PRIVACY STATEMENT – INDIGENESIS

Published on October 10, 2022

INDIGENESIS CONSULTING DMCC¹ (‘INDIGENESIS’) is dedicated to protecting the confidentiality and privacy of information entrusted to it. As part of this fundamental obligation, INDIGENESIS is committed to the appropriate protection and use of personal information (sometimes referred to as “personally identifiable information” or “PII”) that has been collected online.

Generally, our intent is to collect only the personal information that is provided voluntarily by online visitors so that we can offer information and/or services to those individuals or offer information about employment opportunities. Please review this Privacy Statement (“Privacy Statement”) to learn more about how we collect, use, share and protect the PII that we have obtained.

1. Collection and use of personal information

1.1 What information we collect

1.2 The legal grounds we have to use your personal information

1.3 Automatic collection of personal information

1.3.1 IP addresses

1.3.2 Cookies

1.3.3 Google Analytics

1.3.4 Web beacons

1.3.5 Location-based tools

1.4 Social media widgets and applications

1.5 Children

2. Sharing and transfer of PII

2.1 Transfer within the network of INDIGENESIS firms

2.2 Transfers to third parties

3. Choices

4. Your Rights

5. Data security and integrity

6. Links to other sites

7. Changes to this statement

8. Policy questions and enforcement

1. Collection and use of personal information

1.1 What Information we collect?

We obtain personal information about you if you choose to provide it — for example, to contact mailboxes or to register for certain services. In some cases, you may have previously provided your PII to INDIGENESIS (if, for example, you are a former employee). If you choose to register or login to a INDIGENESIS web site using a third party single sign-in service that authenticates your identity and connects your social media login information (e.g., LinkedIn, Google, or Twitter) with INDIGENESIS, we will collect any information or content needed for the registration or log-in that you have permitted the social media provider to share with us, such as your name and email address. Other information we collect will depend on the privacy settings you have set with your social media provider, so please review the privacy statement or policy of the applicable service. When you register or submit personal information to INDIGENESIS we will use this information in accordance with this Privacy Statement. Your personal information is not used for other purposes, unless we obtain your permission, or unless otherwise required or permitted by law or professional standards. For example, if you register to a INDIGENESIS web site and provide information about your preferences we will use this information to personalize your user experience. Where you register or login using a third party single user sign-in we may also recognize you as the same user across any different devices you use and personalize your user experience across other INDIGENESIS sites you visit. If you send us a resume or curriculum vitae (CV) to apply online for a position with INDIGENESIS, we will use the information that you provide to match you with available INDIGENESIS job opportunities.

In some cases where you have registered for certain services, we may store your email address temporarily until we receive confirmation of the information you provided via an email (i.e. where we send an email to the email address provided as part of your registration to confirm a subscription request).

1.2 The legal grounds we have to use your personal information

INDIGENESIS generally collects only the personal information necessary to fulfill your request. Where additional, optional information is sought, you will be notified of this at the point of collection.

The law allows us to process personal information, so long as we have a ground under the law to do so. It also requires us to tell you what those grounds are. As a result, when we process your personal information, we will rely on one of the following processing conditions: Performance of a contract: this is when the processing of your personal information is necessary in order to perform our obligations under a contract;
Legal obligation: this is when we are required to process your personal information in order to comply with a legal obligation, such as keeping records for tax purposes or providing information to a public body or law enforcement agency;
Legitimate interests: we will process information about you where it is in our legitimate interest in running a lawful business to do so in order to further that business, so long as it doesn’t outweigh your interests; or
Your consent: in some cases, we will ask you for specific permission to process some of your personal information, and we will only process your personal information in this way if you agree to us doing so. You may withdraw your consent at any time by contacting INDIGENESIS at [email protected].

Examples of the ‘legitimate interests’ referred to above are:

To offer information and/or services to individuals who visit our website or offer information about employment opportunities.
To prevent fraud or criminal activity and to safeguard our IT systems.
To customize individual’s online experience and improve the performance usability and effectiveness of INDIGENESIS’s online presence.
To conduct, and to analyze, our marketing activities.
To meet our corporate and social responsibility obligations.
To exercise our fundamental rights in the area where we operate, including our freedom to conduct a business and right to property.

In some cases, the personal data that we collect will also include special categories of data, such as diversity related information (including data about racial and ethnic origin, political opinions, religious beliefs and other beliefs of a similar nature, trade union membership and data about sexual life and sexual orientation), or health data and data about alleged or proven criminal offences in each case where permitted by law.

1.3 Automatic collection of personal information

In some instances, INDIGENESIS and its service providers uses cookies, web beacons and other technologies to automatically collect certain types of information when you visit us online, as well as through emails that we may exchange. The collection of this information allows us to customize your online experience, improve the performance, usability and effectiveness of INDIGENESIS’s online presence, and to measure the effectiveness of our marketing activities.

1.3.1 IP addresses

An IP address is a number assigned to your computer whenever you access the internet. It allows computers and servers to recognise and communicate with one another. IP addresses from which visitors appear to originate may be recorded for IT security and system diagnostic purposes. This information may also be used in aggregate form to conduct web site trend and performance analysis.

1.3.2 Cookies

Please click here to read our Cookies Notice.

1.3.3 Google Analytics

INDIGENESIS uses Google Analytics. More information about how Google Analytics is used by INDIGENESIS can be found here: http://www.google.com/analytics/learn/privacy.html

To provide website visitors with more choice on how their data is collected by Google Analytics, Google have developed the Google Analytics Opt-out Browser Add-on. The add-on communicates with the Google Analytics JavaScript (ga.js) to indicate that information about the website visit should not be sent to Google Analytics. The Google Analytics Opt-out Browser Add-on does not prevent information from being sent to the website itself or to other web analytics services.

1.3.4 Web beacons

A web beacon is a small image file on a web page that can be used to collect certain information from your computer, such as an IP address, the time the content was viewed, a browser type, and the existence of cookies previously set by the same server. INDIGENESIS only uses web beacons in accordance with applicable laws.

INDIGENESIS or its service providers may use web beacons to track the effectiveness of third party web sites that provide us with recruiting or marketing services or to gather aggregate visitor statistics and manage cookies.

You have the option to render some web beacons unusable by rejecting their associated cookies. The web beacon may still record an anonymous visit from your IP address but cookie information will not be recorded.

In some of our newsletters and other communications, we may monitor recipient actions such as email open rates through embedded links within the messages. We collect this information to gauge user interest and to enhance future user experiences.

1.3.5 Location-based tools

INDIGENESIS may collect and use the geographical location of your computer or mobile device. This location data is collected for the purpose of providing you with information regarding services which we believe may be of interest to you based on your geographic location, and to improve our location-based products and services.

1.4 Social media widgets and applications

INDIGENESIS web sites may include functionality to enable sharing via third party social media applications, such as the Facebook Like button and Twitter widget. These social media applications may collect and use information regarding your use of INDIGENESIS web sites (see details on ‘Social Sharing’ cookies here). Any personal information that you provide via such social media applications may be collected and used by other members of that social media application and such interactions are governed by the privacy policies of the companies that provide the application. We do not have control over, or responsibility for, those companies or their use of your information.

In addition, INDIGENESIS web sites may host blogs, forums, crowd-sourcing and other applications or services (collectively “social media features”). The purpose of social media features is to facilitate the sharing of knowledge and content. Any personal information that you provide on any INDIGENESIS social media feature may be shared with other users of that social media feature (unless otherwise stated at the point of collection), over whom we may have limited or no control.

1.5 Children

INDIGENESIS understands the importance of protecting children’s privacy, especially in an online environment. In particular, our sites are not intentionally designed for or directed at children under the age of 13. It is our policy never to knowingly collect or maintain information about anyone under the age of 13, except as part of an engagement to provide professional services.

2. Sharing and transfer of PII

2.1 Transfer within the network of INDIGENESIS firms

We share information about you with other member firms of the INDIGENESIS network as part of international engagements, and with INDIGENESIS International and other member firms where required or desirable to meet our legal and regulatory obligations around the world. Other parts of the INDIGENESIS network are also used to provide services to us and you, for example hosting and supporting IT applications, provision of certain forms of insurance for member firms and its clients, performing client conflicts checks and Anti-Money Laundering checks, assisting with client engagement services and otherwise as required in order to continue to run INDIGENESIS’s business.

2.2 Transfers to third parties

We do not share personal information with third parties, except as necessary for our legitimate professional and business needs, to carry out your requests, and/or as required or permitted by law or professional standards.

For more information on such third parties, please see “Appendix – Data Transfers to Third Parties”. In addition, INDIGENESIS may transfer certain PII outside of the area in which it operates to outside companies working with us or on our behalf for the purposes described in this Privacy Statement. INDIGENESIS will also typically store personal information outside of the UAE. INDIGENESIS will not transfer the PII you provide to any third parties for their own direct marketing use.

3. Choices

In general, you are not required to submit any PII to INDIGENESIS online, but we may require you to provide certain PII in order for you to receive additional information about our services and events. INDIGENESIS may also ask for your permission for certain uses of your PII, and you can agree to or decline those uses. If you opt-in for particular services or communications, such as an e-newsletter, you will be able to unsubscribe at any time by following the instructions included in each communication. If you decide to unsubscribe from a service or communication, we will try to remove your information promptly, although we may require additional information before we can process your request.

As described in our Cookies Notice, if you wish to prevent cookies from tracking you as you navigate our sites, you can refuse cookies at the point at which we present you with a choice to accept or reject cookies, and/or you can reset your browser to refuse all cookies or to indicate when a cookie is being sent. Note, however, that some portions of our sites may not work properly if you elect to refuse cookies.

4. Your Rights

If submitted INDIGENESIS processes personal information about you, you have the following rights:

Access and correction: you have the right to reasonable access to that data. This is sometimes called a ‘Subject Access Request’. If we agree that we are obliged to provide personal information to you, we will provide it to you free of charge. Before providing personal information to you, we may ask for proof of identity and sufficient information about your interactions with us that we can locate your personal information. If the information we hold about you is incorrect, you are entitled to ask us to correct any inaccuracies. in the personal information.

Object to processing: you have the right to object to us processing your personal information if we are not entitled to use it any more

Right to be forgotten: in addition, you are entitled to request us to erase all or any of your personal data we hold about you by writing to us at [email protected] we will make all reasonable and practical efforts to comply with your request, so long as it is consistent with applicable law and professional standards.

5. Data security and integrity

INDIGENESIS has reasonable security policies and procedures in place to protect personal information from unauthorized loss, misuse, alteration, or destruction. Despite INDIGENESIS’s best efforts, however, security cannot be absolutely guaranteed against all threats. To the best of our ability, access to your personal information is limited to those who have a need to know. Those individuals who have access to the data are required to maintain the confidentiality of such information. We also make reasonable efforts to retain personal information only for so long i) as the information is necessary to comply with an individual’s request, ii) as necessary to comply with legal, regulatory, internal business or policy requirements, or iii) until that person asks that the information be deleted. The period for which data is retained will depend on the specific nature and circumstances under which the information was collected; however, subject to requirements of i)-iii) above, personal information will not be retained for more than 2 years.

6. Links to other sites

Please be aware that INDIGENESIS web sites may contain links to other sites, including sites maintained by other INDIGENESIS member firms that are not governed by this Privacy Statement but by other privacy statements that may differ somewhat. We encourage users to review the privacy policy of each Web site visited before disclosing any personal information.

7. Changes to this statement

INDIGENESIS may modify this Privacy Statement from time to time to reflect our current privacy practices. When we make changes to this statement, we will revise the “updated” date at the top of this page. We encourage you to periodically review this Privacy Statement to be informed about how INDIGENESIS is protecting your information. Any changes to the processing of personal data as described in this Privacy Statement affecting you will be communicated to you through an appropriate channel, depending on how we normally communicate with you.

8. Policy questions and enforcement

INDIGENESIS is committed to protecting the online privacy of your personal information. If you still have questions or comments about our administration of your personally identifiable information, please escalate your concern to out grievance officer:

Name: Ashish Jain

E-mail:[email protected]

You may also use this address to communicate any concerns you may have regarding compliance with our Privacy Statement.

Appendix – Data Transfers to Third Parties

— Our service providers: we transfer your personal information to our third-party service providers, such as our (IT) systems providers, our hosting providers, our payroll providers, consultants (such as legal advisers) and other goods and services providers. INDIGENESIS works with such providers so they can process your personal information on our behalf. INDIGENESIS will only transfer personal information to them when they meet our strict standards on the processing of data and security. We only share personal information that allows them to provide their services.

— If we are reorganized or sold to another organization: INDIGENESIS will typically also disclose personal information in connection with the sale, assignment, or other transfer of any element of INDIGENESIS’s business to which the personal information relates.

— Courts, tribunals, law enforcement or regulatory bodies: INDIGENESIS will disclose personal information in order to respond to requests of courts, tribunals, government or law enforcement agencies or where it is necessary or prudent to comply with applicable laws, court or tribunal orders or rules, or government or professional regulations.

— Audits: disclosures of personal information will also be needed for data privacy or security audits and/or to investigate or respond to a complaint or security threat.

— Insurers: our professional rules and our business requirements mean that we carry significant insurance cover in respect of business activities (our ‘insurance programme’). This is required to assist each member firm of the INDIGENESIS network in covering the costs associated with claims which may arise in the event that it is alleged that something has gone wrong during the course of providing services to its clients. In order to make the insurance programme work effectively, the insurance programme involves a number of different participants in the insurance market (e.g. brokers, insurers and reinsurers, as well as their professional advisors and other third parties involved should there be a claim). Some of these insurance market participants will require that we disclose personal information about you to them. The information will be used by the insurance market participants in the underwriting and ongoing administration of the insurance programme, where there is a claim that you are relevant to and to allow the insurance market participants to comply with their legal and regulatory obligations. Some of these insurance market participants will handle this information on our behalf (like our service providers described above), but others will want to process information about you independent of us.

The INDIGENESIS name and logo are owned by INDIGENESIS CONSULTING DMCC

¹ “INDIGENESIS,” “we,” “our,” and “us” refers to INDIGENESIS CONSULTING DMCC