DUNAMI PRIVACY STATEMENT
This is the Privacy Statement of DUNAMI SPHERE FZCO, established at Dubai Silicon Oasis, Dubai, UAE, along with its operating groups, consortiums, affiliates and subsidiaries (collectively referred to as “DUNAMI”, “we”, “us”, or “our”). Your personal data is processed by and shared within the DUNAMI group as described in this Privacy Statement.
When this Privacy Statement mentions “DUNAMI”, “we”, “us”, or “our”, it refers to the DUNAMI group that determines the purposes and means of processing your personal data under this Privacy Statement. If you have any questions about which DUNAMI entity is controlling your personal data in a specific instance, please contact us using the details provided in Section 7 of this Privacy Statement. We are committed to handling your personal data with the utmost care.
This Privacy Statement applies to the processing of personal data belonging to our clients, prospective clients, applicants, and any individuals who visit our website (https://www.dunami.nl/) or who contact us.
All processing of your personal data is subject to applicable regulations as outlined in the UAE Regulation on the Protection of Natural Persons with regard to the Processing of Personal Data and the UAE Data Protection Laws, collectively referred to as the “Data Protection Laws”.
1. Personal Data we process, purposes and legal basis
1.1 Personal Data of Clients
We process contact details (such as name, company name, phone number, and email) of our client contacts to fulfill orders and maintain communication. This processing is based on our legitimate interest, as these contacts are not the formal parties to the contract with DUNAMI. For natural persons, such as sole traders, processing their data is necessary for contract execution.
We also process these contact details for relationship management, including sending holiday greetings or updates. This processing is justified by our legitimate interest in fostering positive client relationships.
From time to time, we conduct customer satisfaction surveys using client contact details. Participation is voluntary, and this processing is based on our legitimate interest in enhancing our services.
1.2 Recording Conversations
We may record telephone conversations in the trading room and between our operations team and client contacts to maintain proof of trades and enhance our services. This processing is based on our legitimate interest in ensuring transparent communication.
1.3 Personal data of prospective clients
We process contact details of prospective and former clients to offer our services and maintain engagement. This processing is based on our legitimate interest in expanding our client base and is derived from publicly available sources.
1.4 Contact information
If you contact us via our website, email, social media, or phone, we process the data provided (e.g., name, email, phone number, and query). This information is used to respond appropriately. We may also save this data in our prospective clients’ database, underpinned by our legitimate interest in servicing our clients.
1.5 Recruitment and application procedures
We process personal data from job applicants, which may be obtained from recruitment agencies or professional networking sites like LinkedIn. This may include contact details, resumes, and relevant information.
During interviews, we will process all additional information provided by the applicant, encompassing education, work experience, and references. For advanced applications, we may conduct personality tests and competence assessments to evaluate fit.
Background checks may be conducted through third-party agencies where necessary, safeguarding personal data with care and securing necessary authorizations.
1.6 Website visitors
We collect data about visitors to our website using cookies. This information includes website usage statistics, IP addresses, and browser types. This processing is based on consent for non-functional cookies and legitimate interest for functional cookies. You can withdraw consent at any time.
2. Retention of personal data
2.1 We will retain your personal data only as long as necessary for the purposes outlined in this Privacy Statement and in compliance with legal obligations.
2.2 Clients and Contacts:
We typically retain these records for two years post contract completion and for seven years for tax-related documentation.
2.3 Recording Conversations:
Retained for a minimum of five years or longer as needed.
2.4 Prospective Clients:
Data is deleted upon request or after one year of last communication.
2.5 Other Contact Information:
Stored for one year post final contact or until a deletion request is made.
2.6 Recruitment Data:
Non-hired applicant data is stored for four weeks post-process. If consented, data can be stored for one year for future openings.
2.7 CCTV Footage:
Retained for a maximum of four weeks unless required for incident investigation.
3. Where do we store and transfer your personal data?
To fulfill the purposes specified in this Privacy Statement, we may share your personal data within the DUNAMI group of affiliates and subsidiaries, as well as with third parties located outside the UAE.
We have established a model agreement within the DUNAMI group, based on the standard contractual clauses approved by the UAE Court and other applicable laws.
When transferring your personal data to third parties outside the UAE, we ensure that appropriate safeguards are in place to protect your rights and freedoms as a data subject in compliance with applicable Data Protection Laws. We accomplish this by relying on:
3.1 An adequacy decision adopted by the UAE Commission, in line with Article
[insert applicable Article related to UAE data protection laws].
3.2 Standard contractual clauses for data transfers, as issued by the UAE Commission.
3.3 Other appropriate safeguards as outlined in the relevant data protection regulations.
3.4 If you would like to receive more information regarding the international transfer of your personal data, please feel free to contact us using the details provided in Section 7 of this Privacy Statement.
4. With whom do we share your personal data?
We share your personal data internally within the DUNAMI group and with third parties under the following circumstances:4.1 Within the DUNAMI Group
Personal data may be stored electronically and included in emails sent or received by us, which may be processed by our IT service providers. We maintain data processing agreements with these providers to ensure at least the same level of security and reliability that you expect from us.
4.2 Service Providers We may collaborate with other service providers who process your personal data on our behalf to facilitate their services. These providers are also bound by data processing agreements, ensuring high standards of data security and reliability.
4.3. Customer Satisfaction Surveys
We may share information with firms conducting customer satisfaction surveys to gather feedback and enhance our services.
4.4. Client contact persons
We may share the personal data of client contact persons with third parties where necessary to execute orders, including, but not limited to, sellers or regulatory authorities when required.
4.5. External Advisors Our external advisors, such as auditors, consultants, lawyers, and accountants, may have access to personal data for the purposes of providing their services. For example, our accountant may access the personal data of client contact persons.
4.6. Legal requirements
We may be required to share your personal data by law, court order, or other legal processes, such as with law enforcement or governmental agencies, to enforce our legal rights or in connection with corporate transactions.
4.7. Consent-based sharing
We may share your personal data with other third parties if you have provided your explicit consent or if sharing is mandated by applicable law.
For more information about how we process and share your personal data, please refer to the contact details provided in Section 7 of this Privacy Statement.
6. What are your rights ?
As an individual whose personal data we process, you have several rights that you can exercise regarding your information: – Right of Access: You have the right to request a copy of the personal data we hold about you and to understand how we use it. Generally, this information will be provided to you digitally, or you may have the option to view it in person. We may require proof of your identity before fulfilling your request. – Right to Rectification: We strive to keep your information accurate and up-to-date. If you believe that any information we hold is incomplete or incorrect, you have the right to request corrections. – Right to Erasure: You may request the deletion of your personal data when it is no longer necessary for the purposes for which it was collected, where it has become outdated, or if you withdraw your consent. Please note that there may be legal or regulatory obligations that prevent us from immediately complying with such requests. – Right to Restrict Processing: You have the right to request that we temporarily halt the processing of your personal data under certain circumstances, such as when you believe the data we hold is inaccurate or unnecessary for our purposes. – Right to Data Portability: You may have the right to request that we transfer your personal data to another party of your choice. This right applies only to data you have provided to us and when we process that data based on your consent or to fulfill a contract. – Right to Object: You have the right to object to the processing of your personal data based on our legitimate interests. If you file an objection, we will cease processing your personal data unless we can demonstrate compelling legitimate grounds. – Rights Related to Automated Decision Making: You have the right not to be subject to decisions based solely on automated processing, including profiling, that have significant effects on you. If you disagree with any automated decision, you may contact us to request a review. – Right to Withdraw Consent: If we process your personal data based on your consent, you have the right to withdraw that consent at any time. We will cease processing your data as soon as possible following your withdrawal, without affecting the legality of the processing prior to your withdrawal.
To exercise any of your rights, please contact us using the details in Section 7 of this Privacy Statement. Keep in mind that certain exceptions and limitations may apply to these rights, and we may not be obligated to fulfill every request.
If you are dissatisfied with how we handle your complaint, you may file a complaint with the relevant data protection authority. In the UAE, this may include the local data protection office.
7. Contact information
If you have any questions regarding how DUNAMI handles your personal data, wish to exercise your rights under the Data Protection Laws, or want to file a complaint regarding our data practices, please reach out to our central contact point at +971582684128 or email us at info@dunami.nl.
8. Changes to this Privacy Statement
Changes in our data processing activities or applicable laws may necessitate updates to this Privacy Statement. In the event of significant changes, we will publish an updated version on our website and, where feasible, notify you of these changes via email.

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Dubai Silicon Oasis