This is One Zaabeel LLC’s (OZ) privacy policy and related privacy notice. OZ respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we deal with your personal data when you visit our website (regardless of where you visit it from).

By accessing OZ’s website you:

– agree to be bound by the following terms and conditions, including any modifications made to them from time to time, and each time you receive any information as a result of such access; and
– confirm that your agreement provided above is (i) freely given and confirmed by your continued access to the OZ website and/or by you providing your personal and sensitive data to OZ in the ways envisaged by this privacy notice.

Purpose of this privacy notice — This privacy notice aims to give you information on how OZ may collect and process your personal data through your use of this website, including any data you may provide through this website. This privacy notice supplements our terms of use and any other notices and is not intended to override them.

Controller and Processor

OZ may be the controller and processor and responsible for your personal data (collectively referred to as “OZ”, “we”, “us” or “our” in this privacy notice). We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about or requests relating to this privacy notice, please contact the data privacy manager using the details set out below.

Contact details

Our full details are: One Zaabeel LLC
Email address: [email protected]
Postal address: PO Box 333888, Dubai, UAE
You have the ability to contact certain supervisory authorities who deal with data protection issues.

Changes to the privacy notice and your duty to inform us of changes

Data protection laws are constantly evolving, the General Data Protection Regulations of the European Union came into force on 25 May 2018, and the Federal Decree-Law No.45/2021 on the Protection of Personal Data came into force on 2 January 2022. It is important that the personal data we hold about you, if any, is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements.
The data which may be collected.

Personal data, or personal information, generally means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows: Identity Data, Contact Data, Financial Data, Transaction Data, Technical Data, Profile Data, Usage Data, Marketing & Communications Data and Aggregated Data. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice. We do not seek to collect any Special Categories of Personal Data about you nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, in relation to the provision of goods or services). In this case, we may have to cancel a product or service.

How we collect your personal Data? — We may use different methods to collect data from and about you including through:

• Direct interactions. You may give us your personal data (including sensitive personal data) by filling in forms, by corresponding with us by post, phone, email, or by visiting our offices or otherwise.
• Automated technologies or interactions. As you interact with (i) our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns; and/or (ii) our offices, we may automatically collect personal (including sensitive personal data) about you. We collect this personal data by using cookies, server logs and other similar technologies, including those introduced in connection with limiting the spread of COVID-19.
• Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources.

How we use your personal data — We will only use your personal data when the law that is applicable to us allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) (including measures introduced in connection with limiting the spread of COVID-19) and your interests and fundamental rights do not override those interests.
• Where we need to comply with legal or regulatory obligations.

Purposes for which we will use your personal data

We have set out below a description of the ways we may use your personal data, which of the legal bases we rely on to do so, and have also identified what our legitimate interests are where appropriate. The below is not intended to be, and is not, exhaustive and we do rely on the consent you have provided as a basis for the collection and processing of your personal and sensitive data.

Contact by Us

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). You may receive marketing communications from us if you have requested information from us or purchased from us or if you provided us with your details and, in each case, you have not opted out of receiving that marketing. We will get your express opt-in consent before we share your personal data with any company outside the OZ group of companies for marketing purposes.

Opting out and Cookies

You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see Cookie Policy.

Change of purpose

We will only use your personal data and/or sensitive personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may collect and process your personal data and/or sensitive personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Disclosure of your personal data

We may have to share your personal data and/or sensitive personal data with Internal Third Parties, External Third Parties or third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets or where we seek to acquire other businesses or merge with them (if a change happens to our business, then the new owners may use your personal data and/or sensitive personal data in the same way as set out in this privacy notice). We seek to ensure that all relevant third parties respect the security of your personal data and/or sensitive personal data and treat it in accordance with the law.

Data security — We seek to ensure that appropriate security measures are in place to prevent any of your personal data and/or sensitive personal data that we may hold from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We have put in place procedures to deal with any personal data breach and will seek to notify you and any applicable regulator of a breach where we are legally required to do so.

Data retention — By law we have to keep basic information for certain periods of time. In some circumstances you can ask us to delete your data: see below for further information. In some circumstances we may anonymise your personal data and/or sensitive personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Your legal rights — Under certain circumstances, you may have rights under data protection laws that apply to us in relation to your personal data. You may find certain information about your rights on the internet. You may, in certain circumstances and subject to certain conditions, have the right to: Request access to your personal data (commonly known as a “data subject access request”). Request correction of the personal data that we hold about you. Request erasure of your personal data. We may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. Request restriction of processing of your personal data. Request the transfer of your personal data to you or to a third party. Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you wish to exercise any of the rights, please contact us in writing detailing your specific concern and legal right you are seeking to exercise. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. We try to respond to all legitimate requests within three months. Occasionally it may take us longer than this if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

The following Privacy Policy provides an overview of how One Zaabeel LLC (which includes all of its subsidiaries and related companies, including One Zaabeel Operations LLC) (together, “we”, “us” “our” or “One Za’abeel”) Processes the Personal Data (as defined below) you provide to us. This Privacy Policy applies to you because you are, will be or were a corporate tenant in a property owned and/or managed by One Za’abeel and you have provided us with the Personal Data of individuals or individuals have provided their Personal Data directly to us in relation to the tenancy arrangement we have with you (“Data Subjects”).

This Privacy Policy sets out the rights of the Data Subjects whose Personal Data we have been provided with, in accordance with Federal Decree-Law No. 45/2021 On the Protection of Personal Data, as amended from time to time (the “UAE Data Protection Law”).

1 Definitions

For the purposes of this Privacy Policy, the following terms (and any other capitalised terms used in this Privacy Policy) are defined in accordance with the UAE Data Protection Law:

“Personal Data” means any data relating to an identified natural person, or one who can be identified directly or indirectly by way of linking data, using identifiers such as name, voice, picture, identification number, online identifier, geographic location, or one or more special features that express the physical, psychological, economic, cultural or social identity of such person. It also includes Sensitive Personal Data and Biometric Data.

“Sensitive Personal Data” means any data that directly or indirectly reveals a natural person’s family, racial origin, political or philosophical opinions, religious beliefs, criminal records, biometric data, or any data related to the health of such person, such as his/her physical, psychological, mental, genetic or sexual condition, including information related to health care services provided thereto that reveals his/her health status.

“Biometric Data” means Personal Data resulting from Processing, using a specific technique, relating to the physical, physiological or behavioural characteristics of a Data Subject, which allows or confirms the unique identification of the Data Subject, such as facial images or fingerprint data.

“Processing” or “Process” means any operation or set of operations which is performed on Personal Data using any electronic or other means. This process includes the collection, storage, recording, organization, adaptation, alteration, circulation, modification, retrieval, exchange, sharing, use, or classification or disclosure of Personal Data by transmission, dissemination or distribution, or otherwise making it available, or aligning, combining, restricting, blocking, erasing or destroying Personal Data or creating models therefor.

2 Who is the controller of personal data and how can you contact them

For the purposes of the UAE Data Protection Law, a One Za’abeel entity will be the “Controller” processing the Personal Data of Data Subjects. This means that we specify the method, criteria and purpose of Processing such Personal Data.

If you or any Data Subject have any questions about this Privacy Policy, or our processing of Data Subjects’ Personal Data, please contact us at [email protected].

3 What personal data and sources do we use

We Process Personal Data in a variety of ways when you interact with One Za’abeel, both physically and online. Some examples include:

Personal Data that we obtain directly from you or a Data Subject, either electronically or in hard copy:
— via our website(s) and/or our mobile application(s);
— during contacts by phone, by email or by any other forms of electronic communication;
— during visits to our kiosks, events and/or offices (including engagements with our visitor management services team);
— when you make a tenancy application and/or enter into a lease or license with us;
— when you, or a Data Subject, participate in our customer surveys or promotions;
— when you make payments to us; or
— otherwise, as a result of your engagement with One Za’abeel.

Personal Data that we obtain from third parties we engage with, or which is otherwise publicly available, such as:
— brokers and agents working on our behalf;
— companies (such as security and facility management companies) providing services to us;
— social media platforms;
— marketing and advertising partners; and
— government or judicial authorities

We Process the following categories of Personal Data, which may include but are not limited to:
— personal contact details (e.g. name, phone number, email address);
— identification data (e.g. passport copies, visa copies and Emirates ID / government ID copies);
— access card information (e.g. access card number);
— parking card and vehicle information (e.g. make of car, car model and license plate number);
— images from CCTV and other monitoring technologies; and
— additional data provided to us, for example when accessing our website or mobile application(s)(e.g. username; password, IP address, etc.).

In certain limited circumstances, we may Process Sensitive Personal Data (e.g. as part of documenting a health & safety incident).

4 What do we process personal data for (purpose of processing)  and on what legal basis

We process Personal Data on the following legal grounds:
— if the Processing is necessary to perform a contract to which the Data Subject is a party or to take, at the request of the Data Subject, actions to conclude, amend or terminate a contract;
— if the Processing is necessary to fulfil obligations imposed by other UAE laws on One Za’abeel;
— if the Processing is necessary to protect the public interest;
— if the Processing is necessary to protect the interests of the Data Subject; or
— as a result of Data Subject consent. Data Subjects should be made aware that they can withdraw their consent at any time by contacting us using the contact details above.

One Za’abeel processes Personal Data for various purposes which may include but are not limited to:
— onboarding corporate tenants;
— managing the building (please see the Tenant Handbook for building management details);
— complying with applicable laws;
— marketing purposes; and/or
— for the performance of our tenancy agreement (or other contracts or policies).

5 Who receives personal data and will the data be transferred  to a third country

For the purposes described in this Privacy Policy, and subject to the UAE Data Protection Law, Personal Data may be shared with third party recipients outside of One Za’abeel, such as One Za’abeel’s suppliers and service providers including: auditors, brokers; agents, facilities management, parking, IT, security and marketing service providers; professional advisers that perform services on our behalf, as well as with other third parties such as One Za’abeel hotel or restaurant partners, government or judicial authorities and law enforcement agencies, as the case may be.

One Za’abeel may transfer Personal Data to countries located outside of the UAE. This may happen when One Za’abeel’s suppliers and/or service providers are based outside of the UAE. In such cases, One Za’abeel will transfer the Personal Data in accordance with the UAE Data Protection Law and use the protection measures granted thereunder.

6 How do we protect personal data

One Za’abeel has implemented reasonable and appropriate technical and organizational security measures to protect your Personal Data against unauthorized access, disclosure, misuse, loss or destruction. This includes encrypting your Personal Data, implementing data back-up measures and regularly conducting security testing.

7 For how long will my personal data be stored

One Za’abeel will process Personal Data until the purpose for Processing is fulfilled, in accordance with the UAE Data Protection Law. This includes retaining Personal Data to comply with its contractual and statutory obligations and/or to comply with accounting, reporting or internal policy requirements. If the purpose for Processing Personal Data has ceased, the Personal Data is deleted.

8 How do we protect personal data

A Data Subject has certain rights in relation to their Personal Data, subject to certain limitations, under the UAE Data Protection Law. These include the right in certain circumstances to:
— access their Personal Data;
— obtain and request the transfer of their Personal Data;
— correct and/or erase their Personal Data;
— restrict, and stop, the Processing of their Personal Data;
— object to, and stop, the Processing of their Personal Data; and
— object to decisions made by automated processing, that have legal consequences or seriously affect the Data Subjects.
If any Data Subject has any questions about the type of Personal Data we hold about them or if they wish to exercise any Data Subject right, they can contact us at [email protected].
A Data Subject can withdraw any consent granted for the Processing of Personal Data at any time. The withdrawal will not affect the lawfulness of any Processing based thereon before the withdrawal.
While we will make reasonable efforts to accommodate any Data Subject rights request to the extent, and as soon as, reasonably practicable, we reserve the right to reject any such requests or to impose restrictions or requirements upon such requests if required or permitted by applicable laws. 

9 Use of personal data for marketing

If a Data Subject has provided their consent for the purposes of marketing our products and services to them, we may process their Personal Data for such purposes. Any marketing by us, or any third parties on our behalf, will be conducted in accordance with applicable laws. A Data Subject has the right to object to the Processing of their Personal Data for marketing purposes and we will provide the means to opt-out or unsubscribe to marketing communications. 

10 Are data subjects obliged to provide their personal data

We may require certain Personal Data to comply with legal or contractual obligations and/or to provide our products and services to you. If a Data Subject fails to provide their Personal Data or withdraws their consent to our Processing their Personal Data, we may not be able to provide you with such products and services. We will notify you if this is the case. 

11 Changes to this privacy policy

We may from time to time make changes to this Privacy Policy. Please check back regularly for any changes in this Privacy Policy. These changes are effective immediately following their publication on our website.