Data Privacy Notice
AG Used Cars By Al Ghurair, AG Used Cars, an AG Auto Trading LLC Company we take your privacy seriously. This Data Privacy Notice contains information on what Personal Data we and other our Group companies collect, what they do with that information, and what rights you have. This Data Privacy Notice has been prepared with reference to DIFC Data Protection Law considerations and will be augmented by jurisdictional specific addendums from time to time.
We are committed to safeguarding the privacy of the personal information that we process in the course of our business, including the personal information we receive from you. This Data Privacy Notice describes how and why we collect, store and use personal information, and provides information about the rights of the individuals to whom such personal information relates.
For the purposes of applicable data protection law, AG Auto Trading LLC is typically the “data controller” of any personal information provided to us. Specifically, your data will be controlled by the AG Auto Trading LLC that you have instructed, or that is providing services to or communicating with you. Very occasionally, we will act on specific retainers as a “processor” (meaning that we process Personal Data only in accordance with the directions of a data controller, or as otherwise permitted by law).
Please read the following information carefully to understand our views and practices regarding how we handle personal information. If you have any queries about our approach to data protection that are not already addressed in this Data Privacy Notice, please contact our Data Protection Officer, as per the contact details set out at the end of this Data Privacy Notice.
1. Scope and Application
This Policy applies to persons anywhere in the world who has an access or uses the AG Auto Trading LLC websites or related apps.
2. Collection of Personal Data
We may collect personal information from you in electronic and/or physical way in the course of our business, when you contact us or request information from us, when you use our website or mobile app (or other platforms), or as a result of your relationship with any of our personnel or clients.
The personal information that we process (“Personal Data”) includes:
- basic details, such as your name, and your contact information (such as your email address, contact numbers);
- bank account or other financial information, if relevant to our engagement with you.
- technical information (including your location, IP address, browser details, traffic data, location data), such as information from your visits to our website or mobile app (page interaction information, length of visits, etc.), or in relation to marketing emails we send to you.
- information relating to your visits to our offices or our meetings and events, including appointment details (e.g., time, location, participants) or photographic and video images.
- any other information relating to you which you may provide to us.
We may use or process your personal information for the following purposes:
- as part of our new business intake and client on-boarding or client maintenance activities.
- when we are acting on a matter where you or your employer are a party to the same.
- when you interact with our website or mobile app or use any of our online services.
- when you interact with us in respect of any of our marketing communications or events.
We collect most of this information directly from you, or through your use of our website. However, we may also collect data about you from a third-party source, such as our clients, your employer, other parties to matters in which we are involved, other organisations that you have dealings with, regulators or other government authorities, information service providers, or from publicly available records.
The information you provide may be confidential, and we will maintain such confidentiality and protect your information in accordance with our professional obligations and applicable law.
3. Use of Personal Data
Whether we receive your Personal Data directly from you or from a third party, we will only use your personal information if we have obtained your consent, or if we have another lawful basis upon which to do so.
Depending on the purpose of the processing activity, the legal basis for the processing of your Personal Data will be one of the following:
- necessary to perform our contractual obligations towards you or to take pre-contractual steps at your request.
- necessary to meet our legal or regulatory obligations.
- necessary in the public interest.
- necessary to protect the vital interests of the relevant individual or of another natural person, such as providing disability access to places of work where applicable.
- necessary for the legitimate interests of AG Auto Trading LLC, without unduly affecting your interests or fundamental rights and freedoms and to the extent such Personal Data is strictly necessary for the intended purpose; or
- in some cases, and as may be requested from you from time to time, we have obtained prior consent (for instance where required by law) or processed with your explicit consent in the case of special category of Personal Data (i.e., your medical information).
We always process your Personal Data for a specific purpose and only process the Personal Data which is relevant to achieve that purpose. The purposes for which we process your personal information are as follows:
- processing your orders; and managing the accounts you hold with us.
This is so we can provide the services to you in line with our contractual obligations to you.
We may use your personal information to personalise the marketing messages we send to you and to make them more relevant and interesting, as this is in our legitimate business interests. Where necessary we will obtain your consent first. We may use your personal information for this purpose in the following ways:
- using your online browsing behaviour to help us better understand you as a customer and provide you with personalized offers and services.
- providing you with relevant marketing communications (including by email, post, telephone, SMS, or online advertising), relating to products and services we offer, and those of our suppliers and partners.
- to help us to better understand you and provide you with services and marketing communications, that are relevant to your interests, we combine personal information we collect with personal information collected from our websites, mobile apps and other sources.
4. Sharing of Personal Data
We may share Personal Data with other Al Ghurair Investment Group companies for the purposes indicated in section 3 to ensure a consistently high service standard across our group and to provide services and products to you.
We may disclosure your Personal Data to third parties only:
- where you have given your consent,
- where we are required to do so by law, or
- where it is necessary for the purpose of or in connection with legal proceedings or in order to exercise or defend legal rights.
We do not sell, rent, distribute, or otherwise make, personal information commercially available to any third party. Where we transfer your data to third parties, we take steps to ensure they meet our data security standards, so thar your Personal Data remains secure.
5. Transfer of your Personal Data
The information you submit will be processed internally and stored on servers based in the United Arab Emirates. It is not transferred outside the United Arab Emirates in the usual course of our business.
In the event your personal information is transferred to a foreign jurisdiction, it may be subject to the laws of that jurisdiction, and we may be required to disclose it to the courts, law enforcement or governmental authorities in those jurisdictions but we will only do so where required by applicable laws. We will implement appropriate measures to ensure that your personal information remains protected and secure when it is transferred outside the United Arab Emirates.
6. Your data protection rights
Various rights may be available to you, depending on the circumstances and the applicable law. We summarise key rights likely to be available to most data subjects:
- Withdraw consent: When personal information is processed on the basis of consent, you may withdraw consent at any time, although such withdrawal will not affect the lawfulness of processing occurring prior to such withdrawal.
- Access and rectification, etc.: You may request access to and rectification or erasure of personal information, or restriction of processing concerning the data subject or to object to processing as well as the right to data portability.
- Objecting and restricting: You may object, on legitimate grounds, to the processing of your personal information, or request that processing be restricted; and
- Complaints: If you believe that your data protection rights may have been breached, you may lodge a complaint with the relevant data protection authority (e.g., the Commissioner of Data Protection in the case of the DIFC).
- would like to discuss or exercise above-mentioned rights.
- would like to see or access the personal information we hold about you.
- concerned that any of the information we hold about you is incorrect, or out of date, please write to the address stated at the end of this Data Privacy Notice to report your concerns and we will take appropriate steps to fulfil your request
7. Data retention
We will retain your personal information for the length of time needed to fulfil the purposes for which it was collected, unless we specifically agree a longer retention period with you, or a longer retention period is required or permitted by law.
8. How we protect your Personal Data
We have implemented reasonable administrative, technical, and physical measures to protect your personal information against loss, misuse and alteration. However, no internet-based site can be 100% secure and we cannot be held responsible for unauthorised or unintended access that is beyond our control.
We only set a few cookies ourselves, but when we include content from other websites, they also get the opportunity to set cookies, to help them serve their content better. We cannot guarantee that we will have listed every cookie you might get from a third party, as they can change them at any time as their needs change.
The main types and categories of cookies used by our Site are set out below.
Types of cookies:
- Session cookies: these cookies remain in your browser during your browser session only, i.e., until you leave the website.
- Persistent cookies: these cookies remain in your browser for a set period of time after the browser session (unless deleted by you).
Categories of cookies:
- Strictly Necessary Cookies: These cookies are fundamental to website functionality and cannot be switched off without blocking features on the website. They are usually set in response to your actions on the Site, such as filling in forms, setting preferences, or recognize the user as valid and authenticated while accessing protected areas of the website.
- Analytics cookies: we collect information about how you use our website including details such as the website that referred you (e.g. search engines, marketing campaigns, referring domains), the content you viewed, the website path you navigated and the links that you clicked on. This is in order to understand your interests on our Site and the number of times you visit our Site. We use this information to improve our Site and enhance visitor experience. We share this information with analytics and search engine providers that assist us in improving and optimising our website.
- Preference cookies: we use preference cookies also known as “functionality cookies,” to allow our website to remember the choices you have made in the past (such as your username, language or the region you are in) and provide you with an enhanced more personalised experience.
- Advertising cookies: we may present ads to you on websites that are not owned or operated by AG Auto Trading LLC to promote our services. The cookies are used to make advertising messages more relevant to you and your interests. They also perform functions like preventing the same ad from continuously re-appearing. These advertisements are solely intended to make you aware of relevant AG Auto Trading LLC promotions. We do not sell your data to any third parties.
Once you have given us your consent to the use any categories of cookies, we shall store cookies on your computer or device. If you wish to withdraw your consent at any time, you will need to delete our cookies using your internet browser settings.
10. Changes to the Data Privacy Notice
11. Contact Details
If you have any concerns about our compliance with applicable privacy laws or this Data Privacy Notice, please use the contact details below:
- Data Protection Officer (Group Risk Assurance Services Department)
- Al Ghurair Investment – Corporate Office
- United Arab Emirates, Dubai
- Post Box No. 5326
- e-mail: DataProtection.Officer@al-ghurair.com
We will endeavour to respond to your concerns as soon as possible.