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Overview:  Abu Dhabi Global Market Data Protection Regulations 2021 (ADGM DPR 2021) became effective on February 14, 2021. The ADGM DPR 2021 provide the ADGM’s data subjects with the following individual rights and freedoms:

THE RIGHT TO BE INFORMED: You may be entitled to request information about how we process your Personal Information.

RIGHT OF ACCESS:
You may be entitled to ask us for confirmation of whether we are processing your Personal Information and for a copy of your Personal Information.

This right is known as an “Individual Request.”

We will normally send you a copy of your Personal Information within a reasonable period, but at the latest with two months of receiving your request.

There is usually no charge; but in exceptional circumstances we may charge where a request is unreasonable or excessive, in particular because it is repetitive.

RIGHT TO RECTIFICATION:
You may have the right to request that any inaccurate Personal Information about you is corrected, and for incomplete Personal Information to be completed.

RIGHT TO ERASURE:
In certain circumstances, you may be entitled to ask us to erase your Personal Information.

RIGHT TO DATA PORTABILITY:
In certain circumstances, you may wish to obtain and to re-use your Personal Information for your own purposes and across different services.

If this right applies, you may request a copy of your Personal Information or request us to transmit your Personal Information to another data controller, where technically feasible, and where permitted under ADGM DPR 2021.

RIGHT TO OBJECT:
If the right applies, you may be able to object to the processing of your Personal Information at any time.

This effectively allows you to stop us from further processing your Personal Information.

Where we rely upon legitimate interests as the legal basis for processing your Personal Information, you may object to us continuing to process your Personal Information, but you must give us specific reasons for objecting.

We will consider the reasons you provide, but if we consider that there are compelling legitimate grounds for us to continue to process your Personal Information, we may continue to do so.

In that event, we will let you know the reasons for our decision.

RIGHT TO RESTRICTION:
You may be entitled to restrict the processing of your Personal Information in certain circumstances.  The right is available where:

• You contest the accuracy of your data, while we are verifying the accuracy of your Personal Information;
• The processing of your Personal Information is unlawful and you request restriction instead of erasure;
• We no longer need your Personal Information for the purposes of processing, but it is required by you for the establishment, exercise, or defense of legal claims; or
• You have exercised your right to object to processing of your Personal Information based on the “legitimate interest” basis while we verify whether our legitimate grounds override your individual rights and freedoms.

RIGHTS RELATED TO AUTOMATED INDIVIDUAL DECISION-MAKING INCLUDING PROFILING: 
We will not use your Personal Information in connection with any automated decision-making process. 

We use limited contact information to carry out certain business development profiling activities to support and grow our business.  When doing so, we rely upon our legitimate interests as the lawful basis for processing your Personal Information and you may exercise the above rights if you do not wish your Personal Information to be processed in this way.

You may contact King and Spalding at dataprivacy@kslaw.com should you have any questions regarding its privacy program.

You can submit requests about your Personal Information here.

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Overview:  Australia’s Privacy Act became effective in 1988. Australia’s Privacy Act of 1988 provides Australia’s data subjects with the following individual rights and freedoms:

RIGHT TO BE INFORMED:
You have the right to know why your Personal Information is being collected, how it will be used, and to whom it will be disclosed.

RIGHT OF ACCESS:
You have the right to request access to your Personal Information (including your health information).

RIGHT NOT TO RECEIVE DIRECT MARKETING:
You have the right to ask us to stop sending you direct marketing communications.

RIGHT TO MAKE A COMPLAINT:
You have the right to make a complaint if you think we have mishandled your Personal Information.

RIGHT TO NOT IDENTIFY YOURSELF:
You have the option to not identify yourself, or to use a pseudonym when you interact with our services in certain circumstances.

RIGHT TO CORRECTION:
You have the right to ask that inaccurate Personal Information is corrected.

You may contact King and Spalding at dataprivacy@kslaw.com should you have any questions regarding its privacy program.

You can submit requests about your Personal Information here.

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Overview:  Dubai International Financial Center Data Protection Law Number 5 of 2020 (DIFC DP Law 2020) became effective on July 1, 2020. The DIFC DP Law 2020 provides the DIFC’s data subjects with the following individual rights and freedoms:

RIGHT TO WITHDRAW CONSENT:
You may be entitled to withdraw consent for the processing of your Personal Data by notifying us.

RIGHT TO ACCESS, RECTIFICATION, AND ERASURE of PERSONAL DATA:
Upon request, you may be entitled to ask us without charge and within one month of request.

Confirmation in writing as to whether or not your Personal Data is being processed at least to the purposes for the processing, the categories of Personal Data concerned, and the recipients to whom the Personal Data are disclosed.

A copy of the Personal Data undergoing processing in an appropriate format, including but not limited to electronic form or hard copy format, and any available information as to its source, including up-to-date information.

RIGHT TO OBJECT TO PROCESSING: 
You may be entitled to the right to:

• Object at any time on reasonable grounds relating to your particular situation to the processing of your Personal data when it is necessary for the performance of a task carried out in the public interest or the exercise of official authority, or it is necessary for the purpose of “legitimate interests.”
• Where Personal Data are processed for direct marketing purposes, object at any time to such processing, including profiling to the extent it is related to direct marketing.
• Where we rely upon legitimate interests as the legal basis for processing your Personal Information, you may object to us continuing to process your Personal Information, but you must give us specific reasons for objecting.
• We will consider the reasons you provide, but if we consider that there are compelling legitimate grounds for us to continue to process your Personal Information, we may continue to do so.
• In that event, we will let you know the reasons for our decision.

RIGHT TO RESTRICTION:
You may be entitled to restrict the processing of your Personal Information in certain circumstances.  The right is available where:

• You contest the accuracy of your data, while we are verifying the Personal Information’s accuracy.
• The processing is unlawful and you request restriction instead of erasure.
• We no longer need your Personal Information for the purposes of processing, but it is required by you for the establishment, exercise, or defense of legal claims.
• You have objected to processing based on the “legitimate interest” basis while we verify whether our legitimate grounds override your individual rights and freedoms.

RIGHT TO DATA PORTABILITY:  
In certain circumstances, you may be entitled to receive Personal Data provided to us in a structured, commonly used and machine-readable format where the processing is based on your consent or the performance of a contract, and carried out by automated means.

RIGHTS RELATED TO AUTOMATED INDIVIDUAL DECISION-MAKING INCLUDING PROFILING:  
We will not use your Personal Information in connection with any automated decision-making process. 

We use limited contact information to carry out certain business development profiling activities to support and grow our business. 

When doing so, we rely upon our legitimate interests as the lawful basis for processing your Personal Data and you may exercise the above rights if you do not wish us to process your Personal Data in this way.

You may contact King and Spalding at dataprivacy@kslaw.com should you have any questions regarding its privacy program.

You can submit requests about your Personal Information here.

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Overview:  The European Union’s General Data Protection Regulation (EU GDPR) 2016/679 became effective on May 25, 2018. The EU GDPR provides the EU’s data subjects with the following rights and freedoms:

RIGHT OF ACCESS:
You may be entitled to ask us for a copy of any Personal Information which we process about you. This right is known as an “Subject Access Request.”

We will normally send you a copy of the Personal Information within one month of your request.

However, that period may be extended by two further months where necessary, taking into account the complexity of the request or the difficulty in accessing the Personal Information that you request.

There is usually no charge; but in exceptional circumstances we may make a charge.  We will discuss this with you if those circumstances apply.

RIGHT TO RECTIFICATION:
If the Personal Information we hold about you is inaccurate, you may request rectification. We will review your Personal Information and, where appropriate, inaccuracies will be rectified.

RIGHT TO ERASURE:
In certain circumstances, you may be entitled to ask us to erase your Personal Information.

RIGHT TO DATA PORTABILITY:
In certain circumstances, you may request to move, copy, or transfer the electronic Personal Information that we hold about you to another organization.

RIGHT TO OBJECT:
You may object to your Personal Information being used for direct marketing.

You may object to the continued use of your Personal Information in any circumstances where we rely upon consent as the legal basis for processing it.

Where we rely upon legitimate interests as the legal basis for processing your Personal Information, you may object to us continuing to process your Personal Information, but you must give us specific reasons for objecting.

We will consider the reasons you provide, but if we consider that there are compelling legitimate grounds for us to continue to process your Personal Information, we may continue to do so. In that event, we will let you know the reasons for our decision.

RIGHTS RELATED TO AUTOMATED DECISION-MAKING INCLUDING PROFILING:
We will not use your Personal Information in connection with any automated decision-making process. 

We use limited contact information to carry out certain business development profiling activities to support and grow our business. 

When we do so, we rely upon our legitimate interests as the lawful basis for processing your Personal Information and you may exercise the above rights if you do not wish us to process your Personal Information in this way.

You may contact King and Spalding at dataprivacy@kslaw.com should you have any questions regarding its privacy program.

You can submit requests about your Personal Information here.

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Overview:  Japan’s Amendment to the Act on the Protection of Personal Information (AAPI) became effective on April 1, 2022. Japan’s AAPI provides Japan’s data subjects with the following individual rights and freedoms:

RIGHT TO BE INFORMED:
You may have the right to know the how we use of your Personal Information.

We must provide notification to you about how we use your Personal Information. We should provide you with the notification in a format that allows you to understand how we use your Personal Information relevant to our business.

RIGHT TO ACCESS: 
You may be entitled to ask us for a copy of any Personal Information which we process about you.

We must also provide you with information about how to correct your Personal Information or and how to request we cease processing your Personal Information.

We may charge a fee to respond to your request, provided that the fee is reasonable, taking into account the actual expenses we incur to comply with the request.   

RIGHT TO RECTIFICATION: 
You have the right to request correction of the Personal Information we process about you without undue delay.

RIGHT TO ERASURE:
You have the right to request that we delete the Personal Information we process about you.

RIGHT TO OBJECTION/RIGHT TO OPT-OUT:
You have the right to request that we cease to use the Personal Information where our processing is in breach of the APPI.

Additionally, you may request that we cease to transfer your Personal Information to a third party in violation of the APPI.  If we receive such a request, and it is made on reasonable grounds, we will cease to transfer Personal Information to third-party transfers without delay.

You may contact King and Spalding at dataprivacy@kslaw.com should you have any questions regarding its privacy program.

You can submit requests about your Personal Information here.

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Overview:  Saudi Arabia’s Personal Data Protection Law (PDPL) became effective on September 16, 2021. Saudi Arabia’s PDPL 2021 provides Saudi Arabia’s data subjects with the following individual rights and freedoms:

RIGHT TO BE INFORMED:
You have the right to know how we use your Personal Information and to whom it will be disclosed.

When we collect Personal Information directly from you, we must take adequate steps to inform the you before we collect your Personal Information.

RIGHT OF ACCESS:
You may be entitled to ask us for a copy of any Personal Information which we process about you.

RIGHT TO RECTIFICATION:
You have the right to request that we correct, complete or update your Personal Information.

Furthermore, if we rectify your Personal Information we will notify any other party to whom your Personal Information has been transferred of any such changes, and provide them with information about the changes we have made.

We will usually carry out your request within 30 days of receiving it.  If carrying out the request requires extraordinary effort, or if we receive multiple requests from you we may extend the period for responding by no more than 30 additional days, provided we notify you of the extension and the reasons for it.

RIGHT TO ERASURE:
You have the right to request that your Personal Information is erased.  We will erase your Personal Information on your written request in the following cases:

• If we no longer need to process your Personal Information for the purpose for which we collected it.
• If you withdraw your consent to the collection of your Personal Information when we relied on consent as the legal basis for processing.
• Where we rely upon legitimate interests as the legal basis for processing your Personal Information, you may object to us continuing to process your Personal Information, but you must give us specific reasons for objecting.
• If we are processing your Personal Information for direct marketing.
• If our processing of your Personal Information is inconsistent with the PDPL.

We will usually carry out your request within 30 days of receiving it.  If carrying out the request requires extraordinary effort, or if we receive multiple requests from you we may extend the period for responding by no more than 30 additional days, provided we notify you of the extension and the reasons for it.

You may contact King and Spalding at dataprivacy@kslaw.com should you have any questions regarding its privacy program.

You can submit requests about your Personal Information here.

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Overview:  The Singapore Personal Data Protection (Amendment) Act (PDPA) of 2020 became effective on February 1, 2021. The PDPA provides Singapore’s data subjects with the following individual rights and freedoms:

RIGHT TO BE INFORMED:
We must provide you with information about the purposes for which we intend to collect, use, or disclose your Personal Information at or before the point of collection.

You have a right for us to notify you of a data breach that results in significant harm to you in certain circumstances.

RIGHT TO ACCESS:
Upon request, you may be entitled to ask us for access to your Personal Information in our possession or under our control.

We will respond to your requests to accessing your Personal Information as accurately and completely as necessary and reasonably possible.  We must provide you with information about how your Personal Information has been or may be used or disclosed by us for the year before the date of the request.

Upon request, we will provide you with a copy of your Personal Information in documentary form or any other form you requested which is acceptable to us.

We may charge use you a reasonable fee to respond to your request, and provide you with a written estimate of the fee.

RIGHT TO RECTIFICATION:
You may be entitled to correct your Personal Information we process about you in certain circumstances.

You have the right to correct any inaccurate data that is in our control, subject to the exceptions set out in the Sixth Schedule of PDPA.

RIGHT TO OBJECT/OPT-OUT:
You may be entitled to withdraw your consent to the collection, use, or disclosure of your Personal Information at any time on reasonable notice to us.

However, our processing of your Personal Information before you withdraw your consent shall be unaffected.

You may contact King and Spalding at dataprivacy@kslaw.com should you have any questions regarding its privacy program.

You can submit requests about your Personal Information here.

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Overview:  Switzerland’s revised Federal Act on Data Protection (revFADP) was enacted on September 25, 2020. It will become effective on September 1, 2023. Switzerland’s revFADP provides Switzerland’s residents with the following individual rights and freedoms:

RIGHT TO BE INFORMED:
You have the right to know why your Personal Information is being collected, how it will be used, and to whom it will be disclosed.

We will only process your Personal Information for the purposes we notify you about at the time we collect it, for purposes which are evident from the circumstances, or which are provided for by law.

We will notify you about the Personal Information we collect, and in particular, the purpose of our processing.

If your consent is required for the processing of Personal Information, we understand such consent is valid only if given voluntarily and if you have been provided with adequate information about our purposes for processing.

RIGHT OF ACCESS:
You have the right to request information from us about whether your Personal Information about you is being processed by us.

This right applies to every person irrespective of age, place of residence, and nationality.

We will respond to your request for access within 30 days of receipt of the request.

If we cannot provide you with the information within 30 days, we will notify you of this and of the date by which the information will be provided.

RIGHT TO RECTIFICATION:
You have the right to request that incorrect or outdated Personal Information be corrected by us.

We will ensure that your Personal Information is correct, and we will take all reasonable measures to ensure that Personal Information that is incorrect or incomplete is either corrected or destroyed.

RIGHT TO DATA PORTABILITY:
You have the right to request from us the disclosure of your Personal Information in a standard electronic format if:

• We possess the data in an automated manner.
• The data is processed with your consent or directly in connection with the conclusion or performance of a contract between you and us.
• Additionally, you may request that we transfer your Personal Information to another controller in compliance with the revFADP.
• There is usually no charge for making such a request.

DUTY TO OBJECT TO AN AUTOMATED INDIVIDUAL DECISION:
You have the right to be informed of a decision made solely on the basis of an automated processing, and which might have legal effects on you, or that affects you significantly (automated individual decision).

We will not use your Personal Information in connection with any automated decision-making process. 

You may contact King and Spalding at dataprivacy@kslaw.com should you have any questions regarding its privacy program.

You can submit requests about your Personal Information here.

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Overview:  The United Kingdom’s General Data Protection Regulation (UK GDPR) became effective on January 1, 2021, as a result of the UK’s departure from the European Union. The UK GDPR provides the UK’s data subjects with the following rights and freedoms:

RIGHT OF ACCESS:
You may be entitled to ask us for a copy of any Personal Information which we process about you. This right is known as an “Subject Access Request.”

We will normally send you a copy of the Personal Information within one month of your request. However, that period may be extended by two further months where necessary, taking into account the complexity of the request or the difficulty in accessing the Personal Information that you request.

There is usually no charge; but in exceptional circumstances we may charge but we will discuss this with you if those circumstances apply.

RIGHT TO RECTIFICATION:
If the Personal Information we process about you is inaccurate, you may request rectification. The Personal Information will be checked, and, where appropriate, inaccuracies will be rectified.

RIGHT TO ERASURE:
In certain circumstances, you may be entitled to ask us to erase your Personal Information.

RIGHT TO DATA PORTABILITY:
In certain circumstances, you may request that we move, copy, or transfer the electronic Personal Information that we hold about you to another organization.

RIGHT TO OBJECT:
You may object to your Personal Information being used for direct marketing.

You may object to the continued use of your Personal Information in any circumstances where we rely upon consent as the legal basis for processing it.

Where we rely upon legitimate interests as the legal basis for processing your Personal Information, you may object to us continuing to process your Personal Information, but you must give us specific reasons for objecting.

We will consider the reasons you provide, but if we consider that there are compelling legitimate grounds for us to continue to process your Personal Information, we may continue to do so.

In that event, we will let you know the reasons for our decision.

RIGHTS RELATED TO AUTOMATED DECISION-MAKING INCLUDING PROFILING:
We will not use your Personal Information in connection with any automated decision-making process. 

We use limited contact information to carry out certain business development profiling activities to support and grow our business. 

When doing so, we rely upon our legitimate interests as the lawful basis for processing your Personal Information and you may exercise the above rights if you do not wish us to process your Personal Information in this way.

You may contact King and Spalding at dataprivacy@kslaw.com should you have any questions regarding its privacy program.

You can submit requests about your Personal Information here.

In order to submit your request, please select your relationship with King & Spalding:

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