Al Dobowi Privacy Notice
Al Dobowi Group takes the privacy and security of personal information seriously and is committed to ensuring it is compliant with Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data, the General Data Protection Regulation.
This Privacy Notice sets out how Al Dobowi Group processes and protects the personal data of all individuals with whom it comes into contact, other than its own employees. This includes individuals who are, or who are engaged by, Al Dobowi Group’s customers, suppliers and other third parties, or with whom it otherwise deals. This Privacy Notice includes the information which the General Data Protection Regulation requires Al Dobowi Group to provide, including a statement of the rights of such individuals.
Personal Data or Personal Information: means information capable of identifying an individual, being “personal data” as defined in the General Data Protection Regulation
Processing (and cognate expressions) means any operation we perform on Personal Data, including, but not limited to, collection, organising, storing, updating, using, disclosing and erasing it.
Who we are and How to Contact Us
This Privacy Notice is issued by Al Dobowi Group, comprising the following companies:
- Infinity Tyres Nigeria (Infinity Group)
- African Automotive Limited – Nigeria (Infinity Group)
- Tyreplus Industries – Nigeria (Infinity Group)
- Infinity Tyres (Ghana) Limited (Infinity Group)
- West African Automotive T.L.L. – Ghana (Infinity Group)
- Tyreplus Industries Limited – Ghana (Infinity Group)
- Eternity Technologies South Africa
- Eternity Technologies Inc (U.S.)
- Eternity Technologies South America S.P.A. (Chile)
- Eternity Rubber (Qingdao) Co. Ltd. (China)
- Eternity Industrial Batteries (India) LLP
- Eternity Technologies Singapore
- Eskay Spain SLU
- Eternity FZ LLC
- Eternity LLC – Dubai
- Eternity Technologies Manufacturing Germany
- Eternity Technologies GmbH (Germany)
- Eternity Technologies Ibérica, S.A. (Spain)
- Eternity Technologies Limited (UK)
- Al Dobowi FZE
- Al Dobowi Oilfield Equipment Trading LLC
- Al Dobowi LLC
- Al Dobowi Tyres Co. LLC
- Exide Al Dobowi Batteries LLC
- Trelleborg Wheel Systems Middle East Ltd.
- Kays Trading Co. LLC
- Eternity Technologies FZ LLC (Middle East)
- General Automotive KSA (GTR)
- General Automotive KBH (GTR)
- General Batteries Co. Ltd. (GTR)
- General Retreads (GTR)
- General Industries (GTR)
Al Dobowi Group’s contact details are as follows: Al Dobowi Group, P.O.Box 61348, Jebel Ali Free Zone, Dubai, United Arab Emirates
Each such company is the data controller of the Personal Data which it processes. References in this Privacy Notice to Al Dobowi Group are to the applicable company, or, where the context requires, to all companies within Al Dobowi Group.
In relation to Al Dobowi Group’s processing of Personal Data or any other data protection or data privacy matters, Al Dobowi Group’s contact detail is firstname.lastname@example.org
Purposes for which Al Dobowi Group Processes Personal Data
Al Dobowi Group holds and further processes Personal Information on its customers, suppliers and individuals engaged by them and others with whom it deals, such as names, contact details and bank/account details, in order to:
- manage its relationship with its customers, including providing them with products and/or services, communicating with them and maintaining its relationship with them
- manage its relationship with its suppliers, including procuring products and/or services from them, communicating with them and maintaining its relationship with them
- managing relationships with intermediaries and other third parties
- informing customers and potential customers about its products and services, including by direct marketing
- inviting relevant individuals to events
- informing suppliers and potential suppliers about its requirements
- to provide features or tools on its websites
- to develop and improve its products and services
- to track purchase history
- for account and promotional purposes
- if necessary, to comply with any legal obligations it may have including requests from law enforcement agencies or to comply with legal processes
- for internal administration
- to detect and prevent fraud
- ensuring information and networking security
- to exercise its rights
- to protect the rights, property or personal safety of its employees, third parties, business partners and the general public
- purposes related to its proposed corporate activities, such as a sale or merger.
These are referred to in this Privacy Notice as the purposes of processing.
Legal bases for Al Dobowi Group’s processing of Personal Data
The legal bases on which Al Dobowi Group Processes Personal Data are as follows, depending on the purpose of the processing:
- Legitimate Interests. In most cases, the purposes set out above represent the legitimate interests of Al Dobowi Group in operating its business and the processing is necessary to achieve them and does not override the interests, fundamental rights or freedoms of the individuals concerned.
- Performance of a contract. Sometimes Al Dobowi Group needs to process Personal Data to perform a contract to which the individual is a party or to take steps at the individual’s request before entering into a contract, for example to provide goods or services to customers who are individuals or to purchase goods or services from suppliers who are individuals.
- Legal Obligation. Al Dobowi Group may need to process Personal Data to comply with a legal obligation, such as an enforceable request from Government.
- Consent – in certain specific situations, Al Dobowi Group may process Personal Data as a result of having obtained the specific freely given consent of the individual concerned. When doing so, Al Dobowi Group will inform the individual of the purpose of the processing and the individual can withdraw consent at any time.
Recipients of Personal Data
Al Dobowi Group may disclose or transfer Personal Data to the following recipients:
- third-party service providers for the purposes of providing services to Al Dobowi Group itself, which may include I.T. maintenance and service providers and providers of Finance and Accounting software systems or services;
- third-party service providers for the purposes of providing services to the customers and suppliers of Al Dobowi Group or other persons with whom it deals;
- other members of Al Dobowi Group or other companies or organisations under common ownership with Al Dobowi Group in either case, for administrative or internal purposes and/or so that they can contact individuals or those engaging them with information about products or services which may be of interest to them; or
- authorities and other bodies who can compel Al Dobowi Group to do so under applicable law.
Al Dobowi Group will not sell Personal Information to third parties unless it has the specific consent of the individual concerned to do so.
Transfer of Personal Data outside the EU
Al Dobowi Group may transfer Personal Data outside the EU, for example where any of the recipients described above are located outside the EU or in respect of Al Dobowi Group’s own operations outside the EU. Non-EU countries do not have the same data protection laws as the EU and therefore often do not provide the same safeguards. On occasion, such transfer is necessary to perform a contract with an individual. In other cases, where such transfer occurs, Al Dobowi Group will ensure at least one of the following safeguards is implemented:
- the transfer is to a country that has been deemed to provide an adequate level of protection for Personal Data by the European Commission; or
- Al Dobowi Group transfers the Personal Data under a specific contract with the recipient in a form adopted by the European Commission or adopted by a supervisory authority and approved by the European Commission, for example the standard contractual clauses issued under decision 2001/497/EC, decision 2004/915/ or decision 2010/87/EU; or
- Al Dobowi Group transfers the Personal Data under approved binding corporate rules of Al Dobowi Group; or
- where the transfer is to the USA, the recipient is within the EU-US Privacy Shield.
Copies of the relevant safeguards can be obtained from Al Dobowi Group using the contact details set out above.
Period of storage of Personal Data
Al Dobowi Group will not keep personal information for longer than is necessary for the purposes for which it processes it. This is determined in accordance with its retention policy.
The criteria used to determine the retention periods of Al Dobowi Group include: (i) the nature of the Personal Data; (ii) the length of time Al Dobowi Group has a continuing relationship with the individual or the organisation engaging the individual; (iii) whether there is a legal obligation to which Al Dobowi Group is subject requiring it to retain the Personal Data (iv) whether retention for a period is advisable in light of the Al Dobowi Group Companies legitimate interests (such as with regard to applicable statutes of limitations or regulatory investigations).
Based on the above, Al Dobowi Group’s policy is to retain Personal Data about individuals for three (3) years from the last contact with the individual or organisation concerned except where it relates to statutory, regulatory, legal or security reasons or if it includes a transaction or financial data in which case Al Dobowi Group retain it for up to seven (7) years from the data of the transaction or last active use of the financial data.
Rights of Individuals in relation to their Personal Data
Individuals have the following rights where Al Dobowi Group processes their Personal Data
- to obtain confirmation as to whether or not Al Dobowi Group processes their Personal Data
- to access a copy of their Personal Data that Al Dobowi Group does process
- to request the correction of inaccurate Personal Data held by Al Dobowi Group
- to request that Al Dobowi Group erases their data or to object to Al Dobowi Group continuing to process it
- where Al Dobowi Group relies on having obtained consent for the purposes of the processing, the right to withdraw such consent, without affecting the lawfulness of processing before such withdrawal
- in certain cases, to receive Personal Data, which they have provided to Al Dobowi Group, in a structured, commonly used and machine-readable format and to transmit it to another controller or have it directly so transmitted
- to lodge a complaint with their local data protection regulator — in the UK, this is the Information Commissioner’s Office, https://ico.org.uk/.
Should individuals have any queries regarding Al Dobowi Group’s Privacy Notice, the processing of their personal data or wish to exercise their rights they should contact Al Dobowi Group directly using the following email address: email@example.com