Privacy

March 2024

PRIVACY NOTICE

At Trifecta Advisory Group Limited (“Trifecta”, “we”, “us”, “our”) we are committed to protecting the privacy and security of your Personal Data. This Privacy Notice (the “Notice”) explains the type of Personal Data that we collect about you, and how we process and use that information, in accordance with the Abu Dhabi Global Market (ADGM) Data Protection Regulations 2021 (the “Regulations”).

We reserve the right to revise and amend this policy, or part of it, at any time. Should you no longer wish for us to hold data about you or to update us on your data, please contact us using the contact details below.

Who we are

Trifecta, in the ordinary course of business, collects, uses, and shares personal information pertaining to its employees, clients, partners and other parties. Trifecta is a data controller; we are responsible for determining how we hold and use most of the personal information about you. However, if we are processing your personal information on the instructions of one of our clients, it is likely we are working as a data processor in line with a written contract. In this case, the data controller will be our client and your Personal Data will be processed as set out in their Privacy Notice.

Our contact details are:

Email: [email protected]

Phone Number: + 971 2 816 4338

Address: Al Maqam Tower, 1121, 11th Floor, Abu Dhabi Global Market Square, Abu Dhabi, Al Maryah Island, United Arab Emirates

Personal Data – What we collect & How we collect it

“Personal Data” is any information relating to an individual which, when used or processed, means the individual can be identified, directly from that Personal Data or can be identified from that information in combination with other information. If you contact us using our website, by email or through social media, we collect the personal information you provide to us.

We collect data when you:

Register online or place an enquiry for any of our products or services;
Use or view our website via your browser’s cookies; and
Interact or communicate with us in a business capacity, for example through the provision of services to you.

During this contact and through our services to you, types of information that is considered Personal Data about you typically includes:

Your identity (including, but not limited to, your full name and any previous names, in addition to evidence of name changes, date of birth, gender, marital status, health or disability data, and any relevant travel, residency or visa documents);
Your contact details (including, but not limited to, your address, phone number(s), email address(es));
Your employment history (including, but not limited to, current and previous employment details, such as job titles, remunerations, and performance records, contact details of current and previous employers and employee references);
Your educational history (including, but not limited to, educational certificates, and contact details of educational references);
Your technical data, (including, but not limited to, your internet protocol (IP) address, login data, browser type and version and relevant plug-in types, time zone setting and location, platform and operating system and any other technology on the device used to access our website, including if you visit other websites employing our cookies;
Your feedback and responses to questionaries and surveys we provide;
Your usage data, including information about you may use our website; and
Marketing and communications data (including, but not limited to, any preferences you have informed us of relating to receiving marketing from us or third parties appointed by us, where you provide these preferences to us and consent that we may process it).

Personal information provided by you in relation to racial or ethnic origin, political opinions or affiliations, criminal record, religious or philosophical beliefs, trade union membership, and health or sex life (not limited to genetic or biometric data used to identify you), will be processed only to the extent that this data is relevant and necessary. Where you provide us with such data, and we do not use it, we will delete it.

It is important that the Personal Data we hold stays up-to-date, current, and accurate. Please contact us if any Personal Data relating to you changes or is no longer applicable.

We may aggregate data, derived from your Personal Data, in an anonymised way. Such aggregated data does not constitute Personal Data.

How we use your Personal Data

We collect and process your Personal Data if and to the extent applicable law provides a lawful basis for us to so. As such, we process your Personal Data:

After you have provided your consent for us to do so;
In order to service or perform our contractual obligations with you;
In order to process your request or enquiry;
Market products of interest that we believe may be of interest to you based on the Personal Data we have on you;
If we need to comply with a legal obligation to which we are subject; and
Where necessary, we (or a third party) have a legitimate interest not overridden by your own interests, fundamental freedoms or rights.

Why do we collect your Personal Data?

We process your Personal Data to meet our legal, statutory, and contractual obligations. We will never collect any unnecessary Personal Data from you and do not process your information in any way other than as specified in this Notice.

It is important to note that the provision of your personal information to us remains at your sole discretion. However, where you do not wish to provide us with the personal information we have requested, we will advise you of the repercussions of such omission, including any legal effect.

Sharing your data

Trifecta will only share your Personal Data where it is necessary or where it is required by law. We may share your Personal Data with a range of third parties, including, but are not limited to:

Companies engaged by us to perform service and business functions on our behalf. For example, payroll service provider, legal, accounting, audit, and other professional services or data storage facilities;
Government and law enforcement agencies, regulators, and supervisors;
Consultancy services such as IT consultants; and
Third parties to who we may choose to merge, transfer, or sell parts of our business.

How long we keep your data

We retain your personal information for as long as it is reasonably necessary for the purpose of our relationship, for as long as we are legally obliged or until you object to us processing your data or withdraw your consent to us doing so.

From time to time, we may retain some Personal Data for reasons relating to legal, accounting and tax, or compliance purposes.

Automated decision making

We do not use Personal Data for automated decision-making. We may use automated decision-making to assist in our decision-making process only where there is a human element to ensure fairness of the outcome.

Minors

We do not act as the data controller for any Personal Data belonging to minors (persons under the age of 18).

Personal Data security

In accordance with the Regulations, we have implemented and maintain appropriate organisational and security measures to protect your Personal Data, in order to prevent and protect it against destruction (whether accidental or unlawful) alteration, or unauthorised disclosure or unlawful processing. Your Personal Data is only available to employees and contractors who have a business need to be able to access it.

Any breaches of your Personal Data will be notified to you and the Commissioner of Data Protection, when legally required to do so.

Marketing

We may use your information to market services that are similar to those that you have expressed an interest in. If you do not wish to receive marketing information from us, you may opt-out by emailing our data protection email address ([email protected]) or responding to our marketing communication and selecting the ‘opt-out’.

Your rights

In accordance with the Regulations and, in certain circumstances or subject to relevant and applicable exemptions, you have the following rights in relation to your Personal Data:

You may request access to your Personal Data;
You may request corrective action on any Personal Data that is incorrect or out of date;
You may request erasure of your Personal Data, or object to or request restriction of our data processing of your Personal Data;
You may withdraw consent to us marketing to you; and
You may request that we transfer your Personal Data to another party under certain circumstances.

Where we rely on consent to process your Personal Data, you may withdraw your consent at any time to prevent further processing.

If we receive a request from you to exercise any of the above rights, we may ask you to verify your identity before acting on the request; this is to ensure that your Personal Data is protected and kept secure.

If you are not satisfied with the outcome of your request, you have the right to escalate your request to the Commissioner of Data Protection by contacting the Commissioner using the following details:

Phone Number: + 971 2 333 8888

Email: [email protected]

Address: ADGM Building, Abu Dhabi Global Market Square, Al Maryah Island, Abu Dhabi, United Arab Emirates

If you wish to exercise your rights, please contact us at [email protected]