privacy notice
Introduction
This Privacy Notice is issued by Orca Technology Limited, a company registered in Dubai International Financial Centre under commercial license number CL7323, for and on behalf of itself and its group companies and affiliated entities (collectively, “we”, “us”, “our” or the “Group”).
This Privacy Notice explains how we collect, use, disclose, transfer and otherwise process personal data in connection with our business activities, website, services, operations, employment relationships and interactions with individuals.
This Privacy Notice has been prepared with reference to applicable data protection laws, including the DIFC Data Protection Law No. 5 of 2020 and related regulations (“DIFC Data Protection Law”).
For the purposes of applicable data protection law, the relevant entity within our Group that collects or receives your personal data, communicates with you, employs you, contracts with you, provides services to you, or otherwise determines the purposes and means of processing your personal data, shall generally act as the relevant data controller.
Collection of Personal Data
We may collect personal data directly from you, from your employer or representatives, through your interactions with us, through our website and systems, from publicly available sources, or from third parties where legally permitted.
The personal data we process may include:
- basic identification and contact information, such as your name, job title, employer, email address, telephone number, address and other contact details;
- identification and verification information, including passport details, visa information, Emirates ID details and other identification documents;
- information relating to your organization, position, role, interactions, transactions, correspondence and communications with us;
- financial and payment information, including bank account details, billing details and transaction-related information;
- information relating to recruitment and employment, including CVs, educational and professional background, employment history, compensation information, performance-related information and other HR-related records;
- information relating to dependants where relevant for employment, insurance, immigration or administrative purposes;
- technical and electronic information, including IP address, browser information, device information, website usage data and security or access logs;
- any other information voluntarily provided to us.
We may also process limited personal data relating to representatives, employees or contact persons of our clients, counterparties, suppliers, service providers and business partners.
How We Use Personal Data
We may process personal data for the following purposes:
- managing our business operations and activities;
- providing, supporting and administering our services, systems and technology solutions;
- managing relationships with clients, counterparties, suppliers, service providers and business partners;
- communicating with individuals and responding to enquiries or requests;
- entering into, administering and performing contracts;
- conducting onboarding, verification and due diligence procedures;
- processing payments, accounting and financial administration;
- managing recruitment processes and employment relationships;
- administering compensation, benefits, insurance, immigration and HR-related matters;
- maintaining internal records and corporate administration;
- complying with legal, regulatory and compliance obligations;
- establishing, exercising or defending legal claims;
- improving our website, systems, infrastructure and business operations;
- any purpose related or ancillary to the foregoing.
Lawful Basis for Processing
Whether we receive your personal data directly from you or from a third party, we will only process your personal data where permitted under applicable law, including where we have obtained your consent (where required) or where another lawful basis for processing applies under applicable data protection laws.
Sharing of Personal Data
We may disclose or transfer personal data within our Group and to third parties where reasonably necessary for the purposes described in this Privacy Notice, including to:
- other entities within our Group;
- professional advisers, including legal, accounting, audit, compliance or other advisers;
- banks, insurers and financial institutions;
- service providers supporting our operations, including IT, cloud hosting, software, infrastructure, communications, cybersecurity, administrative or support service providers;
- recruitment providers and HR-related service providers;
- regulators, governmental authorities, courts, tribunals or law enforcement authorities;
- counterparties, business partners or service providers involved in our operations or activities;
- other persons where disclosure is required or permitted by law.
We may also disclose personal data in connection with corporate transactions, restructurings, reorganisations, financings or similar business activities.
Such recipients may process personal data on our behalf or for their own purposes where permitted by applicable law.
International Transfers
Personal data may be transferred to, stored in or accessed from jurisdictions outside the DIFC and the United Arab Emirates, including jurisdictions in which entities within our Group or our service providers operate.
Where we transfer personal data internationally, we take reasonable steps to ensure that such transfers are carried out in accordance with applicable data protection laws and subject to appropriate safeguards where required.
Cookies and Website Information
Our website may use cookies or similar technologies to support website functionality, improve user experience, analyse website usage and maintain security.
We may collect certain technical information through our website, including IP address, browser type, device information and website interaction information.
You may configure your browser settings to reject or restrict cookies, although this may affect certain website functionality.
Retention of Personal Data
We retain personal data for as long as reasonably necessary for the purposes for which it was collected, including for legal, regulatory, compliance, accounting, reporting or legitimate business purposes, or for the establishment, exercise or defence of legal claims.
Data Subject Rights
Subject to applicable law, individuals may have rights in relation to their personal data, including the right to:
- request access to personal data;
- request correction of inaccurate or incomplete personal data;
- request erasure of personal data in certain circumstances;
- request restriction of processing;
- object to certain processing activities;
- request portability of personal data where applicable;
- withdraw consent where processing is based on consent.
These rights may be subject to limitations or exceptions under applicable law.
Requests relating to personal data may be submitted using the contact details below. We may request information necessary to verify identity before responding to a request.
Information Security
We implement reasonable technical, organisational and administrative measures designed to protect personal data against unauthorised access, disclosure, loss, misuse or alteration.
Changes to this Privacy Notice
We may update or amend this Privacy Notice from time to time. Any updated version will become effective when published or otherwise communicated.
Contact Us
If you have any questions regarding this Privacy Notice or our processing of personal data, please contact:
Orca Technology Limited
Unit 809, Level 8, Liberty House, Dubai International Financial Centre, Dubai, United Arab Emirates
Email: hr@ordercapital.com
You may also have the right to lodge a complaint with the DIFC Commissioner of Data Protection or another competent authority where applicable.