Data protection is of particularly high importance to us. The use of our website is generally possible without providing any personal data. However, if a data subject wants to use special services via our website, processing of personal data may become necessary. If the processing of personal data is required and there is no legal basis for such processing, we generally obtain the consent of the data subject.
The processing of personal data, such as the name, address, e-mail address or telephone number of a data subject, is always carried out in accordance with the General Data Protection Regulation (GDPR) and in compliance with the country-specific data protection regulations applicable to us. Through this privacy policy, we aim to inform the public about the nature, scope, and purpose of the personal data we collect, use, and process. Furthermore, data subjects are informed of their rights through this privacy policy.
As the controller, we have implemented numerous technical and organizational measures to ensure the most complete protection of personal data processed through this website. Nevertheless, internet-based data transmissions may have security gaps, so absolute protection cannot be guaranteed. For this reason, every data subject is free to transmit personal data to us via alternative means, for example, by telephone.
1. Definitions
Our privacy policy is based on the terms used by the European legislator when adopting the General Data Protection Regulation (GDPR). This policy is intended to be easy to read and understand for the public, as well as for our customers and business partners. To ensure this, we would like to explain the terminology used in advance.
We use the following terms, among others, in this privacy policy:
a) Personal Data
Personal data means any information relating to an identified or identifiable natural person (hereinafter “data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
b) Data Subject
A data subject is any identified or identifiable natural person whose personal data is processed by the controller responsible for the processing.
c) Processing
Processing is any operation or set of operations which is performed on personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
d) Restriction of Processing
Restriction of processing is the marking of stored personal data with the aim of limiting its future processing.
e) Profiling
Profiling means any form of automated processing of personal data consisting of the use of such data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements.
f) Pseudonymization
Pseudonymization is the processing of personal data in such a manner that the data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.
g) Controller or Data Controller
Controller or data controller means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data. Where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.
h) Processor
Processor means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
i) Recipient
Recipient means a natural or legal person, public authority, agency or another body to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients.
j) Third Party
Third party means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process personal data.
k) Consent
Consent means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
2. Name and Address of the Controller
The controller within the meaning of the GDPR, other data protection laws applicable in the member states of the European Union and other provisions of a data protection nature is:
Abu Adel Group - FZCO
Office 1002, Floor 10
B2B Tower, Marasi Drive
Business Bay, Dubai, U.A.E
Phone: +971 58 506 5913
E-Mail: info@adai-ai.com
3. Collection of General Data and Information
Each time our website is accessed by a data subject or an automated system, a series of general data and information is collected. This general data and information is stored in the server log files. The following may be collected: (1) browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our website (so-called referrers), (4) the sub-websites accessed via an accessing system on our website, (5) the date and time of access to the website, (6) an Internet protocol address (IP address), (7) the Internet service provider of the accessing system, and (8) other similar data and information that serve to protect our IT systems in the event of attacks.
When using this general data and information, we do not draw any conclusions about the data subject. Rather, this information is needed to (1) deliver the content of our website correctly, (2) optimize the content and advertising of our website, (3) ensure the long-term functionality of our IT systems and website technology, and (4) provide law enforcement authorities with the necessary information in the event of a cyberattack. These anonymously collected data and information are therefore evaluated by us statistically and with the aim of increasing data protection and data security in our company, ultimately to ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from all personal data provided by a data subject.
4. Contact via the Website
Due to legal requirements, our website contains information that enables quick electronic contact with our company, as well as direct communication with us, which also includes a general address for electronic mail (e-mail address). If a data subject contacts the controller by e-mail or via a contact form, the personal data transmitted by the data subject are automatically stored. Such personal data transmitted voluntarily by a data subject to the controller are stored for the purpose of processing or contacting the data subject. There is no disclosure of this personal data to third parties.
5. Routine Erasure and Blocking of Personal Data
The data controller processes and stores personal data of the data subject only for the period necessary to achieve the purpose of storage or as provided for by the European directives and regulations or any other legislator in laws or regulations to which the controller is subject.
If the purpose of storage ceases to apply or a storage period prescribed by the European directives and regulations or another competent legislator expires, the personal data will be routinely blocked or deleted in accordance with legal requirements.
6. Rights of the Data Subject
a) Right to Confirmation
Every data subject has the right granted by the European legislator to obtain confirmation from the controller as to whether personal data concerning them are being processed. If a data subject wishes to exercise this right, they may contact a staff member of the controller at any time.
b) Right of Access
Every data subject has the right granted by the European legislator to obtain at any time from the controller, free of charge, information about the personal data stored concerning them and a copy of this information. Furthermore, the data subject has the right to obtain the following information:
- The purposes of the processing
- The categories of personal data being processed
- The recipients or categories of recipients to whom the personal data have been or will be disclosed, especially in third countries or international organizations
- Where possible, the planned duration for which the personal data will be stored, or if not possible, the criteria used to determine that duration
- The existence of the right to request rectification or erasure of personal data, or restriction of processing, or to object to such processing
- The existence of the right to lodge a complaint with a supervisory authority
- Where the personal data are not collected from the data subject: any available information as to their source
- The existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) GDPR and—at least in those cases—meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing
If personal data are transferred to a third country or to an international organization, the data subject also has the right to be informed of the appropriate safeguards relating to the transfer.
c) Right to Rectification
Every data subject has the right granted by the European legislator to request the immediate rectification of inaccurate personal data concerning them. Considering the purposes of the processing, the data subject also has the right to request the completion of incomplete personal data, including by means of a supplementary statement.
d) Right to Erasure (Right to Be Forgotten)
Every data subject has the right granted by the European legislator to request from the controller the erasure of personal data concerning them without undue delay where one of the following grounds applies and insofar as the processing is not necessary:
- The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed
- The data subject withdraws consent on which the processing is based according to Art. 6(1)(a) or Art. 9(2)(a) GDPR and where there is no other legal ground for the processing
- The data subject objects to the processing pursuant to Art. 21(1) GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Art. 21(2) GDPR
- The personal data have been unlawfully processed
- The personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject
- The personal data have been collected in relation to the offer of information society services referred to in Art. 8(1) GDPR
If one of the above reasons applies and a data subject wishes to request the deletion of personal data stored by us, they may contact a staff member of the controller at any time. The request will be acted upon without delay.
If the personal data were made public by us and we, as the controller, are obliged pursuant to Art. 17(1) GDPR to erase the personal data, we shall take reasonable steps, including technical measures, to inform other controllers which are processing the published personal data that the data subject has requested the erasure by such controllers of any links to, or copy or replication of, those personal data, as far as processing is not required.
e) Right to Restriction of Processing
The data subject has the right to obtain from the controller restriction of processing where one of the following applies:
- The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data
- The processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead
- The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defense of legal claims
- The data subject has objected to processing pursuant to Art. 21(1) GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject
If one of the above conditions is met, the data subject may contact a staff member of the controller at any time to request the restriction of processing.
f) Right to Data Portability
Every data subject has the right to receive the personal data concerning them, which they have provided to a controller, in a structured, commonly used and machine-readable format. They also have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where the processing is based on consent pursuant to Art. 6(1)(a) or Art. 9(2)(a) GDPR or on a contract pursuant to Art. 6(1)(b) GDPR and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest.
In exercising their right to data portability pursuant to Art. 20(1) GDPR, the data subject shall have the right to have the personal data transmitted directly from one controller to another, where technically feasible and where this does not adversely affect the rights and freedoms of others.
g) Right to Object
Every data subject has the right to object, on grounds relating to their particular situation, at any time to processing of personal data concerning them which is based on Art. 6(1)(e) or (f) GDPR, including profiling based on those provisions.
In the event of an objection, we shall no longer process the personal data unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defense of legal claims.
Where personal data are processed for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data for such marketing. This also applies to profiling to the extent that it is related to such direct marketing.
Where the data subject objects to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.
The data subject also has the right, on grounds relating to their particular situation, to object to processing of personal data concerning them for scientific or historical research purposes or statistical purposes pursuant to Art. 89(1) GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
h) Automated Individual Decision-Making, Including Profiling
Every data subject has the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning them or similarly significantly affects them, unless the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and a data controller; or (2) is authorized by Union or Member State law and which also lays down suitable measures to safeguard the data subject's rights and freedoms and legitimate interests; or (3) is based on the data subject's explicit consent.
Where the decision (1) is necessary for entering into or the performance of a contract, or (2) it is based on the data subject’s explicit consent, we will implement suitable measures to safeguard the data subject's rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express their point of view and to contest the decision.
i) Right to Withdraw Data Protection Consent
Every data subject has the right granted by the European legislator to withdraw their consent to the processing of personal data at any time.
7. Legal Basis for Processing
Art. 6(1)(a) GDPR serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is a party—such as processing operations necessary for the delivery of goods or the provision of any other service—the processing is based on Art. 6(1)(b) GDPR. The same applies to such processing operations that are necessary for carrying out pre-contractual measures, for example in cases of inquiries concerning our products or services. If our company is subject to a legal obligation by which the processing of personal data is required, such as for the fulfillment of tax obligations, the processing is based on Art. 6(1)(c) GDPR. In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or another natural person. This would be the case, for example, if a visitor were injured in our company and their name, age, health insurance data, or other vital information had to be passed on to a doctor, hospital, or other third party. In that case, the processing would be based on Art. 6(1)(d) GDPR. Finally, processing operations could be based on Art. 6(1)(f) GDPR. This legal basis is used for processing operations which are not covered by any of the above legal grounds, if processing is necessary for the purposes of the legitimate interests pursued by our company or by a third party, unless such interests are overridden by the interests or fundamental rights and freedoms of the data subject. Such processing operations are particularly permissible because they have been specifically mentioned by the European legislator (Recital 47 Sentence 2 GDPR).
8. Legitimate Interests Pursued by the Controller or a Third Party
If the processing of personal data is based on Article 6(1)(f) GDPR, our legitimate interest is to carry out our business in favor of the well-being of all our employees and shareholders.
9. Duration of Storage of Personal Data
The criterion for the duration of storage of personal data is the respective statutory retention period. After expiry of that period, the corresponding data are routinely deleted, provided they are no longer necessary for the performance or initiation of a contract.
10. Statutory or Contractual Requirements to Provide Personal Data; Necessity for Contract Conclusion; Obligation of the Data Subject to Provide the Data; Possible Consequences of Failure to Provide Such Data
We inform you that the provision of personal data is partly required by law (e.g., tax regulations) or may also result from contractual arrangements (e.g., information about the contractual partner). Sometimes it may be necessary to conclude a contract that the data subject provides us with personal data that must subsequently be processed by us. The data subject is, for example, obliged to provide us with personal data when our company signs a contract with them. The non-provision of personal data would mean that the contract with the data subject could not be concluded. Before providing personal data, the data subject must contact one of our employees. Our employee will clarify for the data subject whether the provision of personal data is required by law or contract, or necessary for the conclusion of a contract, whether there is an obligation to provide the personal data, and what the consequences of non-provision of personal data would be.
11. Existence of Automated Decision-Making
As a responsible company, we do not use automatic decision-making or profiling.
