1. Introduction
Protecting your privacy is very important to us. This privacy policy sets out how My Group LLC collects and processes your personal information. It also sets out your rights in relation to the personal information we hold about you. If you have questions about this policy, please contact My Group LLC’s Data Protection and Privacy Office at [email protected]
What does this policy do?
This policy describes how we deal with the collected personal information of individuals that interact with our offices – this includes representatives of our suppliers, customers, sponsors and business partners; users of the My Group Holding’s website and mobile applications (“apps”); shareholders; and job applicants.
For the purposes of this policy, “personal information” means any information about an identified or identifiable person. This includes where you can be identified, directly or indirectly, including by reference to an identifier (for example, a name or email address, or an online identifier such as a unique device identification number).
Who we are
References to “My Group LLC”, “we” or “us” in this policy mean MyGroup LLC, Dubai 16C, Creek Tower, DLD, United Arab Emirates, and all subsidiaries within the MyGroup Holding Companies worldwide (together “MyGroup”, “we”, or “us”).
2. Types of personal information we collect
We collect and process different types of personal information depending on how you interact with us. In some cases, this may include information that shows who you are and/or is linked to you as a result of your interactions with our offices. In some circumstances, we may also collect sensitive personal information about you.
How we collect personal information
We will primarily collect personal information from you either directly (such as when you subscribe to a news alert or request information from us, including through the Contact Us form available on our website) or indirectly from your interactions with us (such as by monitoring your use of the MyGroup website and apps).
Types of personal information we collect
The types of personal information that we collect about you may include:
Identification data – such as your name, gender, job title, photograph and date of birth.
Contact details – such as your home and business address, email address and telephone number.
Recruitment-related information – such as your name, email address, location, telephone number, qualifications, employment history, interests, types of roles you are interested in, your work application form and resume or CV. If you progress through the interview process, we may also collect interview notes, references, results of any psychometric tests and background checks (including criminal records checks), your documents and other information to verify your identity and right to work.
e-Business information – this includes information required to provide access to our website (such as login information, IP addresses), and records of your use of those websites or portals.
Usage information – information we collect when you use our websites or apps, such as server log information (your IP address, browser type, operating system, browser language, time zone, access times and any referring addresses) and location information.
Other information – this includes information about access and attendance to MyGroup premises and physical assets (such as security records about times of entry and exit, and information collected through CCTV), details about your use of our assets, communications with you (including complaints or concerns raised by you or any feedback or survey responses that you provide to us) and other information you voluntarily provide to MyGroup.
3. Why we process your personal information
We process personal information to conduct our business – this includes managing our contractual relationships, recruitment, monitoring access to our websites and apps, managing safety and security risks, and complying with our legal obligations. We also process sensitive personal information where you have provided your consent or it is necessary to comply with legal obligations.
The purposes for which we process your personal information will depend on the type of personal information collected and the context in which it was collected. However, the primary purposes for which we process personal information include:
managing our relationship with you – this includes providing you with information or services, improving our products and services and communicating with you;
business-related purposes – this includes negotiating, managing, and fulfilling our contracts with customers, suppliers and third parties (including e-commerce transactions); managing business relationships; administering real estate leases and licenses; conducting clearance procedures; managing accounts and records; supporting corporate social responsibility activities; resource planning and workforce management; activities and operations; internal investigations; and debt administration;
marketing and public relation purposes – this includes analyzing the characteristics of visitors to our website; to prepare analytics and profiling for business intelligence purposes; to personalize your experience on our website; managing our communications for demographic analysis and personalization of the website.
recruitment-related purposes – this includes considering you for career opportunities (including internship positions) with MyGroup Holding LLC and inviting you to participate in recruitment activities and events;
managing safety and security risks – this includes managing and monitoring access and use of our premises and sites, safety and security at our sites (including through the use of CCTV), and our IT environment (including monitoring electronic communications) and the health of those on our sites;
website administration and internal operations – this includes troubleshooting, data analysis, testing, research, statistical and survey purposes;
managing shareholder relationships – this includes for the purposes of undertaking share transactions, dividend payments and communications with shareholders; and
legal obligations – this includes meeting obligations imposed under law; responding to lawful requests from governments and public authorities; and responding to potential or actual litigation.
We may also collect and process your personal information for any other purposes for which you have provided your consent or if there is another lawful basis for doing so.
The information is collected and processed in accordance with local laws including General Data Protection Regulation regulations in the European Union. For those individuals to whom the General Data Protection Regulation applies, general personal information is collected and processed on the basis of the contract formed or to be formed between MyGroup LLC and the applicant, but the additional sensitive personal information is collected and processed under the lawful basis of consent.
By agreeing to use our services and giving your consent, you are giving MyGroup LLC the following rights:
The right to collect your personal information;
The right to process your personal information;
You can revoke consent at any time and you also have the right to have your personal information erased at any time. MyGroup LLC will erase any data as long as it is legally allowed in the country where we operate. You may make this request by simply sending us a request.
After review we will:
inform you that your data has been removed from our database;
inform you that MyGroup LLC is legally not allowed to remove the mentioned data from our records considering the nature of the data and the country of its origin.
We are using all reasonable measures to ensure that your personal information remains confidential.
If you consider that your rights have been violated under General Data Protection Regulation you may complain to the data protection authority in the country in which you reside or through the website https://ec.europa.eu/commission/priorities/justice-and-fundamental-rights/data-protection/2018-reform-eu-data-protection-rules_en
Cookies
Our websites and apps may use cookies. Cookies are small pieces of data stored on the web browser of your device. These are used by us for site administration and analysis purposes and to deliver tailored content. If you wish not to take advantage of cookies, you may configure your browser not to accept them (although this may disable or render unusable some of the features our online services). We use a combination of session cookies and persistent cookies in order to track how you use and experience our website, build anonymous statistical data about how our website is performing, and power the personalization of website content to you. You can find more information about cookies at www.allaboutcookies.org. We have little control over these “third-party” cookies, so we suggest that you check the respective privacy policies for these external services to help you understand what data these organizations hold about you and what they do with it.
∙ Google AdWords: https://support.google.com/adwords/answer/2549116?hl=en
∙ Google Analytics: http://www.google.com/analytics/learn/privacy.html
∙ Google Tag Manager: https://www.google.com/analytics/tag-manager/faq/
Web Beacons and Web Server Logs
A web server logs are a record of activity created by the computer that delivers the web pages you request to your browser. The web server log also may record information about your browsers, such as your IP address and the cookies set on your web browser by the server.
A web beacon is a clear picture file used to keep track of your navigation through a website that allows us to count and recognize users who have visited that page. Among other things, a web beacon can be used in an HTML-formatted email to determine responses to our communications and measure their effectiveness. You can generally avoid web beacons in email by turning off the HTML display and displaying only the text portion of your email.
Hyperlinks
Our websites and apps may contain links to other websites. We are not responsible for the privacy practices or the content of other websites. The privacy practices applicable to other websites may differ substantially from ours. Please read the privacy policy of any other websites you visit before using such websites.
4. Who we share your personal information with
We may share your personal information within our corporate group as well as with third parties involved in the running of our business and your authorized representatives. This may involve sharing information across national borders.
Disclosures within our corporate group
We may share your personal information (which may sometimes include sensitive personal information) within our corporate group who require the information for the purposes in this policy. This will include sharing your personal information with MyGroup LLC entities in countries other than where the information was originally collected. Sharing of this information within our group is governed by a data transfer agreement that we have in place with all relevant MyGroup LLC entities.
Some members of our corporate group also perform shared services for other MyGroup LLC entities.
5. How we store and protect your personal information
We take steps to ensure that your personal information is kept secure and protected against unauthorized access or use. We only keep your personal information for as long as we need it to carry out the purposes described in this policy.
Information security
We have put in place procedures and technologies to maintain the security of your personal information from the point of collection to the point of destruction.
We also take steps to ensure that all our workers are aware of, and are properly trained through applicable information security policies and procedures that are designed to keep your personal information secure. We will investigate and take appropriate action if we become aware of any failure to comply with these policies and procedures.
Storing personal information
We generally store the personal information that we collect in electronic databases. These databases are generally hosted in our dedicated data centres. We may also use third parties to store and process your personal information. However, we will only do this if the party agrees to comply with our procedures and policies or if they put in place equivalent security measures.
Information retention
Our aim is to keep personal information for no longer than is necessary for the purposes described in this policy or as otherwise required by law.
Job applicants
If you are a job applicant, and your application is unsuccessful, we may retain your personal information for 12 months for the purposes of considering you for other roles within MyGroup LLC. We are under no obligation to retain your personal information for this purpose and may elect to delete your personal information at any time following an unsuccessful application. You may request that we delete your personal information from our database at any time.
6. Your rights and choices
You have rights relating to your personal information held by MyGroup LLC. Let us know if you want to correct your personal information or if you have concerns about how we are handling your personal information.
Your rights
You have certain rights in relation to your personal information that we hold about you, though the details of these may vary depending on the country where you are based. We respond to all requests we receive from individuals wishing to exercise their rights in relation to any information we hold in accordance with applicable data protection laws.
If you wish to access, correct or update any personal information that we hold about you, please send a request to [email protected].
If you are concerned about how we are dealing with your personal information, then you may have the right to complain to an applicable data protection authority. The relevant authority will depend on which country you are located in. Before raising a complaint with a data protection authority, we recommend that you first raise the issue with us so we can address your concerns as quickly as possible. We will make a record of your complaint and will deal with it as quickly as we can while keeping you informed of progress. Even if we are not able to address your concern, we will be able to provide further information about how you can contact a relevant data protection authority. For more information, please contact the MyGroup LLC Data Protection and Privacy Office.
7. You have the right, in certain circumstances, to request:
the erasure of any personal information that we hold about you;
the restriction of processing of any personal information that we hold about you; and
the transfer of your personal information from MyGroup LLC to a third party.
You also have the right to object to the processing of your personal information by MyGroup LLC in certain circumstances.
You can also request a copy of the documented safeguards that we have put in place relating to the sharing of personal information across national borders, including our group data transfer agreement,
If you wish to make a request, or raise an objection, of this nature, contact the MyGroup LLC’s Data Protection and Privacy Office.
8. Updates to this policy
We will update this policy from time to time where necessary to reflect changes in applicable laws or in our privacy compliance practices. The latest version of this policy will always be available online through the MyGroup LLC’s website.