IGT Services and Technologies FZ LLC (UAE Branch) (hereinafter referred to as “IGT Solutions”, the "Company", "IGT", "we," "us," and "our”) values relationships with prospective employees, business partners, clients (including prospective clients) and any parties who may be interested in IGT Solution’s business services and solutions for any reason, and is committed to protecting your information by handling it responsibly and safeguarding it using appropriate technical, administrative, physical, logical security measures. This Statement outlines the types of personal data collected on our website, how this data is used and safeguarded. IGT Solutions strives to comply with applicable laws that are designed to protect individual privacy however, this document has been drafted to comply with the Federal Decree-Law No. 45/2021 On the Protection of Personal Data ("UAE PDPL") and some of IGT's obligations and the rights of any UAE Data Subjects identified in this document or any other policy, procedure or guideline may not be applicable to non-UAE Data Subjects, who will be subject to the rights available to them in their jurisdiction and as per the local data protection laws that may be applicable.
The terms used in this Policy document have the same meaning and connotation as in the UAE PDPL.
How do we collect personal data?
- Directly: We obtain personal data directly from individuals in a variety of ways, including obtaining personal data from individuals who provide us their business card, complete our online forms, subscribe to our newsletters and preference centre, register for webinars, attend meetings or events we host, visit our offices or apply for open roles. We may also obtain personal data directly when, for example, we are establishing a business relationship, performing professional services through a contract, or through our hosted software applications.
- Indirectly: We obtain personal data indirectly about individuals from a variety of sources, including recruitment services, other third-party providers we engage for the purpose of identifying and forming business contacts and our clients. We may attach personal data to our customer relationship management records to better understand and serve our business clients, subscribers and individuals or satisfy a legal obligation.
- Public sources — Personal data may be obtained from public registers (such as Companies House), news articles, sanctions list, and Internet searches.
- Business clients — Our business clients may engage us to perform professional services which involves sharing personal data they control as part of that engagement.
- Recruitment services – We may obtain personal data about candidates from an employment agency, and other parties including former employers, recruitment sites and credit reference agencies.
What Personal Data will IGT Solutions collect?
The personal data we process may include your:
- name, gender, age and date of birth;
- contact information, such as address, email, and mobile phone number;
- country of residence;
- marital status and dependents);
- employment and education details (for example, the organisation you work for, your job title and your education details);
- financial and tax-related information (for example your income, investments and tax residency);
- postings or messages on any blogs, forums, platforms, wikis or social media applications and services that we provide (including with third parties);
- IP address, browser type and language, your access times;
- information in any complaints you make;
- details of how you use our products and services;
- CCTV footage and other information we collect when you access our premises; and
- details of how you like to interact with us, and other similar information relevant to our relationship.
The personal data we collect may also include so called ‘sensitive’ or ‘special categories’ of personal data, such as details about your:
Racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation
If you choose not to provide, or object to us processing, the information we collect, we may not be able to process your instructions or continue to provide some or all of our services to you or our client. We will notify you of such data at the time that we collect this data.
For what purpose will IGT Solutions process your personal data?
IGT Solutions will use the personal data:
- To provide services to our clients,
- To meet legal or regulatory requirements.
- Conduct due diligence checks relating to the services.
- For other activities that form part of the operation of our business.
- To manage and respond to any request you submit through our Website.
- Promoting our professional services, products and capabilities to existing and prospective business clients.
- Sending invitations and providing access to guests attending our events and webinars or our sponsored events.
- Personalizing online landing pages and communications we think would be of interest based on interactions with us and group companies.
- Administering, maintaining and ensuring the security of our information systems, applications and websites.
- Authenticating registered users to certain areas of our sites.
Whom do we share your personal data?
In connection with any of the purposes outlined in the “For what purpose will IGT Solutions process your personal data” section above, we may disclose details about you to:
- other members of the IGT Solutions group companies or third parties that provide services (subject to appropriate safeguards);
- competent authorities (including courts and authorities regulating us);
- our advisers, or your advisers each of whom are bound by a duty of confidentiality;
- anyone to whom we may transfer our rights and/or obligations under the Terms;
- any other person or organisation after a restructure, sale or acquisition of any member of the IGT Solutions group, as long as they use your information for the same purposes we did;
- credit reference agencies or other organisations that help us make credit decisions and reduce the incidence of fraud; and
- other third parties that reasonably require access to personal data relating to you.
Where do we transfer your personal data?
Information we hold about you may be transferred to countries:
- where we do business;
- which are linked to your engagement with us;
- from where you regularly receive or transmit information; or where our third parties conduct their activities.
We note that these countries may have less stringent privacy laws than we do and any information they hold can become subject to their laws and disclosure requirements, including disclosure to governmental bodies, regulatory agencies and private persons. In addition, a number of countries have agreements under which information is exchanged with other countries for law enforcement, tax and other purposes.
We may only transfer your personal data when:
- the transfer is to a country deemed to provide adequate protection of your personal data by the UAE Data Office; or
- where we have otherwise put in place adequate protections (such as contractual obligations or additional technical and organizational safeguards) to ensure the same level of protection for your data as under the UAE PDPL.
Otherwise, when we, or our permitted third parties, transfer your personal data outside the UAE or to countries not deemed adequate, we will impose contractual obligations on the recipients of that data to protect your personal data to the standard required in the UAE. We or they may also require the recipient to subscribe to international frameworks intended to enable secure data sharing. If we transfer your personal data outside the UAE in other circumstances (for example, because we have to by law), we will make sure it remains adequately protected.
We may share non-personal, anonymized and aggregated information that no longer constitutes Personal Data under UAE PDPL with third parties for several purposes, including data analytics, research, submissions, thought leadership and promotional activity.
How IGT Solutions protects your personal data?
We use a range of measures to ensure we keep your personal data secure, accurate and up to date. These include but not limited to:
- education and training to relevant staff to ensure they are aware of our privacy obligations when handling personal data;
- administrative and technical controls to restrict access to personal data to a ‘need to know’ basis;
- technological security measures, including fire walls, encryption and anti- virus software;
- we may apply pseudonymisation, de-identification and anonymisation techniques in efforts to further protect personal data; and
- physical security measures, such as security passes to access our premises.
The transmission of data over the internet (including by e-mail) is never completely secure. So although we use appropriate measures to try to protect personal data, we cannot guarantee the security of data transmitted to us or by us.
What are your rights?
Data subject may exercise the following or any other rights that may be provided under the UAE PDPL:
- Correction – You can ask us to correct our records if you believe they contain incorrect or incomplete information about you. . Please note that we may need to verify the accuracy of the new data provided.
- Erasure – You can ask us to erase (delete) your personal data after you withdraw your consent to processing or when we no longer need it for the purpose it was originally collected. Please note that IGT Solutions can refuse to delete or remove Personal Data where it requires information to comply with a legal requirement, for the defense of legal claims or any other lawful purpose under UAE PDPL.
- Processing restrictions – You can ask us to temporarily restrict our processing of your personal data if you contest the accuracy of your personal data, prefer to restrict its use rather than having us erase it, or need us to preserve it for you to establish, exercise, or defend a legal claim. A temporary restriction may apply while verifying whether we have overriding legitimate grounds to process it. You can ask us to inform you before we lift that temporary processing restriction.
- Data portability – In some circumstances, where you have provided personal data to us, you can ask us to transmit that personal data (in a structured, commonly used, and machine-readable format) directly to another company if is technically feasible.
- Automated Individual Decision-making – You can ask us to review any decisions made about you which we made solely based on automated processing, including profiling, that produced legal effects concerning you or similarly significantly affected you and you have the right not to be subject to such decisions.
- Right to Object to Direct Marketing including Profiling – You can object to our use of your personal data for direct marketing purposes, including profiling. We may need to keep some minimal information to comply with your request to cease marketing to you. Unless we expressly obtain your consent, we will not use any Personal Data collected via your use of this website to carry out direct marketing.
- Right to Withdraw Consent – You can withdraw your consent at any time that you have previously given to one or more specified purposes to process your personal data. This will not affect the lawfulness of any processing carried out before you withdraw your consent. It may mean we are not able to provide certain products or services to you and we will advise you if this is the case.
- Right to make a complaint– You can make a complaint at any time to the relevant supervisory authority in your jurisdiction, depending on your location. We would welcome the chance to deal with a Data Subject's concerns before it approaches the supervisory authority.
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information or to exercise any of your other rights. This helps us to ensure that personal data is not disclosed to any person who has no right to receive it. No fee is required to make a request unless your request is clearly unfounded or excessive. Depending on the circumstances, we may be unable to comply with your request based on other lawful grounds.
How long will IGT Solutions retain your personal data?
We seek to ensure that we only keep your personal data for the longest of:
- the period necessary for the relevant activity or services that we are providing to you;
- any retention period that is required by applicable laws; or
- the period in which litigation or investigations might arise in respect of the services.
Following the expiry of the retention period we shall destroy or anonymize your Personal Data in accordance with our internal Data Retention Policy and Retention Schedule, which has been drafted to comply with applicable laws.
Do we link to other websites?
Changes to this privacy statement:
From time to time we may update this statement. When we do, we will publish the changes on this Website. If you do not agree with these changes, you should discontinue your use of our Website. If material changes are made to this Statement, we will notify users by placing a prominent notice on this Website.
How to contact us, request access to your personal data or contact IGT Solutions with questions or feedback?