At Trifecta Advisory Group Limited (“Trifecta”, “we”, “us”, “our”) we are committed to protecting the privacy and security of your Personal Data. This Privacy Notice (the “Notice”) explains the type of Personal Data that we collect about you, and how we process and use that information, in accordance with the Abu Dhabi Global Market (“ADGM”) Data Protection Regulations 2021 (the “Regulations”).
We reserve the right to revise and amend this Notice, or part of it, at any time. If you wish to exercise any of your rights in relation to your Personal Data, please contact us using the contact details below.
Trifecta, in the ordinary course of business, collects, uses, and shares personal information pertaining to its employees, clients, partners and other parties. Trifecta is a data controller; we are responsible for determining how we hold and use most of the personal information about you. However, if we are processing your personal information on the instructions of one of our clients, it is likely we are working as a data processor in line with a written contract. In this case, the data controller will be our client, and your Personal Data will be processed as set out in their Privacy Notice.
Our contact details are:
Email: advisory@tagluae.com“Personal Data” is any information relating to an individual which, when used or processed, means the individual can be identified, directly from that Personal Data or can be identified from that information in combination with other information. If you contact us using our website, by email or through social media, we collect the personal information you provide to us.
We collect data when you:
During this contact and through our services to you, types of information that is considered Personal Data about you typically includes:
Personal information provided by you in relation to racial or ethnic origin, political opinions or affiliations, criminal record, religious or philosophical beliefs, trade union membership, and health or disability information, sex life or sexual orientation, and genetic or biometric data used for identification, constitutes or may constitute Special Categories of Personal Data. We process such Personal Data only where necessary and permitted by the Regulations, including where an application condition for such processing is satisfied. Where you provide us with such data, and we do not use it, we will delete it.
We generally collect Personal Data from you directly. Where relevant, we may also receive it from our clients, your employer, recruitment agencies, referees, service providers or authorities.
It is important that the Personal Data we hold stays up-to-date, current, and accurate. Please contact us if any Personal Data relating to you changes or is no longer applicable.
We may aggregate data, derived from your Personal Data, in an anonymised way. Such aggregated data does not constitute Personal Data.
We collect and process your Personal Data only where we have a lawful basis to do so under the Regulations. Depending on the circumstances, this may include where processing is necessary to perform or enter into a contract with you, comply with a legal obligation, pursue our legitimate interests or those of a third party where those interests are not overridden by your rights and freedoms, or where you have provided your consent.
We may process your Personal Data for purposes including:
We process your Personal Data to meet our legal, statutory, and contractual obligations. We seek to collect only Personal Data that is adequate, relevant, and limited to what is necessary for the applicable purpose, and do not process your information in any way other than as specified in this Notice.
It is important to note that the provision of your personal information to us remains at your sole discretion. However, where you do not wish to provide us with the personal information we have requested, we will advise you of the repercussions of such omission, including any legal effect.
Trifecta will only share your Personal Data where it is necessary or where it is required by law. We may share your Personal Data with a range of third parties, including, but not limited to:
A Group Company may act as a separate Data Controller or as a Data Processor, depending on its role in the relevant activity. Access to Personal Data is limited to what is necessary for that activity.
Your Personal Data may be accessed or processed outside ADGM by group companies or service providers. Access from another jurisdiction may constitute a transfer even where the data remains stored in the same system.
Where an ADGM adequacy decision applies to the destination and recipient, we may rely on it. For transfers that are not covered by an adequacy decision, we will put in place an applicable transfer safeguard or rely on another lawful transfer mechanism or derogation permitted by the Regulations.
We retain your personal information for as long as it is reasonably necessary for the purposes for which it was collected, including for the duration of our relationship with you, and as necessary to satisfy applicable legal, regulatory, accounting, tax, and compliance requirements.
In determining the appropriate retention period, we may consider the nature and sensitivity of the Personal Data, the purposes for which it was processed, and applicable legal and regulatory requirements.
We do not ordinarily make decisions about individuals based solely on automated processing, including profiling, where those decisions produce legal or similarly significant effects. We may use automated decision-making to assist in our decision-making process only where there is a human element to ensure fairness of the outcome.
Our services are not directed at minors. We do not knowingly collect Personal Data from minors except where necessary for a legitimate business, employment, regulatory or legal purpose.
In accordance with the Regulations, we have implemented and maintain appropriate organisational and security measures to protect your Personal Data, in order to prevent and protect it against destruction (whether accidental or unlawful) alteration, or unauthorised disclosure or unlawful processing. Your Personal Data is only available to employees and contractors who have a business need to be able to access it.
Where required by the Regulations, we will notify the Commissioner of Data Protection and effected individuals of a Personal Data breach.
We may use your information to send you information about our services where permitted by applicable law. You may object to or opt out of receiving direct marketing from us at any time by emailing our data protection email address (dataprotection@tagluae.com) or responding to our marketing communication and selecting the ‘opt-out’.
In accordance with the Regulations and, in certain circumstances or subject to relevant and applicable exemptions, you have the following rights in relation to your Personal Data:
Where we rely on consent to process your Personal Data, you may withdraw your consent at any time to prevent further processing. Withdrawal does not affect processing already carried out lawfully.
If we receive a request from you to exercise any of the above rights, we may ask you to verify your identity before acting on the request; this is to ensure that your Personal Data is protected and kept secure.
If you are not satisfied with the outcome of your request, you have the right to escalate your request to the Commissioner of Data Protection by contacting the Commissioner using the following details:
Phone Number: +971 2 333 8888If you wish to exercise your rights, please contact us at dataprotection@tagluae.com