Privacy Policy

About this Privacy Notice

At e&, we are committed to protecting and respecting your privacy. We recognise and value the trust that you place in us when you provide us with your personal data and we aim to protect it in line with applicable data protection laws.

This privacy notice explains how we use the personal data that we may collect from individuals who engage with us at the Etisalat Academy.

In this notice, "academy", “we”, “us” and “our” refers to the Etisalat Academy LLC, which is part of Emirates Telecommunications Group Company PJSC, collectively "e&".

We encourage you to read and understand this Privacy Notice. It will help you understand:

• the personal data we may collect about you during the recruitment process;
• how we may use that personal data.
• when we may share or disclose your personal data with third parties.
• when we may transfer your personal data outside of the jurisdiction where it was collected.
• how long we will retain your personal data.
• your rights concerning your personal data.
• what to do if you have a complaint relating to your personal data and how to contact us.

This Privacy Notice applies to personal data that we collect and process in connection with the services the academy provides:

• When you use our website.
• When you contact us, use our live chat service, or purchase (or are a recipient of) our services.
• When you register for a course via our website, email or another communication channel including via social media.
• When you input your data directly into our Learning Management System (LMS) or another platform, as part of training courses.

The Personal Data We May Collect About You

Your “personal data” means any information, which allows us to identify you directly or indirectly. We may collect and process the following types of personal data, in accordance with applicable laws and regulations:

• Basic Personal Information: name, address, contact details, date of birth and nationality.
• Government-Issued Identification: Emirates ID, passports or other official proof of identification (and the personal data contained in those IDs).
• Financial Information: payment details, credit or debit card data.
• Travel Information: travel booking details.
• Photographic and Video Information: CCTV images and footage, recordings of online trainings.
• Job Related Details: details about your job role, business unit, place of employment, and years of experience.
• Training and Learning Information: records of attendance to our training courses and workshops, and achievement and completion certificates.

Special Categories of Personal Data

We may also process special categories of personal data, where lawful and relevant. This will be limited to the extent necessary for the provision of our services and products and may include: data concerning health, such as, any existing medical conditions, mobility needs or dietary requirements. We will ensure that such data is processed in line with applicable laws and only for specific purposes directly related to our services and products.

Children Personal Data

The information collected in relation to persons under 16 years of age is limited to their name, nationality and date of birth, for registration and attendance of Youth Camps, which can only be supplied to us by an adult (i.e. a parent or guardian).

We would be grateful if you could ensure that your children do not send us any personal data without your consent (particularly via the Internet). If such data is sent, you can contact us to arrange for this information to be deleted (see ‘How to contact us’).

Sources of Personal Data

Data Collected Directly from You

We generally collect personal data directly from you, this may occur when you:

• When you register for a course via our website, email or another communication channel, including via social media.
• When you contact us, use our live chat service, or purchase (or are a recipient of) our services.
• When you input your data directly into our Learning Management System (LMS) or other platform, as part of our training courses.

Data Collected from Other Sources

We may also collect personal data about you from other sources, such as:

• Third Parties (Government Entities & Private Sector Companies):</strong > instances where entities provide information about their employees directly to Etisalat Academy.
• Guardians & Parents: instances where parents or guardians register students for Youth Camps on their behalf.

Where we collect data from external sources, we ensure that this is done lawfully, and we only proceed with your authorisation where required by applicable laws.

How We Use Your Personal Data

We will process your personal data when you engage the Etisalat Academy to register for our learning courses and related services. This may include the following activities:

• Customer Relationship Management (CRM): we process your information in our CRM system to manage our relationship with you, deliver services including in-person and virtual training courses, and keep you updated on our products and developments. For example, we may contact students who registered in previous years' camps to invite them to register for new camps held at Etisalat Academy in the future.
• Learning Management System (LMS): we process individual learner data in our LMS to enable access to online learning, monitor progress, facilitate course completion, provide access to resources, evaluate or score trainees at the end of the training, and issue personalised certificates. In some instances, recordings of online training sessions (e.g. via Zoom or Teams) may be placed on the LMS system for trainees to consult.
• Marketing: we may use your personal data to contact you for marketing purposes, such as, providing information about our products and services, assisting with any questions or inquiries you have submitted, and sending newsletters if you have subscribed to them.
• Email Newsletter Programme: we may process your information to manage our email newsletter programme, which keeps subscribers informed about our products and services. This information may also be used to refine future email campaigns and provide you with more relevant content based on your interests and activity.
• Legal and policy compliance: ensuring compliance with applicable laws and internal policies, including those related to the Etisalat Academy, payment processing and general safety and security operations at our facilities.
• Other lawful purposes: carrying out any other lawful activities reasonably related to the services you are using.

Grounds for Processing Personal Data

By using our services and accessing our website, you consent to us processing your personal data in accordance with the terms of this policy. We may also process your personal data for our legitimate business interests as described above (or the legitimate business interests of any of our group companies), such as, managing our relationship with you and improving our services. Additionally, we may process your personal data to comply with applicable legal and regulatory requirements.

Sharing or Disclosing Your Personal Data

Within Our Group of Companies

We may share your personal data with other members of our group for the purposes as described above. We will take steps to ensure that your personal data is protected and is accessed only by e& employees and authorised third parties that have a legitimate need to access the data for the purposes described in this notice.

With Third Parties Outside Our Group of Companies

We may need to share your personal data with third parties outside of our organisation for various reasons related to the provision of our services and managing our business operations. Third parties that we may share your data with include the following:

• LMS Providers: our training courses may be offered through third-party LMS platforms and vendors with whom we have a contractual relationship.
• Service Providers: companies that provide products and services to us, including IT and software providers (such as, cloud services and communications providers), payment processors, and data storage services.
• Professional Advisors: our accountants, lawyers, and other professional advisors who assist us in business, legal, or contractual matters.

In all cases, we will only share your personal data in accordance with applicable law and with organisations that we have a written agreement with. We have strict internal controls to ensure that only the minimum necessary information is shared with third parties and that it is properly protected.

We may also disclose your personal data to public or government authorities in compliance with our legal obligations.

Cross-Border Transfers

To the extent permitted by applicable data protection law, the personal data that we collect from you may be transferred to, and stored at, a destination outside of the jurisdiction in which it was originally collected (“Relevant Location”). It may also be stored and processed by other companies and/or third parties in other countries.

Where your personal data is transferred outside of the Relevant Location, we aim to ensure that it is protected in a manner that is consistent with how your personal data will be protected by us in the Relevant Location. In all cases, we will ensure that any transfer of your personal data is compliant with applicable data protection law.

You can get more details about the protection given to your personal data when it is transferred outside the Relevant Location by contacting us (see ‘How to contact us’).

How Long We Will Retain Your Personal Data

We will keep your information for as long as it is necessary to fulfil the purposes described in this privacy notice and in accordance with applicable data protection laws and regulations.

For training courses offered to organisations, we will invite customers to renew their service before the contractual expiration date. If the service is not renewed, access to courses and training materials will cease 3 months after the contract expiration date and the relevant organization, learner data, and training history will be permanently deleted from our LMS and CRM systems. However, we may retain key organisation data and contact details in our CRM system for essential updates, with an opt-out option.

For individual learners, we retain your personal data in our LMS systems for 5 years, however, you can request the deletion of your personal data and training history at any time.

Your Rights Concerning Your Personal Data

You have a number of legal rights in relation to your personal data. Depending on where your personal data is located, these rights may include the following:

• Right to a copy of your personal data: you can access or receive a copy of the personal data which we hold about you.
• Right to rectification: you can request that we correct your personal data if it is inaccurate or incomplete.
• Right to erasure: you can request that we erase your personal data in certain circumstances.
• Right to restrict processing: you can request that we restrict the means or manner in which we are processing your personal data in certain circumstances, even though we may continue to store it.
• Right to portability: where technically possible, you can request that we move, copy or transfer your personal data back to you (or to another controller) to reuse it.
• Right against discrimination: you have the right to not be discriminated against by us when exercising your rights.
• Right to object: you can object to the processing of your personal data by us in certain circumstances.
• Right to withdraw consent: you are entitled to withdraw your consent to personal data processing at any time. We may still be entitled to process your personal data if we have another legitimate reason for doing so (for example, we may need to retain personal data to comply with a legal obligation).
• Right to raise a complaint: you can lodge a complaint with the local data protection authority if you have any concerns about how your personal data is being processed.

You can exercise your rights in line with applicable data protection law in the relevant location by contacting us (see ‘How to Contact Us’ section below).

Direct Marketing

We may contact you for marketing purposes if you have consented to receive marketing information, if you have made an enquiry regarding Etisalat Academy services, or if it has been identified that Etisalat Academy services may be of legitimate interest to you. Our direct marketing activities include:

• Providing Information: we may use your personal data to provide you with information about the products and services we offer.
• Answering Queries: we may use your personal data to assist you in answering any questions or queries you may have submitted to us.
• Sending Newsletters: if you have opted in to receiving our newsletters, we will use your personal data to send you these newsletters.

Our marketing emails campaigns may include tracking features that help us understand how you engage with our content. This tracking allows us to collect data, such as, email open rates, link clicks, forwards, access times, dates, and frequency of interaction. This information is used to enhance your experience by refining our email campaigns and delivering more relevant content based on your interests.

We are committed to complying with all our legal obligations whenever we send any marketing to you. You have the right to stop us from contacting you for marketing purposes at any time. If you wish to opt-out of receiving marketing communications from us, you can do so by:

• Clicking the applicable unsubscribe link in our marketing emails.
• Following other instructions provided by us in the marketing communication.
• Contacting us directly through our contact page.

Keeping Your Personal Data Secure

We have appropriate security measures in place to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way. We limit access to your personal data to those who have a legitimate business need to access it. Those who may be processing your personal data will do so only in an authorised manner and are subject to a duty of confidentiality.

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

Cookies

We may (or may ask our partners to) set cookies and other tracking technologies on the device that you use to access our website. Most of the time we do not know who you are from this information, but we may be able to identify you from some of the data collected using these cookies. For example, we may be able to link the information that we collect about you with information provided to us by third parties. We will always use this information in accordance with this notice.

Links to External Websites and Social Media Platforms

Links to Other Websites

If any part of the Etisalat Academy website links you to other websites, please note that those websites are not governed by this Privacy Notice. We recommend reviewing the privacy statements posted on those websites to understand their policies for collecting, using, and disclosing personal information. The Etisalat Academy is not responsible for the content, privacy practices, or security of any external sites.

Social Media Usage

Etisalat Academy may engage with social media platforms in line with their privacy terms. We advise you to exercise caution when sharing personal information on these platforms. For sensitive or confidential matters, please contact us via secure channels, such as, email or phone or via the contact details in the ‘How to contact us’ section.

Sharing Features and Shortened Links

We also share web links through our social media pages, which may sometimes be shortened for convenience. While we take precautions to ensure the integrity of these links, it is important to note that shortened URLs or displayed URLs can potentially be altered without our knowledge, redirecting you to unintended sites. We cannot take responsibility if you are redirected to an incorrect site.

What to Do If You Have a Complaint Relating to Your Personal Data

You can contact us (see ‘How to contact us’) if you have any concerns about how we have handled your personal data. If you are not satisfied with the manner in which we have dealt with your complaint, you may contact the relevant data protection authority in your jurisdiction.

How to Contact Us

If you would like further information on the collection, use, disclosure, transfer or processing of your personal data or the exercise of any of the rights listed above, please contact the e& Group Data Protection Officer at groupdataprotection@eand.com.

Changes to this Privacy Notice

Please review this Privacy Notice at regular interval as we may update it from time to time at our discretion. If we intend to use your previously collected personal data for a new purpose that is incompatible with the purposes described in this Privacy Notice or at the time of collection, we will provide you with additional notice and, where legally required, seek your consent.