting for you, provides us with your CV and other Personal Data, we will use that information solely for the purposes of considering your application for a position with the DAE Group, including to check your references. However, we will only hold Personal Data of applicants for positions for a period of 24 months from our final interaction with a candidate during the recruitment process. If you are a successful candidate, some of the Personal Data we obtain during the recruitment process will be held on your personnel file, which will be subject to our separate Employee Privacy Statement.

Sharing Personal Data
The DAE Group will not disclose any Personal Data to any third party, except as outlined above and / or as follows:

(a) to enable the DAE Group to carry out the obligations under and enforce its contracts with its customers, suppliers, service providers, vendors and other commercial partners;

(b) to anyone providing a service to the DAE Group or acting as the DAE Group’s agent, as data processors, for the purposes of providing services to the DAE Group and on the understanding that they will keep the Personal Data confidential;

(c) where the DAE Group needs to share Personal Data with its auditors, and legal and other advisors;

(d) in the event of a merger or proposed merger, any (or any proposed) transferee of, or successor in title to, the whole or any part of the DAE Group’s business, and their respective officers, employees, agents and advisers, to the extent necessary to give effect to such transaction; and

(e) the disclosure is required by law or regulation, or court or administrative order having force of law, or is required to be made to any of the DAE Group’s regulators.

You should note that where you interact with one member of the DAE Group, your Personal Data may be shared with the other members of the DAE Group for the purposes and in the circumstances outlined above.

International transfers
Personal Data may be transferred outside the country in which you or the DAE Group entity with which you initially interact in connection with the uses described above, where you have explicitly consented to the transfer, and / or as otherwise required or permitted by law.

Many of the countries to which Personal Data is transferred will be within the European Economic Area (the “EEA”), or will be ones which the European Commission has approved, and will have data protection laws which are the same as or broadly equivalent to those in the European Union. However, some transfers may be to countries which do not have equivalent protections, and in that case the DAE Group shall use reasonable efforts to implement contractual protections for the Personal Data. While this may not always be possible (for example where we are legally obliged to transfer the Personal Data), any transfers will be done in accordance with applicable data protection laws, including through the implementation of appropriate or suitable safeguards in accordance with such applicable data protection laws.

For the avoidance of doubt, safeguards in the form of EU Commission approved standard contractual clauses will be implemented where personal data is transferred for processing to any DAE Group member or a service provider outside the EEA. Further information in relation to international transfers can be obtained by writing to us at the address specified below.

Third Party Providers of Information
The DAE Group and each member of the DAE Group may obtain Personal Data relating to Individuals from someone other than that Individual, such as his / her employer. The person providing the information will be asked to warrant that it will only do so in accordance with applicable data protection laws, and that it will ensure that before doing so, the Individuals in question are made aware of the fact that the DAE Group will hold information relating to them and that it may use it for any of the purposes set out in this Privacy Statement, and where necessary that it will obtain consent to the DAE Group’s use of the information.

Recipients of the Personal Data
In any case where the DAE Group or any member of the DAE Group shares Personal Data with a third-party data controller, the use by that third party of the Personal Data will be subject to the third party’s own privacy policies.

Updates to Personal Data
The DAE Group will use reasonable efforts to keep Personal Data up to date. However, you will need to notify the DAE Group without delay in the event of any change in your personal circumstances, or those of the others mentioned above, so that the DAE Group can keep the Personal Data up to date.

Retention of Personal Data
The DAE Group is obliged to retain certain information to ensure accuracy, to help maintain quality of service, for legal and regulatory purposes, and for legitimate business purposes.

Information will be retained for no longer than is necessary for the purpose for which it was obtained by the DAE Group or as required or permitted for legal and regulatory purposes, and for legitimate business purposes. In general, the DAE Group (or its service providers on its behalf) will retain your Personal Data for a period of seven years after you cease to interact with the DAE Group, unless it is obliged to hold it for a longer period under law or applicable regulations.

Your Rights in relation to Personal Data
You may at any time request a copy of your Personal Data from the DAE Group. This right can be exercised by writing to the DAE Group at the address specified below.

You also have the right to correct any inaccuracies in, and in certain circumstances, to request erasure, or restriction on the use, of your Personal Data, and to object to certain uses of your Personal Data, in each case subject to the restrictions set out in applicable data protection laws. Further information on these rights, and the circumstances in which they may arise in connection with the DAE Group’s processing of Personal Data, can be obtained by writing to the DAE Group at the address specified below. In any case where the DAE Group is relying on your consent to process your Personal Data, you have the right to change your mind and withdraw consent by writing to the address specified below.

Where the DAE Group is relying on a legitimate purpose of the DAE Group or a third party recipient of the Personal Data, in order to use and disclose Personal Data, you are entitled to object to such use or disclosure of your Personal Data, and if you do so, the DAE Group will cease to use and process the Personal Data for that purpose unless the DAE Group can show there are compelling legitimate reasons for it to continue or it needs to use the Personal Data for the purposes of legal claims.

You also have the right to lodge a complaint about the processing of your Personal Data by the DAE Group with:

(A) DIFC –
Commissioner of Data Protection
P.O. Box 74777
Level 14, The Gate
DIFC
Dubai
United Arab Emirates

(B) Ireland –
Data Protection Commissioner
Canal House
Station Road
Portarlington
Co. Laois
Ireland

(C) Singapore –
The Officer-in-Charge, Enforcement
Personal Data Protection Commission
10 Pasir Panjang Road
#03-01 Mapletree Business City
Singapore 117438

(D) U.S.A.
Federal Trade Commission
ftc.gov/complaint

OR

Centralized Case Management Operations
U.S. Department of Health and Human Services – Office of Civil Rights
200 Independence Avenue, S.W.
Room 509F HHH Building
Washington, D.C. 20201
U.S.A.

Contacting the DAE Group

Any queries or complaints regarding the use of employee-related Personal Data by the DAE Group and / or the exercise of your rights should be addressed to the DAE Group at Susan.Bradford@dubaiaerospace.com or by writing to:

Susan Bradford (Chief Human Resources Officer)
Dubai Aerospace Enterprise
Central Quay
Block B Riverside IV
Sir John Rogerson’s Quay
Dublin 2
Ireland

Any queries or complaints regarding the use of all other Personal Data by the DAE Group and / or the exercise of your rights should be addressed to the DAE Group at Lesley.Jones@dubaiaerospace.com or by writing to:

Lesley Jones
Chief Legal Officer
DAE Capital
P.O. Box 506592
Building 4, Level 3 The Gate District
DIFC
Dubai
United Arab Emirates

Last updated 25 May 2018