Effective Date: 19th October 2016
GWP Management Limited (“Gateway Dubai“) is allowed to collect Personal Data by the Commissioner of Data Protection of the Dubai International Financial Centre (“DIFC”) and it processes, stores and transfers personal data in accordance with notification made to Commissioner of and in line with the DIFC Data Protection Law No. 1 of 2007 and its regulations thereunder.
Information We Collect
We may collect Personal Data about you that you provide to us when using the Site or when sent to us via other means, such as electronic mail or by agents whom you have authorised to release such data. Such information may include your name, phone number, physical address, net-assets, income and e-mail address. We assume all Personal Data provided by you is accurate and up-to-date.
We may also collect other information which may be linked to your Personal Data, including your IP address, geographic data, operating system type, and search preferences related to specific searches as well as other generic Internet usage related data.
How We Use and Disclose the Information We Collect
We may use Personal Data and other information collected through the Site for reasonable business purposes, including (a) to confirm your qualifications to access the Site; (b) to respond to your questions or comments submitted on the Site; (c) to build features that will make the services available on the Site easier to use; (d) for an improved user experience and general optimization purposes; and (e) to contact you from time to time.
We may share your Personal Data with third parties we appoint to perform services on our behalf, such as (a) web hosting; (b) data analysis; (c) search engine optimization; and (d) responding to queries received by you. All such third parties will be under an obligation to maintain the security and confidentiality of the Personal Data, and to process the Personal Data only in accordance with our instructions.
Gateway may, in compliance with applicable law, disclose Personal Data to protect ourselves against liability, to respond to subpoenas, judicial processes, lawsuits, warrants or equivalent by law enforcement officials or authorities, to investigate fraud or other wrongdoing or as otherwise required or necessary in order to comply with applicable law, or protect our legitimate interests.
Protecting Your Personal Data
To prevent unauthorized access to your Personal Data, we maintain reasonable physical, electronic and organizational procedures to protect Personal Data against accidental or unlawful destruction or accidental loss, alteration, or unauthorized disclosure or access. Personal Data is stored in a secure database that is only accessible to authorised employees of Gateway and other members our affiliated (group) companies.
Retention of Your Personal Data
Gateway will retain Personal Data for as long as it is necessary to fulfil the purpose for which it was collected, the legal or business purposes of Gateway, or as required by relevant laws.
When destroying Personal Data, we will take commercially reasonable and technically possible measures to make the personal information irrecoverable or irreproducible in accordance with applicable laws.
How You Can Access or Correct Your Personal Data
Under the Access and Correction Obligation, any member of the public may request access to their personal data under Gateway’s possession, enquire about the ways their personal data has been used over the past year, or submit a complaint with regards to Gateway’s application of the Personal Data Protection Act. To protect your privacy and security, we will verify your identity before granting access or making changes to your Personal Data.
Such requests or complaints should be directed to the Data Protection Officer in either Singapore or Dubai (contact details below).
All requests and/or complaints should be made via email. The requestor/complainant will be notified in advance of any administrative fee that will be imposed for such requests.
Requests and/or complaints will be promptly investigated by the relevant Data Protection Officer, and the requestor/complainant will receive a formal response following the completion of that investigation.
Singapore Data Protection Officer
#06-01A Suntec Tower Two
9 Temasek Blvd
You may also contact our Singapore Data Protection Officer at the following number: +65 6908 7404 or any other number that we may advise from time to time.
Dubai Data Protection Officer
2203 North Tower
Emirates Financial Towers
DIFC, Dubai 507080
United Arab Emirates
You may also contact our Dubai Data Protection Officer at the following number: +971 (0)4 518 5911 or any other number that we may advise from time to time.