Privacy Policy
This Privacy Policy describes Our policies and procedures on the collection, use, and disclosure of Your information when You use the Service. It also explains Your privacy rights under the UAE Personal Data Protection Law (Federal Decree-Law No. 45 of 2021) (“PDPL”) and how We protect Your information.
By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.
Interpretation and Definitions
Company (referred to as either "the Company", "We", "Us" or "Our") refers to First Path Montessori Early Childhood Center, BB07 7 Al Asayel St, Business Bay, Bay Square, Dubai, UAE.
Country refers to: United Arab Emirates.
Personal Data means any information that relates to an identified or identifiable individual. This may include sensitive personal data such as health, biometric, or religious information, which is subject to additional safeguards under UAE law.
Service refers to the Website.
You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.
Other terms (such as Account, Cookies, Service Provider, Device, Usage Data, and Third-Party Social Media Services) retain the same meaning as in the original policy.
Compliance with UAE Data Protection Law
We comply with the PDPL (Federal Decree-Law No. 45 of 2021) and related legislation, including Federal Law No. 34 of 2021 on Combating Cybercrime. This means:
1. Legal Basis & Consent – We only process personal data with your explicit, informed consent, or where processing is required by law, for public interest, or for contractual necessity. Consent can be withdrawn at any time.
2. Your Rights – You have the right to access, correct, erase, restrict, or stop processing your data, and the right to be forgotten, in line with the PDPL.
3. Transfers Abroad – We only transfer your data outside the UAE where the destination offers an adequate level of protection, or under contractual safeguards, or with your explicit consent.
4. Data Protection Officer (DPO) – You may contact our appointed DPO (or our Privacy Officer where no formal DPO is required) at: Asma Ibrahim, [email protected].
5. Recordkeeping & DPIAs – We maintain a record of processing activities, including purpose, retention, and transfer mechanisms. Where high-risk processing occurs, we conduct Data Protection Impact Assessments.
6. Breach Notification – If a data breach occurs, we will notify the UAE Data Office and, where necessary, affected data subjects without undue delay.
7. Sensitive Data – If we process sensitive data (health, ethnicity, religious beliefs, biometrics), we do so with additional safeguards and only on lawful grounds.
8. Regulatory Context – This Policy is governed by PDPL. If you are based in DIFC or ADGM, please note those zones have separate frameworks; this Policy applies outside those jurisdictions.
9. Cybercrime Law – Unauthorised access or misuse of data is criminalised under UAE Cybercrime Law, and we take strict technical and organisational measures to prevent it.
Collecting and Using Your Personal Data
Types of Data Collected
- Personal Data: such as name, email address, phone number, and postal address.
- Sensitive Personal Data: if collected (e.g. health or child-related information), this will only be processed with explicit consent or where permitted by law.
- Usage Data: such as IP address, browser type, device details, and activity logs.
Legal Basis for Processing
We process Personal Data under the PDPL on the following lawful bases:
- With Your explicit consent (which You may withdraw at any time).
- To perform a contract with You.
- To comply with a legal obligation.
- To protect the public interest or the safety of You and others.
- For Our legitimate interests, provided these do not override Your rights.
Your Rights Under UAE Law
You have the following rights in relation to Your Personal Data:
- Access – to know what data we hold about You.
- Rectification – to correct inaccurate or incomplete data.
- Erasure – to request deletion of Your data (“right to be forgotten”).
- Restriction – to limit how we process Your data.
- Objection – to object to certain types of processing, including direct marketing.
- Data Portability – to request Your data in a portable format.
To exercise these rights, please contact Us at: [email protected].
International Transfers of Data
Your Personal Data may be transferred and stored outside the UAE. Such transfers will only take place if:
- The destination country ensures an adequate level of protection,
- Appropriate contractual safeguards are in place, or
- You have given explicit consent.
We take steps to ensure Your information is treated securely and in line with UAE law.
Data Retention
We retain Personal Data only as long as necessary to fulfil the purposes outlined in this Privacy Policy, unless a longer retention period is required by UAE law.
Security and Breach Notification
We implement appropriate technical and organizational measures to protect Your Personal Data. However, no system is completely secure.
In case of a data breach that poses a risk to Your rights, we will notify the UAE Data Office and, where required, inform You without undue delay.
Children’s Privacy
Our Service is not directed at children under the age of 13. If we learn that we have collected Personal Data from a child without parental consent, we will delete it promptly.
Data Protection Officer
Where required under UAE law, we have appointed a Data Protection Officer (DPO) to oversee compliance. You can contact the DPO by emailing [email protected].
Links to Third-Party Websites
Our Service may contain links to third-party websites. We are not responsible for their privacy practices and recommend reviewing their policies.
Changes to this Privacy Policy
We may update this Privacy Policy from time to time to reflect legal or operational changes. Updates will be posted on this page with a revised “Last Updated” date.
Contact Us
If you have any questions about this Privacy Policy or how your data is handled under UAE law, you can contact us:
By email: [email protected]
By post: First Path Montessori Early Childhood Center, BB07 7 Al Asayel St, Business Bay, Bay Square, Dubai, UAE