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Privacy Policy

Last modified: 12 April 2017

The Dubai College of Tourism LLC and its affiliates (“DCT” or “we”) are committed to providing a high standard of service to our customer and respecting the privacy of individuals that use or benefit from our services.

The purpose of this Privacy Policy is to inform individuals that enrol onto the DCT's Learning Management System and use its associated platforms (collectively, "LMS") about how we collect, use and protect personal information relating to them (“personal information”) when they access and use the LMS. In this Privacy Policy, we refer to an individual that enrols on the LMS as a "Student" or "you".

This Privacy Policy should be read together with the LMS Terms and any other documents referred to in it.

In this Privacy Policy, "personal information" has the meaning given to it (or the term "personal data") under applicable law. Generally this means information relating to an individual, from which the identity of that individual can be ascertained (directly or indirectly). For example, names and contact details are generally considered "personal information".

Your privacy matters to us, so if you have any questions please contact us at dubaiway@dct.ac.ae.
Acceptance and Management of Personal Information

By enrolling on the LMS, you acknowledge and agree to the terms of this Privacy Policy and consent to us collecting and using your personal information in the manner described in it.

Personal information we collect about you

We collect and use the following types of personal information:

Information you give to us:To enrol on a Course we will ask you to provide the following information:

  • Your full name;
  • Your email address;
  • Your mobile number;
  • Your Emirates identity card number or passport number;
  • The name of your employer and/or your employer's establishment code;
  • Your job role; and
  • Date of birth.

 

You may not be able to complete enrolment without the above information.

Information provided by your employer: Your employer may nominate you for enrolment on a Course. If your employer does this, we will receive your full name and Emirates ID number or passport number from your employer. You will still need to provide the above personal information to us in order to enrol in a Course, and we will use the information provided by your employer to verify your eligibility for enrolment.

Information collected through your participation in a Course: We record your progress during a Course, including the learning outcomes you have completed and the assessments you have undertaken (including your responses and your assessment scores). We may also require you to use a webcam during assessments, in which case we will collect the recording of you sitting the assessment in order to ensure fairness of test conditions among all Students.

Information we collect about you through your use of the LMS: We collect information about your use of the LMS through the use of online cookies and other similar technologies. For more detail on this please see the following and our Privacy Policy.

The information we collect through cookies and other similar technologies may include (i) internet protocol address, (ii) device-specific information (such as your hardware model, operating system version, unique device identifiers, and mobile network information including phone number), (iii) device event information such as crashes, system activity, hardware settings, browser type, browser language, the date and time of your request and referral URL, (iv) cookies or similar technologies that may uniquely identify your browser or your LMS user account; (v) information (including personal information) locally on your device using mechanisms such as browser web storage (including HTML 5) and application data caches.

You may set your browser to block all cookies, including cookies associated with the LMS, or to indicate when a cookie is being set by us. However, it’s important to remember that many of our services may not function properly if your cookies are disabled. For example, we may not remember your preferences and certain content may not display properly.

We may also collect and process your location information through various technologies such as Wi-Fi access points and mobile location services.

Purposes for which we use your personal information

We use your personal information:

  • to register your enrolment on a Course;
  • to ensure that Course content is relevant to you;
  • to create a user profile for you in the LMS so that you can access the LMS;
  • to verify your identity and eligibility to enrol for the Course;
  • to allow you to participate in interactive features of our service, when you choose to do so;
  • to notify you when you have completed the Course (or specific learning outcomes) and to send you a certificate of accreditation when you have passed the Course;
  • to send you reminders or otherwise contact you about the Course;
  • to notify you about changes to the LMS, the LMS Terms or this Privacy Policy;
  • to provide updates to your employer;
  • to ensure that content from the LMS is presented in the most effective manner for you and for your computer;
  • to prevent, detect and take action against cheating on any Course assessments;
  • for data analysis, testing, research, statistical and survey purposes;
  • to improve the LMS and our Courses;
  • as part of our efforts to keep the LMS safe and secure;
  • to measure or understand the effectiveness of advertising we serve to you and others, and to facilitate the delivery of relevant advertising to you on the LMS or third party online properties;
  • to provide you with the information, products and services that you request from us;
  • to respond to your questions, comments and requests;
  • where you have indicated your consent, to provide you, or permit selected third parties to provide you, with additional services and/or information about additional services that may interest you (see Marketing section below);
  • to comply with any applicable law;
  • to cooperate with or comply with orders or requests from regulators or law enforcement bodies;
  • to enforce, protect, or defend the legal rights or property of DCT, Lobster, our customers, Students and/or any other persons; and/or

 

  • for purposes relating to any of the above.

Who we share your personal information with

We keep your personal information confidential, but we may disclose your personal information to the following third parties in connection with the purposes described above:

  • Your employer.We will disclose your full name, Emirates ID number or passport number, and other similar personal information to your employer in order to confirm your eligibility for the Course and to enable us to charge your employer for the Course. We may also disclose information about your progress on a Course to your employer, for example when you complete a Course.

 

  • The DNRD. We disclose your full name, Emirates ID number (if you have one) and other similar personal information to the General Directorate of Residency and Foreigners Affairs ("DNRD") to verify your identity.
  • Contractors. We may disclose your personal information to agents, contractors and suppliers that provide services such as analytics, hosting, IT support and other services to DCT from time to time. For example, if you have problems logging into the LMS and require IT support, your personal information may be provided to a third party contractor to provide that support. DCT uses a platform owned and operated by Lobster International S.A. or an affiliate thereof ("Lobster") and Lobster may have access to your personal information in the operation of this platform.

 

  • Regulators, governmental bodies, law enforcement agencies or industry bodies. We would only disclose your personal information to such an entity if we had a reasonable suspicion of wrongdoing (on the part of you or a third party) or if such an entity were to order or request disclosure.
  • Selected third parties in the event of a business sale, purchase or restructuring. In the event that DCT sells or buys any business or assets, we may disclose your personal information to the prospective seller or buyer of such business or assets. You also agree that if DCT or substantially all of its assets are acquired by a third party, personal information held by it will be transferred to the acquirer as an asset.

 

We may share non-personally identifiable information publicly and with our partners, like publishers, advertisers or connected websites. For example, we may share information publicly to show trends about the general use of our services.

Marketing

Where you have indicated your consent, we (and permitted third parties) may contact you for direct marketing purposes via post, telephone, email, SMS/MMS, push notifications, and social media channels such as Facebook, Twitter and Whatsapp.

This marketing may relate to:

• additional products and services we (or permitted third parties) feel may interest you;

• information about other goods and services we offer that are similar to those that you have already used or enquired about; and

• upcoming events, promotions and new products/services or other opportunities as well as those of selected third parties.

If you are an existing customer, we will only contact you by electronic means without seeking your consent in advance (including but not limited to telephone, e-mail, SMS/MMS, push notifications, and social medial channels such as Facebook, Twitter and Whatsapp) with information about services similar to those which were the subject of a previous dealing with you.

If you no longer wish to receive marketing communications from us you may unsubscribe by following the unsubscribe link in our email communications or by requesting us to remove you and your personal information collected electronically from our database(s) by emailing dubaiway@dct.ac.ae.

Retention

We do not retain personal information for longer than required to fulfil the purposes set out in this Privacy Policy, or to comply with the law.

Links to Other Websites

We are not responsible for the practices employed by websites or services linked to or from our websites, including their data collection practices or privacy policies. Please remember that when you use a link to go from our websites to another website, our Privacy Policy does not apply to third-party websites or services. Your browsing and interaction on any third-party websites or service, including those that have a link or advertisement on our websites, are subject to that third party’s own rules and policies. In addition, you agree that we are not responsible and we do not have control over any third-parties that you authorize to access your user content. If you are using a third-party website or service (like Facebook, Twitter, Instagram, or Google groups etc.) and you allow such a third-party access to your user content you do so at your own risk.

Where we store your personal information

The data that we collect from you may be transferred to, stored and otherwise processed on servers located outside the country in which you reside and which may be based in locations both within and outside of the UAE.

Contact us with Your Questions and Comments

If you elect to contact us with any questions, comments or requests using one of our online forms, you will need to provide your full name, telephone number and e-mail address so that we can be sure to be able to contact you. Depending on which online form you complete, you may be given the opportunity to provide additional information that will allow us to serve you better, although the additional information might not be required in order for you to complete and submit the online form.

You can also contact us by simply sending an e-mail addressed to dubaiway@dct.ac.ae .
Security

We will take reasonable steps to protect the personal information that we hold from misuse, loss, or unauthorized access including by technical means such as firewalls, password access and secure servers as well as by physical and administrative safeguards

Unfortunately, there is always risk involved in sending information through any channel over the internet. You send information over the internet entirely at your own risk. Although we will do our best to protect your personal information, we cannot guarantee the security of your data transmitted over the internet and we do not warrant the security of any information, including personal information, which you transmit to us over the internet.

If you suspect any misuse or loss of, or unauthorized access to, your personal information, please let us know immediately.

Compliance and cooperation with regulatory authorities

We regularly review our compliance with our Privacy Policy. When we receive formal written complaints, we will contact the person who made the complaint to follow up. We work with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of personal information that we cannot resolve with our users directly.

Privacy Policy Changes

In the future, we may revise or amend this Privacy Policy at any time by amending this page. All changes will be made here so you will always know what information we gather, how we might use that information and whether we will disclose it to anyone. Some of the provisions contained in this Privacy Policy may also be superseded by provisions or notices published elsewhere on our websites.

Your continued use of the LMS following the posting of changes to these terms will mean you accept those changes.

Access and correction requests

You may request access to your personal information held by us. Please contact us at dubaiway@dct.ac.ae to do this.

In addition, you are able to update and amend your personal information held by us at any time by emailing dubaiway@dct.ac.ae.

Students and applicants in the EU

Please refer to the Schedule to this Privacy Policy which contains additional terms applicable to Students and applicants in the EU.

Questions Concerning this Privacy Policy

If you have questions regarding this Privacy Policy, please feel free to e-mail us at dubaiway@dct.ac.ae.


SCHEDULE

Provisions applicable to Students and applicants who are in the European Union:

1. Legal basis for the processing of personal data for the purposes named above ("purposes for which we use your personal information") and – in case of a justification based on legitimate interests (art. 6, nr. 1, f) – the legitimate interests pursued by DCT or a third party:
• to register your enrolment on a Course:
Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract, Art. 6, nr. 1, b GDPR
• to ensure that Course content is relevant to you:
Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract, Art. 6, nr. 1, b GDPR
• to create a user profile for you in the LMS so that you can access the LMS;
Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract, Art. 6, nr. 1, b GDPR
• to verify your identity and eligibility to enrol for the Course:
Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract, Art. 6, nr. 1, b GDPR
• to allow you to participate in interactive features of our service, when you choose to do so:
Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract, Art. 6, nr. 1, b GDPR
• to notify you when you have completed the Course (or specific learning outcomes) and to send you a certificate of accreditation when you have passed the Course:
Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract, Art. 6, nr. 1, b GDPR
• to send you reminders or otherwise contact you about the Course:
Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract, Art. 6, nr. 1, b GDPR
• to notify you about changes to the LMS, the LMS Terms or this Privacy Policy:
Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract, Art. 6, nr. 1, b GDPR
• to provide updates to your employer:
Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract, Art. 6, nr. 1, b GDPR
• to ensure that content from the LMS is presented in the most effective manner for you and for your computer:
Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract, Art. 6, nr. 1, b GDPR
• to prevent, detect and take action against cheating on any Course assessments:
- Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child, Art. 6, nr. 1, f GDPR;
- there is a legitimate interest of both DCT and the participating employee in avoidance of cheating because cheating would reduce the reputation and the value of the test from the perspective of Dubai employers, e.g.
• for data analysis, testing, research, statistical and survey purposes:
- Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child, Art. 6, nr. 1, f GDPR;
- DCT as well as the participating employees have an obvious interest in DCT testing the performance of LMS and researching is usage and conducting surveys to improve it.
• to improve the LMS and our Courses;
- Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child, Art. 6, nr. 1, f GDPR;
- DCT as well as the participating employees have an obvious interest in improving the LMS and our Courses
• as part of our efforts to keep the LMS safe and secure:
Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract, Art. 6, nr. 1, b GDPR
• to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you:
- Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child, Art. 6, nr. 1, f GDPR;
- DCT has a legitimate interest to examine the success of its advertisement strategies; the interest in delivering relevant advertising to customers is also a legitimate interest as Art. 21, para. 2 GDPR shows
• to comply with any applicable law:
processing is necessary for compliance with a legal obligation to which the controller is subject, Art. 6, nr. 1, c GDPR;
• to cooperate with or comply with orders or requests from regulators or law enforcement bodies:
processing is necessary for compliance with a legal obligation to which the controller is subject, Art. 6, nr. 1, c GDPR;
• to enforce, protect, or defend the legal rights or property of DCT, Lobster, our customers, Students and/or any other persons
- Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child, Art. 6, nr. 1, f GDPR;
- Defending the legal rights of DCT or those of third parties is obviously a legitimate interest.

2. Your rights

You have the right to review the information DCT holds about you, and in some situations to have that information corrected, erased, blocked, restricted, or ported. You can also object to how DCT uses your information.
Where we are using your information on the basis of your consent, you have the right to withdraw that consent at any time.
You also have the right to object at any time to the DCT's use of your information where that use is based on legitimate interest or the public interest.
If you wish to exercise these rights, or to notify a change in your details, or if you have any questions on the content of this Notice, please contact DCT, DTCM, Al Fattan Plaza, Airport Road, Garhoud, dubaiway@dct.ac.ae.