PRIVACY POLICY – DOCKENDALE SHIP MANAGEMENT FZCO

1. Important information and who we are

Purpose of this privacy policy

This privacy policy aims to give you information on how Dockendale collects, processes, and shares your personal data through your use of this website.
It is important that you read this privacy policy together with any other privacy policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them. Any relevant privacy policy or notice that should be read in conjunction with this policy is publicly available on our site under "Terms and Conditions".

Controller

Dockendale is the Controller under the Data Protection Laws and responsible for your personal data (referred to as "we", "us" or "our" in this privacy policy).
If you have any questions about this privacy policy or our privacy practices, including any requests to exercise your legal rights, please contact us using the details set out below.

Contact details

Email address: mhb@dockendale.net
You have the right to make a complaint at any time to the UAE Data Office established by virtue of United Arab Emirates’ Federal Decree No. 44/2021 (the “Office”). We would, however, appreciate the chance to deal with your concerns before you approach the Office so please contact us in the first instance using the contact details above.

Changes to the privacy policy and personal data we hold

We keep our privacy policy under regular review.
It is important that the personal data we hold about you is accurate and current. We discuss your right to notify us of inaccuracies below.

Third-party links

This website may include links to third-party websites (including websites of entities within our corporate group), plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements and, in relation to the data (including personal data) collected by such sites, plug-ins and applications, those privacy statements shall apply in place of our privacy policy. When you leave our website, we encourage you to read the privacy policy of every website you visit to understand how your data may be collected, processed, and shared.

2. The data we collect about you

Personal data means any information about an individual from which that person could or can be identified whether directly or indirectly. It does not include data where the possibility of identifying an individual has been rendered sufficiently remote (anonymous data).

Subject to compliance with applicable controls and security measures under the Data Protection Laws, we may collect, use, store (for as long as is necessary to fulfil the purpose of processing your personal data) and transfer different kinds of personal data about you which we have grouped together as follows:

• Technical Data includes internet protocol (IP) address and other geographic identifiers for the purpose of identifying your location.
• Usage Data includes information about how you use our website, products, and services.
• Contact Data includes any information that would allow us to contact you such as your name, email ID, company name and contact number together with any documents you upload such as your resume or certifications.

We also collect, use, and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data under Data Protection Laws as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your family, race, or ethnicity, religious or philosophical beliefs, sexual condition, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

Restricting collection of personal data

Please refer to our cookie policy for information on restricting the use of the types of cookies that operate on our website.

How is your personal data collected?

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

• Technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy for further details.

2. The data we collect about you

Except where permitted by the applicable law, we will only use and process your personal data with your consent. Most commonly, we will not rely on consent as a legal basis for processing your personal data if:

• Processing is necessary to protect the public interest.
• Processing is for Personal Data that has become available and known to the public by an act of yours.
• Processing is necessary to initiate or defend against any actions to claim rights or legal proceedings or related to judicial or security procedures.
• Processing is necessary to protect your interests.
• Processing is necessary to perform, conclude, amend, or terminate a contract with you.
• We need to comply with a legal obligation.

You may withdraw your consent for us to process and use your personal data at any time by contacting us at the email address provided above.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data.

Purpose/Activity	Type of data
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Technical
To use data analytics to improve our website, products/services, marketing, and user experiences	(a) Technical (b) Usage
To allow you to subscribe to our updates, promotional materials, make applications, report issues to us, submit feedback or make any inquiries	(a) Usage Data (b) Contact Data

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, including how to restrict their use, please see our Cookie Policy

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will obtain your consent to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

4. Disclosures of your personal data

We may share your personal data with the Internal Third Parties and/or the External Third Parties, as set out in the Glossary, for the purposes set out in the table Purposes for which we will use your personal data above.
We require all third parties to respect the security of your personal data and to treat it in accordance with the applicable law via contractual means. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

5. International transfers

We share your personal data with the Internal Third Parties and/or the External Third Parties, some of which might involve transferring your data outside the UAE, as may be permitted by the appliable Data Protection Laws.
Whenever we transfer your personal data outside of the UAE, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• we will only transfer your personal data to countries that have been deemed by the Office to provide an adequate level of protection for personal data; or
• where the United Arab Emirates has acceded to bilateral or multilateral agreements concerning the protection of Personal Data.

We will only transfer your personal data out of the UAE to a country that is not deemed to have an adequate level of protection if:

• The recipient of your personal data is contractually obligated to implement the provisions, measures, controls, and requirements compliant with the requirements laid out in the UAE Data Protection Law.
• We obtain your express consent and that such transfer does not conflict with the state’s security and public interest.
• If the transfer is necessary to fulfil obligations and establish, exercise, or defend rights before judicial authorities.
• If the transfer is necessary to enter into or execute a contract with you or between Dockendale and a third party to achieve your interest.
• If the transfer is necessary to perform a procedure relating to international judicial cooperation.
• If the transfer is necessary to protect the public interest.

6. Data security

We have put in place appropriate technical and organisational 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, provided they apply sufficient technical and organisational rules and controls that comply with the processing requirements set out in the Data Protection Laws.

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

7. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. Except where retention is necessary for compliance with the Data Protection Laws, we will erase such personal data upon you withdrawing your consent. We reserve the right to retain non-personally identifiable information provided it is anonymised in accordance with the applicable Data Protection Laws.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting, or other requirements.

8. Your legal rights

Subject to your jurisdiction, you have rights under the Data Protection Laws in relation to your personal data. Please note that there may be limitations on these rights, depending on the specific circumstances concerning your personal data and the applicable law. Subject to applicable exemptions, Data Subjects covered by the Data Protection Laws have the following rights:

• Right to Obtain Information on the type of your Personal Data being processed and be provided with information in relation to that data to ensure it is being lawfully processed. Please contact us for further instructions on making such a request.
• Rectification of any incomplete or inaccurate data held about you by us (although we may need to verify the accuracy of any new data provided). We reserve the right to verify and authenticate your identity and your Personal Data to ensure accuracy and authenticity of the information provided by you.
• Erasure of Personal Data where there is no compelling reason for us to continue to process it; where you have successfully exercised your rights to object to processing (below), where we have processed Personal Data unlawfully, where you have withdrawn your consent (below) or where we are required to erase your Personal Data to comply with the Data Protection Laws. Please note that we can refuse to delete or remove Personal Data where we require information for defence of legal claims or where we are prevented from doing so under applicable law.
• To restrict processing of Personal Data; you may exercise this right where (a) you are requesting rectification, in which case processing is suspended until the information is verified, (b) we are processing your Personal Data unlawfully and as an alternative to exercising your right to request erasure, (c) we no longer need to process your Personal Data but you need the personal data for the establishment, exercise or defence of legal claims; or (d) you have exercised your right to object to processing of Personal Data which relies on legitimate interests as a basis for lawful processing, and we need to verify that we have such legitimate interests. However, in some cases we may demonstrate that we have compelling legitimate grounds to process Personal Data which overrides your rights and freedoms or where we require that information for defence of legal claims.
• Object to processing of Personal Data if the processing (a) is for direct marketing purposes, (b) is to conduct statistical surveys or (c) has been carried out in violation of Data Protection Laws. However, in some cases we may demonstrate that we have compelling legitimate grounds to process Personal Data which overrides your rights and freedoms or where we require that information for defence of legal claims.
• To receive a copy of Personal Data in a machine-readable format or request the transfer of Personal Data to another party, whenever technically feasible.
• Right to withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
• To not be subject to automated decision-making, including profiling, which has a legal or other significant effect on you, unless we are entitled to do so whether by contract or at law.
• Right of nominate where you can nominate, any other individual, who shall, in the event of your death or incapacity, exercise your rights.

If you wish to exercise any of the rights set out above or in case of any grievance, please contact us via the methods set out in this privacy policy.

No fee required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights).

What we may need from you

We will need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests promptly and in any event within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Please note that, where we have requested information relating to identity and/or to clarify your request, the time for us to respond will run from the moment such information is provided to us.

9. General Matters

Consents: We reserve the right to update or change our privacy policy to reflect such changes as may be necessary. Should this Privacy Policy change, we endeavour to take every reasonable step to ensure that these changes are brought to Your attention by posting the updated privacy policy on our website.

Children’s Policy: We do not knowingly collect or solicit personal information from any person under the age of 18 or knowingly allow such persons to use the website. If you are not 18 years of age, please do not use or attempt to register on our website.

Assignment: If all or part of our assets are acquired or sold to another party, or in the event of a merger or amalgamation, you grant us the right to transfer the personal data collected from you to the relevant third party in compliance with the applicable Data Protection Laws.

10. Glossary

THIRD PARTIES

Internal Third Parties means the companies within the MACSTEEL INTERNATIONAL group of companies.

External Third Parties means a service provider acting as a processor based outside of the UAE who provides data analytics reporting services to us based on the operation of Google Analytics on our website.