Privacy Notice

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1.  ABOUT US AND THE PURPOSE OF THIS NOTICE

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Sanctuary Corporate Services FZ LLC and Alderley Global LLC (together, “Sanctuary” and "we", “us”, “our” and “ours”) provide corporate services, personal and business administration, tax advice and related services from our branches and offices in the UAE.

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We take your privacy seriously.This notice will tell you how we[1]look after your personal data, about your privacy rights, and about our compliance with and your protections under relevant data protection legislation.

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If you are a resident of the EU or UK, we are obliged to process and use your data in line with the General DataProtection Regulation 2016/679 and the Data Protection Act 2018 respectively. If you are UAE resident, we are subject to UAE law Federal Decree 45 of 2021. Depending on your circumstances the scope of the protections afforded to you by applicable law may vary.  

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You may contact us in relation to this privacy notice on ask@sanctuary.ae or by writing to Head of Compliance at the address provided in paragraph 11 (Contact Us) below.


[1] Sanctuary Corporate Services FZ LLC – Dubai Branch, Sanctuary Corporate Services FZ LLC –ADGM Branch and Alderley Global LLC

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2.  THE KIND OF INFORMATION WE HOLD ABOUT YOU

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The personal data we collect and process will include identity, contact, transactional, technical, profile, usage and marketing and communications data such as:

  • Identity Data - includes first name, last name, title or other identifier (such as job title), marital status, date of birth, gender and images. We will also process documentary details from you such as a driving licence, passport or birth certificate, and data in order to comply with our obligations under identification, money laundering and anti-terrorism legislation.
  • Contact Data - includes billing address, email addresses and telephone numbers.
  • Transaction Data - includes details about services you have purchased from us or your visits to our premises
  • Financial Data - includes bank account and payment card details, tax affairs, payroll information
  • Profile Data - includes your username and password, purchases or orders made by you, your interests, preferences (including details about your personal likes and dislikes as identified during your visits to our premises), feedback and survey responses
  • Usage Data includes information about how you use our website, products and services.
  • Marketing and Communications data - includes your preferences in receiving marketing from us and our third parties and your communication preferences.

Please note that we may collect and/or process other personal data from time to time, for example, information about criminal convictions and offences

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3.  HOW WE MAY COLLECT YOUR PERSONAL DATA

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We use different methods to collect data from and about you including through:

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Direct interactions

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You may give us your Identity, Contact, Profile and Financial Data by filling in forms or by corresponding with us by post, phone, messaging service, email or otherwise.

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This includes personal data you provide when you:

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(a)  apply for our services;

(b)  through engagement of our services;

(c)  register or creating an account on our website;

(d)  via communications, including email, post, telephone, and social media;

(e)  networking;

(f)   request marketing to be sent to you;

(g)  enter a promotion or survey; or

(h)  give us feedback or contact us.

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Third parties or publicly available sources

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We may obtain personal data about you from various third parties and public sources as set out below:

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(a) Contact, Financial and Transaction Data from providers of technical, or payment services.

(b) Identity and Contact Data from data brokers or aggregators, including specialist databases used to comply with our legal and regulatory obligations under applicable anti money laundering and counterterrorism laws, trade organisations or exhibition organisers

(c) Identity and Contact Data from publicly available sources such as UK Companies House and other registers.

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4.  HOW WE USE PERSONAL DATA WE HOLD ABOUT YOU

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We may process your personal data for purposes necessary for the performance of our contract with our clients and to comply with our legal obligations. This may include processing your personal data where you are an employee, subcontractor, supplier, or customer of our client.

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We may also process your personal data for the purposes of our own legitimate interests provided that those interests do not override any of your own interests, rights and freedoms which require the protection of personal data.This includes processing for marketing, business development, statistical and management purposes.

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Please note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data.

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Situations in which we will use your personal data

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We may use your personal data in order to:

  • carry out our obligations arising from any agreements entered into between our clients and us (which will most usually be for the provision of our services);
  • carryout our obligations arising from any agreements entered into between our clients and us (which will most usually be for the provision of our services) where you may be a subcontractor, supplier or customer of our client;
  • provide you with information related to our services and our events or seek your thoughts and opinions on the services we provide; and
  • notify you about any changes to our services.

In some circumstances we may anonymise or pseudonymise the personal data so that it can no longer be associated with you, in which case we may use it without further notice to you.

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We may also process your personal data without your knowledge or consent, in accordance with this notice, where we are legally required or permitted to do so.

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Data retention

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We will only retain your personal data for as long as is necessary to fulfil the purposes for which it is collected or to comply with applicable law and regulation.

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When assessing what retention period is appropriate for your personal data, we take into consideration the requirements of our business and the services provided, any statutory or legal obligations and the purposes for which we originally collected the personal data.

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Change of purpose

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Where we need to use your personal data for a reason, other than the purpose for which we originally collected it, we will only use your personal data where that reason is compatible with the original purpose. If we need to use your data for a new purpose, we will notify you and communicate our legal basis for this new processing.

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5.  DATA SHARING

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We will share your personal data with third parties where we are required by law, where it is necessary to administer the relationship between us, or where we have another legitimate interest in doing so. This may include sharing your personal data with a regulator or to otherwise comply with the law.

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“Third parties” includes third-party service providers and other entities within our group. The following activities are carried out by third-party service providers Professional advisory services, administration services, marketing services and banking services. We only permit our third-party service providers to process your personal data for specified purposes and in accordance with our instructions.

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We may share your personal data with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal data with a regulator or to otherwise comply with the law.

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6.  LOCATION OF YOUR DATA

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The personal data that we collect about you in order to perform our contract with you will be held in the United Arab Emirates.

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7.  DATA SECURITY

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We have put in place commercially reasonable and appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

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We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

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8.  RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION

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Your duty to inform us of changes

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It is important that the personal data we hold about you is accurate and current. Should your personal information change, please notify us of any changes of which we need to be made aware by contacting us, using the contact details below.

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Your rights in connection with personal data

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Under certain circumstances, by law you have the right to:

  • Request access to your personal data. This enables you to receive details of the personal data we hold about you and to check that we are processing it lawfully.
  • Request correction of the personal data that we hold about you.
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below).
  • 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 basis. You also have the right to object where we are processing your personal information for direct marketing purposes.
  • Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
  • Request the transfer of your personal data to you or another data controller if the processing is based on consent, carried out by automated means and this is technically feasible.

If you want to exercise any of the above rights, please email our Data Protection Point of Contact: privacy@sanctuary.ae

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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 for the administrative costs of complying with the request if your request for access is manifestly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

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We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

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9.  RIGHT TO WITHDRAW CONSENT

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In the limited circumstances where you may have provided your consent to the collection, processing, and transfer of your personal data for a specific purpose (for example, in relation to direct marketing that you have indicated you would like to receive from us), you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please email us on ask@sanctuary.ae

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Once we have received notification that you have withdrawn your consent, we will no longer process your personal information (personal data) for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

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10. CHANGES TO THIS NOTICE

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Any changes we may make to our privacy notice in the future will be available for you to see on our website at: http://www.sanctuary.ae

This privacy notice was last updated on 7th June 2023.

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11. CONTACT US

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If you have any questions regarding this notice or if you would like to speak to us about the manner in which we process your personal data, please email us on ask@sanctuary.ae, or write to us at the address below.

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Sanctuary Corporate Services FZ LLC

Suite 903, 9th floor

Bay Square – Building 1

Business Bay

Dubai, UAE

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