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Scope of Data Covered The Company’s Data Protection Policy applies to all personal data currently held or to be obtained in the future. This includes data related to:
- Company personnel, including senior management, staff, and agents
- Company customers, contractors, and suppliers
- Third-party consultants, business partners, or associates assisting the Company in executing transactions
Personal Data Personal data pertains to any information that can identify a person (the “Data Subject”) directly or indirectly, including:
- Names of individuals or legal entities
- Nationality
- Date and place of birth
- Correspondence address
- Contact details (email and phone number)
- Identity card details (passport number, Emirates ID, or other national IDs)
- Identification details of close family and associates
Data Protection Processing personal data involves operations such as collecting, recording, evaluating, organizing, altering, and transmitting data to third parties for compliance or service provision, including data retention, deletion, or destruction.
Key Principles for Data Protection The Company is committed to preserving privacy and upholding data protection rights for employees, customers, suppliers, and other stakeholders. Our approach to processing personal data aligns with data protection guidelines and the ADGM’s Data Protection Regulations. We adhere to the following core principles:
Fairness and Lawful Processing
- We ensure the rights of data subjects are protected, and personal data is obtained and processed fairly and legally.
- Only relevant data necessary for business transactions is obtained and processed.
- Data is collected and processed with the lawful consent of the concerned person.
- The Data Protection Officer ensures compliance, provides internal notices, establishes procedures, and educates employees on data handling in alignment with these principles.
Purpose Limitation Personal data is collected for specific, explicit, and legitimate purposes, as communicated to the data subject before obtaining the data. No further processing is done beyond these pre-determined purposes.
Adequate Data Collection We collect only necessary and relevant personal data for intended processing purposes, following strict data collection processes with periodic reviews.
Accuracy and Timeliness Ensuring the accuracy of personal data is crucial. Inaccuracies are promptly addressed, and expired information is updated in consultation with the data subject to maintain relevance and compliance.
Transparency Personal data is obtained directly from the data subject in compliance with regulatory requirements. The data subject is informed about the purpose of data collection and handling, including possible third-party transfers.
Data Retention and Deletion Personal data is retained only as long as necessary to fulfill regulatory requirements. Historical data with no significance is securely deleted, anonymized, pseudonymized, or encrypted. If secure deletion or encryption is not possible, data is archived to restrict further processing.
Data Security We ensure the security and confidentiality of all personal data, preventing unauthorized or unlawful processing, accidental loss, or destruction.
Rights of Data Subjects and Handling Data Requests Individuals are informed about their data processing and usage. Data subjects are entitled to:
- Request information about personal data held, its collection, and purpose.
- Be informed about possible third-party data transmission.
- Correct or delete inaccurate or incomplete data.
- Request data deletion if it is no longer required for legal compliance.
- Object or restrict data processing to protect their interests.
- Receive a justifiable reason for any denial of data access or information.
Providing Information to Data Subjects Data subjects can request personal data or related information by emailing the Data Protection Officer at legal@metropolitan.realestate. The Data Protection Officer will verify the requestor’s identity before granting access.
Transmission of Personal Data Data transmission to internal stakeholders or third parties requires the data subject’s consent, and third parties must comply with strict data protection standards. Transmission to regulatory authorities does not require consent.
Data Retention Personal data records are maintained, along with a log of their purposes, for a minimum of six years.
Violation and Reporting Non-compliance with data protection principles will lead to an investigation and possible suspension or termination of business relationships. Staff and stakeholders are encouraged to report any suspected non-compliance to the Group’s Data Protection Officer.