Scope

Abu Dhabi Early Childhood Authority (“ECA”) respects the privacy of the online visitors to our Platforms and its related sub-domains, sites, services and tools (“Platforms”), and highly values your trust in ECA. In this privacy statement (“Privacy Statement”), ECA explains how your information is collected, used, disclosed, and protected when you visit our Platforms.

This Privacy Statement might change at any time and for any reason. If possible, we will notify you of any changes to this Privacy Statement using the contact information you have provided to us, and by providing such contact information, you consent to being contacted by us for this purpose. We will also update the Privacy Statement on our Platforms which you can refer to at any time, and we will notify you and ask you to accept the new Privacy Statement when you next visit our Platforms.

The following information is provided by ECA to enable our online visitors to be fully informed of ECA’s privacy policies. By visiting our Platforms and clicking “ACCEPT” on our privacy banner at any of the Platforms, you are accepting and consenting to the practices described in this Privacy Statement and our online terms and conditions (see here [insert link to web address of ECA Platforms terms and conditions]) (the “Terms and Conditions”).

If you are under 16, we require that you inform a parent or guardian about the terms of this Privacy Statement and of our Terms and Conditions and obtain their agreement and consent to the terms of this Privacy Statement and of our Terms and Conditions, as well as your use of our Platforms. 

Platforms

Data Collection and Lawful Basis for Use

When you browse, read, or download information from our Platforms, ECA automatically gathers and stores certain information about your visit. This information includes:

• your IP address and geolocation to identify the country you are accessing ECA from;
• personal identifying information such as name and contact details (if voluntarily provided);
• the name of the top-level domain from which you accessed the Internet (for example .ae, .com, etc.);
• the type of browser you use;
• cookies (see “Cookies” section below);
• the date and time you accessed the site;
• the pages you accessed; and
• the documents you have downloaded and the previous internet address from which you came directly to the site.

The above information is defined as (“Personal Data”). [Does ECA will or is collecting Sensitive Personal Data at any of its Platforms?]

We will use your Personal Data for statistical purposes and to administer and assist us in the operation of our Platforms. This may include, for example, troubleshooting, data analysis, testing, research, statistical and survey purposes, or to ensure that our Platforms is displayed in relevant format for your browser, platform, or operating system.

In accordance with the UAE’s data privacy laws, ‘controllers’ of Personal Data must have a lawful basis for collecting and using your Personal Data. ECA processes your Personal Data on the following bases:

• ‘necessary for the performance of any contract to which the data subject is a party’ – using your Personal Data to perform obligations under the Terms and Conditions, this Privacy Statement or any other contract that ECA and you may have entered into for goods or services;
• ‘legal obligation’ – collecting or using your Personal Data so we can comply with the law.
• ‘statistical studies’ – using your Personal Data for statistical studies (such as demographic surveys or trend analyses) provided the processing is carried out in accordance with other applicable UAE laws or regulations;
• ‘consent’ – using your Personal Data where we have permission from you. Where consent is the only legal basis for us using your information, you may withdraw this at any time.

ECA does not sell, exchange, or otherwise distribute the data collected for commercial or marketing purposes or for any other purpose other than those specified above. 

ECA, occasionally, may conduct online surveys to get your feedback. ECA shall use the survey data for research and to improve ECA or early childhood related matters. The participation in those surveys is always optional and ECA will obtain your consent prior to obtaining your feedback.

Use and Disclosure of Personal Information

You may browse and access information contained within the Platforms without providing any Personal Data (information from which your identity is apparent or can be reasonably ascertained). If you are required to provide Personal Data to download or access any of our information and consent to the processing of your Personal Data, the information may be saved and logged, if necessary, on ECA servers for the purpose of logging and tracking services.

ECA is a government entity and Your Personal Data may be shared with Federal government entities and the governments of other UAE Emirates[ [Does ECA share with suppliers personal data?] Infosec and Data Team to advise]. We may also use your Personal Data to communicate with you and/or to assess your input to improve the content our Platforms. unsolicited/public information shall be deemed to be non-confidential and we shall be free to reproduce, use, disclose, and distribute such unsolicited/public information to others without limitation or attribution.

Cookies

The Platforms uses “persistent cookies” for any personalized content. A cookie is a data file that a Platforms asks your internet browser to store on your electronic device. A “persistent cookie” allows our Platforms to "remember" your actions or preferences when you visit our Platforms in the future. A cookie may transmit information via your internet browser in order to authenticate or identify the electronic device (for example, via the IP address) and/or the user. 

The use of cookies is a standard practice among internet portals and Platforms. Cookies may contain other information such as registration data or user preferences. When our servers receive a request from an electronic device which stores a cookie from our Platforms, our servers can use the information stored in the cookie in combination with the information which we store on our servers.

By using our Platforms and clicking “ACCEPT” on our privacy banner, you agree that we can place these types of cookies on your device and access them when you visit our Platforms in the future.

How Do I Delete or Reject Cookies?

You can delete cookies at any time. If you want to delete any cookies that are already on your electronic device, please refer to the help and support area on your internet browser for instructions on how to locate the file or directory that stores cookies.

Information on deleting, rejecting or controlling cookies is available at https://allaboutcookies.org/. Please note that by deleting a number of our cookies or disabling or rejecting future cookies, you may not be able to access certain areas or features of our Platforms, and certain functions may not work correctly.

If you use our Platforms without deleting or rejecting some or all cookies and have clicked “ACCEPT” on our privacy banner, you agree that any cookies you have not deleted or rejected may be placed by us on your electronic device.

You may change your cookie preferences (and withdraw your consent to our use of ‘non-essential cookies’ (being cookies not necessary for the basic functioning of the Platforms but may be used to enhance user experience, collect data for analytics, or display targeted advertising) that collect your Personal Data) at any time using our [cookie preference platform]. 

External Links

The Platforms might contain links to other sites. We are not responsible for the content and the privacy practices of other Platforms and encourage you to examine each Platforms’s privacy policy to make your own decisions regarding the accuracy, reliability, and correctness of the material and information found.

Security

ECA has appropriate security measures in place to protect against the loss, misuse or alteration of information that has been posted. These measures cover commercial software programs and secure technology infrastructure to monitor network traffic, authenticate legitimate users, and identify unauthorized attempts to upload or change information, or otherwise cause damage.

ECA will update these policies, controls, and measures from time to time as appropriate, including when new technology becomes available.

Retention of Your Personal Data

We will only retain your Personal Data for as long as necessary to fulfil the purposes for which we collected it. To determine the appropriate retention period, we consider the amount, nature, and sensitivity of your Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances, for example, where the basis of processing your Personal Data has changed or ceased to exist, we may anonymize your Personal Data so that it can no longer be associated with you, in which case we may use such information without further notice to you.

Your Rights

ECA aims to keep the Personal Data we hold about you as accurately as possible. As a data subject, you have several statutory rights available to you under the data privacy laws. These rights are summarized below.

If you wish to exercise any of your rights in relation to your Personal Data, please follow the instructions in the ‘Contact Us’ section.

Where you make any request to us, we reserve the right to request further details from you to evidence your identity before processing your request.

• The Right to Withdraw Consent

Where we rely on your consent as the lawful ground for our processing, you may withdraw your consent at any time by notifying us in accordance with this section and the section entitled ‘Contact Us.’ We will cease any processing based upon your consent as soon as reasonably practicable after receiving a withdrawal notification from you, provided that no other lawful ground is available to us to continue such processing.

Any withdrawal of consent must:

• be in writing (either in hard copy or electronic form);
• notified us by one of the methods set out in the section entitled ‘Contact Us’; and
• clearly set out the processing for which consent is withdrawn.

If the applicable legislation or regulations set out any additional requirements to which a withdrawal of consent must adhere, then we may, in our sole discretion, specify that such additional requirements shall apply in addition to the above requirements.

The withdrawal of consent will not affect the validity of the processing of your Personal Data that occurred prior to the withdrawal of your consent.

 

• The Right to Receive Information, Correction and Erasure

You may request details from us about whether we are processing your Personal Data, the purpose of our processing, the categories of your Personal Data being processed, and the recipients or categories of recipients to whom we are disclosing your Personal Data.

In some cases, you may also request us to correct any Personal Data that we hold about you.

You may also be entitled to require us to erase your Personal Data. This right may be available to you where the purposes of the processing are no longer necessary, your Personal Data must be deleted under applicable law, and there are no other grounds upon which we may rely to continue our processing. Please note that we may not be able to process your erasure request if applicable law requires us to retain such Personal Data or if it is subject to or for establishing a legal defense or legal claim.

We may not be able to process your erasure or correction request when it is technically not feasible. In such cases, we will inform you and provide further details.

We have the right to reject your request to obtain information that is excessive because of its repetitive character. We may also be unable to provide you with certain information in certain circumstances pursuant to laws applicable to us.

 

• The Right to Restrict Processing

In some circumstances, you may restrict the processing of your Personal Data. Please get in touch with us using the details provided in the ‘Contact Us’ section to find out more about what restrictions you may request and the circumstances in which we may continue to process, irrespective of such a request. 

 

• The Right to Request Transfer of Personal Data

Where our processing of your Personal Data is carried out on the grounds of consent or the performance of a contract and is carried out by automated means, you may have the right to receive such data in a machine-readable format, provided that it is technically feasible to do so and such disclosure will not infringe the rights of any other natural person.

 

• The Right to Object to any Decision Based Solely on Automated Processing.

You may have the right to object to decisions made solely on the basis of automated processing, such as profiling, if such decisions result in legal or other impactful consequences on you. You may also require such decisions to be reviewed manually. Please note that our recruitment or employment practices do not use automated decision-making or profiling.

• The Right to Lodge a Complaint

While we encourage you to contact us directly with any complaints so we can address them promptly, you may also lodge a complaint with the UAE Data Bureau or the UAE Ministry of Economy’s Consumer Complaints Department (https://www.moec.gov.ae/en/complaints-service). Please see the “Contact Us” section below for more details.

Data Breach

In the event we become aware that the security of our Platforms (or our services) has been compromised, or your Personal Data has been disclosed to unrelated third parties as a result of external activity, including, but not limited to, security attacks or fraud, we reserve the right to take reasonably appropriate measures, including, but not limited to, investigation and reporting, as well as notification to and cooperation with law enforcement authorities. In the event of a data breach, we will make reasonable efforts to notify affected individuals if we believe that the breach would prejudice the privacy and confidentiality of the user or if notice is otherwise required by law. When such notifications are made, we will post a notice on our Platforms, and where required, send you an email. If, for any reason, you have a reason to believe that your Personal Data shared with us is no longer secure, you may contact us via our e-mail address at [insert email address].

Contact Us – To Ask Questions or File Complaints

We, the Abu Dhabi Early Childhood Authority, are responsible for any Personal Data collected by us relating to you.

To contact us relating to any concerns in relation to this Privacy Statement or to exercise your rights, please send a communication by email to [insert email address] with the subject "Data Protection".

Severability

If any term or condition of this Privacy Statement is deemed invalid or unenforceable by a court of law or tribunal with binding authority, then the remaining terms and conditions shall not be affected.

Governing Law and Dispute Resolution

This Privacy Statement and the rights of you and ECA hereunder shall be governed by the laws of the United Arab Emirates and the Emirate of Abu Dhabi. 

Any dispute arising out of the formation, performance, interpretation, nullification, termination or validation of this Privacy Statement in any manner whatsoever shall be referred to and settled exclusively by the courts of the Emirate of Abu Dhabi.