This Cookies Policy governs the usage of cookies on websites or branded pages ("Website") operated by THE ASSOCIATION. By accessing the Website, you consent to the usage of cookies in accordance with this Cookies Policy.

1.    Introduction

1.1.    Cookies are small files placed and stored on the end user’s device (e.g., computer, tablet, mobile phone) when accessing certain websites or branded pages in online platforms. The widespread use of cookies in the online environment aims to enhance user browsing experiences, track website activities, store, and exchange information, facilitate marketing efforts, and optimize website functionality and responsiveness.

While cookies are typically sent to the server that set them or to a server within the same internet domain, newer internet protocols allow for the transmission of cookies to third-party websites ("Third Party Cookies"). For instance, an advertisement displayed on a social media platform page may transmit cookie information to the browser accessing the media platform (e.g., Google Chrome, Mozilla, Safari).
Users have the option to disable the usage of cookies from their browsers; however, this may impact their browsing experience or restrict access to various areas of websites or online platforms. For example, disabling cookies may prevent users from completing transactions on the Website.

2.    Purpose of Cookies Usage

2.1.    We utilize cookies for the following purposes:
(a)    Enhancement of Website(s) and branded pages activity
(b)    User recognition and determination of user location and preferences for future marketing and advertisement endeavors
(c)    Measurement and analysis of user activity on the Website and facilitation of access to various Website areas
(d)    Facilitation of user logins and retention of user IDs and login credentials for future visits
2.2.    While certain cookies may store personal data (as described below), such storage is intended for advertising and marketing purposes, consistent with our Data Policy.

3.    Types of Cookies Used

3.1.    We generally employ two types of cookies:
(a)    Session cookies: Temporary in nature and disabled upon leaving the Website or branded pages;
(b)    Persistent cookies: Remain stored in the user’s browser even after it is closed or when the user navigates to other internet pages.
3.2.    Both types may be used by the Website or Third-Party Websites and may store personal information as described below:
(i)    Cookies facilitating exploration of various Website areas and ensuring proper functionality;
(ii)    Cookies enabling user interaction with the Website and providing information on user behavior;
(iii)    Cookies facilitating the Website's retention of usernames, preferences, and profile information.

4.    Disabling or Managing Cookies

While most internet browsers are initially configured to accept cookies, users have the option to modify settings to disable cookies entirely or allow specific types. Users may also choose to receive notifications when a new cookie is to be stored on their device. The settings and configurations of each internet browser are the responsibility of the user and fall outside the purview of THE ASSOCIATION.

5.    Third Party Cookies from Sites & Advertisements

The Website may contain links to external websites and advertisements from Third-Parties or links to social media platforms such as LinkedIn. Please note that these external websites are not controlled by THE ASSOCIATION and may utilize cookies and/or collect user personal information. Details regarding the usage of cookies by Third-Party websites are available in the respective websites’ terms and conditions. THE ASSOCIATION bears no responsibility for the usage of Third-Party Cookies.

6.    Usage of Google AdSense, Google Analytics, and Similar Technologies

Google Analytics and similar technologies offered by Google Inc. provide website traffic statistics, traffic source analysis, and conversion tracking. These technologies utilize cookies, and their operations are solely determined and controlled by Google Inc. The processing of personal data obtained through these technologies is subject to Google Inc.'s regulatory requirements.

If THE ASSOCIATION employs such technologies, the purpose would be to enhance website integration, optimize web pages, measure website traffic, improve services and products, and enhance sales. By accessing the Website or branded pages, users consent to the data processing requirements of THE ASSOCIATION and Third-Party providers such as Google Inc.
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For further information, clarification, notifications, requests, alerts & complaints on these policies, please contact the Data Privacy Officer at privacyofficer@emla-uae.com.
THE ASSOCIATION may update their Privacy Policy & Cookie Policy from time to time. These policies are uploaded on the Website. Any such amendments or update becomes automatically and immediately applicable to all Data Subjects and will be published on the Website.  Data Subjects are advised to regularly check THE ASSOCIATION website at https://www.emla-uae.com/ 

By becoming a member of THE ASSOCIATION or by attending ASSOCIATION events,  or by accessing the WEBSITE, you consent expressly to the Privacy Policy & Cookies Policy of the ASSOCIATION and their content, including THE ASSOCIATION’s activities and practices in processing personal data.  

 
SCHEDULE 1: RECORD OF PROCESSING ACTIVITIES 

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THE ASSOCIATION recognizes that Article 15 of the DIFC DP Law 2020, imposes documentation and record keeping requirements on Controllers and Processors. Therefore, this Schedule 1 sets out how THE ASSOCIATION processes Personal Data.

Controller Details    
Name:    MARITIME LAW ASSOCIATION (UAE) NPIO
Address:    Unit GV-00-10-07-OF-02, Level 7, Gate Village Building 10, Dubai International Financial Centre, Dubai, United Arab Emirates
Email     info@emla-uae.com
Website    https://www.emla-uae.com/
Data Protection Officer (DPO)        Paul Wilkinson: privacyofficer@emla-uae.com

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1.    Categories of Data Subjects

THE ASSOCIATION collects personal data from the following categories of Data Subjects: 
-    Members; and
-    Events attendees.

THE ASSOCIATION may collect the following categories of Personal Data about Data Subjects: 
-    Personal details including name and contact information;
-    Date and place of birth;
-    Nationality;
-    Gender;
-    Home status and address; 
-    Marital status;
-    National Insurance numbers;
-    Family details; 
-    Tax residence and other tax related information;
-    Online user identities and subscriptions;
-    Site preferences;
-    Signature;
-    Geographic information; 
-    CCTV footage;
-    ID and/or passport details;
-    Employment details;
-    Power of Attorney and authorized signatory information;
-    Passport and domicile / residential address;
-    Financial details;
-    Associations such as marital status, family, friends, business partners and whether you are financially connected to another person;
-    Correspondences with us, whether face-to-face, telephonically, by post, email, online or otherwise; and
-    Information pertaining to succession and relative heirs.

THE ASSOCIATION may collect Special categories of Personal Data about Data Subjects, including:
-    Religion;
-    Racial or ethnic origin;
-    Biometrics, or health details, including medical insurance details; and 
-    Criminal record and/or Police Good Conduct Certificate, details of past or ongoing court proceedings.

2.    Purposes of Data Processing

THE ASSOCIATION collects and processes personal data about Data Subjects for the following purposes:
-    Maintaining and enhancing the activity of THE ASSOCIATION;
-    Direct marketing; 
-    Auditing; 
-    Detecting and preventing fraud and other financial crime;
-    To manage risk; 
-    To respond and manage complaints or proposals; 
-    Complying with legal obligations; 
-    To perform background checks; 
-    Assessing and monitoring compliance with our policies and standards;
-    Administrative purposes in relation to the security and access of our systems, premises, platforms and secured websites and applications;

3.    Data Retention Periods

Except as otherwise permitted or required by Applicable Laws, THE ASSOCIATION retains proprietary and Personal Data for as long as necessary to fulfil the purposes THE ASSOCIATION collected it for, or to satisfy any legal, accounting, or reporting obligations. 

THE ASSOCIATION typically retains proprietary and personal data for the periods set out below, subject to THE ASSOCIATION sole discretion, any exceptional circumstances, or requirements to comply with laws or regulations that require a specific retention period:
Further Information Requests: five (5) years from the date of reply to the relevant authority making such request. 

Telephone recordings: 
General Telephone Communication: for a maximum period of thirty (30) days.
Video recordings: indefinitely, provided that they do not contain images of Data Subjects, in which case the video recording must be purged within a maximum period of seven (7) days. 
Accounting Records: ten (10) years starting from the end of the financial year to which the records relate. 
Preliminary Third-Party Contracts: six (6) years from the date of termination, expiration, discharge. 
Court summons: one (1) year from last testifying in court or until THE ASSOCIATION’s last involvement in the court proceedings have concluded.
Outsourcing and reliance records: five (5) years from the date of termination of any such arrangement.
Emails: indefinitely, except emails containing Special Categories of Personal Data, which will only be retained for a maximum period of one (1) year, from the date of receipt. 
Special Categories of Personal Data: (1) year from the date of receipt. 

Personal Data Records:
Records of data, including Personal Data will generally be held as follows:
(a)    physical records: a maximum period of five (6) years, provided that the records do not contain any Special Categories of Personal Data, in which case thy may only be retained for a maximum period of one (1) year; 
(b)    electronic records: maximum period of six (6) years, provided that the records do not contain any Special Categories of Personal Data, in which case thy may only be retained for a maximum period of one (1) year.  

Technical and Organizational Security Measures
THE ASSOCIATION has implemented the following technical and organizational security measures to protect personal data: 
-    Pseudonymization of personal data;
-    Encryption of personal data;
-    Segregation of personal data from other networks;
-    Access control and user authentication;
-    Employee training on information security; and 
-    Written information security policies and procedures. 

Changes to this Record of Processing Activities

THE ASSOCIATION reserves the right to amend this Record of Processing Activities from time to time consistent with the DP Law 2020 and other applicable data protection requirements. 
Effective Date:
30 May 2024 
Last modified: 
30 May 2024
 
SCHEDULE 2: PERSONAL DATA PROCESSING PROCEDURES

THE ASSOCIATION processes Personal Data for (i) maintaining its membership register; and (ii) marketing and advertising purposes.