The DIFC Wills Service (the ‘Wills Service’) is committed to maintaining the privacy of information that you might share with us while visiting our website and interacting with us online.
This Policy applies to all visitors of the website (collectively, “Site Users” or “Users”), including (i) casual Site Users who visit the Site to learn more about our services (“General Visitors”); and (ii) registered users to whom we have granted access to certain password- protected areas and features of our Site, consisting of our E-Commerce Online Payment Facility (for booking appointments and using our services) (“Registered Users”). If you would like to become a Registered User of our mobile app for the appointments section of site, please visit: https://difcwills.ae/login-appointments/.
The term “you”, “your”, and “User”, or similar terms in this Policy means both General Users and Registered Users.
The terms “us”, “we” and “our” refer to the DIFC Wills Service part of the DIFC’s Dispute Resolution Authority. Our contact details can be found at the end of this Policy.
- The difcwills.ae Website
The portion of our Website that is accessible to all Site Users (the “General Site”) is designed to provide General Visitors with a range of information concerning (i) the services we offer; (ii) our team; (iii) the mandate of the Wills Service; (iv) the DIFC Wills and Probate Registry Rules and ongoing legal developments (public consultations); and (v) other materials concerning our service. Through our General Site, for example, Users can request or be provided alerts, e-vites, e-announcements and other communications from our team. Our Website also provides Registered Users with a gateway to the password-protected areas to which they have access, to book appointments for services, and make online payments for our services.
- Information You May Provide
The types of information you may provide while visiting our Site falls into two broad categories: (i) personal information; and (ii) anonymous information. We use the term “Personal Information” to mean any information you provide to us via the Site that could reasonably be used to identify you, such as your name, address, e-mail address, date of birth, telephone number or any combination of such information. “Anonymous Information” is information that does not identify you, and may include, for example, statistical information concerning how you and other General Visitors use our Site.
- Our Uses of the Information You Provide
We use information you provide to us via the Website only as provided in this Policy. We use the Personal Information you provide via the Website only for purposes of providing you information concerning the Wills Service, and for responding to requests you may make via our Website. We do not share your Personal Information with any third parties (except as provided in Section 7 (Disclosures to Third Parties)).
Specifically, we collect, or receive, information from General Visitors at different points on our Website, and use this information as follows:
- Appointments: In order to access the Login Appointments section and make use of our services on the password-protected areas of our Site, we require that you provide certain information, such as (i) name; (ii) phone number; (iii) e-mail address; (iv) date of birth; (v) gender); and (vi) nationality. The registration process for certain portions of the Site may require a Registered User to provide additional Personal Information, as specified in the registration process. We use the information a Registered User provides during the registration process to provide him or her with a user name and a password, and to allow the Registered User to gain access to password-protected areas of the Site. We also use contact information Registered Users provide during the registration process as further detailed below.
- E-mail Communication: We use your e-mail address to send alerts/newsletters, e-announcements and other communications concerning the Wills Service, legal developments, notifications, and other information relating to our Site and the Wills Service. In addition, we may use your e-mail address to invite you to seminars/briefings, or other functions we believe may be of interest to you. You have the ability to opt-out of receiving these materials, as provided in Section 8 (Removing Information; Opting-Out).
- Information Notices and Bulletins: Periodically, we may choose to send news, bulletins, seminar and legal education announcements, and other information to General Visitors, and will use Personal Information to send such communications. If we choose to undertake such communications, you will have the ability to opt-out of receiving these communications as provided in Section 8 (Removing Information; Opting-Out).
- Surveys: Periodically, we may initiate surveys at difcwills.ae, and we may request Personal Information from you in connection with such surveys. You are free to choose whether to participate in this type of survey. The information we request may include contact information (such as name and e-mail address). Survey information will be used for purposes of monitoring or improving our Site and our services. We will notify you of relevant details in connection with asking for your participation in such surveys. By submitting information to us when registering as a Registered User, you consent to the use of your information for these purposes.
- Anonymous Information
We use Anonymous Information to analyze the effectiveness of our Website, and other similar purposes. In addition, we may on occasion undertake or commission statistical and other summary analyses of the general behaviour and characteristics of General Visitors, and may share Anonymous Information with third parties for this purpose. The Anonymous Information provided to third parties will not allow anyone to identify you. We may collect Anonymous Information through features of the software that support our Site, through cookies, and through other means described below.
- IP Addresses; Logs: We may automatically receive and record information in our server logs from your browser, including your IP address, your computer’s name, the type and version of your Web browser, referrer addresses, and other generally accepted log information. We may also record page views and other general statistical and tracking information, which will be aggregated with that of other General Visitors in order to analyze how our Website is being used, and for security and monitoring purposes.
- Pixel Tags or Web Beacons: We may also use pixel tags which are small graphic images indicating to us what parts of our Website have been visited, and whether e-mail messages have been opened, to measure the effectiveness of our Site, and for other purposes. None of this data includes Personal Information, and you can opt-out of receiving these types of e-mails from us by following the directions provided in Section 8 (Removing Information; Opting- Out).
- Click-Through Data: We may send e-mail messages which use a “click-through URL” linked to content on our Site. When you click one of these URLs, you pass through our Web server before arriving at the destination website. We track click-through data to determine General Visitors’ interest in particular topics, and to measure the effectiveness of our client communications. If you prefer not to be tracked, simply do not click text or graphic links in the e-mail, or notify us in accordance with Section 8 (Removing Information; Opting- Out).
- Any Information Linked with Your Personal Information Is Protected as “Personal Information”
- Relationship Between Information You Provide Via Our Site and Information You Provide Via Offline Sources
This Policy applies to information that you provide through the use of our Website and does not apply to information you provide to the Wills Service through other means.
- Disclosures to Third Parties
As an exception to the policies set out in Section 4 (Our Uses of the Information You Provide), we will disclose your Personal Information to third parties without your express consent in the following circumstances:
- Site Vendors: We may employ other companies to perform functions on our behalf, such as maintaining the Website, providing services related to the Site, collecting information, responding to and sending electronic mail, or other functions related to our mandate and services. In order to obtain these services, we may need to share your Personal Information with these companies (collectively, “Site Vendors”). We will provide Site Vendors with only the information necessary to perform their duties with respect to our Website, and we obligate our Site Vendors to safeguard your Personal Information and refrain from using your Personal Information for any other purpose.
- Affiliates: We may disclose your Personal Information to our affiliates and entities under common control of the DIFC Dispute Resolution Authority.
- Harm Mitigation: We may reveal your Personal Information to third parties such as law enforcement or investigative agencies if we believe it is necessary in order to prevent, or take action against illegal activities, fraud, or situations involving the potential threats to the rights, property, or personal safety of any person, or that you are violating these Terms, or other legal obligations.
- Legal: We will reveal Personal Information to the extent required to do so by law.
- Your rights in relation to your information
- You have a number of rights concerning the way that we use your information.
- At any time, you have the right:
- to request access to or a copy of any personal data which the DRA holds about you;
- to rectification of your personal data, if you consider that it is inaccurate.
- In addition, if you are offered our services and are located in the EU, you have the following additional rights:
- to ask us to delete your information, if you consider that we do not have the right to hold it;
- to restrict processing of your information;
- to data portability (moving some of your information elsewhere) in certain circumstances;
- to withdraw your consent at any time, to the extent we rely on your consent to process your personal data; and
- object to your information being processed in certain circumstances;
- to not to be subject to a decision based on automated processing and to have safeguards put in place if you are being profiled based on your information (we do not carry out any automated decision making).
- If you wish to exercise any of these rights, or you wish to raise a complaint about how we are using your information, please contact the DRA in the following ways:
- Write to: Nour Hineidi Kirk < >
- Call: +9714 427 3308
- Email: Nour.Kirk@difccourts.ae
- Removing Information; Opting-Out
- Opt-Out: If we send electronic communications, we will also provide you with the ability to opt-out of receiving further such communications. Instructions for opting-out will be provided either with the communication itself; or in a prominent location on our Website. You will not be allowed to opt-out of formal notices concerning operation of this Website, and legal and other related notices concerning your relationship to the Site and the services provided to you by your request.
- Deleting Information Provided Via Our Site: We will remove the Personal Information you provided to us in connection with your use of this Site from our databases upon your request. Please note that it may not be possible to completely remove this information from our databases, due to backups and records of deletions. You may not remove de-identified, anonymous, or aggregate data from our databases.
Limitations on Deleting Information: Please keep in mind that this Policy applies only to information provided through our Website, and does not apply to “Non-Website Information”, which is information the Wills Service obtains via other channels, such as public databases. Therefore, removal of information from our Website databases in accordance with Section 8.2 (Deleting Information Provided Via Our Website),will not remove Non-Website Information from our databases. We will retain Non-Website Information in our databases, including Personal Information that may relate to our General Visitors, in accordance with applicable law. If you have questions concerning Non-Website Information, you may contact us as provided in Section 12 (Site Administration).
We take reasonable steps to secure and safeguard the security of your personally identifiable information that we collect, including training our employees on the obligations of this policy, and the use of software systems that guard against unauthorized access.
However, no data transmission over the Internet can be guaranteed as completely secure and accordingly we cannot warrant that the security of any information you transmit to us will remain free from loss, misuse, or alteration by third parties who, despite our efforts, obtain unauthorized access. If we detect, despite the safeguards set out above, an intrusion or other unauthorized access to or use of Personal Information, we will notify affected users of the intrusion if the information at issue is sensitive, as determined by law.
- Data Transmitted During Payments
Your visit to our Website may result in the use of our E-Commerce Internet Payment Services. Any credit card or debit card details and related personally identifiable information will not be stored, sold shared, rented or leased to any third parties.
- Children’s Privacy
The Wills Service will not accept or request Personal Information from individuals we know to be under 21 years of age or legally disabled. If we learn that a minor under 21 or a legally disabled person has provided Personal Information, we will delete this information from our databases, in accordance with our deletion procedures, set out in Section 9 (Removing Information; Opting Out).
- Additional information for individuals located in the European Union to whom we offer our services
- Legal basis:
- Our processing of your personal information is necessary:
- for the performance of contracts to which you will be a party to and in order to take steps at your request prior to you entering into those contracts;
- for the purposes of legitimate interests pursued by us; or
- in order to comply with a legal obligation to which we are subject.
- Where our processing is based on the legitimate interest grounds described above, those legitimate interests include: (i) collecting personal information to provide you with smooth and efficient customer experience; (ii) running our business; (iii) to offer and provide the products and services you have requested; (iv) to detect and prevent fraud; and (v) for our own marketing, research and product development.
- Our processing of your personal information is necessary:
- International transfers
- As you are aware we are located in Dubai and as a result, the information that we collect from you may be transferred to, and will be stored at, a destination outside the European Economic Area (“EEA“).
- It will be processed by our staff operating outside the EEA or for one of our suppliers. Such staff may be engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services.
- When we, or our permitted third parties, transfer your information on from Dubai to a jurisdiction outside of the EEA, we or they will impose obligations on the recipients of that data to protect your information to the standard required in the EEA or otherwise require the recipient to subscribe to international frameworks intended to enable secure data sharing. In the case of transfers by us, we will put in place appropriate safeguards to ensure that your information remains adequately protected.
- Rights – you have additional rights in relation to your personal information set out at above at paragraph 8 of this Policy.
- Failure to provide information – the provision of personal data to us is necessary for us to provide our services and failure to do so may result in us being unable to provide the goods or services which you have requested.
- Complaints – If you have any concerns about our use of your information, you also have the right to make a complaint to the data protection regulator in your country.
- Notification of Changes
- Contacting Us
The DIFC Wills Service
Dubai International Financial Centre
Level 3, Precinct Building 5 (South)
The Gate District
Dubai, United Arab Emirates
Phone No. +971 (0) 4 404 4488
- Effective Date and Legal Notice
The original effective date of this Agreement is [●] September 2018