1. The National Central Cooling Company PJSC ("we", "us", "our" and/or "Tabreed") has developed this Privacy Notice ("Notice") to provide you ("you" and/or "your") with important information about how your personal data is collected and processed by us.
2. You may be:
   1. an employee, former employee, intern, secondee or job applicant;
   2. a contractor or consultant hired by us;
   3. a customer or client of ours;
   4. a supplier, service provider, or other third-party representative;
   5. a visitor to our website: www.tabreed.ae ("Website");
   6. a visitor to our premises;
   7. an investor, partner, or attendee at an event which we have attended;
   8. anyone else who has interacted with us through electronic, telephone, or in-person channels.
3. Tabreed is committed to safeguarding the privacy of your personal data in accordance with UAE Federal Decree by Law No. (45) of 2021 Concerning the Protection of Personal Data ("Data Protection Law") and acts as the "Controller" (as defined in the Data Protection Law) when processing your personal data.
4. Please read the following information carefully to understand how we process and handle your personal data.

1. We may collect and process the following personal data:

   1. Personal data you provide to us:

      This may include some or all of the following:

      1. your name and job title;
      2. your personal and/or work contact details including email addresses, telephone numbers, and home and/or work addresses;
      3. payroll and/or other financial details;
      4. health data, if for example, you are an employee of Tabreed;
      5. nationality, and national ID details;
      6. date of birth, age, and gender;
      7. CCTV images and photographs; and
      8. customer, contractual, and/or communication records.

   2. Information we collect about you:

      When you visit our Website, we may automatically collect the following information:

      1. technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, browser type and version, date and time zone details, browser plug-in types and versions, and operating system;
      2. information about your visit; services you viewed or searched for; page response times, download errors, length of visits, page interaction information (such as scrolling, clicks, and mouse-overs); and
      3. other cookie-related and analytics data (also see Section 5 (Cookies and Internet Advertising) below).

1. We may use your personal data for the following purposes, where permitted by applicable law:
   1. Where the processing is necessary for:
      1. the purposes of running our businesses and providing our services to our customers;
      2. processing and responding to enquiries or complaints;
      3. auditing usage of our Website;
      4. reviewing the Website's technical design specifications, and identifying improvements as well as system performance or other problem areas;
      5. administering promotions and events;
      6. sending newsletters and/or other communications related to our relationship with you; and
      7. carrying out business development activities including sending information about promotions and details of events.
   2. For purposes which are required by law:
      1. responding to requests by governmental or law enforcement authorities conducting an investigation; and
      2. complying with any applicable court order or legislation.

1. We may also share your personal data with various third parties including:
   1. other Tabreed group entities and offices within the Middle East (specifically UAE, Bahrain, Oman, and Saudi Arabia) and those in Egypt and India;
   2. certain suppliers and service providers, who provide services to us including:
      1. information technology services, including data hosting and storage providers;
      2. Website maintenance and improvements;
      3. surveys and market research;
      4. couriers and postal services;
      5. advertising and marketing agencies; and
      6. any other services required for our usual business activities;
   3. consultants we have retained in connection with our business activities; and
   4. third-party consultants and professional advisers including external auditors.
2. Moreover, we may disclose your personal data to third parties:
   1. if we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
   2. if Tabreed, its business, or its assets are acquired by a third party, in which case personal data held by it about its users will be one of the transferred assets;
   3. if we are under a duty to disclose or share your personal data in order to comply with a legal obligation, or if we are required to do so by a legal process, or in order to enforce or apply our terms and conditions or other agreements;
   4. if we reasonably consider it necessary, including to protect the rights, property, or safety of Tabreed and its affiliates and employees; or
   5. for the purposes of crime prevention and fraud protection.
3. We may also disclose your personal data to competent law enforcement authorities or other government officials where they have a legally valid reason for their request.

1. We use 'cookies' to improve our Website. Cookies are small text files that are sent to a computer's hard drive by a web server. Cookies enable websites to remember who you are. Information from cookies may include information relating to your use of our Website, information about your computer (such as IP address and browser type), and demographic data.
2. The list below broadly sets out the types of cookies we use. Most internet browsers have a mechanism notifying you when you receive a new cookie and how to reject new cookies or disable them altogether. We use cookies:
   1. to recognize repeat visitors for statistical/analytical purposes;
   2. to customize or personalize your experience of the Website (for example, your user name, language or location). This makes your browsing experience simpler, easier and more personal to you;
   3. to measure the effectiveness of our advertising campaigns and limit the number of times you see an advertisement;
   4. for marketing purposes including communicating promotional information about us, our partners and our Website, through newsletters and re-marketing ads. This is subject to whether you have opted out of receiving such communications.
3. We also use advertising identifiers which are similar to cookies and are found on many mobile devices and tablets. Like cookies, advertising identifiers are used to make online advertising more relevant. Cookies and advertising identifiers use information about your use of this and other websites and apps, and your response to ads and emails, to deliver ads that are more relevant to you. These types of ads are called "internet-based advertising".

1. We use up to date information storage and security to hold your personal data securely in electronic and physical form to protect your personal data from unauthorized access, improper use or disclosure, unauthorized modification or unlawful destruction or accidental loss.
2. Whilst we have put in place physical, electronic, and managerial procedures to secure and safeguard your personal data, we will not be held responsible for any unauthorized access by third parties and we cannot guarantee that the personal data provided by you, or that is transmitted via your use of the Website or by e-mail, is totally secure and safe, and you provide it at your own risk.

1. Your personal data may be transferred to, and stored on, servers and facilities located in the UAE, Bahrain, Oman and Saudi Arabia, as well as in some circumstances to other countries outside of the Middle East including Egypt and India.
2. Some of the recipient countries do not provide the same level of data protection as the country in which you reside, so when we transfer your personal data to those countries, we will transfer and safeguard your personal data, as required under Data Protection Law.
3. We only transfer personal data to other countries subject to appropriate safeguards such as 'Standard Contractual Clauses' (or SCCs) that assure the protection of your personal data.

1. We, or trusted third parties on our behalf, may wish to contact you by email or post with information about our services, products or promotions that might be of interest to you. If we wish to send you marketing communications, you will first be given the opportunity to indicate whether or not you are happy to receive them.
2. You would also be able to withdraw your consent subsequently by clicking on the link (if one is provided) in the relevant email, or by emailing us at: compliance@tabreed.ae
3. You should also note that withdrawal of consent to receive marketing communications will not affect the processing of your personal data more generally.

1. You may have certain rights under Data Protection Law in relation to the processing of your personal data by us. Such rights include the following:
   1. the right to withdraw your consent to our processing of your personal data, although we may be able to continue processing it where we have another lawful basis for doing so;
   2. the right to receive information in relation to our processing of your personal data;
   3. the right to receive a copy of your personal data processed by us in an ordinary machine-readable format, and the right to request transfer of your personal data to an external third party where technically feasible;
   4. the right to request the correction, completion or erasure of your personal data processed by us subject to certain limited exceptions;
   5. the right object to our processing of your personal data and to restrict us from further processing, although again we may continue to do so in some circumstances, where we have another lawful basis for doing so; and
   6. the right to object to decisions resulting from our automated processing of your personal data.
2. If you wish to exercise any of these rights, or obtain more information in relation to your rights, you can make a request by emailing us at: compliance@tabreed.ae

1. We retain personal data in line with our internal Personal Data Retention & Deletion Policy which establishes the principle that personal data should only be retained for the length of time needed to fulfill the purposes for which it was collected, and which are outlined in this Notice. It will then be securely deleted or anonymized when no longer required, unless a longer retention period is required based on:
   1. legal or regulatory requirements;
   2. our reasonable business and operational requirements;
   3. our contractual obligations;
   4. our security requirements; or
   5. ongoing legal claims and investigations.
2. Any personal data processed for marketing purposes will be stored until you exercise the right to withdraw your consent to that marketing, and once such right is exercised, your personal data will be kept only during the applicable statute of limitations period for any disputes or liabilities that may arise as a consequence of the processing of that personal data. Once potential actions are time barred, we will proceed to delete the personal data.
3. All CCTV recordings are retained for no longer than six months.
4. In any other circumstances, we will only retain your personal data for a shorter or longer period as required by any applicable law.

1. This Website may link to other, unaffiliated third-party websites. Please note that Tabreed is not, and cannot, control or be responsible for the content or privacy and confidentiality practices of any third-party websites.
2. You must always carefully review the privacy and confidentiality Notice of any third-party website that you may visit in order to understand how the operators of that website may collect, store and use your personal data.

AUTOMATED DECISIONS AND PROFILING

Automated decision-making takes place when an electronic system processes personal data to make a decision about you without human intervention. We do not envisage that any decisions will be taken about you using automated means, however we will take steps to notify you if this position changes.

Changes to This Privacy Notice

We may from time to time make changes to this Notice. Please check back regularly to keep informed of updates to this Notice. These changes are effective immediately after they are posted on the Website.

Contact Details

If you have any questions about this Notice, or our processing of your personal data, please contact us at: compliance@tabreed.ae