Abu Dhabi Center for Sheltering and Humanitarian Care – Ewaa

Privacy Policy

Last updated February 17, 2022


The Abu Dhabi Center for Sheltering and Humanitarian Care – Ewaa (“Ewaa”, “we”, “us”, “our”) is committed to protecting individual privacy and securing the personal information made available by users of www.ewaa.gov.ae and all pages/sites in this domain (together, the “Ewaa website”) as well as Ewaa web pages on other sites (such as of cial Ewaa pro les on social networks). By visiting Ewaa’s website you are accepting the provisions set out in this policy.
This privacy policy describes what information is made available to Ewaa and third parties when you visit the Ewaa website, use any of our services (the “Services”, which include the Ewaa website) or of cial Ewaa web pages on other sites, and how Ewaa uses and stores that information.
We seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. Any information voluntarily disclosed to Ewaa by users of the Ewaa website is held with the utmost care and security and will not be used in ways other than as set forth in this privacy policy.
Through the Ewaa website you may reach or be directed to other sites that relate to Ewaa, such as the sites of our national or global partners. All these sites have their own privacy statements which are similar to this one but may vary slightly.
We hope you take some time to read through it carefully, as it is important. If there are any terms in this privacy notice that you do not agree with, please discontinue use of our Services immediately.

1. INFORMATION WE COLLECT

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Ewaa website, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Ewaa website or otherwise when you contact us.

The personal information that we collect depends on the context of your interactions with us and the Ewaa website, the choices you make and the products and features you use. The personal information we collect may include the following:

    • Personal Information Provided by You. We may collect names; phone numbers; email addresses; mailing addresses; contact preferences; data collected from surveys; usernames; passwords; contact or authentication data; information you provide when using our products (e.g., business name, business email, business address, business fax, the center’s website, etc.); number of unique views and total number of visitors when you deploy your cookie banner using our consent management solution; information in blog comments; profile photo; and other similar information.
    • Social Media Login Data. We may provide you with the option to register with us using your existing social media account details, like your Facebook, Twitter or other social media account. If you choose to register in this way, we will collect the information described in the section called “HOW DO WE HANDLE YOUR SOCIAL LOGINS?” below. All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit the Ewaa website.

We automatically collect certain information when you visit, use or navigate the Ewaa website. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use the Ewaa website and other technical information. This information is primarily needed to maintain the security and operation of our Ewaa website, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies. You can find out more about this in our Cookie Notice.

The information we collect automatically includes:

    • Log and Usage Data. Log and usage data is service-related, diagnostic, usage and performance information our servers automatically collect when you access or use the Ewaa website and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type and settings and information about your activity in the Ewaa website (such as the date/time stamps associated with your usage, pages and files viewed, searches and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called ‘crash dumps’) and hardware settings).
    • Device Data. We collect device data such as information about your computer, phone, tablet or other device you use to access the Ewaa website. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system and system configuration information.
    • Location Data. We collect location data such as information about your device’s location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Ewaa website. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. Note however, if you choose to opt out, you may not be able to use certain aspects of the Services.

Information collected from other sources

In Short: We may collect limited data from public databases, marketing partners, social media platforms, and other outside sources.

In order to enhance our ability to provide relevant services to you and update our records, we may obtain information about you from other sources, such as public databases, joint marketing partners, affiliate programs, data providers, social media platforms, as well as from other third parties. This information includes

mailing addresses, job titles, email addresses, phone numbers, intent data (or user behavior data), Internet Protocol (IP) addresses, social media profiles, social media URLs and custom profiles, for purposes of targeted advertising and event promotion. If you interact with us on a social media platform using your social media account (e.g. Facebook, Instagram or Twitter), we receive personal information about you such as your name, email address, and gender. Any personal information that we collect from your social media account depends on your social media account’s privacy settings.

2. INFORMATION WE USE

In Short: We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.

We use personal information collected via the Ewaa website for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.

We use the information we collect or receive:

    • To facilitate account creation and logon process. If you choose to link your account with us to a third-party account (such as your Google or Facebook account), we use the information you allowed us to collect from those third parties to facilitate account creation and logon process for the performance of the contract.
    • To manage user accounts. We may use your information for the purposes of managing our account and keeping it in working order.
    • To request feedback. We may use your information to request feedback and to contact you about your use of our Services.
    • To post testimonials. We post testimonials on the Ewaa website that may contain personal information. Prior to posting a testimonial, we will obtain your consent to use your name and the content of the testimonial. If you wish to update, or delete your testimonial, please contact us at info@ewaa.gov.ae and be sure to include your name, testimonial location, and contact information.
    • To protect our Services. We may use your information as part of our efforts to keep our Services safe and secure (for example, for fraud monitoring and prevention).
    • To enforce our terms, conditions and policies for business purposes, to comply with legal and regulatory requirements or in connection with our contract.
    • To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
    • To deliver and facilitate delivery of services to the user. We may use your information to provide you with the requested service.
    • To respond to user inquiries/offer support to users. We may use your information to respond to your inquiries and solve any potential issues you might have with the use of our Services.
    • To send you marketing and promotional communications. We and/or our third-party marketing partners may use the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. For example, when expressing an interest in obtaining information about us or our Services, subscribing to marketing or otherwise contacting us, we will collect personal information from you. You can opt-out of our marketing emails at any time (see the “WHAT ARE YOUR PRIVACY RIGHTS?” below).
    • To send administrative information to you. We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.
    • To deliver targeted advertising to you. We may use your information to develop and display personalized content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness. For more information see our Cookie Notice.
    • For other business purposes. We may use your information for other business purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve the Ewaa website, Services, products, marketing and your experience. We may use and store this information in aggregated and anonymized form so that it is not associated with individual end users and does not include personal information. We will not use identifiable personal information without your consent.

3. INFORMATION WE SHARE

In Short: We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations.

We may process or share your data that we hold based on the following legal basis:

    • Consent: We may process your data if you have given us specific consent to use your personal information for a specific purpose.
    • Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.
    • Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.
    • Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
    • Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

More specifically, we may need to process your data or share your personal information in the following situations:

    • Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, financing, or acquisition of all or a portion of our business to another company or entity.
    • Vendors, Consultants and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Ewaa website, which will enable them to collect data on our behalf about how you interact with us over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content, pages or features, and better understand online activity. Unless described in this policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes. We have contracts in place with our data processors, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organization apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct.
    • Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy notice. Affiliates include our parent entity and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.
    • Business Partners. We may share your information with our business partners to offer you certain services or promotions.
 

4. WHO WILL YOUR INFORMATION BE SHARED WITH?

In Short: We only share information with the following categories of third parties.

We only share and disclose your information with the following categories of third parties. If we have processed your data based on your consent and you wish to revoke your consent, please contact us using the contact details provided in the section below titled “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?“.

    • Ad Networks
    • Affiliate Marketing Programs
    • Cloud Computing Services
    • Communication & Collaboration Tools
    • Data Analytics Services
    • Data Storage Service Providers
    • Finance & Accounting Tools
    • Order Fulfillment Service Provider
    • Payment Processors
    • Performance Monitoring Tools
    • Product Engineering & Design Tools
    • Retargeting Platforms
    • Sales & Marketing Tools
    • Social Networks
    • Testing Tools
    • User Account Registration & Authentication Services
    • Website Hosting Service Providers

5. COOKIES AND OTHER TRACKING TECHNOLOGIES

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice.

6. SOCIAL LOGINS

In Short: If you choose to register or log in to our services using a social media account, we may have access to certain information about you.

The Ewaa website offers you the ability to register and login using your third-party social media account details (like your Facebook, Google or Twitter logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile information we receive may vary depending on the social media provider concerned, but will often include your name, email address, friends list, profile picture as well as other information you choose to make public on such social media platform.

We will use the information we receive only for the purposes that are described in this privacy notice or that are otherwise made clear to you on the relevant Ewaa website. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider.

We recommend that you review their privacy notice to understand how they collect, use and share your personal information, and how you can set your privacy preferences on their sites and apps.

7. TRANSFER OF INFORMATION

In Short:We may transfer, store, and process your information in countries other than your own.

We are based in the Emirate of Abu Dhabi, United Arab Emirates and our servers are located in the United States. In order to provide our Services to you, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information (see “WILL YOUR INFORMATION BE SHARED WITH ANYONE?” above), in the European Union, United States, United Arab Emirates, and other countries.

If you are located in the European Economic Area (EEA) or United Kingdom (UK), then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. With that in mind, we use appropriate safeguards when we transfer your information outside the EEA or UK to ensure your personal information remains protected and to comply with applicable data protection laws.

The bases, mechanisms, and measures we rely on include:

• Adequacy Decisions. When applicable, we may rely on EU or UK adequacy decisions to transfer your information outside the EEA or UK. When the relevant EU or UK authority issues an adequacy decision, that means they found the third country to offer adequate protection for personal information.

• Derogations. We may transfer information based on a derogation listed in Article 49 of the GDPR. We will only do so if the transfer of information meets specific strict conditions.

• Standard Contractual Clauses. We have implemented measures to protect your personal information, including by using Standard Contractual Clauses for transfers of personal information between us and our group companies and between us and our third-party providers. These clauses require all recipients to

protect all personal information that they process originating from the EEA or UK in accordance with European data protection laws and regulations. We have implemented similar appropriate safeguards with our third-party service providers.

• Supplementary Measures. When necessary, in addition to the Standard Contractual Clauses, we may adopt technical, contractual, and organizational supplementary measures to better ensure that the level of protection guaranteed by the GDPR is not undermined by the transfer.

8. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than three (3) months past the termination of the user’s account.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

9. KEEPING YOUR INFORMATION SAFE

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security, and improperly collect, access, steal, or modify your information.

Although we will do our best to protect your personal information, transmission of personal information to and from the Ewaa website is at your own risk.

10. RESPONSIBILITY OF USERS

In Short: We do not accept responsibility for user generated content.

We may ask our stakeholders and community to share their photos and videos with the public on its websites. This type of media is generally defined as User Generated Content (UGC).

Users of the Ewaa website acknowledge that such content is treated as being non-proprietary and non- confidential. If you send this content to us, either via email, by tagging content on a social network, or via a specifically designed upload site, you are granting Ewaa the irrevocable, perpetual, non-exclusive, royalty-free, worldwide right to use, reproduce, modify and publish such content elsewhere in its websites and publications.

Furthermore, you grant Ewaa the right to use the name that you submit in connection with such content.

However you still own and can continue to use your content as you like including the ability to also allow others to use it.

If you upload or share your content with the Ewaa website or social media account, it might be used by any affiliate websites or social media accounts across the globe.

When we ask our community to share content with us, we explain how we intend to use the content. Mostly, we will re-share content on our social media channels or for our marketing purposes. If it is particularly strong, we may use the content shared with us. In those cases, we will attempt to contact you to discuss whether you agree for it to be used, and to ask whether and how you would like to be credited.

Ewaa does not pay for nor does it generate any revenue from selling or licensing individual pieces of UGC.

Conditions to upload content

When you submit or share content with Ewaa, you must only submit/share your own original content. If your content contains the work(s) of others (e.g. music, images and/or video) you must have obtained the necessary rights or permissions.

If your content clearly identifies anyone else you will need to ensure that the persons concerned have consented to the content being used by Ewaa. Where your content clearly identifies children under the age of 16 you must ensure that their parent or guardian has provided their consent as set out above.

Ewaa also requires that you do not submit or share any content or information:

  • That is knowingly false or misleading, defamatory, infringing, obscene, indecent, threatening or invasive of a person’s privacy or unlawful in any way;
  • Which you do not own or for which you have not obtained all necessary licenses and/or approvals as may be required by law;
  • Which is technically harmful (including, without limitation, files that contain viruses, corrupted files or any other similar software or programs that may damage the operation of another’s computer); or
  • Impersonating any person or entity, or falsely stating or otherwise misrepresenting your affiliation with anyone or any entity.
  • Deleting any author attributions, legal notices or proprietary designations or labels in any file that is uploaded;
  • Falsifying the origin or source of software or other content contained in a file that is uploaded;
  • Advertising or offering to sell any goods or services, or conducting or forwarding surveys, contests or chainletters, or downloading any file posted by another user of UNHCR websites that you know, or reasonably should know, cannot be legally distributed in such a manner.Any inappropriate content will be rejected or removed from Ewaa websites and social media accounts. If in doubt, please do not share your content with Ewaa. If you post on, or transmit to, any of our websites any content of the type prohibited under the above paragraphs or any applicable laws and regulations, and Ewaa incurs any costs, expenses, liability or losses as a result then you agree to indemnify Ewaa for all such costs, expenses, liability or losses.You should be aware that Ewaa is entitled to reveal your identity (or any information which it has about you) to any third party who is claiming that any of that content violates any of their rights or to any government or regulatory authority that may request Ewaa to do so.

Uploading Content to Social Networks

If you upload content to a social network and then tag Ewaa, your submission will be subject to that website’s terms of use and privacy policy. Please be aware of a website’s terms and privacy policy, which may differ from Ewaa’s, when submitting your content to it. Some large UGC websites are also based in the US so your personal information may be stored outside your country where different laws apply.

11. INFORMATION FROM MINORS

In Short: We do not knowingly collect data from children under 16 years of age.

We do not knowingly solicit data from children under 16 years of age. By using the Ewaa website, you represent that you are at least 16 years of age or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Ewaa website.

If we learn that personal information from users less than 16 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 16, please contact us at info@ewaa.gov.ae.

12. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

13. PRIVACY RIGHTS – EEA

In Short: In some regions, such as the European Economic Area (EEA) and United Kingdom (UK), you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.

In some regions (like the EEA and UK), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information.

To make such a request, please use the contact details provided below. We will consider and act upon any request in accordance with applicable data protection laws.

If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.html.

If you are a resident in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.

14. PRIVACY RIGHTS – CALIFORNIA RESIDENTS

In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with the Ewaa website, you have the right to request removal of unwanted data that you publicly post on the Ewaa website. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Website, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g. backups, etc.).

15. CHANGES TO THIS POLICY

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We will occasionally update this policy to reflect changes in our privacy policy. When we post changes to this policy, we will revise the “Last Updated” date at the top of this policy. If we make any material changes in the way we collect, use, and/or share information held in cookies, we will notify you by prominently posting notice of the changes on www.ewaa.gov.ae. We recommend that you check this page from time to time to inform yourself of any changes in this policy or any of our other policies.

16. CONTACT US

If you have any questions or comments about this policy, or privacy matters generally, please contact us via email at info@ewaa.gov.ae or this address: 15th Floor, Daman Building, ADNEC Area, PO Box 30039, Abu Dhabi, United Arab Emirates.