Internal Apps privacy policy
PRIVACY POLICY
Version dated: 15 August 2024
INTRODUCTION
Abu Dhabi Future Energy Company PJSC - Masdar (“Masdar”, “us” or “we”) acknowledges and respects your right to privacy and is committed to protecting and safeguarding your data that we use in compliance with applicable data protection laws.
Please read this privacy policy (the “Policy”) carefully, as it outlines the purposes of collecting, using, retaining and disclosing your personal data and how we and certain third parties and group companies use your personal data in connection with your use of our mobile application (“the App”). In addition, it informs you about your privacy rights, and how to contact us with any concerns or inquiries regarding the management of your personal data.
HOW DATA IS COLLECTED
We automatically collect information about your use of the App by the use of “cookies” or small text files that are stored on your device while using the App and contain a unique identification number that identifies you each time you use the App. The type of information recorded allows us to record how many people use the App, which pages and items are the most popular, and about how users interact with the App, but the information stored in the cookies does not include any personal data.
We may collect your personal data in several ways, for example (i) when you use our services or you contact us through the App, by telephone, post, e-mail or through any other means; (ii) when you register with us and set up an account to receive our services; (iii) when you set your preferences for receiving marketing communications from us;(iv) when you provide permission for the App to use location data to support time and attendance functionalities (you must grant permission for location services to enable geofencing and reminder notifications. If location services are disabled or rejected, the geofencing features will not function until location permissions are re-enabled).
Where you provide your personal data to us, you are providing your consent for us to use such personal data for the relevant purposes and not any other purpose. If you do not provide the necessary personal data or you refuse or withdraw your consent to our processing of your personal data, we may be unable to provide certain services or information to you, and you may not be able to make use of certain services and information offered by us.
TYPES OF COLLECTED DATA
We may collect certain types of your personal data, including, but not limited to (i) your name, address, employee identification number, email address, telephone number, and other contact information; (ii) entry and exit times and other relevant details to manage and monitor your entry to Masdar group premises; (iii) device's location coordinates (latitude and longitude); (iv) information about your use of our services; (v) your employment information to provide our services including, but not limited to digital business cards.
USE OF PERSONAL DATA
We may use your personal data (i) to provide you with our services, and to develop and improve services and to ensure that the information we hold about you is kept up-to-date; (ii) to prevent, detect and prosecute fraud and other crime; (iii) to comply with certain legal and regulatory obligations; or (iv) to manage your time and attendance, ensuring the security of Masdar group premises; (v) to manage and administer your account and to deal with any matters that arise on your account; (vi) to provide, maintain and update Masdar group employee digital business card services; (vii) to verify that your device's location coordinates are within the Masdar office radius to be eligible for the 15-minute grace period.
When you submit personal data to us, you agree to permit us to access, store, and use such personal data for our business and other applicable services.
DISCLOSURE OF PERSONAL DATA
We will not sell, trade or distribute your personal data for commercial purposes. We do, however, reserve the right to disclose your personal data as required by law or contract, or when we believe that disclosure is necessary to protect our rights (such as to verify or enforce our applicable policies or detect and protect against technical or security vulnerabilities) and/or comply with a judicial proceeding, court order, request from a regulator or any other legal process served on Masdar or its group of companies.
For the purposes of maintaining the App and providing you with a service, we may share your personal data with (i) our employees, agents and/or professional advisors; (ii) other companies within the Masdar group; (iii) other third-party contractors who provide services to us which require the processing of personal data; (iv) relevant governmental bodies or authorities upon request.
In the event of a reorganization of our business, such a transaction may involve the disclosure of your personal data to other entities within the Masdar group of companies or the new owner of the business, in which case, we may notify you if required under applicable data protection laws.
Your personal data may also be processed by Masdar, its group companies and the third parties described above, outside of the country in which you are based. Where the data protection regulator in your home country has not issued an adequacy decision in relation to the jurisdiction where your personal data is to be processed, we will ensure that there are adequate mechanisms in place to protect your personal data in accordance with applicable data protection and privacy laws, including, where applicable, through use of data transfer agreements implementing standard data protection clauses. You can receive further information about the data transfer agreements that concern your personal data, and the mechanisms we implement to protect your personal data, by contacting us.
SECURITY AND SAFEGUARDS
Transmission of data via the web or electronically is not always secure and we cannot guarantee the security of your personal data which is transmitted to this App from third-party sites. We can, however, confirm that we have implemented appropriate policies, procedures, and both physical and electronic security safeguards to keep your personal data secure once it is received by us. These measures vary depending on the nature and sensitivity of the personal data and may include encryption and other forms of security measures aligned with global standards and best practices. These efforts are undertaken to protect your personal data from unauthorized access, unlawful processing, misuse, accidental loss, involuntary disclosure, modification, destruction or damage. Our application server and database are hosted in Azure within Masdar's tenant in the UAE.
The App does not store any location data beyond what is necessary for time attendance verification and reminder notifications. The location coordinates are temporarily stored for the purpose of timekeeping and are not used for any other monitoring or tracking purposes. The geofencing and location monitoring are conducted entirely on the device and are not accessible or monitored externally by administrators or through the system.
If you would like more information about the safeguards we have put in place or at any point you suspect or become aware of a data breach, please contact us immediately at ethics@masdar.ae.
We will retain your personal data for as long as required to provide the service requested. We may retain your personal data beyond the minimum retention period to comply with any legal and/or regulatory obligations to which we are subject or in connection with any legal action or investigation involving Masdar.
YOUR DATA PRIVACY RIGHTS
In accordance with applicable data protection laws and under certain conditions, you may have the right to require us to:
-
provide you with clear, transparent and easily understandable information about how we use your personal data and your rights;
-
provide you with access to the personal data we hold about you;
-
correct your personal data we hold about you if it is inaccurate or incomplete;
-
delete or remove any of your personal data that we no longer have a lawful ground to use your personal data, unless an exception applies at law;
-
where processing is based on consent, stop that particular processing by withdrawing your consent at any time;
-
object to certain types of processing of your personal data;
-
restrict how we use your personal data, provided that we may still store your personal data; or
-
transfer your data to your or a third party in a standardized machine-readable format without affecting its usability.
We usually act on requests and provide information free of charge, but may charge a reasonable fee to cover our administrative costs of providing the information for:
-
baseless or excessive/repeated requests; or
-
further copies of the same information.
Alternatively, we may be entitled to refuse to act on the request.
Please consider your request responsibly before submitting it. We will respond as soon as we can. Generally, this will be within one month from when we receive your request but, if the request is going to take longer to deal with, we’ll come back to you and let you know.
You also have the right to lodge a complaint about the way we handle or process your personal data with your national data protection regulator.
CHANGES TO THIS POLICY
We review this Policy regularly and may modify it from time to time, so you should check this page from time to time. We reserve the right to update or modify this Policy at any time and without prior notice, by posting the revised version on the App. By continuing to use this App after such changes have been made, you acknowledge and agree you have read, understood and accept the changes. You may determine when this Policy was last updated by referring to the date found at the top of this Policy.
CONTACT INFORMATION
If you have any questions or concerns about this Policy, or our privacy practices, you can contact us at ethics@masdar.ae.
Abu Dhabi Future Energy Company PJSC - Masdar, Masdar City. Presidential Flight, Khalifa City, P.O. Box P.O Box 54115, Abu Dhabi, United Arab Emirates.