Privacy Notice Statement Template for United Arab Emirates

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Privacy Notice Statement

"I need a Privacy Notice Statement for my Dubai-based e-commerce company that will launch in March 2025, with specific provisions for customer data collection through our mobile app and website, including coverage for both DIFC and mainland UAE operations."

Document background
The Privacy Notice Statement is a mandatory document under UAE Federal Decree-Law No. 45 of 2021, required for organizations that collect and process personal data within the UAE jurisdiction. This document must be provided to data subjects before or at the time of data collection, explaining how their personal data will be handled. It needs to address requirements from both federal law and, where applicable, specific regulations from free zones such as DIFC and ADGM. The Privacy Notice Statement should be clear, accessible, and comprehensive, covering all aspects of data processing activities, security measures, data subject rights, and international transfer mechanisms. It serves as a crucial compliance tool and helps organizations maintain transparency in their data processing activities.
Suggested Sections

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, aligned with UAE law definitions

4. Types of Personal Data Collected: Detailed categorization 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: Specific purposes for which personal data is collected and used

7. Data Subject Rights: Rights of individuals under UAE data protection law and how to exercise them

8. Data Security Measures: Overview of technical and organizational measures to protect personal data

9. Data Retention: How long personal data is kept and criteria for determining retention periods

10. International Data Transfers: Information about cross-border data transfers and safeguards

11. Contact Information: Details of the data controller and how to contact for privacy matters

12. Updates to Privacy Notice: How changes to the privacy notice will be communicated

Optional Sections

1. Specific Processing Activities: Detailed section for organizations with complex data processing operations requiring additional explanation

2. Cookies and Tracking Technologies: Required for organizations operating websites or online services that use tracking technologies

3. Children's Privacy: Required if services or products may be accessed by or target children

4. DIFC/ADGM Specific Provisions: Required for organizations operating in these free zones to address additional requirements

5. Sector-Specific Disclosures: Additional disclosures required for specific sectors (e.g., healthcare, financial services)

6. Marketing Communications: Required if personal data is used for marketing purposes

7. Automated Decision Making: Required if the organization uses automated processing to make decisions about individuals

8. Employee Data Processing: Required for organizations processing employee personal data

Suggested Schedules

1. Data Processing Activities Register: Detailed list of data processing activities and their purposes

2. Categories of Recipients: List of third parties with whom personal data is shared

3. Technical and Organizational Measures: Detailed description of security measures implemented

4. Data Subject Request Procedures: Detailed procedures for handling data subject rights requests

5. Retention Schedule: Detailed retention periods for different categories of personal data

6. Cross-border Transfer Mechanisms: Details of mechanisms used for international data transfers

Authors

Alex Denne

Head of Growth (Open Source Law) @ Genie AI | 3 x UCL-Certified in Contract Law & Drafting | 4+ Years Managing 1M+ Legal Documents | Serial Founder & Legal AI Author

Relevant legal definitions
Clauses
Relevant Industries

Financial Services

Healthcare

E-commerce

Technology

Telecommunications

Real Estate

Education

Retail

Professional Services

Manufacturing

Hospitality

Transportation

Media and Entertainment

Insurance

Energy

Relevant Teams

Legal

Compliance

Information Security

Risk Management

IT

Human Resources

Data Protection

Privacy

Operations

Information Governance

Regulatory Affairs

Corporate Governance

Information Technology Security

Data Management

Relevant Roles

Chief Privacy Officer

Data Protection Officer

Legal Counsel

Compliance Manager

Information Security Manager

Risk Manager

Chief Information Security Officer

Privacy Manager

Chief Legal Officer

Compliance Director

Data Governance Manager

Chief Technology Officer

IT Security Manager

Chief Operating Officer

Human Resources Director

Industries
Federal Decree-Law No. 45 of 2021: The UAE's main Personal Data Protection Law that establishes the general framework for protecting personal data and regulating its processing. It includes requirements for privacy notices, data subject rights, and data processing principles.
UAE Cabinet Resolution No. 100 of 2019: Concerning the Executive Regulations of Federal Decree-Law No. 2 of 2019 on the Use of ICT in Healthcare, which includes specific provisions for handling health-related personal data.
DIFC Law No. 5 of 2020: The Data Protection Law specific to Dubai International Financial Centre (DIFC), which follows GDPR-like principles and includes specific requirements for privacy notices within the DIFC jurisdiction.
ADGM Data Protection Regulations 2021: Abu Dhabi Global Market's data protection regulations that govern the collection and processing of personal data within the ADGM jurisdiction.
Federal Law No. 19 of 2018: Foreign Direct Investment Law that includes provisions affecting how foreign companies must handle data in the UAE.
UAE Consumer Protection Law (Federal Law No. 15 of 2020): Contains provisions related to consumer data protection and privacy in commercial transactions.
UAE Cyber Crime Law (Federal Decree-Law No. 5 of 2012): Includes provisions relating to privacy violations and unauthorized access to personal data, which should be considered in privacy notices.
UAE Telecommunications Law: Regulations governing data protection and privacy in telecommunications and digital communications, administered by the Telecommunications and Digital Government Regulatory Authority (TDRA).
Teams

Employer, Employee, Start Date, Job Title, Department, Location, Probationary Period, Notice Period, Salary, Overtime, Vacation Pay, Statutory Holidays, Benefits, Bonus, Expenses, Working Hours, Rest Breaks,  Leaves of Absence, Confidentiality, Intellectual Property, Non-Solicitation, Non-Competition, Code of Conduct, Termination,  Severance Pay, Governing Law, Entire Agreemen

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