Responsible persons and contact points
If you have any questions about this Policy or your privacy (including any access, correction, complaint or marketing opt-out requests, or for further details of the entities to which this Policy applies) you can contact us via the following contact details:
- Email: email@example.com
- or by writing to our Privacy Officer at:
ATTN: Privacy Officer
Office 02 Level 25
Boulevard Plaza Tower 1
Sheikh Mohammed Bin Rashid Boulevard
T +971 4 524 8555
This Policy is subject to change at any time.
What types of Personal Information do we collect?
In the course of general business we may collect:
i. Personal information including:
- mailing and/or street addresses;
- email address;
- telephone number;
- facsimile number;
- age or date of birth;
- government identifiers;
- country of birth;
- various financial information;
- interests, preferences and opinions; and
- information about your use of our products and services and your other dealings with us, including any contact we have with you by telephone, email or online.
- Information you provide by filling in forms on our Website.
ii.Sensitive information including:
- professional memberships; and
- criminal records.
We may also collect some information that is not personal information because it does not identify you or anyone else. For example, we may collect anonymous answers to surveys or aggregated information about how users operate our website/s.
How do we collect and hold your Personal Information?
How we collect personal information will largely depend upon whose information we are collecting. If it is reasonable and practical to do so, we collect personal information directly from you, for example:
- through your access and use of our website/s;
- during conversations between you and our representatives; or
- when you make an enquiry or complete an application.
We may also collect personal information from your organisation and representatives, our related companies, public sources and third parties such as our fund administrator or independent sources.
Sometimes we may be provided with your personal information without having sought it through our normal means of collection. We refer to this as unsolicited information. Where we collect unsolicited information we can generally only hold, use and or disclose that information if we could otherwise do so had we collected it by normal means. If that unsolicited information could not have been collected by normal means then we may be required to destroy, permanently delete or de-identify the information as appropriate.
We may log the electronic address of your computer, otherwise known as an IP address, to analyse trends, administer websites, track user movements and gather broad demographic information.
How we use your Personal Information
Our uses of personal information include but are not limited to:
- Providing you with one or more of our services;
- Improving and tailoring our services;
- Making you aware of job opportunities you have expressed an interest in either with Roberts or one of our international businesses;
- Conducting product and market research;
- Understanding your needs, interests and behaviour;
- Verifying your identity and personal information;
- Maintaining and updating our records;
- Training and managing our people;
- Communicating with you about the products and services that we offer across the Group (subject to legal requirements and your right to opt out) and conducting other marketing activities;
- Co-operating with regulators and authorities and complying with our legal obligations;
- Dealing with suspected fraud, misconduct and breaches of legal obligations; and
- Facilitating the sale of any interest in our business.
It may be necessary for us to disclose your personal information to certain third parties (some of whom may be located overseas), e.g. in order to assist us with one or more of our functions or activities. This may include our related companies, your representatives, government agencies, bodies or authorities (including regulatory bodies) and organisations providing services to us, such as unit registry, fund administration, custodial, audit, investment management, legal, customer contact, data processing, data analysis, information broking, research, investigation, insurance, website or technology services. It is not practicable to list every country in which such recipients are located but it is likely that such countries will include the USA, Canada, the United Kingdom, the Middle East and members of the European Union from time to time.
Storage and Security of your Personal Information
We may hold your information in either electronic or hard copy form.
We take a range of steps to protect the personal information we hold about you from misuse, loss, unauthorised access, modification or disclosure.
Depending on the circumstances, these steps may include:
- Restricting access to information on our databases on a need to know basis with different levels of security being allocated to staff based on their roles and responsibilities and security profile.
- Ensuring all staff are aware that they must not reveal or share personal passwords.
- Ensuring where sensitive information is stored in hard copy files that these files are stored in a secure location with access restricted to staff on a need to know basis.
- Implementing physical security measures at our premises to prevent break-ins.
- Implementing security systems, policies and procedures to protect personal information stored on our computer networks.
- Implementing human resources policies and procedures, such as email usage, confidentiality and document security policies, designed to ensure that staff follow correct protocols when handling personal information.
- Undertaking due diligence with respect to third party service providers who may have access to personal information, including customer identification providers and cloud service providers, to ensure they are able to provide appropriate protection to your information.
Where any personal information is no longer needed by us, or required to be retained by any other laws, we are required to take reasonable steps to destroy it in a secure manner, or delete or de-identify it as appropriate.
Despite implementing measures designed to secure your personal information from accidental loss and unauthorised access, unfortunately the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, completing forms on the internet is not completely secure. Any transmission of your personal information is at your own risk.
Our website may contain links to other third-party websites. We do not share your personal information with those websites and we are not responsible for their privacy practices.
Third party websites are responsible for informing you about their own privacy practices. Please check their privacy policies.
How we ensure the quality of your Personal Information
We take reasonable steps to ensure the personal information we collect, use and disclose is accurate, complete and up-to-date.
You can help us with this by contacting us if any of the details you have provided change or if you believe that the information we have about you is not accurate, complete or up-to-date.
Gaining access to your Personal Information
You may request access to the personal information we hold about you, or request that we change or destroy the personal information, by contacting us.
If we do not agree to provide you with access or to amend your personal information as requested, you will be notified accordingly. Where appropriate we will provide you with the reason/s for our decision. If the rejection relates to a request to change your personal information you may make a statement about the requested change and we will attach this to your record.