1. About this policy

Hartley Salt must comply with the UAE Personal Data Protection Law (PDPL), the country’s first comprehensive federal law on data privacy which came into effect in 2022. The purpose of this Privacy Policy is to explain:

1. the kinds of information that Hartley Salt Trading FZE may collect about you and how that information is held;
2. how Hartley Salt Trading FZE collects and holds personal information;
3. the purposes for which Hartley Salt Trading FZE collects, holds, uses and discloses personal information;
4. how you can access the personal information Hartley Salt Trading FZE holds about you and seek to correct such information; and
5. the way in which you can complain about a breach of your privacy and how Hartley Salt Trading FZE will handle that complaint.

2. Definitions

In this Privacy Policy: personal information means information or an opinion about an identified individual, or an individual who is reasonably identifiable whether the information or opinion is:

1. true or not; and
2. recorded in a material form or not.

3. Collection and use of personal information

3.1. Types of personal information collected by Hartley Salt Trading FZE

1. Customers
   Hartley Salt collects information from you which is necessary to supply you with goods and services. This includes collecting personal information such as your name, address, email address, telephone and fax numbers, and any other information which is necessary to assist Hartley Salt in providing you with goods and services.
2. Suppliers / Service providers
   Hartley Salt collects information from you which is necessary to properly operate its business. This includes collecting personal information such as your name, address, email address, telephone, fax numbers, ABN and professional experience and expertise, and any other information which may be necessary to appropriately conduct its business.
3. Credit applicants and their guarantors
   Hartley Salt collects information from you which is necessary to provide you (or the relevant credit applicant) with a credit facility in connection with the supply of goods and services to you (or the relevant credit applicant). This includes collecting personal information such as your name, address, date of birth, drivers license number, email address, telephone and fax numbers, trade references, and any other information which is necessary to assist Hartley Salt assess your (or the relevant credit applicant’s) eligibility for credit, manage your (or the relevant credit applicant’s) credit account and assess your (or the relevant credit applicant’s) ongoing credit-worthiness.
4. Job applicants
   Hartley Salt collects information from you which is necessary to assess and engage employment applicants. This includes collecting personal information such as your name, address, professional experience, qualifications, references, past employers, medical information, and any other information which is necessary to assist Hartley Salt assess your suitability for employment.

3.2. How we collect personal information

Hartley Salt will usually collect your personal information directly from you, either face to face, over the telephone, via post, fax or email or over the internet. From time to time, Hartley Salt may also collect personal information from third parties, such as:

1. past employees, referees and recruitment consultants;
2. related entities (being those listed in the schedule); and
3. health service providers.

We will only collect information from third parties where:

1. you have consented to such collection;
2. such collection is necessary to enable us to provide you with appropriate services;
3. such collection is reasonably necessary to enable us to appropriately manage and conduct our business (such as in assessing applications from job applicants); or
4. it is legally permissible for us to do so.

Hartley Salt will only collect information which is necessary to provide you with goods and services or appropriately manage and conduct our business.

3.3. How Hartley Salt uses your personal information

Hartley Salt only uses your personal information for the purpose for which it was collected by Hartley Salt (primary purpose), unless:

1. there is another purpose (secondary purpose) and that secondary purpose is directly related to the primary purpose, and you would reasonably expect, or Hartley Salt has informed you, that your information will be used for that secondary purpose;
2. you have given your consent for your personal information to be used for a secondary purpose; or
3. Hartley Salt is required or authorized by law to use your personal information for a secondary purpose (including for research and quality improvements within Hartley).

For example, Hartley Salt may use your personal information to:

1. provide goods and services to you;
2. provide you with a credit facility in connection with the provision of goods and services;
3. assess your suitability for employment;
4. contact you about our facilities, business developments, products and services which may be relevant to you, where you have provided us with consent to do so;
5. appropriately manage or assist us in the running of our business, such as assessing insurance requirements, conducting audits, quality assurance programs, billing, improving its services, implementing appropriate security measures and training personnel;
6. compile statistics regarding inquiries and customer information for purposes of improving our services and tailoring our marketing; and
7. effectively communicating with third parties, including any related bodies corporate.

3.4. Complete and accurate details

Where possible and practicable, you will have the option to deal with Hartley Salt on an anonymous basis or by using a pseudonym. However, if the personal information you provide us is incomplete or inaccurate, or you withhold personal information, we may not be able to provide the goods and services or support to you are seeking, or deal with you or your application effectively.

4. Disclosing your personal information

4.1. Disclosure

Hartley Salt will confine its disclosure of your personal information to the primary purpose for which that information has been collected, or for a related secondary purpose. This includes when disclosure is necessary to provide services to you, assist us in running our organisation, or for security reasons.

We may provide your personal information to:

1. third parties involved in providing services to you;
2. government agencies;
3. liquidators, administrators or other persons appointed to administer your financial affairs; or
4. third parties contracted to provide services to Hartley Salt, such as:
   1. third party managers of Hartley Salt’s website and online ordering capabilities;
   2. third party logistic providers;
   3. lenders, credit providers, credit reporting/reference agencies and debt collection agencies;
5. any of the related bodies corporate of Hartley Salt;
6. anyone authorized by you to receive your personal information (your consent may be express or implied); or
7. anyone Hartley Salt is required by law to disclose your personal information to.

4.2. Disclosing personal information overseas

Hartley Salt is not likely to disclose your personal information to overseas recipients, except:

1. as disclosed to our related bodies corporate (including those operating in the GCC) in the ordinary course of business; or
2. to the extent that Hartley Salt or its related bodies corporate or any third party uses overseas-based servers or service providers.

5. Data storage, quality and security

5.1. Data quality

Hartley Salt will take reasonable steps to ensure that your personal information which is collected, used or disclosed is accurate, complete and up to date.

5.2. Storage

All your personal information is stored securely by Hartley Salt or third party storage providers, (including those operating in MENA & GCC Regions) in either hard copy or electronic form.

5.3. Data security

Hartley Salt strives to ensure the security, integrity and privacy of personal information, and will take reasonable steps to protect your personal information from misuse, interference, loss, unauthorised access, modification or disclosure.

Hartley Salt reviews and updates (where necessary) its security measures in light of current technologies.

5.4. Online transfer of information

While Hartley Salt does all it can to protect the privacy of your personal information, no data transfer over the internet is 100% secure. When you share your personal information with Hartley Salt via an online process, it is at your own risk.

There are ways you can help maintain the privacy of your personal information, including:

1. always closing your browser when you have finished your user session;
2. always ensuring others cannot access your personal information and emails if you use a public computer; and
3. never disclosing your username and password to third parties.

6. Use of cookies

A ‘cookie’ is a small data file placed on your machine or device which lets Hartley Salt identify and interact more effectively with your computer. Cookies do not identify individual users, but they do identify your ISP and browser type.

Cookies which are industry standard and are used by most web sites, including those operated by Hartley Salt, can facilitate a user’s ongoing access to and use of a site. They allow Hartley Salt to customise our website to the needs of our users. If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to deny or accept the cookie feature. However, cookies may be necessary to provide you with some features of our on-line services via the Hartley Salt website.

7. Links to other sites

Hartley Salt may provide links to third party websites. These linked sites may not be under our control and Hartley Salt is not responsible for the content of or privacy practices adopted by those websites. Before disclosing your personal information on any other website, we recommend that you carefully read the terms and conditions of use and privacy statement of the relevant website.

8. Accessing and amending your personal information

You have a right to access your personal information which Hartley Salt holds about you. If you make a request to access your personal information, we will ask you to verify your identity and specify the information you require.

You can also request an amendment to any of your personal information if you consider that it is inaccurate.

You can contact Hartley Salt about any privacy issues as follows:

Contact: Hartley Salt Trading FZE Privacy Officer

Address: Ajman Free Zone, AFZ-Ajman, United Arab Emirates

Telephone: +971 52 902 4850

9. Complaints

If you have a complaint about Hartley Salt’s information handling practices or consider we have breached your privacy, you can lodge a complaint with:

1. the Privacy Officer, on the contact details listed in clause 8 above; or
2. the UAE Data Office.

Hartley Salt aims to deal with all complaints in a fair and efficient manner.