Overview
 
This Privacy Policy applies to anyone whose Personal Data is provided to us. It sets out how and why we collect, store, use and share your Personal Data. It also tells you about your privacy rights and how the law protects you. It tells you how you can  if you have any suggestions, questions or concerns about how we handle your Personal Data. 
 
“We” or “us” means Eltezam Ltd (ELTEZAM). ELTEZAM will usually be the Controller in relation to the Processing of your Personal Data.
  
The Data Protection Regulations 2021 (DP Regulations) apply to how we approach data privacy. In certain circumstances, other laws may apply to Personal Data we Process. 
 
1.     How we collect Personal Data
 
We collect Personal Data from you and your authorised representatives. There are several ways in which we collect this data, including through:
 
a.     email and telephone contact;
b.     web-based conference or video calls with us;
c.      onsite visits or other meetings that take place with us in person;
d.     use of our website, including applications, surveys, online forms and systems available on our website; or
e.     correspondence and other documents (hand delivered or sent to us by post or courier).
  
Where we collect your Personal Data from third parties, we do so on the legal bases set out in sections 3 and 4 of this Policy. 
 
2.         What personal information we collect
 
The Personal Data that we collect depends on how or why you are interacting with us, what services we are providing, or what supervisory or regulatory functions we are carrying out. 
 
In many cases it will be mandatory for you to provide Personal Data to ELTEZAM to enable us to provide services. If you do not provide us with the requested Personal Data in these instances, we will not be able to provide you with the relevant services. 
 
The types of personal information we may collect include:
 
* Names,  and contact details such as current and previous email addresses, postal addresses, residential addresses, phone numbers and other contact information; 
* Nationality, residency, date and place of birth, passport numbers and other information available on copies of identification documents such as passports and ID cards;
* Records of correspondence including email communications;
* Payment information such as credit or debit card numbers and bank account details;
 
Minors (i.e. individuals under the age of 18) should not provide us with their Personal Data – it should be provided via their parent or guardian. Where we receive Personal Data relating to a minor, we will assume it has been appropriately provided.
 
3.         Ways we use your Personal Data
 
Some of the ways we may use your Personal Data are set out below. 
 
General
 
Website Use
 
We may use Personal Data which you provide to us or we collect from you to maintain and improve our website services as well as to develop new features to improve customer experience and support, authenticate users and send administrative messages. We may conduct data analysis, testing, and research and to monitor and analyse usage and activity trends. 
 
ELTEZAM Services
 
We may collect and use Personal Data as part online platform to facilitate debt collection services, to enable creditors to track and recover monies from delinquent or defaulted loans. Debtors, or authorized third parties,  or help resolve delinquent debts.
 
AAA  
 
4.         Lawful basis for collection and Processing of Personal Data
 
We collect Personal Data only where it is relevant to and necessary for specified, explicit and legitimate purposes determined at the time of collection. 
 
Generally, we Process Personal Data on one or more of the following grounds set out in Section 5 of the DP Regulations:
a.     for the performance of a contract to which an individual is a party or to take steps at the request of an individual before entering into such contract (Section 5(1)(b) of the DP Regulations); 
b.     where Processing is necessary for ELTEZAM to comply with applicable laws (Section 5(1)(c) of the DP Regulations); and
c.      in certain circumstances, we may rely upon the consent of an individual given for specific purposes in accordance with the DP Regulations (Section 5(1)(a) of the DP Regulations).
  
The DP Regulations identify certain Personal Data Processing which leads to a high risk to the rights and freedoms of individuals by virtue of the nature, scope, context and purposes of the Processing of their Personal Data and imposes specific requirements concerning such activities. We do not ordinarily undertake any of the high-risk Processing activities as described in the DP Regulations.
 
Unless we explicitly tell you on a case by case basis, we do not engage in automated decision-making when Processing Personal Data.
 
5.         Sharing Personal Data
 
 
We may share Personal Data in the following circumstances:
 
a.     to our third-party professional advisors, service providers, agents, subcontractors and other organisations for the purposes of providing services to us or to you on our behalf, who are under a duty of confidentiality with ELTEZAM; 
b.     any person to whom information is required or requested to be disclosed by any governmental, taxation or other regulatory authority or similar body or pursuant to any applicable law or regulation. 
We may also share your Personal Data with our affiliates for internal reasons, primarily for business and operational purposes. 
 
In most cases, the laws of the ADGM allow us to share this information without the consent of the individual to whom the Personal Data relates. Where we are required to obtain such consent, we ensure that we obtain adequate consent from the relevant individual in accordance with the DP Regulations.
  
We may share your Personal Data with any other person if we notify you and obtain your consent to the disclosure.
 
Your Personal Data may be processed by us, our subsidiaries and those other parties described above, outside of the ADGM. We will ensure that there are adequate mechanisms in place to protect your personal information in accordance with applicable data protection and privacy law. We will do this through use of data transfer agreements implementing standard data protection clauses. 
 
6.         Where we store your Personal Data
 
The Personal Data that we collect from you may be securely transferred to and securely stored on our databases, located on our secure servers both in the United Arab Emirates or abroad. 
 
7.         Data Security
 
We store Personal Data in electronic, digital and paper format. We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only Process your Personal Data on our instructions, and they are subject to a duty of confidentiality.
 
We have put in place procedures to deal with any suspected or actual Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. Where a direct communication to you will involve disproportionate effort, we may instead inform you via a public communication or other similar measures that are equally effective. 
 
Unfortunately, no data transmission over the internet can be guaranteed to be 100% secure. Therefore, ELTEZAM cannot guarantee the security of any Personal Data you transmit to us over the internet, and you do so at your own risk. 
  
8.         Data retention 
 
We Process Personal Data for such periods as is necessary to fulfil our statutory functions and for the purposes set out in this Policy, unless a longer period for the retention of Personal Data is required by law. 
 
We may retain your Personal Data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
  
Personal Data Processed based on consent will be retained for the period specified in the consent, or where not specified, until you withdraw your consent. 
 
9.         Cookies & Third-Party Websites
 
Our website uses cookies. A cookie is a small piece of data that a website stores on a visitor’s computer or mobile device. 
 Our website may from time to time contain links to and from other websites. This includes websites owned or controlled by independent parties not controlled or authorised by ELTEZAM. If you follow a link to any of these websites, please note that these websites have their own privacy policy, data collection practices and security measures and we do not accept any responsibility or liability for these policies. Please ensure you check these policies before submitting any Personal Data. If you decide to access linked third-party websites, you do so at our own risk. 
 
 
10.       Your rights
 
Under the DP Regulations you have rights as an individual which you can exercise in relation to the Personal Data we hold about you. 
  
If you wish to exercise any of these rights set out above, please contact dpo@ELTEZAM.com
 
Note: your right of access can be exercised in accordance with DP Regulations and other applicable laws. There are circumstances where we may not be able to comply with your request, such as where we have a legal duty to retain Personal Data, or where access to Personal Data would prejudice the proper function of ELTEZAM’s statutory duties. In addition, certain Authorities are required to adhere to certain legal requirements of confidentiality.
 
11.       Our Data Protection Officer and how you can contact us
 
We have appointed a Data Protection Officer (DPO) who oversees data privacy and data protection compliance across ELTEZAM and each of the Authorities and informs and advises us on our data protection obligations. The DPO acts as our contact point with the ELTEZAM Office of Data Protection. 
 
If you have any questions or requests or wish to make a complaint, you can let us know by email to dpo@ELTEZAM.com. 
  
12.       Changes to our Privacy Policy
 
ELTEZAM may amend this Policy from time to time to meet changes in the regulatory environment, business needs, or to satisfy the needs of our customers and service providers. Any changes we make to this Policy will be posted on our website and date stamped so that you are always aware of the latest update. You should check this page from time to time to ensure you are happy with any changes.