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Privacy Policy

Privacy Policy

1. Introduction

This data privacy policy (hereinafter the “Policy”) sets out how INP (defined below) collects, uses, stores, and protects your personal data as well as any rights you may have in relation to your data.

The Policy is provided in a layered format so you can navigate to the specific areas set out below.

The Policy has been developed with reference to applicable data protection laws including the Abu Dhabi Global Market (“ADGM”) Data Protection Regulations 2021 (“DPR”) and the Federal Decree by Law No. (45) of 2021 Concerning the Protection of Personal Data, and may be supplemented from time to time by jurisdiction-specific addenda.

Under applicable data protection laws, INP generally acts as a “data controller” of your personal data. Your data is controlled by the relevant INP entity you engage with or that provides services to you. In limited cases, we may act as a “data processor,” processing personal information only on the instructions of a data controller or as permitted by law.

Please review this Policy carefully to understand how we handle personal data. If you have any questions not addressed here, you may contact us using the details at the end of this notice.

Note: This website and our services are not intended for children, and we do not knowingly collect data relating to children.

2. Types of Personal Data We Collect

Personal data means any information about an individual from which that person can be identified.

Depending on the nature of your interactions with us, we collect, use, store and transfer different kinds of personal data which we have grouped together as follows:

Category Description
Identity Data First name, last name, any previous names, username or similar identifier, marital status, title, date of birth, passport or ID numbers, photographs, place of birth, and gender, and other demographic information.
Contact Data Billing address, delivery address, email address, and telephone numbers, and details of publicly available social media profiles.
Financial Data Bank account details, payment card information, retainer or fee arrangements, and other financial information relevant to our engagement with you.
KYC Data Bank statements, ownership percentages, utility bills, salary certificates, visa pages, and employment letters, and other documents required for verification and compliance purposes.
Technical & Usage Data IP address, login information, browser type and version, operating system and platform, device identifiers, time zone, plug-ins, and information about how you use our website, products, and services.
Profile Data Username and password, your interests and preferences, feedback, and survey responses.
Marketing & Communications Data Your preferences for receiving marketing from us and third parties, and your communication preferences.
Client-Provided or Generated Data Personal information provided to us by or on behalf of clients, or generated by us in the course of providing services, which may include special categories of personal data.
Professional & Educational Data Current or former employers, job titles, qualifications, and related information.
Preferences Stated interests, newsletter or communication preferences, and other personal choices you share with us.

We may also collect, use, and share aggregated or anonymized data, such as statistical or demographic information that does not identify any individual. For example, we may analyze trends in how visitors use our website, interact with our services, or engage with our communications. This helps us improve our website, enhance our services, and better meet the needs of our clients, while ensuring your personal information remains confidential.

3. How We Collect Your Personal Data

We collect your personal data in several ways, depending on your interactions with INP and the services you use:

DIRECTLY FROM YOU — Most of the personal data we process is provided directly by you when you:

  • Engage our legal services or seek advice.
  • Register on our website, subscribe to newsletters, or use our online services.
  • Attend our events, seminars, or meetings, or visit our offices.
  • Apply for a role, work experience, or participate in alumni or recruitment programs.
  • Provide services to us, either personally or on behalf of your employer.

FROM THIRD PARTIES — We may also receive your personal data from:

  • Our clients, your employer, or your representatives.
  • Other law firms, professional advisers, or parties involved in matters where we act.
  • Recruitment agencies, technology platform providers (e.g., webinar or event platforms), or other service providers.
  • Regulators, government authorities, or credit reporting agencies.
  • Publicly available sources or registers.

AUTOMATICALLY THROUGH OUR SERVICES — We may collect Technical and Usage data when you visit or interact with our website, mobile applications, digital communications, or online services.

We take care to ensure that all data collected from third parties is lawfully obtained, and we maintain confidentiality in accordance with our professional obligations and applicable law. All personal information you provide to us is treated as confidential. We have appropriate contractual and operational arrangements with our personnel and service providers to ensure that your information is protected and used only for legitimate purposes.

4. How We Use Your Personal Data

We use your personal data for purposes that are necessary to provide our legal services, manage our business, and comply with legal and regulatory obligations. This includes, but is not limited to, the following:

PROVISION OF LEGAL SERVICES — To provide legal advice, representation, and other services you request, and to manage and administer your matters efficiently.

COMMUNICATION — To respond to your enquiries, send updates about your matters, provide administrative information, and maintain ongoing communications regarding our services.

REGULATORY COMPLIANCE & RISK MANAGEMENT — To perform due diligence, anti-money laundering checks, sanctions screening, and other compliance obligations, and to protect INP’s legal rights and interests.

OPERATIONAL PURPOSES — To administer and manage our internal business operations, including billing, accounting, IT systems, reporting, and management of personnel.

MARKETING & CLIENT ENGAGEMENT — To send you information about our services, events, publications, or other offerings, where you have consented or where permitted by law.

IMPROVEMENT OF SERVICES — To analyze anonymized or aggregated data to understand usage trends, improve our website, enhance our services, and better meet client needs.

LEGAL PROTECTION — To protect and enforce our legal rights, manage disputes, or investigate potential misconduct or fraud.

All processing of personal data is based on one or more lawful bases, which may include: contractual necessity, compliance with legal obligations, INP’s legitimate interests, or your consent where required.

We will not use your personal data for purposes incompatible with the purposes for which it was collected, and we will always ensure that any use is proportionate, necessary, and compliant with applicable law.

5. Disclosure of Your Personal Data

We may share your personal data with certain third parties where necessary for the purposes set out in this Policy, including:

SERVICE PROVIDERS & ADVISERS — Professional advisers, external lawyers, auditors, IT service providers, and other consultants who provide services to INP and need access to personal data to perform their duties.

CLIENTS OR COUNTERPARTIES — Where necessary for the provision of legal services, including sharing information with clients, opposing parties, or other parties involved in a matter.

REGULATORS & GOVERNMENT AUTHORITIES — To comply with applicable laws, regulations, court orders, or regulatory requirements, including anti-money laundering, sanctions, tax, or other legal obligations.

BUSINESS TRANSFERS — In the event of a reorganization, merger, sale, or transfer of all or part of our business, personal data may be transferred to the relevant third party.

MARKETING & COMMUNICATIONS PARTNERS — Where you have consented, to allow third parties to assist us in providing newsletters, events, publications, or other client engagement communications.

We only disclose personal data on a strictly need-to-know basis and ensure that recipients maintain appropriate safeguards to protect your information. We do not sell your personal data to third parties. Any sharing of your personal data is done in accordance with this Policy, applicable law, and our professional obligations.

6. Data Transfers

Internal

As part of providing our legal services, your personal data may be transferred to, and stored or processed in, jurisdictions across the UAE and in Egypt. This may occur, for example, when we share information between INP’s offices in the UAE.

External

There may also be circumstances where we share your personal data externally and outside of INP and the UAE to:

  • Professional advisers, service providers, or other entities located in other jurisdictions; or
  • Courts, regulators, or other authorities located outside the UAE in relation to a legal matter.

Whenever we transfer your personal data internationally, we ensure that appropriate safeguards are in place to protect your information and that the transfer complies with applicable data protection laws. Such safeguards may include:

  • Personal data transfers from our ADGM entity to countries that the DPR consider to provide an adequate level of protection;
  • Using contractual clauses approved by the ADGM to ensure your personal data is protected when required for personal data transfers from our ADGM entity;
  • Ensuring we have a lawful basis for each transfer of your personal data such as your explicit and lawful consent; or
  • Any other appropriate measures to ensure the confidentiality, integrity, and security of your personal data.

We will take all reasonable steps to ensure that your personal data is treated securely and in accordance with this Policy, regardless of where it is processed.

7. Data Security

We take the security of your personal data very seriously and have implemented appropriate technical, organizational, and administrative measures to protect it against unauthorized or unlawful access, use, disclosure, alteration, or destruction. Some examples of these measures are:

PERSONNEL TRAINING — Ensuring that all personnel are trained in data protection principles and understand their obligations to maintain confidentiality.

CONTRACTUAL SAFEGUARDS — Ensuring that any third-party service providers or advisers who process personal data on our behalf maintain appropriate security measures in accordance with applicable law and this Policy.

Despite these measures, no method of transmission over the internet or electronic storage is completely secure. While we strive to protect your personal data, we cannot guarantee absolute security. In the event of a data breach affecting your personal information, we will take prompt action in accordance with applicable laws and our internal procedures.

8. Data Retention

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required to comply with legal, regulatory, or professional obligations. The retention period may vary depending on the type of data and the purpose for which it is processed, including:

CLIENT MATTERS — Personal data related to your engagement with INP will generally be retained for the duration of the matter and for a period thereafter as required to meet our legal, regulatory, and professional obligations, or to resolve any disputes.

EMPLOYMENT & RECRUITMENT — Data relating to employees, job applicants, or alumni will be retained for the duration of the employment or engagement and for a reasonable period thereafter in accordance with applicable law.

MARKETING & COMMUNICATIONS — Personal data used for marketing purposes will be retained until you opt out or withdraw your consent.

LEGAL & REGULATORY COMPLIANCE — Data may be retained for longer periods where required to comply with statutory obligations, professional guidelines, or to protect INP’s legal rights.

Once personal data is no longer required, we take reasonable steps to securely delete, anonymize, or destroy it, in accordance with industry standards and applicable law.

9. Your Rights

The rights available to you in relation to your personal data will vary based on the relevant legal framework and circumstances. Generally, these rights are likely to include:

RIGHT OF ACCESS — You may request access to your personal data (commonly known as a “subject access request”) to receive a copy of the data we hold about you and to check that it is being processed lawfully.

RIGHT TO CORRECTION — You may request that we correct or update any inaccurate or incomplete personal data we hold about you. We may need to verify the accuracy of the information you provide.

RIGHT TO ERASURE — In certain circumstances, you may request that we delete or remove your personal data. This includes cases where there is no longer a lawful reason to process it, where you have successfully exercised your right to object, where we have processed your information unlawfully, or where we are required to comply with local law. Note that we may not always be able to comply with a request for erasure for specific legal reasons, which we will notify you of at the time.

RIGHT TO OBJECT — You may object to the processing of your personal data where we rely on a legitimate interest (including profiling) as the legal basis for processing. You also have an absolute right to object at any time to processing for direct marketing purposes. In some cases, we may demonstrate compelling legitimate grounds to continue processing which override your objection.

RIGHT TO RESTRICT PROCESSING — You may request that we suspend processing of your personal data in certain scenarios, including:

  • To verify the accuracy of the data;
  • Where processing is unlawful but you do not want it erased;
  • Where the data is required to establish, exercise, or defend legal claims; or
  • Where you have objected to processing and we need to verify if our legitimate grounds override your objection.

RIGHT TO DATA PORTABILITY — Where applicable, you may request that your personal data be provided to you or a third party in a structured, commonly used, and machine-readable format. This right applies to automated information you provided consent for or that we process to perform a contract with you.

RIGHT TO WITHDRAW CONSENT — Where we rely on consent to process your personal data, you may withdraw it at any time. This will not affect the lawfulness of processing carried out before withdrawal. Withdrawal of consent may affect our ability to provide certain services, and we will inform you if this is the case.

RIGHT TO MAKE A COMPLAINT — You may have the right to make a complaint at any time to the relevant data protection authority (such as the ADGM Commissioner of Data Protection or the UAE Data Bureau) if you believe any of your rights in relation to your personal data have been violated. We would, however, appreciate the chance to deal with your concerns, so please contact us in the first instance if you are able.

Please note the exercise of these rights is subject to the applicable laws governing the relevant INP entity responsible for processing your personal data.

To exercise any of these rights, please contact us at [email protected].

You will not usually have to pay a fee to access your personal data or to exercise any of your other rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. In such cases, we may also refuse to comply with your request.

10. Contact Details

If you have any questions about this privacy policy or about the use of your personal data or you want to exercise your privacy rights, please contact us at [email protected].

11. Cookies

We use cookies and similar tracking technologies (“cookies”) on our website to ensure its proper functioning, enhance your browsing experience, and help us understand how visitors use our site.

What Are Cookies?

Cookies are small data files stored on your browser or device. Some are temporary and expire when you close your browser, while others remain for a longer period to recognize your device when you return.

Types of Cookies We Use

ESSENTIAL COOKIES — Necessary for the operation of our website and to provide you with the services you request (e.g., page navigation, security features). These cannot be switched off through our website.

PERFORMANCE & ANALYTICS COOKIES — Help us understand how visitors interact with our website, such as which pages are visited most frequently and the duration of visits. This information is used to improve our website and the services we offer.

FUNCTIONAL COOKIES — Allow the website to remember choices you make (such as language or region) and provide enhanced, more personalized features. Disabling them may limit certain functionalities.

MARKETING COOKIES — With your consent, we may use cookies to deliver relevant marketing and promotional content.

Cookie Consent and Opt-Out

When you first visit our website, you will be asked to provide your consent for the use of non-essential cookies. You may withdraw or change your consent at any time by managing your cookie preferences through our website or by adjusting your browser settings. Please note that blocking or deleting cookies may affect the functionality of certain features on our website.

12. Changes to the Privacy Policy and Your Duty to Inform Us of Changes

We may update this Policy from time to time to reflect changes in our practices, legal or regulatory requirements, or to improve clarity. Any updates will be posted on our website, and where appropriate, we may notify you directly.

It is important that the personal data we hold about you is accurate and up to date. Please inform us promptly if your contact details or other relevant information change, so that we can continue to provide you with our services effectively and ensure your personal data remains accurate.

13. Third-Party Links

Our website or communications may contain links to third-party websites or resources. Please note that we are not responsible for the privacy practices or content of these third parties.

We encourage you to read the privacy policies of any third-party websites you visit, as their practices may differ from ours. The inclusion of any links does not imply endorsement by INP of the linked websites, their operators, or their content.

We recommend exercising caution and taking appropriate steps to protect your personal data whenever you interact with third-party websites.

14. INP Entities

The term ‘INP’ in this Policy refers to the entities listed below that may deliver services to you and handle your personal data:

  • INP Ibrahim N Partners Legal Consultancy FZ-LLC
  • INP Ibrahim N Partners Legal Consultancy FZ-LLC – Dubai Branch
  • INP Ibrahim N Partners Legal Consultancy Ltd