Privacy Notice
1. Introduction and Scope
This privacy notice explains how DP World and its affiliated companies (“us” or “we” or “our”) use personal information about you (and the other parties with whom we may share it with) when:
- you use and interact with our website;
- you are our customer/client;
- you are our vendor/supplier;
- you use our any of our applications (“Apps’);
- you are involved in our filming or taking photographs of you;
- we market to you;
- you are our partner; and
- use of Artificial intelligence (“AI”)
It also tells you about your rights and choices with respect to your personal information, and how you can contact us about our privacy practices.
You can see DP World affiliates by going to the “annual report” section here: DP World Investors | Stocks & Shares | DP World.
If you provide us with the personal information of anyone else, we ask that you provide this privacy notice to them so that they can understand how we process their personal information.
Our privacy practices may vary among the territories in which we operate to reflect local practices and legal requirements. Additional disclosures that must be made by us under those applicable local laws can be found in the annexes attached to this privacy notice.
2. Data Controller
A data controller (or other synonymous definition under your national data protection legislation) is the entity who decides the means and purpose for which your personal information will be processed.
As a data controller, we collect personal information and process it in accordance with relevant data protection principles, including lawfulness, fairness and transparency; purpose limitation; collection limitation; data minimization; accuracy; rectification measures; storage limitation; integrity and confidentiality (security), with all relevant laws and regulations considered.
3. Further Information
For any further information regarding this privacy notice, please email eur.dataprotection@dpworld.com
4. Information We Collect From Or About You, Why We Use It And Where We Get It From
We collect and process different types of personal information, which we set out in the table below together with the lawful basis for our use of your information and the source of such information. Please read the below table in conjunction with the respective annexes of this privacy notice.
Note: In conjunction with and in certain circumstances instead of, where we are required to do so due to jurisdictional requirements, we will process your personal information based on your consent.
| Data Subject | Processing Activities | Information we use | Purpose / activity | Lawful basis / condition | Source of information |
|---|---|---|---|---|---|
Website Users |
Provide a website |
IP address, details of visits to Our Website, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, the full Uniform Resource Locators (URL), clickstream to, through and from Our Website and the date and time of the clickstream, products or services you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (scrolling, clicks, and mouse-overs) and methods used to browse away from the page |
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Note: please visit our Cookies Policy | DP World for information on consent and cookies |
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Customer/Clients – potential or actual (includes but is not limited to carriers, shippers, freight forwarders, etc.) |
Negotiating/entering into an agreement with us, us providing services to you and us better understand you as a Customer/Client |
Names, address, job title/position/role, contact details, gender, nationality, data of birth, order number, IP address, identification documents, tax identification number, financial information, screening information, KYC documentation, profile ID/picture. |
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Vendors/Suppliers - potential or actual (includes but is not limited to sellers, contractors, agents etc) |
Negotiating/entering into an agreement with us, and you providing services to us |
Names, address, employer, job title/position/role, contact details, driving license, health information, qualifications, gender, order number, IP address, identification documents, tax identification number, financial details, screening information. |
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Partners including but not limited to:
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Entering into and carrying out partner relationships |
Name, contact details. identification details, |
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All Users of our Apps |
Use of our Apps |
Name, contact information, login details (e.g., email, phone number, password), location data, your personalized settings in our app, information about your use (e.g., errors, interaction information (such as scrolling and clicks), images, voice and video recordings, feedback and opinions. |
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All individuals that we market to |
Marketing |
Name, contact details e.g. telephone number, email address, fax machine number, behavioural data, demographic data, contextual data, predictive data |
To provide marketing materials via newsletters, electronic or analogue communication, via our apps or social media. This will include receiving information, notifications, newsletters, offers, or similar, depending on our relationship and your personal preferences. Depending on our relationship, we use:
The marketing in newsletters, in our apps, and on our websites, including social media, is adapted based on our relationship and your personal preferences based on our knowledge of you through profiling, which includes the use of:
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All individuals that we use Artificial Intelligence with (“AI”) |
Use of Artificial AI |
name, title, contact details, other profile information, correspondence, images and voice recordings, as the case may be and your data privacy requirements or privacy settings, interactions with you |
We harness the power of artificial intelligence (AI) to enhance many of our products and services designed to boost productivity by providing assistance across multiple areas. This includes the incorporation of generative AI features such as ChatGpt and Claude Sonnet. We gather data from interactions with you. The data collected, processed and/or generated varies based on your interactions, privacy settings, and/or the features used. You can choose what products/services to use and the data to share. You may decline to provide personal information, but some interactions need it to function. If you don't provide the required data, you may not be able to use some products or services. Similarly, if we need personal information by law or for a contract, and you don't share it, as a result, we may be unable to enter into the contract or may suspend or cancel an existing service. We will inform you if this happens. |
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All individuals who we take videos or photographs of (including using the likeness of the individual) |
Taking videos or images of individuals for use in our promotional materials/publications |
Live images, videos, still images, likenesses (“images”) |
We use this information to place images across our portfolio of websites, promotional materials and publications for advertising and marketing purposes |
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You are not under a legal obligation to provide us with any of the above personal information but please note that if you elect not to provide us with the personal information, we may be unable to provide our products or services to you.
5. Disclosing, Sharing and Transferring Personal Information
We use third party service providers in connection with providing our services to you. We have contracts in place with third-party service providers we use, that strictly govern how they use the personal information we disclose to them.
Where we transfer your personal information to third parties outside of the jurisdiction you are in, we shall do so only where there are adequate provisions to ensure your privacy. Where the jurisdiction is not considered adequate by the relevant authorities, we put in place alternative contractual measures including standard contractual clauses approved under the relevant laws.
The below indicates the categories of organisations to whom we may disclose information about you, the reason we disclose this information and what information is shared with them.
Affiliates - We may disclose personal information to our affiliated companies for the purposes described in this privacy notice. Affiliates are those companies that are under common control of our parent company DP World FZE. You can see DP World affiliates by going to the “annual report” section here: DP World Investors | Stocks & Shares | DP World.
Third Parties – We may use third parties to provide services to us which may require disclosure of your personal information to such third parties. This includes but is not limited to IT service providers, professional advisors, analytics and search engine providers, credit reference and marketing agencies. If we allow a third party to have access to your personal information, they will only be permitted access for purposes that are consistent with this privacy notice and will be required to protect your personal information in accordance with all applicable data protection laws.
Law enforcement - In certain circumstances, we may be called upon to release your personal information in response to a court order, subpoena, search warrant, law or regulation. We plan to cooperate in responding to such requests, taking appropriate measures to ensure that the requester understands the sensitive nature of the personal information that they may receive. We also reserve the right to cooperate with law enforcement authorities in investigating and prosecuting users who violate our rules or engage in behaviour that is illegal or harmful to individuals or the personal information we are responsible for.
Corporate transactions - We may disclose your information to a third party in connection with a corporate reorganisation, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock, including in connection with any bankruptcy or similar proceedings.
6. Data Retention
We store your personal information for as long as it is necessary to fulfil the purpose of the use, unless we are obliged under applicable laws and regulations or are entitled to store the personal information for a longer period. More specifically:
- we retain your personal information as long as we have an ongoing relationship with you (in particular, if you have an account with us or have not withdrawn your marketing consent);
- we will only keep the personal information while your account is active or for as long as needed to provide services to you or for you to provide services to us;
- we retain your personal information for as long as needed in order to comply with our global legal and contractual obligations; and
- we will also retain your personal information where this is advisable to safeguard or improve our legal position (for instance in relation to statutes of limitations, security, litigation, or regulatory investigations).
7. Artificial Intelligence (AI)
By leveraging the robust capabilities of AI, we remain committed to innovating while upholding the highest standards of responsible AI use and data privacy. Such processing is based on our legitimate interest or your consent given to us, where applicable laws allow us to use it. Accountability, fairness, and transparency are essential to our AI practices. Our accountability measures include rigorous oversight and governance structures that monitor AI deployment and usage. This ensures users understand and trust the technology. By continuously testing and validating the performance and outcomes we believe that we use AI technology in a fair, equitable and unbiased manner. We are open about what AI algorithms and models we use, the data used, and the decisions made. By adhering to these standards, we ensure that our AI initiatives are conducted with integrity and respect for user privacy and data protection. We remain committed to leveraging AI in ways that enhance our services while maintaining the highest standards of ethical and compliance conduct.
To ensure compliance with local requirements, you can find additional information on our local applications/websites, where required by local law.
8. Your Rights
Data protection law grants you certain rights which we summarise in the table below. Please note that these rights are not absolute, and they may not always apply in your particular circumstances. To exercise your rights, please email us at eur.dataprotection@dpworld.com. We may need to request specific information from you to help us confirm your identity and ensure your entitlement to such rights. This security measure is to ensure that your personal information is not disclosed to any person who has no right to receive it.
| Right of access and data portability | You have the right of access to personal information we hold about you and/or to have it transferred to another data controller in some circumstances |
| Right of rectification or erasure | If you feel that any personal information that we hold about you is inaccurate you have the right to ask us to correct or rectify it. You also have a right to ask us to erase personal information about you |
| Right to restriction of processing | You have a right to request that we refrain from processing your personal information in certain circumstances |
| Right to object | You have a right to object to our processing of your personal information |
| Right to withdraw consent | You have the right to withdraw your consent for the processing of your personal information where the processing is based on consent |
| Right not to be subject to automated decision making | You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning yourself or similarly significantly affects |
| Right of complaint | If you are unhappy with the way we have used or are handling your personal information you have the right to lodge a complaint with your supervisory authority. We would, however, appreciate the chance to deal with your concerns before you approach the supervisory authority, so please contact us in the first instance at the email set out above |
Please note that some of these rights are limited by applicable data protection law and we have the right to collect, process and hold your personal information to perform our legal obligations.
China Annex
1. Introduction and Scope
This annex (“China Annex”) to DP World’s Website, Customer, Vendor & Partner Privacy Notice Global Privacy Policy (“Global Notice”) applies to you if your personal information is being processed in the People’s Republic of China (“China”) by DP World China Co., Ltd, or DP World Management Consultation (Shanghai) Co Limited (collectively referred to as “DPW China”), which are subject to data protection laws and regulations of China, including the Personal Information Protection Law (“PIPL”).
2. Data Controller
Pursuant to the PIPL the synonymous term for a data controller is a personal information processor.
3. Information We Collect From or About You, Why We Use It, and Where We Get it
We will process your personal information based on your consent, unless we are allowed to process your personal information without your consent as permitted by the PIPL, including:
- where it is necessary for the conclusion or performance of a contract to which you are a contracting party;
- where it is necessary for carrying out human resources management under an employment policy legally established or a collective contract legally concluded;
- where it is necessary for performing statutory responsibilities or statutory obligations;
- where it is necessary for responding to a public health emergency, or for protecting the life, health or property safety of the natural person in the case of an emergency;
- where the personal information is processed within a reasonable scope to carry out any news reporting, supervision by public opinions or any other activity for public interest purposes;
- where the personal information which has already been disclosed by you or otherwise legally disclosed, is processed within a reasonable scope and in accordance with the PIPL; or
- any other circumstance as provided by laws or regulations.
A list of the types of personal information we collect and process, and the source of the information can be found in the Global Notice.
In the event we require sensitive personal information as defined by the PIPL, we will obtain your separate consent prior to collection and processing. PIPL defines sensitive personal information as personal information that is likely to result in damage to the personal dignity of any natural person or damage to his or her personal or property safety once disclosed or illegally used, including such information as biometric identification, religious belief, specific identity, medical health, financial account and whereabouts and tracks, as well as the personal information of minors under the age of 14.
4. Disclosure, Sharing & Transferring Personal Information
To fulfill the purposes indicated in the Global Notice, we may need to transfer your personal information to our affiliated entities located outside of China, including, but not limited to, DP World China Holdings Limited located in Hong Kong, DP World Asia Pacific Pte. Ltd. in Singapore, and DP World FZE in Dubai, UAE, where it will be processed by staff operating outside of China who work for us or one of our suppliers for purposes described in the Global Notice. These entities may be contacted by emailing eur.dataprotection@dpworld.com.
In accordance with applicable legal requirements, we will seek your consent before exporting your personal information. You have the right to refuse or withdraw your consent. Please note that this may impact the services we can provide to you, depending on the circumstances and applicable laws.
When exporting your personal information to jurisdictions outside of China, we will implement appropriate measures as required by applicable laws, including, but not limited to, conducting risk assessments, and entering into applicable contracts.
India Annex
1. Introduction and Scope
This annex (“India Annex”) to DP World’s Website, Customer, Vendor & Partner Privacy Notice Global Privacy Policy DP World’s Global Privacy Policy (“Global Notice”) applies to you if your digital personal information is being processed (a) within the territory of India (“India”) or (b) outside of India in connection with the offering of goods or services to you in India by DP World Limited, Hindustan Infralog Private Limited, Hindustan Ports Private Limited and/or any of their direct or indirect subsidiaries which are subject to data protection laws and regulations of India (collectively referred to as “DPW India”), including the Digital Personal Data Protection Act (“DPDPA”).
2. Data Controller
Pursuant to the DPDPA the synonymous term for a data controller is a data fiduciary.
3. Information We Collect From or About You, Why We Use It, and Where We Get it
We will process your personal information for certain legitimate uses as defined by the DPDPA, including instances where you voluntarily give your personal information for a specific purpose and you do not object to the processing activity. For all other purposes we will process your personal information based on your consent. A list of the types of personal information we collect and process, and the source of the information can be found in the Global Notice.
4. Your Rights
In addition to any applicable rights listed in the Global Notice, you have:
- the right to nominate another other individual who may exercise your privacy rights in the event of your death or mental or physical incapacity; and
- the right to grievance addressal.
Grievances regarding our processing of your personal information and/or handling of your rights may be submitted to eur.dataprotection@dpworld.com. To the extent you have exhausted this right you may make a complaint to the Data Protection Board of India.