1. Introduction

At EXCELLENCE, we are committed to safeguarding personal data in compliance with all relevant UAE laws and regulations, including the UAE Cyber Crimes Law, UAE Penal Code, UAE Federal Law No. 2 of 2019 (Data Protection Law), and other applicable legal frameworks. This policy outlines how we manage, process, and protect personal data, ensuring full compliance with legal obligations while maintaining the highest standards of privacy and security.

2. Purpose

The purpose of this policy is to ensure that all personal data we collect, process, store, and transfer is handled in accordance with the legal and regulatory requirements set forth by UAE laws and international standards. We aim to maintain transparency, security, and trust with all individuals whose personal data we handle.

3. Scope

This policy applies to all individuals within the EXCELLENCE, including employees (meaning permanent, fixed term, and temporary staff, any third-party representatives or sub-contractors, agency workers, volunteers, interns and agents engaged with the Company in the UAE or overseas)consultants, contractors, third-party service providers, shareholders and any other stakeholders engaged in processing personal data, both within the UAE and abroad. All individuals must comply with the provisions outlined in this policy.

4. Legal Framework

This policy is based on and compliant with the following UAE laws and regulations:

In addition, we ensure that our practices meet international best standards, including the General Data Protection Regulation (GDPR) where or if applicable.

5. Key Principles of Data Protection

EXCELLENCE adheres to the following key principles in all data processing activities:

6. Data Collection and Processing

We collect personal data in a lawful and transparent manner, including but not limited to:

Personal data is only collected for legitimate business purposes, such as providing services, complying with contractual obligations, or fulfilling legal requirements. We do not collect sensitive data unless it is required by law or consented to by the data subject.

7. Data Protection Measures

We implement strong data protection measures to ensure personal data is protected against unauthorized access, destruction, or misuse, in compliance with UAE legal standards:

8. Rights of Data Subjects

Under the UAE Data Protection Law and relevant regulations, individuals have the following rights concerning their personal data:

9. Data Protection Governance

10. Data Retention

Personal data is stored only for the period necessary to fulfil the purposes for which it was collected or to meet legal obligations. After the retention period, personal data is securely deleted or anonymized in accordance with our data retention policy.

11. Data Transfers and International Data Protection

When personal data is transferred outside the UAE, we ensure compliance with applicable UAE laws and implement appropriate safeguards to protect personal data, such as the use of Standard Contractual Clauses (SCCs) for international transfers (if applicable).

12. Incident Response and Data Breach Management

In accordance with the UAE Cyber Crimes Law and UAE Data Protection Law, we have a dedicated breach notification process in place. In the event of a data breach:

13. Employee Training, Awareness & Third-Party Obligations

All employees and third-party vendors who handle personal data are required to comply with this policy. Non-compliance can result in disciplinary action, termination of contracts, or legal consequences in accordance with UAE laws.

14. Disciplinary Consequences

Violations of this policy may result in severe consequences, including termination of employment or contracts and legal action in accordance with the UAE Penal Code and other relevant legislation. Fines of up to AED 1 million and imprisonment of up to 1 year may apply in case of data protection violations, as outlined in the UAE Cyber Crimes Law.

15. Continuous Improvement

We are committed to the continuous improvement of our data protection practices. Our policy is reviewed regularly to reflect updates in UAE legislation, industry standards, and emerging risks.

16. Conclusion

EXCELLENCE is committed to maintaining the highest standards of data security and privacy, fully complying with UAE laws and international data protection standards. This policy ensures the safety of personal data and demonstrates our commitment to trust, security, and legal compliance.