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PRIVACY POLICY

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We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities if you have a complaint. 

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This privacy policy does not apply to any third party websites that may have links to our own website.

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Clients of Jodha Legal should read this policy alongside our general terms and conditions, which provide further information on confidentiality.

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Who are we and what do we do?

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Jodha Legal FZ LLE (Jodha Legal) is an alternate legal service provider which provides General Counsel and Legal Consultancy services to its clients. We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UAE Data Protection laws. 

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Key terms

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It would be helpful to start by explaining some key terms used in this policy:

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We, us, our: Jodha Legal FZLLE or Jodha Legal, incorporated in Creative City Fujairah with registration number 18542/2023, having its registered office at Office 2002, 20th Floor, Creative Tower, Fujairah.

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Personal data: Any information relating to an identified or identifiable individual

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Special category personal data: 

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• Personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership

• Genetic data: Biometric data (where used for identification purposes)

• Data concerning health, sex life or sexual orientation

 

Data subject: The individual who the personal data relates to

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Personal data we collect about you

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Following are the personal data we will or may collect in the course of providing services to you:

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• Your name, address, email address, mobile number and telephone number, and if you are a corporate client, those of your employees

• Information to enable us to check and verify your identity, eg your date of birth or passport details

• Information relating to the matter in which you are seeking our advice or in relation to which we provide our services

• Information to enable us to undertake a credit or other financial checks on you

• Your financial details so far as relevant to your instructions, eg the source of your funds 

• Information about your use of our IT, communication and other systems, and other monitoring information

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We collect and use this personal data to provide services to you. If you do not provide personal data we ask for, it may delay or prevent us from providing those services.

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How your personal data is collected

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We collect most of the above information from you. However, we may also collect information:

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• from publicly accessible sources;

• directly from a third party, eg:

  • sanctions screening providers;

  • credit reference agencies;

  •  client due diligence providers;

• from a third party with your consent, eg:

  • your bank or building society, another financial institution or advisor;

  • your employer and/or trade union, professional body or pension administrators;

  • your doctors, medical and occupational health professionals.

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How and why we use personal data

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Under data protection law, we can only use your personal data if we have a proper reason, eg:

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• you have given consent—where we need your consent, we will ask for it separately of this privacy policy and you can withdraw consent at any time;

• to comply with our legal and regulatory obligations;

• to fulfil our contract with you or take steps at your request before entering into a contract; or

• for our legitimate interests or those of a third party.

 

A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests.

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What we use your personal data for and why is explained below:

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Providing services to you 

To fulfil our contract with you or to take steps at your request before entering into a contract

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Preventing and detecting fraud against you or us 

For our legitimate interest, ie to minimise fraud that could be damaging for you and/or us

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Conducting checks to identify our clients and verify their identity and/or 

Screening for financial and other sanctions or embargoes and/or 

Other activities necessary to comply with professional, legal and regulatory obligations that apply to our business, eg under health and safety law 

Depending on the circumstances:

—to comply with our legal and regulatory obligations

—for our legitimate interests

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To enforce legal rights or defend or undertake legal proceedings 

Depending on the circumstances:

—to comply with our legal and regulatory obligations

—for our legitimate interests, ie to protect our business, interests and rights

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Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies

To comply with our legal and regulatory obligations

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Ensuring internal business policies are complied with, eg policies covering security and internet use

For our legitimate interests, ie to make sure we are following our own internal procedures so we can deliver the best service to you

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Operational reasons, such as improving efficiency, training and quality control

For our legitimate interests, ie to be as efficient as we can so we can deliver the best service to you at the best price

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Ensuring the confidentiality of commercially sensitive information

Depending on the circumstances:

—for our legitimate interests, ie to protect trade secrets and other commercially valuable information

—to comply with our legal and regulatory obligations

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Statistical analysis to help us manage our business, eg in relation to our financial performance, client base, services range or other efficiency measures 

For our legitimate interests, ie to be as efficient as we can so we can deliver the best service to you at the best price

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Protecting the security of systems and data used to provide services, preventing unauthorised access and changes to our systems

Depending on the circumstances:

—for our legitimate interests, ie to prevent and detect criminal activity that could be damaging for you and/or us

—to comply with our legal and regulatory obligations

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Updating client records

Depending on the circumstances:

—to fulfil our contract with you or to take steps at your request before entering into a contract

—to comply with our legal and regulatory obligations

—for our legitimate interests, eg making sure we can keep in touch with our clients about existing and new services

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Statutory returns

To comply with our legal and regulatory obligations

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Ensuring safe working practices, staff administration and assessments

Depending on the circumstances:

—to comply with our legal and regulatory obligations

—for our legitimate interests, eg to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you

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Marketing our services to existing and former clients and third parties

Depending on the circumstances:

—for our legitimate interests, ie to promote our business

—consent

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Credit reference checks via external credit reference agencies

For our legitimate interests, ie to ensure our clients are likely to be able to pay for our services

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To share your personal data with members of our group and third parties that will or may take control or ownership of some or all of our business (and professional advisors acting on our or their behalf) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale or in the event of our insolvency

Depending on the circumstances:

—to comply with our legal and regulatory obligations

—in other cases, for our legitimate interests, ie to protect, realise or grow the value in our business and assets

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Where we process special category personal data (see above ‘Key terms’), we will also ensure we are permitted to do so under data protection laws, eg:

• we have your explicit consent;

• the processing is necessary to protect your (or someone else’s) vital interests where you are physically or legally incapable of giving consent 

• the processing is necessary to establish, exercise or defend legal claims; or

• the processing is necessary for reasons of substantial public interest

 

Who we share your personal data with

 

We routinely share personal data with:

• companies within Jodha Legal’s group

• third parties we use to help deliver our services to you, eg providers of our case management and finance system, IT service providers including cloud service providers such as data storage platforms, shared service centres and financial institutions in connection with invoicing and payments

• third party external advisors or experts engaged in the course of providing services to you, eg insert, eg barristers, lawyers, tax advisors, local counsel and technology service providers such as eDiscovery and document review platforms

• companies providing services for money laundering checks and other crime prevention purposes and companies providing similar services, including financial institutions and credit reference agencies 

• our insurers and brokers;

• our banks.

 

We only allow those persons to handle your personal data if we are satisfied they take appropriate measures to protect your personal data.

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We or the third parties mentioned above occasionally also share personal data with:

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• our and their external auditors, eg in relation to the audit of our or their accounts, in which case the recipient of the information will be bound by confidentiality obligations

•  our and their professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations

• law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations

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If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).

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Where your personal data is held

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Personal data may be held at our offices and those of our group companies, third party agencies, service providers, representatives and agents as described above (see ‘Who we share your personal data with’).

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Some of these third parties may be based outside the UK. For more information, including on how we safeguard your personal data when this occurs, see below: ‘Transferring your personal data abroad’.

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How long your personal data will be kept

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We will not keep your personal data for longer than we need it for the purpose for which it was collected or as required by law. 

As a general rule, we will keep your personal data for at least seven years from the conclusion of your matter, in case you, or we, need to bring or defend any complaints or claims. 

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Following the end of the relevant retention period, we will delete or anonymise your personal data.

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Transferring your personal data abroad

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It is sometimes necessary for us to transfer your personal data to countries outside the UK. This may include countries which do not provide the same level of protection of personal data as the United Arab Emirates.

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We will transfer your personal data outside the United Arab Emirates only where:

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• the UAE government has decided the recipient country ensures an adequate level of protection of personal data (known as an adequacy decision); or

• there are appropriate safeguards in place (eg standard contractual data protection clauses published or approved by the relevant data protection regulator), together with enforceable rights and effective legal remedies for you; or

• a specific exception applies under data protection law.

• You can contact us (see ‘How to contact us’ below) if you would like a list of countries benefiting from a UK or European adequacy decision or for any other information about protection of personal data when it is transferred abroad.

 

Your rights

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You have the following rights, which you can exercise free of charge:

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Access

The right to be provided with a copy of your personal data 

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Rectification

The right to require us to correct any mistakes in your personal data

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Erasure (also known as the right to be forgotten)

The right to require us to delete your personal data—in certain situations

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Restriction of processing

The right to require us to restrict processing of your personal data—in certain situations, eg if you contest the accuracy of the data

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Data portability

The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations

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To object

The right to object:

• at any time to your personal data being processed for direct marketing (including profiling);

• in certain other situations to our continued processing of your personal data, eg processing carried out for the purpose of our legitimate interests unless there are compelling legitimate grounds for the processing to continue or the processing is required for the establishment, exercise or defence of legal claims.

 

Not to be subject to automated individual decision making

The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

 

The right to withdraw consent

If you have provided us with a consent to use your personal data you have a right to withdraw that consent easily at any time

 

You may withdraw consents by sending an email to us at info@jodhalegal.com

 

Withdrawing a consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn

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If you would like to exercise any of those rights, please:

• email, call or write to us—see below: ‘How to contact us’; and

• provide enough information to identify yourself and any additional identity information we may reasonably request from you;

• let us know what right you want to exercise and the information to which your request relates.

 

Keeping your personal data secure

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We have implemented appropriate technical and organisational measures to keep your personal data confidential and secure from unauthorised access, use and disclosure. We limit access to your personal data to those who have a genuine business need to access it. Those processing your personal data will do so only in an authorised manner and are subject to a duty of confidentiality. 

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We require our business partners, suppliers and other third parties to implement appropriate security measures to protect personal data from unauthorised access, use and disclosure.

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We also have procedures to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are required to do so.

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How to complain

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Please contact us if you have any queries or concerns about our use of your personal data (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.

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You may also have the right to lodge a complaint with the Information Commissioner (the UK data protection regulator). Please contact us if you would like further information.

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Changes to this privacy policy

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We may change this privacy policy from time to time. When we do we will publish the updated version on our website and ask for your consent to the changes if legally required.

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Updating your personal data

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We take reasonable steps to ensure your personal data remains accurate and up to date. To help us with this, please let us know if any of the personal data you have provided to us has changed, eg your surname or address—see below ‘How to contact us’.

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How to contact us

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You can contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.

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Our contact details are shown below:

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Jodha Legal FZ LLE

Suite 2, Unit 1801, 18th Floor

Burlington Tower, Business Bay

Dubai, United Arab Emirates

E-mail: info@jodhalegal.com