Privacy Policy

1. Introduction

This Privacy Policy explains how Emilit Ltd (“Emilit”) collects, uses, stores, discloses and otherwise processes Personal Data.

Emilit is a company incorporated in the United Arab Emirates, with its registered office at:

Emilit Ltd
Masdar City
2282 – Abu Dhabi
United Arab Emirates

Trade licence or registration number: MC 14473
Website: emilit.ae

For the purposes of the UAE Federal Decree-Law No. 45 of 2021 concerning the Protection of Personal Data, as amended or supplemented from time to time (the “UAE PDPL”), Emilit acts as the Controller of the Personal Data described in this Privacy Policy, unless otherwise stated.

This Privacy Policy applies to:

visitors to our website;
persons who contact us through our website, by email, telephone or other communication channels;
prospective, current and former customers;
prospective, current and former suppliers and service providers;
directors, employees, consultants and other representatives of our customers, suppliers and business partners;
any other person whose Personal Data we process in connection with our business activities.

This Privacy Policy does not apply where Emilit processes Personal Data exclusively on behalf of another organisation acting as Controller. In such cases, the privacy policy of that organisation will ordinarily apply.

2. Definitions

For the purposes of this Privacy Policy:

“Personal Data” means any data relating to an identified natural person or to a natural person who can be identified, directly or indirectly, through the linking of data;
“Processing” means any operation or set of operations performed on Personal Data, including collection, recording, organisation, storage, adaptation, use, disclosure, transmission, retrieval, restriction, deletion or destruction;
“Data Subject” means the natural person to whom the Personal Data relates;
“Controller” means the person or entity that determines the method, criteria and purposes of Processing Personal Data;
“Processor” means the person or entity that processes Personal Data on behalf of a Controller;
“Sensitive Personal Data” has the meaning assigned to it under the UAE PDPL and may include health, biometric, genetic, financial, religious, ethnic or other data receiving enhanced protection under applicable law.

3. Personal Data We Collect

Depending on your relationship and interactions with Emilit, we may collect the following categories of Personal Data.

3.1 Identity and contact information

This may include:

name and surname;
job title and professional role;
employer or organisation;
business or personal email address;
telephone or mobile number;
business address;
country of residence or operation;
any other contact information that you provide to us.

3.2 Enquiry and correspondence information

This may include:

the content of messages submitted through our contact forms;
email and other written correspondence;
details of requests for information or quotations;
records of telephone calls or meetings;
complaints, comments and feedback;
documents or information voluntarily provided by you.

3.3 Technical and website usage information

When you access or use our website, we may automatically collect:

Internet Protocol address;
browser type and version;
operating system;
device type and device identifiers;
language and time-zone settings;
date and time of access;
pages viewed and links selected;
referring website or source;
approximate geographical location derived from the Internet Protocol address;
session identifiers;
cookie identifiers;
website interaction and performance information;
security and diagnostic logs.

3.5 Cookie and analytics information

Where permitted by applicable law and, where required, with your consent, we may collect information through cookies, analytical tools and similar technologies, as better stated infra.

4. Sensitive Personal Data

Emilit does not ordinarily seek to collect Sensitive Personal Data through its website contact forms.

You should not submit Sensitive Personal Data through a general contact form unless:

Emilit has expressly requested that information;
the information is strictly necessary for the relevant purpose; and
the Processing is permitted under the UAE PDPL or other applicable law.

Where Emilit needs to process Sensitive Personal Data, it will apply the additional legal, organisational and technical protections required by applicable law.

5. Purposes of Processing

Emilit may process Personal Data for the following purposes.

5.1 Operating and protecting the website

We may process technical, usage and security information in order to:

operate, maintain and administer the website;
ensure that website content is correctly displayed;
detect, prevent and investigate unauthorised access, cyberattacks, fraud and other security incidents;
identify technical faults;
maintain business continuity;
protect our systems, information, personnel and users;
produce aggregated or anonymised statistics.

5.2 Responding to enquiries

We may process identity, contact and correspondence information in order to:

respond to messages and requests submitted through the website;
provide information about our services;
arrange meetings or demonstrations;
prepare proposals and quotations;
communicate with prospective customers, suppliers or partners;
follow up on a request made by you.

5.3 Compliance with legal and regulatory obligations

We may process Personal Data where necessary to:

comply with UAE laws and regulations;
comply with lawful requests from courts, regulators and public authorities;
maintain legally required business, corporate, accounting and tax records;
prevent, detect or investigate unlawful conduct;
establish, exercise or defend legal claims;
cooperate with judicial, regulatory, administrative or law-enforcement proceedings.

5.4 Website analytics and improvement

Subject to any consent required by applicable law, we may use analytical technologies to:

understand how visitors use the website;
measure website traffic and performance;
identify popular content and services;
improve the structure, functionality and usability of the website;
diagnose technical issues;
prepare aggregated reports.

Emilit does not use website analytics information for targeted advertising unless this Privacy Policy and the relevant consent interface are updated accordingly.

5.6 Corporate transactions

We may process and disclose relevant Personal Data in connection with:

a merger;
acquisition;
financing;
restructuring;
sale of shares or business assets;
joint venture;
due diligence exercise;
insolvency or similar corporate procedure.

Any recipient will be required to use the Personal Data only for the relevant transaction and in accordance with applicable law.

6. Legal Grounds for Processing

Under the UAE PDPL, Personal Data may generally be processed with the consent of the Data Subject or where a statutory exception permits Processing without consent.

Depending on the circumstances, Emilit may process Personal Data:

with your freely given, specific, informed and unambiguous consent;
where Processing is necessary to take steps at your request before entering into a contract;
where Processing is necessary to enter into or perform a contract to which you are a party;
where Processing is necessary for Emilit to comply with an applicable legal obligation;
where Processing is necessary to establish, exercise or defend legal claims;
where the Personal Data has been made publicly available by the Data Subject;
where Processing is necessary to protect interests recognised under applicable law;
where another exception or legal basis under the UAE PDPL or other applicable legislation applies.

Where Emilit relies on consent, records of that consent may be retained to demonstrate compliance with the UAE PDPL.

7. Consent and Withdrawal of Consent

Where Processing is based on consent, Emilit will seek consent through a clear affirmative action or statement.

Consent will not be inferred solely from silence, inactivity or the use of pre-selected boxes where an affirmative indication is required by applicable law.

You may withdraw your consent at any time by:

contacting us using the details in Section 20;
changing your cookie preferences through the website’s cookie management tool; or
using any other withdrawal mechanism made available when consent is requested.

Withdrawal of consent will not affect the lawfulness of Processing carried out before the withdrawal.

Following withdrawal, Emilit will stop the relevant Processing unless continued Processing is permitted or required under the UAE PDPL or another applicable law.

8. Consequences of Not Providing Personal Data

Providing Personal Data is generally voluntary.

However, certain information may be necessary for Emilit to:

respond to an enquiry;
prepare a proposal or quotation;
enter into or perform a contract;
process an invoice or payment;
comply with legal or regulatory requirements;
establish or manage a customer or supplier relationship.

Where required information is not provided, Emilit may be unable to respond to your request, provide the requested service, enter into a contract or continue the relevant business relationship.

9. Cookies and Similar Technologies

Cookies are small data files that may be stored on your device when you visit a website.

Emilit may use the following categories of cookies.

9.1 Strictly necessary cookies

These cookies are used where necessary to:

display and operate the website;
maintain website security;
enable basic functions;
remember privacy or cookie choices;
prevent fraudulent or malicious activity.

Strictly necessary cookies will be used only where permitted under applicable law.

9.2 Analytics cookies

Analytics cookies allow Emilit and its service providers to understand how visitors use the website.

Analytics cookies may collect:

cookie or session identifiers;
Internet Protocol address;
device and browser information;
pages visited;
time spent on pages;
navigation paths;
interactions with website functions;
referring sources;
approximate geographical information.

Analytics cookies will be activated only after obtaining consent where such consent is required under applicable law.

9.3 Managing cookie preferences

You may accept, refuse or withdraw consent to non-essential cookies through the cookie management interface.

You may also configure your browser to reject or delete cookies. Disabling certain cookies may affect the availability or functionality of parts of the website.

10. Disclosure and Recipients of Personal Data

Emilit may disclose Personal Data, where necessary and permitted by law, to the following categories of recipients inside or outside the United Arab Emirates:

website hosting providers;
cloud computing and data storage providers;
information technology and cybersecurity providers;
website developers and maintenance providers;
analytics service providers;
communication and email service providers;
customer and supplier management service providers;
accounting, banking and payment service providers;
professional advisers, including lawyers, auditors, accountants and consultants;
insurers;
group companies and affiliated entities;
customers, suppliers and business partners where necessary for the relevant relationship;
prospective purchasers, investors or transaction counterparties;
courts, regulators, government authorities and law-enforcement bodies;
other recipients authorised by you or permitted by applicable law.

Processors acting on behalf of Emilit will be required to process Personal Data only on documented instructions, apply appropriate confidentiality and security measures and comply with their applicable data protection obligations.

Emilit does not sell Personal Data.

11. Retention of Personal Data

Emilit will retain Personal Data only for as long as necessary to fulfil the purpose for which it was collected, unless a longer retention period is required or permitted by applicable law.

Retention periods are determined by considering:

the nature and sensitivity of the Personal Data;
the purpose for which the Personal Data was collected;
the duration of the business relationship;
applicable contractual obligations;
accounting, tax, corporate and regulatory requirements;
applicable limitation periods;
the need to establish, exercise or defend legal claims;
security, fraud-prevention and audit requirements.

At the end of the applicable retention period, Personal Data will be securely deleted, destroyed or anonymised, unless continued retention is required or permitted by law.

Anonymised data that can no longer be linked to an identifiable person may be retained for statistical, analytical or business purposes.

12. Personal Data Security

Emilit implements appropriate technical and organisational measures designed to protect Personal Data against:

unauthorised or unlawful Processing;
accidental or unlawful disclosure;
loss, destruction or alteration;
unauthorised access;
misuse;
cyberattacks and other security incidents.

Such measures may include, as appropriate:

access controls and user authentication;
restriction of access according to job responsibilities;
encryption or pseudonymisation;
secure transmission and storage;
backup and recovery procedures;
logging and monitoring;
malware and intrusion protection;
vulnerability and security testing;
confidentiality obligations;
staff awareness and training;
supplier security assessments;
incident response procedures;
periodic review of security controls.

No method of transmission or electronic storage is completely secure. Emilit therefore cannot guarantee absolute security but will take measures appropriate to the nature, scope and risks of the relevant Processing.

13. Data Subject Rights

Subject to the conditions, limitations and exceptions set out in the UAE PDPL, you may have the following rights.

13.1 Right to receive information

You may request information concerning:

the categories of Personal Data processed by Emilit;
the purposes of Processing;
decisions based on automated Processing, including profiling;
the sectors, establishments or categories of recipients with which Personal Data is shared inside or outside the United Arab Emirates;
the controls and standards applied to storage and retention;
the measures used to protect Personal Data;
the procedures for correcting, deleting, restricting or objecting to Processing;
the safeguards applied to international transfers;
the measures to be taken in the event of a Personal Data Breach;
the procedures for submitting complaints.

13.2 Right to data portability

Where the applicable legal conditions are met, you may request:

a copy of Personal Data that you have provided to Emilit in a structured and machine-readable format; or
the transfer of that Personal Data to another Controller, where technically feasible.

13.3 Right to correction

You may request the correction of inaccurate Personal Data or the completion of incomplete Personal Data.

13.4 Right to erasure

You may request the deletion of Personal Data where the conditions under the UAE PDPL are met.

Emilit may retain Personal Data where retention remains necessary or permitted for legal compliance, contractual obligations, the establishment or defence of legal claims or another lawful purpose.

13.5 Right to restrict Processing

You may request that Emilit restrict or suspend Processing where the applicable legal conditions are met, including while the accuracy of Personal Data or the lawfulness of Processing is being examined.

13.6 Right to object and stop Processing

You may object to and request the stopping of Processing in the circumstances recognised under the UAE PDPL, including certain Processing carried out for direct marketing or statistical survey purposes.

Emilit does not currently use Personal Data collected through the website for direct marketing without separate consent.

13.7 Rights relating to automated decisions

You may object to decisions based solely on automated Processing, including profiling, where such decisions produce legal consequences or otherwise significantly affect you.

You may also request human review where the applicable conditions are met.

13.8 Right to withdraw consent

Where Processing is based on consent, you may withdraw that consent at any time.

13.9 Right to complain

You may submit a complaint directly to Emilit.

You may also have the right to submit a complaint to the UAE Data Office or another competent supervisory or regulatory authority in accordance with the procedures and channels made available by that authority.

13. Exercising Your Rights

Requests concerning Personal Data may be sent to:

Privacy contact: contact@emilit.ae
Postal address: Emilit Ltd, Masdar City, 2282 – Abu Dhabi, United Arab Emirates

Please describe:

the right that you wish to exercise;
the Personal Data or Processing concerned;
your relationship with Emilit;
any information reasonably necessary to locate the relevant records.

Emilit may request information necessary to verify your identity and ensure that Personal Data is not disclosed to an unauthorised person.

Requests will be handled within the period prescribed by applicable law. They will be handled without charge where required by the UAE PDPL, subject to any exception permitted by applicable law.

Emilit may refuse or limit a request where permitted by the UAE PDPL, including where compliance would adversely affect the rights of another person, conflict with applicable law or prejudice judicial, security or legal proceedings. Where legally required, Emilit will explain the reason for its decision.

15. Automated Decision-Making and Profiling

Emilit does not currently make decisions producing legal or similarly significant effects solely through automated Processing of Personal Data collected through the website.

If Emilit introduces such Processing, this Privacy Policy will be updated to explain:

the nature of the automated Processing;
the categories of Personal Data used;
the logic and criteria involved;
the likely consequences for the Data Subject;
the available objection and human-review procedures.

16. Personal Data Breaches

Emilit maintains procedures for identifying, assessing, containing, investigating and responding to Personal Data Breaches.

Where a breach occurs, Emilit will:

take reasonable steps to contain and remedy the breach;
assess the nature, scope and likely consequences of the breach;
preserve appropriate records;
notify the UAE Data Office or another competent authority where required;
notify affected Data Subjects where required;
provide the information prescribed by applicable law;
take measures intended to prevent recurrence.

Notification will be made in accordance with the conditions and time periods prescribed under applicable law.

17. Third-Party Websites

The website may contain links to websites, platforms or services operated by third parties.

Emilit does not control the Processing activities of those third parties and is not responsible for their privacy practices.

You should review the privacy policy of each third-party website or service before providing Personal Data.

Emilit will investigate complaints and respond in accordance with applicable law.

If you are not satisfied with Emilit’s response, you may submit a complaint to the UAE Data Office or another competent authority through the complaint procedures made available by that authority.