PRIVACY POLICY- 4C FOR PROJECT MANAGEMENT SERVICES

At 4C Management, your privacy and data security are paramount to us. This Privacy Policy outlines how we collect, use, disclose, and safeguard your data by using applicable data protection laws, including the UAE Federal Data Protection Law No. 45 of 2021 (as applicable), and any relevant regulations.

By accessing our website (www.4c-management.com) or using our services, you acknowledge and agree to the terms and practices described in this Privacy Policy. This Policy sets out the basis 4C Management will operate on which any information, including personal data, that we collect from you or, each time you interact with our website or submit personal information, you consent to the collection, use, and handling of your data as outlined in this policy. The rights and protections described herein apply to all such interactions.

1. SCOPE AND APPLICATION

This Privacy Policy applies to persons anywhere in the world who access, use, and/or interact with our website and use our services (“Users”). The Company is the data controller of all personal information that we process about you. The Company is an entity within the wider 4C FOR PROJECT MANAGEMENT SERVICES corporate group.

2. WHAT DATA DO WE COLLECT

The personal data you give us by providing information or filling in forms on the Company’s website, or by connecting with us (for example, via telephone, e-mail, or any other digital or electronic form). It includes, for example, the information you provide when you contact us or visit our website to avail of our services or transact with us.

If you contact us, we will keep at least an electronic record of such correspondence, including personal information shared to reply or process it as per your request. The personal information we collect may include your name, residential address, e-mail address, phone number, work address, photograph, copy of passport or Emirates ID, source of wealth, directorship/shareholding information, job title, name of the company or organization and other information you choose to provide (“Personal Data”).

The Company collects and processes Personal Data following the DP Law and applicable laws, including for specific lawful purposes explained herein or at the time of collection, or for the performance of tasks carried out as per your instructions or the legitimate interests of the Company. Such legitimate interests may include processing for providing management consulting services, marketing, prevention of fraud, cyber security, maintaining internal records for administration, etc.

Information we collect about you and your device

Each time you use our website, we may and often will automatically collect the following information:

• Your IP address.
• Location information if the website uses GPS technology to determine your current location. To use this feature, you may need to opt in to sharing your data.
• Technical information, including the type of mobile device you use, a unique device identifier (for example, mobile network information, your mobile operating system, the type of mobile browser you use, device token, device type, and time zone setting (“Device Information”).
• Details of your use of our website include but are not limited to traffic data, weblogs and other communication data, and the resources that you access (“Log Information”).
• How long did you spend on different parts of our website?
• Your cookie preferences.
• Any information you submit to us via email.
• Any other personal information that you send to us; and
• Information that we require for compliance with anti-money laundering, financial, and other regulations (ex. Know Your Customer documents).

If you do not wish to share certain data with us or do not want us to use/share it for certain purposes (to the extent possible, per applicable laws and information in this Privacy Policy), you can alter your preferences at any time by writing to us at the email ID mentioned herein below.

3. HOW DO WE COLLECT YOUR PERSONAL DATA

We collect information:

When you visit our website, browse its pages, avail of our services, or transact with us or when you return.

A third-party website analytics service provider collects some of the information on our behalf, and/or we may collect it using cookies actively on our website. These cookies help us to provide you with a good experience when you are browsing and also help us to improve our website.

4. HOW DO WE USE YOUR DATA

We will process only the data we collect about you if we have a valid reason permitted under DP Law. We will have a lawful basis for processing your information if:

• It is necessary to perform or enter into our contract with you.
• We have a legitimate interest in processing your data.
• Send you communications we think will be of interest to you based on your previous interactions with us, including information about products, services, promotions, news, and company events.
• Notify you about changes to this Privacy Policy (if required).
• You have provided your consent.
• We are under a legal obligation to do so.

Where we use your information for our legitimate interests, we make sure that we take into account any potential impact that such use may have on you. Our legitimate interests don’t automatically override yours and we won’t use your information if we believe your interests should override ours unless we have other grounds to do so (such as your consent or where we are under a legal obligation).

5. PROCESSING AND STORING OF PERSONAL DATA

We will take all reasonably necessary steps to ensure fair processing of your Personal Data, following the DP Law, other applicable laws, and this Privacy Policy. By submitting your Personal Data (including Log, Device, and/or demographic information), we expect you to understand that such transfer, storing, or processing for the Company to perform its general administrative functions is necessary and will be done in a proportionate, lawful manner, including but not limited to responding to inquiries you raise via the website and maintaining contacts for future informational or promotional activities. Unless otherwise notified, the Company does not ordinarily rely solely on automated decision-making when processing your Personal Data.

To preserve the integrity of our databases, to carry out ongoing services, for research, analytics, and statistics purposes, and to ensure compliance with applicable laws and regulations, we retain Personal Data submitted by users for a reasonable length of time unless otherwise prescribed by applicable law.

The Company is not responsible for the accuracy of the information you provide and will modify or update your data in our databases when you provide updated information or ad hoc upon your request, as further outlined below. We will erase or put beyond active use of your data upon request, in which case we align with applicable principles such as purpose specification and data minimization.

6. SHARING OF PERSONAL DATA

We may share your Personal Data with and process it according to the legal grounds set out in this Privacy Policy.

• Our service providers, such as our marketing automation and analytics providers, technology (including cloud) service providers, payment providers, banks, and other support providers.
• Our professional advisors (such as our lawyers, accountants, and auditors).
• We may transfer any agreement with you to another organization, or if we enter into a joint venture with, purchase, or sell to, or merge with another business entity or 4C FOR PROJECT MANAGEMENT and any other affiliates or companies within the 4C FOR PROJECT MANAGEMENT SERVICES corporate group, as permitted by law.

Other Types of Data Sharing

We may share your data

• With vendors, consultants, marketing and advertising partners, and other service providers who need access to such Personal Data to carry out work on our behalf or to perform a contract we enter into with them.

If we notify you otherwise and you affirmatively opt in to share your data, where necessary;

Government Data Sharing

In some circumstances, we are legally obliged to share information with public authorities or law enforcement. For example, we may be required to provide information related to a court order or where we must cooperate with supervisory/government authorities in handling complaints or investigations if we determine that such disclosure is following, or is otherwise required by any applicable law, regulation, or legal process. In any scenario, we will attempt to satisfy ourselves that we have a lawful basis on which to share the information, document our decision-making, and satisfy ourselves we have a legal basis on which to share the information.

7. MARKETING AND PREFERENCES

Where we have a legitimate interest in doing so (and are permitted to do so by law), we will use your information to let you know about our other activities and opportunities such as events and webinars that may be of interest to you and we may contact you to do so by email or phone.

The Company supports users’ legal rights to opt-in or subsequently opt-out of receiving communications from us. You have the right to withdraw your consent or opt out of receiving our marketing communications at any time. You may change your preferences at any time by writing to us at the email provided hereinbelow.

Please note that we may continue to send you transactional or service-related emails despite your desire to not receive promotional or marketing email messages.

Finally, while we may remove your individual contact information from our professional contacts database, please be aware that if such information is in a third party’s marketing directory through your request or election, you will need to request removal with such third party directly.

8. WHAT ARE YOUR DATA PROTECTION RIGHTS

The Company would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following rights:

• The right to withdraw consent: When personal information is processed on the basis of consent, you may withdraw consent at any time, although such withdrawal will not affect the lawfulness of processing occurring prior to such withdrawal.
• The right to access – You have the right to request us for copies of your personal data.
• The right to rectification – You have the right to request us to correct any information you believe is inaccurate. You also have the right to request to complete any information you believe is incomplete.
• The right to erasure – You have the right to request that we erase your personal data, under certain conditions.
• The right to object to processing – You have the right to object to the processing of your personal data, under certain conditions.
• The right to restrict processing – You have the right to request that we restrict the processing of your personal data, under certain conditions.
• The right to data portability – You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.

If you would like to exercise any of these rights, please make a request by contacting us at the email ID provided herein below.

9. CHANGES TO THIS POLICY

The Company may change this Privacy Policy from time to time and without notice. We encourage you to periodically review this Privacy Policy for the latest information on our privacy practices. Your continued use of the website or our services constitutes your understanding of the changes. If we make any changes to the Privacy Policy, they will be posted on our official website along with the “Last Updated” date below.

10. CONTACT US

If you have questions, comments, or requests related to this Privacy Policy, or any complaints about how the Company processes your data, please contact us by contacting our data protection team at info@4c-management.com

If you would prefer to write to us, you can do so at: Ms. Lina Ajana, Business Bay, Emirates Towers, Dubai, United Arab Emirates.

 

Last updated: April 2025