This General Privacy Notice serves as a fundamental compliance document for organizations operating in the United Arab Emirates that collect and process personal data. It is designed to meet the requirements of Federal Decree-Law No. 45/2021, as well as other applicable data protection regulations including those specific to free zones like DIFC and ADGM. The document should be implemented by any organization handling personal data to inform data subjects about their data processing activities, ensure transparency, and demonstrate compliance with UAE privacy laws. It is particularly important given the UAE's increasing focus on data protection and the significant penalties for non-compliance. The notice must be regularly reviewed and updated to reflect changes in data processing activities or regulatory requirements.
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1. Introduction: Overview of the privacy notice and its purpose
2. Scope and Applicability: Who the privacy notice applies to and what activities it covers
3. Definitions: Key terms used throughout the privacy notice
4. Types of Personal Data Collected: Detailed categories of personal data collected and processed
5. Legal Basis for Processing: Legal grounds under UAE law for collecting and processing personal data
6. Purposes of Processing: How and why personal data is used
7. Data Sharing and Disclosure: Third parties with whom data is shared and circumstances of sharing
8. Cross-Border Data Transfers: Information about international data transfers and safeguards
9. Data Security Measures: How personal data is protected
10. Data Retention: How long personal data is kept and criteria for retention periods
11. Individual Rights: Rights of data subjects under UAE law and how to exercise them
12. Updates to Privacy Notice: How and when the privacy notice may be updated
13. Contact Information: How to contact the organization about privacy matters
1. Children's Privacy: Required if services may be used by or data collected from children
2. Cookies and Tracking Technologies: Required for websites and online services that use cookies or similar technologies
3. Mobile App Privacy: Required if the organization operates mobile applications
4. Free Zone Specific Provisions: Required if operating in DIFC or ADGM with additional requirements
5. Sector-Specific Disclosures: Required for regulated industries like healthcare or financial services
6. Marketing Communications: Required if personal data is used for marketing purposes
7. Automated Decision Making: Required if using automated processing to make decisions about individuals
8. CCTV and Surveillance: Required if using surveillance systems in physical locations
1. Data Processing Activities Register: Detailed list of data processing activities and their purposes
2. Third-Party Processors: List of approved data processors and their roles
3. Technical and Organizational Measures: Detailed description of security measures implemented
4. Cookie List: Comprehensive list of cookies used and their purposes
5. Data Retention Schedule: Detailed retention periods for different categories of personal data
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