Additional GDPR Provisions for EEA Individuals

Where the General Data Protection Regulation (EU) 2016/679 (“GDPR”) applies to our processing of personal data, the following additional provisions apply.

Data Controller

For personal data collected in connection with enquiries, consultations, lead-generation activities and services offered through this website and ADAM Global’s advertising activities, Adam Global Corporate Services LLC acts as the data controller where it determines the purposes and means of processing your personal data.

For privacy-related enquiries, you may contact us at info@adamglobal.ae.

Lawful Basis for Processing

Where the GDPR applies, we process personal data only where we have a lawful basis to do so. Depending on the circumstances, this may include:

• Contractual necessity – where processing is necessary to provide services to you or to take steps at your request before entering into a contract.

• Legal obligation – where processing is necessary to comply with applicable legal, regulatory, tax, accounting, compliance or other statutory requirements.

• Legitimate interests – where processing is necessary for our legitimate business interests, including managing enquiries and client relationships, improving our services, maintaining security, preventing fraud and protecting our business, provided those interests are not overridden by your rights and freedoms.

• Consent – where you have provided consent for a specific processing activity, including where consent is required for certain marketing communications.

Where we rely on consent, you may withdraw your consent at any time. Withdrawal will not affect the lawfulness of processing carried out before your consent was withdrawn.

Information Submitted Through Advertising and Lead Forms

Where you submit an enquiry through an advertisement or lead-generation form operated by a third-party platform, including Facebook or Instagram, we may receive the information that you provide through that form.

We use this information to respond to your enquiry, assess your requirements, provide requested information or consultations, and manage our relationship with prospective and existing clients.

Third-party platforms may process personal data independently in accordance with their own privacy policies and terms.

Sharing of Personal Data

We may share personal data, where necessary and permitted by law, with:

• ADAM Global entities involved in responding to your enquiry or providing requested services;

• service providers supporting our CRM, information technology, hosting, communications, analytics and business operations;

• advertising, lead-generation and communication platforms used in connection with our marketing activities;

• professional advisers, including legal, accounting, audit and compliance advisers; and

• government authorities, regulators, courts or law-enforcement authorities where disclosure is required or permitted by law.

Where third parties process personal data on our behalf, we take appropriate steps to require them to protect personal data in accordance with applicable data-protection requirements.

International Transfers of Personal Data

As ADAM Global operates internationally, your personal data may be transferred to or processed in countries outside the European Economic Area (“EEA”), including the United Arab Emirates.

Where the GDPR applies to such transfers, we use an appropriate lawful transfer mechanism and safeguards as required under applicable data-protection law. These may include European Commission-approved Standard Contractual Clauses or other legally recognised transfer mechanisms, where applicable.

You may contact us at info@adamglobal.ae for further information regarding safeguards applicable to international transfers of your personal data.

Additional Rights Under the GDPR

In addition to the rights described elsewhere in this Privacy Policy, where the GDPR applies you may also have the right, subject to applicable legal conditions, to:

• request restriction of the processing of your personal data;

• object to processing based on legitimate interests;

• object at any time to the use of your personal data for direct marketing;

• receive certain personal data in a structured, commonly used and machine-readable format and request data portability where applicable;

• withdraw consent at any time where processing is based on your consent; and

• lodge a complaint with a competent data-protection supervisory authority.

You generally have the right to lodge a complaint with a supervisory authority in the EU Member State of your habitual residence, your place of work, or the place of the alleged infringement.

Requests relating to these rights may be submitted to info@adamglobal.ae. We may request appropriate information to verify your identity before processing certain requests.