PRIVACY POLICY OF ATB GLOBAL LEGAL CONSULTANCY LLC

Last updated: October 19, 2023

ATB Global Legal Consultancy LLC (“ATB”, “we”, “our”, or “us”) is committed to protecting the privacy and security of the Users’ (“you”, “your”) personal information. This Privacy Policy describes how we collect, use, disclose and protect the personal information we collect from the Users, our clients, website visitors and other individuals.

For the purpose of applicable Data Protection Law, ATB is typically the Data Controller of any personal information provided to us. Specifically, your data will be collected by us for the purpose of processing as per your requirements. Only in occasional circumstances, ATB will be acting as the Data Processor and process the personal information as per instructions by Data Controller or otherwise as permitted by law.

By using our website and submitting your information on or through the website, or by choosing to use or avail any of our services through our website, you are giving your consent to the collection, use and disclosure of your personal information as set forth in this Privacy Policy. We will never share any of your information with any third party except as set forth herein.

Our services are predominantly based out of the United Arab Emirates (“UAE”), therefore, if you are accessing our website, or availing our services from outside UAE, please note that your information (including any personal information) shall be processed in accordance with the applicable data protection laws in UAE. If you decide to continue availing services through our website and otherwise, you hereby expressly consent to the storage, processing and disclosure of your information in accordance with this Privacy Policy and the applicable data protection laws in UAE. You shall be deemed to have further expressly waived any claims, rights and remedies that you may have against us, in this regard, under laws applicable to the territory from which you may be using our website or availing services through our website.

1. Definitions

• Personal Information means any information relating to an identified or identifiable individual, comprising of name, identification number, email address, username etc.
• Processing means collecting, recording, organising, structuring, storing, adapting, altering, retrieving, using, disseminating, erasing, or destroying activities carried out manually or in an automated manner.
• Data Subject means the identified or identifiable individual whose personal information is held or processed.
• Data Controller means the person or organisation that determines the purpose and the means of processing Personal information.
• Data Processor means the person or any other body, other than the employee of the Data Controller who processes personal information on behalf of the Data Controller.

2. Information We Collect

We may collect the following types of personal information, at the time of your engagement with us directly or indirectly, or in the course of providing services to you, or when you contact us or request information from us, or when you reach out, interact and /or communicate with our personnel and/or representatives, or when you respond to any queries as may be required by us or provide suggestions, comments, and instructions to us in this regard. The information is confidential, and we will maintain such confidentiality and protect your information in accordance with our professional obligations and applicable law. We have arrangements in place with personnel and service providers who may process your personal information, to ensure that confidentiality is always maintained.

• Contact Information: Such as your name, date of birth, gender, address, email address, phone number and Identification information to check and verify your identity (e.g., ID, passport etc)
• Client Information: Information related to legal matters and consultations including but not limited to role, title, employer, relationship to a person, etc.
• Service-related Information: Information related to the specifics of the services opted by you, nature of services opted by you, advises, opinions and / or documents required by you, details of your visits to our offices (including meeting dates and times).
• Payment Information: Billing details and payment method information in lieu of services provided by us.
• Website Usage Data: Information about how you use our website, including IP addresses, location data, traffic data, browser types and pages viewed, information from your visits to our website (page interaction information, length of visits, etc).
• Other Information: Any other information you provide to us voluntarily.

If you provide personal information to us about someone else (such as one of your directors or employees, or someone with whom you have business dealings) you must ensure that you are entitled to disclose that personal information to us and that, without our taking any further steps, we may collect, use and disclose that personal information as described in this Privacy Policy. In particular, you must ensure the individual concerned is aware of the various matters detailed in this Privacy Policy, as those matters relate to that individual, including our identity, how to contact us, our purposes of collection, our personal data disclosure practices, the individual’s right to obtain access to the personal information and make complaints about the handling of the personal information, and the consequences if the personal information is not provided (such as our inability to provide services).

3. How We use Your Information

We may use your personal information for the following purposes:

• Providing Legal Services: To provide legal advice, services, and consultations, and customizing our services to you, and notifying you of any upcoming events, services, and providing legal updates, circulars, newsletters, etc. in relation to our services.
• Communication: To communicate with you about legal matters, appointments, and updates, managing business relationship with you (or your organisation) either in connection with the legal services or as an employer, and for providing support services.
• Billing and Payments: To process payments, send invoices, and manage billing.
• Website Improvement: To analyse website usage and improve our online services, to manage, monitor and secure the access to our information technology systems, and to prevent any fraudulent /illegal activities through our website.
• Legal Compliance: To comply with legal obligations and resolve legal disputes, if any.
• Any other purpose: That may be related and / or ancillary to any of the above purposes for which your personal information was provided to us.

4. Disclosure of Your Information

We may share your personal information with:

• Authorised Personnel: Our lawyers, staff, and authorised personnel to provide legal services.
• Third-Party Service Providers: Such as payment processors, IT service providers, and other contractors who assist us in providing services.
• Legal Authorities: If required by law or to protect our legal rights, we may disclose your information to legal authorities.

Any personal information you may submit, display, or publish on or through our website or on our social media handles shall be publicly available and may be read, collected, used, and disclosed by others. We cannot control who reads your posts or comments or what other users may do with the information you may voluntarily post, so we encourage you to exercise discretion and caution with respect to your personal information.

We may also need to disclose certain personal information of yours to third parties as may be necessary to efficiently provide our services (including but not limited to our accountants, government or regulatory authorities, professional indemnity insurers, and tax authorities, or for data processing/archival purposes). Any such disclosure shall be only after procuring your consent, where we are required to do so by law, or where it is necessary for the purpose of or in connection with legal proceedings or in order to exercise or defend legal rights. We do not sell, rent, distribute, or otherwise make, personal information commercially available to any third party.

In addition, we may /make use of third-party technology services including, amongst other things, cloud security systems. The use of these services may require your personal information to be held in the cloud on infrastructure managed by the relevant service provider.

5. Cross- Border Transfer of your Information

It may sometimes be pertinent for us to share your personal information with other ATB offices around the Middle East or India regions, any associated professional service firms around the world, who provide services on our behalf. This may entail a transfer of personal information from within the DIFC (Dubai International Financial Centre) to recipients outside the DIFC and vice versa.

The level of protection of personal information may vary depending on the jurisdiction, however, to address this, we have procedures and safeguards in place to ensure the protection of personal information. These procedures include contractual obligations to ensure that all such entities safeguard your personal information and use it only for the purpose for which it has been collected and communicated to you.

6. Information Security Measures

We take appropriate Information security measures (administrative, technical, and physical) to protect your personal information from unauthorised use or access, disclosure, alteration and destruction. However, please note that no method of transmission over the internet or electronic storage is 100% secure.

Your disclosure and sharing of personal information through our website or social media handles constitute your acceptance of this risk, and you hereby agree to waive any claims that you may have against us and any right to seek legal relief from us due to any misuse of the personal information in the manner aforesaid.

7. Retention of Information

We will retain your personal information only for the duration needed to fulfil the purpose for which it was collected, unless we mutually agree to a longer retention period, or a longer retention period is required or permitted by law. We will consider and analyse the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data, and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements, in taking a decision as to the period of time your information shall be retained with us.

We may also anonymise or aggregate your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

8. Your Choices and Rights

As a Data Subject, you have the rights to access, correct, delete, or restrict the use of your personal information, as elaborated below. If you wish to exercise any of these rights, please contact us using the information provided below.

• Right to access: You have the right to request access to the personal information held by us, at any time.
• Right to rectify or erasure: You may request erasure or correction of in-accuracies in your personal information if any.
• Right to delete or restrict: You can request for a certain data to be restricted to limited use or have it deleted or removed if there is no compelling reason for its continued processing. This right is not absolute and applies only in certain circumstances, such as when data is no longer necessary for the purpose for which it was collected.
• Right to withdraw consent: You may withdraw your consent to process personal information at any time, although such withdrawal shall not affect the lawfulness of processing prior to such withdrawal.
• Complaints: If you feel that your data protection rights have been breached, you may lodge a complaint with the relevant Data Protection Authority.

9. Minors

We do not intentionally allow any users under the age of eighteen (18) to use or otherwise access the services of the website. We do not seek any personal information (or any other information at all) from any persons under 18 years of age. Because we do not intentionally collect any information from children under the age of 18, we also do not intentionally share or disclose such information to third parties. If you are under 18 years of age, you may not use our website. If you have reason to believe that a child under 18 years of age has provided us information, then please contact us at the email id provided below.

10. CRM (Client Relationship Management)

We touch base with our prospects and clients via mailing list program to promote our services, including our publications and events. Such marketing messages may contain tracking technologies to track subscriber activity and build profiles. If you do not wish to receive marketing emails, you may inform us directly to the email address provided below.

11. Cookies

Cookies are files with a small amount of data that are commonly used as a unique identifier. These are sent to your browser from the website that you visit and are stored on your device’s internal memory. We use cookies to improve our website and services.

Most internet browsers have a mechanism notifying you when you receive a new cookie, and telling you how to reject new cookies or disable cookies altogether (if you wish to do so). You have the option to either accept or refuse these cookies and know when a cookie is being sent to your device. If you choose to refuse our cookies, you may not be able to use or access certain portions of the services offered by us.

12. Links to Other Sites

Our services and website may contain links to other sites. If you click on a third-party link (including for any payment processes where you may be directed to a payment provider or payment gateway website, or to any sponsor or partner website associated with us and specific to the service you are availing), you will be directed to that site. Please note that these external sites are not operated by us. Therefore, we strongly advise you to review the privacy policy of these websites before proceeding to avail of any services or engaging in a transaction with such third-party websites. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

13. Changes to this Privacy Policy

We reserve the right to update this Privacy Policy from time to time. Any changes will be posted on this page with an updated revision date.

14. Governing Law

The Privacy Policy shall be governed in accordance with the federal laws of the UAE. Any dispute or difference whatsoever arising between you and us with respect to this Privacy Policy shall be conclusively settled by arbitration by a sole arbitrator in accordance with the relevant rules of the Dubai International Arbitration Centre (DIAC) as modified from time to time (which are deemed to be incorporated by reference into this clause), and the award made in pursuance thereof shall be binding on the parties involved. The language of the arbitration shall be English, and the place of arbitration shall be Dubai International Financial Centre, UAE. The arbitration award shall be in lieu of any other remedy which might otherwise be available to the parties.

For disputed claims of less than five hundred thousand dirhams (AED 500,000), the parties may elect to have the disputed claim decided by the Small Claims Tribunal (SCT) located within the DIFC Courts, Dubai.

15. Contact Us

If you have any questions about this Privacy Policy or our privacy practices, please contact us at:

ATB Global Legal Consultancy LLC

P.O Box 6157, Abu Dhabi, UAE

admin@atblegal.com

+971 2 886 9955