Terms and Conditions
Welcome to Claritysolutions.ae (The “Website”). This page (“Terms & Conditions”) states the Terms and Conditions of this Website. Please review these Terms and Conditions carefully before using the site.
Access to and use of this Website are subject to the following terms, conditions, and notices (the “Terms & Conditions”). By using the Website, you are agreeing to all of the Terms & Conditions, as may be updated by us from time to time. You should check this page regularly to take notice of any changes that we may have made to the Terms & Conditions.
Access to this Website is permitted on a temporary basis, and we reserve the right to withdraw or amend the Pages without notice. We will not be liable if for any reason this Website is unavailable at any time or for any period. From time to time, we may restrict access to some parts or all of this Website.
Privacy Policy:
Clarity Consulting Solutions Ltd (“Clarity”) recognises the importance of your privacy. We are a compliance consultancy firm registered in the Dubai International Financial Centre (“DIFC”) and the Abu Dhabi Global Market (“ADGM”).
In connection with providing our services and in compliance with the Data Protection Law, DIFC Law No. 5 of 2020 (“DPL”) and the ADGM Data Protection Regulations 2021 (“DPR”), we collect and process information, including Personal Data (as defined in the DPL and/or DPR, as applicable). This Privacy Policy is to inform you about the information we collect and how that information will be used.
We will not sell, share, or otherwise disclose any of the information we collect about you without your permission. We may share Personal Data, to processors who act on our behalf as per our engagement with you, details of which are enclosed in our Terms of Business.
Clarity may revise this Privacy Policy or any part of it at any time. We suggest you review this Privacy Policy periodically for changes. If you no longer wish us to hold data about you, or wish to change the type of information we send to you, please Contact Us.
Our Responsibilities:
We process Personal Data in relation to our clients and related persons as a Controller on the legal basis of compliance with applicable laws and regulations that we are subject to.
We process Personal Data in relation to the services we provide to, and on behalf of our clients under signed Terms of Business, as a Processor.
Privacy Notice:
Clarity collects, uses, shares and otherwise processes your Personal Data in connection with its contractual arrangements and the subsequent provision of services, in accordance with the DPL and DPR.
What do we use Personal Data for:
We only collect Personal Data in connection with providing our services and conducting our normal business operations. We may hold information about Data Subjects if:
– you are a client, a representative of a client, or the beneficial owner of a client;
– you are a party or the representative of a party in a matter on which we are advising a client;
– we are required to Process your Personal Data in accordance with applicable laws or regulations, for example anti-money laundering laws;
– your information is provided to us by a client or others, or we otherwise obtain your information, in connection with the service(s) we are providing to a client;
– you provide services to us (or you represent a company which provides services to us);
– you represent a regulator, certification body or government body which has dealings with us;
– you attend our events, receive our updates, or visit our office or Website;
– you are an applicant for a job with us; and
– you are or were an employee of Clarity.
Please note that we may use or disclose Personal Data if we are required by law to do so or if we reasonably believe that use or disclosure is necessary to protect our rights and/or to comply with judicial or regulatory proceedings, a court order or other legal process.
References to ‘client’ in this section includes any person(s) related to the client such as employees, managers, directors, shareholders, etc.
What we Collect:
The types of information we collect and Process may include:
Types of Personal Data | Details |
Individual details | Name, address (including proof of address), other contact details (e.g. email and telephone numbers), gender, marital status, date and place of birth, nationality, employer, job title and employment history, and family details, including relationship. |
Identification details | Identification numbers issued by government bodies or agencies, such as passport number, Emirates ID or other national identity number, tax identification number and driving licence number, including copies of such government-issued identification document |
Financial Information | Bank account details, income, source of wealth, source of funds or other financial information. |
Anti-Money Laundering and Sanctions data | Screening information received from various anti-money laundering, counter-terrorism financing and sanctions databases. |
Special Categories of Personal Data | Information about political affiliations or opinions or criminal record, to the extent required for compliance with Applicable Law. As a policy, we do not normally collect any Special Categories of Personal Data, unless such collection is warranted under specific circumstances. |
Identifiers | Information which can be traced back to you, such as an IP address, a website tracking code or any other information that may be automatically collected through our website or any other digital communication or network security applications used by us. |
How we use Personal Data:
Purpose of Processing | Lawful Basis for Processing (pursuant to the DPL and/or DPR, as applicable) |
Anti-Money Laundering and other legal obligations We obtain information about our clients, their representatives and beneficial owners and others to help us comply with laws and regulations on money laundering, terrorist financing, and sanctions. We also collect and disclose Personal Data under applicable legislation and under orders from courts and regulators. Our disclosures will be to those bodies and persons who are entitled to receive the required information. In some cases, this information may include Special Categories of Personal Data (as defined by the DPL or DPR), to the extent required by us to ensure compliance with applicable laws and regulations. | For Personal Data – compliance with applicable laws that we are subject to. For Special Categories of Personal Data – compliance with applicable laws that applies to us in relation to anti-money laundering or counter-terrorist financing obligations or the prevention, detection, or prosecution of any crime. |
Services We may obtain information about individuals where this is necessary or appropriate to provide services to our clients. We disclose this information to our clients in connection with our role in the relevant engagement. | For Personal Data – performance of services under our Terms of Business. |
Service Providers We collect information about you in connection with your provision of services to us or your position as a representative of a provider of services to us. We do not collect Special Categories of Personal Data for this purpose, other than where we are required to do so to meet our legal obligations (see ‘Anti-Money Laundering and other legal obligations’ above). | For Personal Data – performance of services under our Terms of Business. |
Events, regulatory updates and other marketing activities If you wish to attend our events or receive our updates, we will ask you to provide us with a limited amount of information (normally limited to your work contact details, your employer's name, your job title, and the legal subjects/events of interest). We use this information to communicate with you about our events, and updates, to ensure that you are an appropriate audience for them, and to conduct analysis for marketing purposes. We do not collect Special Categories of Personal Data for this purpose. | For all communications with you – consent from Data Subject. |
Visitors to our website Where you provide us with Personal Data on our Website(s) for the purpose of inquiring about our services, we will only use it for the purpose of communicating with you in connection to your request. Our website uses a small number of non-intrusive cookies to help it work more efficiently and to provide us with information on how the website is being used. You can control cookies through the settings or preferences of your browser, as well as through dedicated browser extensions or add-ons. We do not collect Special Categories of Personal Data on our Website(s). | For Personal Data – legitimate interests for business development purposes. |
Staff Recruitment We ask candidates to provide Personal Data to us as part of the job application process. We will also conduct checks in order to verify candidates’ identity and the information in the application as well as to obtain further information about suitability for a position within Clarity. This may include obtaining information from regulators, anti-money laundering databases, sanctions lists, etc. In some cases, this information will include Special Categories of Personal Data, where such information is required for the purpose of pre-employment verification checks or other employment-related Processing. We retain Personal Data of former staff members to the extent that we have a statutory obligation to do so. | For Personal Data – (1) for compliance with applicable laws that we are subject to; and (2) legitimate interests to prevent fraud. For Special Categories of Personal Data – for carrying out our obligations and exercising our rights in the context of a candidate’s employment. |
Accuracy of Information:
It is important that the Personal Data we hold about you is accurate and current. Please let us know if your Personal Data changes during your relationship with us.
What happens if you do not provide the Personal Data we request:
It is in your sole discretion to provide Personal Data to us. If you do not provide us with all or some of the Personal Data we request, we may not be able to provide you with any services.
What are your rights in relation to your Personal Data:
Data Subject rights as per the DPL and DPR are:
– request access to your Personal Data (commonly known as a “data subject access request”) and request certain information in relation to its processing;
– request rectification of your Personal Data;
– request the erasure of your Personal Data;
– request the restriction of processing of your Personal Data;
– object to the processing of your Personal Data;
– right to data portability.
If you want to exercise one of these rights, please Contact Us.
If you believe your data is being processed contrary to DPL or DPR, as applicable, and this privacy notice, you have the right to make a complaint at any time to relevant data protection office as listed below.
ADGM Data Protection Office:
Abu Dhabi Global Market Authorities Building ADGM Square Al Maryah Island PO Box 111999 Abu Dhabi, UAE
Tel. +971 (0) 2 333 8888 | Email: [email protected]
DIFC Data Protection Office:
Dubai International Financial Centre Authority Level 14, The Gate Building DIFC, UAE
Tel. +971 4 362 2222 | Email: [email protected]
Retention of Personal Data:
We will only retain Personal Data for as long as necessary to fulfil the purposes for which it was collected and processed.
To determine the appropriate retention period for Personal Data, we will consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of the Personal Data, the purposes for which we process the Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymise Personal Data so that it can no longer be associated with the Data Subject, in which case it is no longer Personal Data.
Upon expiry of the applicable retention period we will securely destroy Personal Data in accordance with the DPL and DPR, as applicable.
Contact Person for Data Protection:
For any queries relating to our Data Processing activities or other matters under this Privacy Policy, the DPL or DPR, you may contact us by:
– sending an email to: [email protected]
– using the Contact Us tab on our Website: www.claritysolutions.ae
Linked sites:
This Website may contain links to other websites (the “Linked Sites”), which are not operated by Clarity and for which we have no control over and as such, accept no responsibility or liability for them or for any loss or damage that may arise from your use of them. The policy described herein, applies only to data collected by Clarity.
Prohibitions:
You must not misuse this Website or seek to commit or encourage a criminal offense; transmit or distribute a virus, trojan, worm or any other material which is malicious, technologically harmful, in breach of confidence or in any way offensive or obscene. We do not accept any unsolicited advertising or promotional material, commonly referred to as “spam” and breaching this provision would constitute a criminal offence and Clarity will report any such breach to the relevant law enforcement authorities and disclose your identity to them.
Viruses:
Although Clarity operates a secure and compliant Website, we will not be held liable for any loss or damage caused by a distributed denial-of-service attack, viruses or other technologically harmful material that may infect your computer equipment, computer programs, data or other proprietary material due to your use of this Website or to your downloading of any material posted on it, or on any website linked to it.
Intellectual Property:
All content published and made available on our Website is property of Clarity and the Website’s creators. This includes, but is not limited images, text, logos, documents, downloadable files, and anything that contributes to the composition of our Website.
Email Communication
All e-mail messages (including attachments) are given in good faith by Clarity.
Clarity cannot guarantee that the message received by you has not been intercepted by third parties and/or manipulated by computer programmes used to transmit messages and viruses.
The information contained in messages (with attachments) from Clarity may be confidential or privileged and is only intended for the use of the receiver named. If you are not the intended recipient, you are requested by Clarity to delete the message (with attachments) without opening it and email the sender of the message, advising you received the message in error and have deleted the message and attachments. You are hereby notified by Clarity that any disclosure, copying or distribution of the information contained in the message (including but not limited to attachments) is strictly prohibited and unlawful.
Disclaimer of Liability:
The material displayed on this Website is provided without any guarantees, conditions, or warranties as to its accuracy. Unless expressly stated to the contrary to the fullest extent permitted by Clarity hereby expressly exclude all conditions, warranties and other terms which might otherwise be implied by statute, common law or the law of equity and shall not be liable for any damages whatsoever, including but without limitation to any direct, indirect, special, consequential, punitive or incidental damages, or damages for loss of use, profits, data or other intangibles, damage to goodwill or reputation, or the cost of procurement of substitute goods and services, arising out of or related to the use, inability to use, performance or failures of this Website.
Variation:
Clarity shall have the right in its absolute discretion at any time and without notice to amend, remove or vary the Services and/or any page of this Website.
Confidentiality:
Any information or material sent to Clarity through this Website will be handled in a manner consistent with legal and regulatory requirements.
Governing Law and Jurisdiction:
Your access to, visit of and use of the Website, and the present Terms and Conditions are governed by and shall be construed in accordance with the laws of the DIFC and ADGM, as applicable. The Courts of DIFC or ADGM, as applicable, shall have exclusive jurisdiction over any dispute relating thereto, without prejudice to the Company making choice of any other court having jurisdiction on such a dispute under any applicable law.
Clarity may modify these Terms and Conditions at any time, with immediate effect and without prior notice.