1. PURPOSE
The purpose of this document is to serve as a Website Privacy Notice (“Privacy Notice” and “Notice”) for TA’ZIZ Group (hereinafter referred to as “TA’ZIZ” or “us” or “we” or “our”).
The “TA’ZIZ Group” means ABU DHABI CHEMICAL DERIVATIVES COMPANY RSC LTD, a company incorporated and registered in the Abu Dhabi Global Market (“ADGM”), its branch registered in the onshore United Arab Emirates (“UAE”), and each of its affiliates which may vary from time to time.
We take your privacy and the protection of your Personal Data very seriously. We use encryption methods and access controls to prevent unauthorized access. This Privacy Notice sets out important information about how your Personal Data is collected, handled and generally used when you interact with the TA’ZIZ Group.
2. INTRODUCTION
In the course of your engagement with us, we will need to collect and Process your Personal Data. "Personal Data" is any information from which you can be directly or indirectly identified.
"Processing" refers to the collection, recording, storage, disclosure and generally any use of your Personal Data. In compliance with applicable Data Protection Laws and regulations, including the ADGM Data Protection Regulations 2021 (“ADGM DPR”) and Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (“UAE PDPL”) (together, the "Data Protection Laws"), we are required to notify you of what Personal Data is collected and how we hold and Process Personal Data about you.
Please note that the "Data Controller" of your Personal Data is the TA’ZIZ Group entity responsible for the Processing of your Personal Data. Which entity this is will depend on the products traded and location(s) these products are serviced from and with whom you or your company has a contract or liaises. If you have any questions about who the Data Controller of your Personal Data is, please contact us using the contact details in the “Contact Us” section below (see section 10).
This Notice was last updated on 28 September 20026; please take the time to read and understand this Notice. We may need to make changes to it, for example, to reflect legislation changes, new technologies, other developments in privacy laws or any changes in how we Process Personal Data. Therefore, we may update this Notice at any time, but you should check our website periodically to view our most up to date Notice.
3. HOW DO WE COLLECT AND USE YOUR PERSONAL DATA?
3.1 Overview
In addition to Personal Data, Data Protection Laws also specify additional categories of Personal Data that require further protection. Under the ADGM DPR, these categories are known as "Special Categories of Personal Data" and under the UAE PDPL they are known as “Sensitive Personal Data” (together referred to in this policy as “Special Category Data”).
Special Category Data may include data relating to your health, genetic or biometric data, criminal convictions or record, sex life or sexual orientation or sexual condition, racial, ethnic or family origin, political or philosophical opinions, and religious beliefs.
We may, in some circumstances, as outlined in this Notice need to collect and Process your Special Category Data where we have your consent to do so (if applicable) or in the circumstances detailed below, depending on your relationship with us and to the extent permitted under applicable law.
If you are required to provide us with any Personal Data relating to another individual, you confirm that you have a lawful basis for providing that Personal Data to us and, where consent is required under the applicable Data Protection Laws, that you have obtained such consent and can demonstrate that consent to the standards required under the applicable Data Protection Laws.
More information on the types of Personal Data that we will collect and Process about you is detailed below. Please note that depending on your relationship with us (i.e., whether you are a customer of TA’ZIZ, candidate applying to work at TA’ZIZ, a supplier / third party provider we use to run our business, a visitor to a TA’ZIZ office/site or a website user), the Personal Data that we collect about you will vary so please view the relevant section below which best describes your relationship with us.
3.2 Business Customer Contacts
This section will apply to you if you are a TA’ZIZ business customer or key contact or representative with whom we liaise as a prospective or existing business customer.
(a) What Personal Data do we collect and Process about you?
We do not collect or Process any Special Category Data about you.
(b) How will we collect your Personal Data?
All Personal Data is collected directly from you or from one of your colleagues.
(c) What will we use your Personal Data for?
We only Process Personal Data for the purposes described in this Notice. Certain Data Protection Laws require companies to have a "lawful basis" to collect and use Personal Data. Please note that the lawful bases available to us may differ depending on whether the ADGM DPR or UAE PDPL applies. Our 'lawful bases' will be where:
|
Purpose for Processing |
Legal grounds for Processing Personal Data |
|
To manage our customer relationships, generally communicate with you and assist with any complaints you may have |
We have your consent, or, under the ADGM DPR, we have a legitimate business interest (to handle and assist with any complaints you may have and correspond with you as our key customer contact and maintain our relationships with customers). |
|
For general internal business management purposes such as audit; security and accounting purposes; record-keeping and obtaining legal or professional advice from external advisers |
We have your consent, or, under the ADGM DPR, we have a legitimate business interest (to operate and run our business and to comply with audit requirements). We have a legal obligation to protect your Personal Data. |
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To record calls for training and monitoring purpose |
We have your consent, or, under the ADGM DPR, we have a legitimate business interest (to ensure performance quality). |
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To comply with our legal obligations which may include disclosing information, if legally required, to data protection regulators, law enforcement such as the police and tax authorities, governmental and public authorities |
We have a legal obligation. |
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For business development purposes and to market our services to you and to undertake analytics to improve our services |
We have your consent, or, under the ADGM DPR, we have a legitimate business interest (to market our services which we think you might be interested in and to improve our services). |
|
For purposes related to a merger, acquisition, sale or restructure |
We have your consent, or, under the ADGM DPR, we have a legitimate business interest (to buy and sell companies as appropriate). |
(d) Who will we share your Personal Data with?
We may share your Personal Data, where applicable:
All members of the TA’ZIZ Group and third-party providers are required to take appropriate security measures to protect your Personal Data in line with our policies.
3.3 Candidates applying to work at TA’ZIZ
This section applies to individuals applying to work at TA’ZIZ. If, in your application, you provide Personal Data relating to others (e.g., referees or next of kin), you agree to inform them about this Notice and obtain any required consent.
(a) What Personal Data do we collect and Process about you?
We also typically Process the following types of Special Category Data about you:
(b) How will we collect your Personal Data?
(c) What will we use your Personal Data for?
We only Process Personal Data for the purposes described in this Notice. Certain Data Protection Laws require companies to have a "lawful basis" to collect and use Personal Data. Please note that the lawful bases available to us may differ depending on whether the ADGM DPR or UAE PDPL applies. Our 'lawful bases' will be where:
We need to have an additional Processing bases in the event that we Process your Special Category Data. In those limited circumstances, we will only do so in compliance with Data Protection Laws and we will rely on the following legal bases (to the extent permitted under applicable law):
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Purpose for Processing |
Legal grounds for using Personal Data |
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For the purposes of the recruitment cycle including: |
• It is necessary in order to take steps to enter into a contract with you.
Under the ADGM DPR, it is necessary for legitimate business interests (to undertake recruitment).
Special Category Data. |
|
For internal business management purposes such as audit; security and accounting purposes; obtaining legal or professional advice from external advisers |
• We have your consent, or, under the ADGM DPR, we have a legitimate business interest (to operate and run our business and to comply with audit requirements). |
|
To comply with our legal obligations which may include disclosing information, if legally required, to data protection regulators, law enforcement such as the police and tax authorities, governmental and public authorities |
• We have a legal obligation. |
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For purposes related to a merger, acquisition, sale or restructure |
• We have your consent. Under the ADGM DPR, we have a legitimate business interest (to buy and sell companies as appropriate). |
(d) Who will we share your Personal Data with?
We may share your Personal Data:
amongst the TA’ZIZ Group;
with our shareholders (including ADNOC and ADQ) and, where relevant to a particular project or business activity, our joint venture partners, to the extent necessary for corporate governance, reporting, oversight, administration and the management and operation of our business;
recruiters and your referees;
All members of the TA’ZIZ Group and third-party providers are required to take appropriate security measures to protect your Personal Data in line with our policies.
3.4 Suppliers or Third Parties
This section will apply to you if you are a supplier, third party, or contact at a corporate supplier or third party, with whom we engage as part of our day-to-day business operations.
We typically Process the following types of Special Category Data: information about any criminal convictions you may have including offences and alleged offences and any court sentence or unspent criminal conviction.
(c) What will we use your Personal Data for?
We only Process Personal Data for the purposes described in this Notice. Certain Data Protection Laws require companies to have a "lawful basis" to collect and use Personal Data. Please note that the lawful bases available to us may differ depending on whether the ADGM DPR or UAE PDPL applies. We rely on the following 'lawful bases' when Processing your Personal Data, where:
To manage our supplier/third party relationships, generally communicate with you and assist with any complaints you may have
• Under the ADGM DPR we have a legitimate business interest (to handle and assist with any complaints you may have and correspond with you as our supplier or key supplier contact and maintain our relationship).
• It is necessary to perform our contract with you.
To engage and onboard suppliers, business partners and third parties and fulfil our contractual obligations
• It is necessary to perform our contract with you.
• Under the ADGM DPR, we have a legitimate business interest (to engage third parties for business purposes).
• We have a relevant legal obligation to protect your Personal Data.
For general internal business management purposes such as: audit; security and accounting purposes; record‑keeping and obtaining legal or professional advice from external advisers
• Under the ADGM DPR, we have a legitimate business interest (to operate and run our business and to comply with audit requirements).
• We have a legal obligation to protect your Personal Data.
To comply with our legal obligations which may include disclosing information, if legally required, to data protection regulators, law enforcement such as the police and tax authorities, governmental and public authorities
• We have a legal obligation.
For purposes related to a merger, acquisition, sale or restructure
• Under the ADGM DPR, we have a legitimate business interest (to buy and sell companies as appropriate).
Under the UAE PDPL, we rely on your consent.
We may share your Personal Data:
All members of the TA’ZIZ Group and third-party providers are required to take appropriate security measures to protect your Personal Data in line with our policies.
3.5 Office/Site Visitors
This section will apply to you if you are visiting a TA’ZIZ office or site.
We also typically Process the following types of Special Category Data about you:
All Personal Data is collected directly from you.
We only Process Personal Data for the purposes described in this Notice. Certain Data Protection Laws require companies to have a "lawful basis" to collect and use Personal Data. Our 'lawful bases' will be where:
We need to have an additional Processing condition in the event that we Process your Special Category Data. In those limited circumstances, we will rely on the following:
|
Purpose for Processing |
Legal grounds for using Personal Data |
|
To communicate with you and assist you when you visit our offices and/or sites |
• Under the ADGM DPR, we have a legitimate business interest (to correspond with you when you are visiting our offices and/or sites). We have your consent. |
|
For general internal business management purposes such as security (through use of CCTV footage) and record‑keeping |
• Under the ADGM DPR, we have a legitimate business interest (to operate and run our business and to keep records of office/site visitors). |
|
To comply with our legal obligations which may include health and safety compliance and disclosing information, if legally required, to data protection regulators, law enforcement such as the police, governmental and public authorities |
• We have a legal obligation. |
(d) Who will we share your Personal Data with?
We may share your Personal Data:
All members of the TA’ZIZ Group and third-party providers are required to take appropriate security measures to protect your Personal Data in line with our policies.
3.6 Website Users
This section will apply to you if you are visiting a TA’ZIZ website.
We do not collect or Process any Special Category Data about you.
All Personal Data is collected directly from you or your device.
We only Process Personal Data for the purposes described in this Notice. Certain Data Protection Laws require companies to have a "lawful basis" to collect and use Personal Data. Our 'lawful bases' will be where:
|
Purpose for Processing |
Legal grounds for using Personal Data |
|
To communicate with you and respond to your enquiry/chats |
• Under the ADGM DPR, we have a legitimate business interest (to respond to any enquiries you submit via a TA’ZIZ website).
Under the UAE PDPL, we rely on your consent. |
|
For general internal business management purposes such as: audit; security and accounting purposes; record‑keeping and obtaining legal or professional advice from external advisers |
• Under the ADGM DPR, we have a legitimate business interest (to operate and run our business and to comply with audit requirements). |
|
To comply with our legal obligations |
• We have a legal obligation. |
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To send you email marketing based on how you interact with our website |
• We have your consent. |
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To deploy cookies and other similar tracking technologies |
• Under the ADGM DPR, we have a legitimate business interest (to deploy cookies that are strictly necessary to ensure our websites can operate and function). |
(d) Who will we share your Personal Data with?
We may share your Personal Data:
All members of the TA’ZIZ Group and third-party providers are required to take appropriate security measures to protect your Personal Data in line with our policies.
4. USING YOUR PERSONAL DATA FOR MARKETING
We may from time to time, and with your consent, provide you with information about our services or information about any relevant industry developments which we think will be of interest to you or which you have asked us to provide you with. This may be sent by email or we may contact you by phone.
Please note that you can withdraw your consent to receive marketing communications at any time. An "unsubscribe" link appears in all our marketing emails. To unsubscribe from emails sent by us, simply click on the link at any time. Alternatively, you can contact us to withdraw your consent using the contact details in the "Contact Us" section below (see section 10).
5. AUTOMATED DECISIONS AND PROFILING
Automated decision-making takes place when an electronic system Processes Personal Data to make a decision without human intervention. We do not envisage that any decisions will be taken about you using automated means, however we will take steps to notify you if this position changes. If we implement automated decision-making, including profiling, you may have the right not to be subject to a decision based solely on automated processing in certain circumstances. Please contact us using the details in the “Contact Us” section below (see section 10) for further information about your rights and how they may apply to you.
6. DATA TRANSFERS
Due to the international nature of the TA’ZIZ Group’s business and to the extent permitted by Data Protection Laws, your Personal Data may be transferred to other companies within the TA’ZIZ Group and, where necessary, to our shareholders and joint venture partners, in each case for the purposes of business operations, reporting, administration, corporate governance, oversight and project development. This may involve the transfer and/or storage of your Personal Data in a jurisdiction or country that is outside of the jurisdiction in which it was originally collected (“Relevant Location”).
Your Personal Data may also be stored and Processed by our suppliers or service providers in other countries, which may include destinations outside of the Relevant Location.
Where we do transfer to a Relevant Location, we will ensure that such transfers are appropriately safeguarded and undertaken in compliance with Data Protection Laws. This can be done in a number of ways, for instance:
7. PERSONAL DATA SECURITY
We are committed to safeguarding and protecting your Personal Data and therefore we implement a range of technical and organizational measures to protect your Personal Data.
These measures are designed to provide a level of security appropriate to the type of Personal Data Processed and to protect it from accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to Personal Data transmitted, stored or otherwise Processed.
We regularly review and, where appropriate, update our security measures to address changes in technology, processing activities and applicable security risks. However, no method of transmitting or storing Personal Data can be guaranteed to be completely secure.
8. HOW LONG DO WE RETAIN YOUR PERSONAL DATA?
We will only retain your Personal Data as long as is necessary to fulfil the purposes listed in this Notice and to comply with our legal requirements. To determine how long is necessary, we will take into account various criteria including:
For example:
9. YOUR DATA SUBJECT RIGHTS
Please keep us informed if there are any changes in your details or the information you have provided us with as our records should reflect accurate and up to date Personal Data under Data Protection Laws.
Depending on the laws of the jurisdiction in which you are based you will have various rights in respect of your Personal Data. For example, you may have the right to:
Please note that not all of your data subject rights will be absolute; this means that there may be some circumstances where we may not be able to comply with your request (such as where this would conflict with our obligation to comply with other legal requirements). However, if we cannot comply with your request, we will tell you the reason and we will always respond to any request you make.
To exercise any of your data subject rights, please contact us using the contact details set out in Section 10 (“Contact Us”) below.
10. CONTACT US
Thank you for taking the time to read this document. For any queries, concerns, escalations or requests you may have in relation to this Privacy Notice, the Personal Data we hold in relation to you, and how it is Processed, please contact us at dataprivacy@taziz.com, or you may contact your relevant TA’ZIZ Group Company.
In the event that you believe TA’ZIZ has been unable to assist you with a fair resolution to your request, query or complaint, you have the right to make a complaint to the competent data protection authority as mentioned under the “Your Data Subject Rights” section above (see section 9).
TTA’ZIZ Offices, P.O. Box 764618, Abu Dhabi, UAE