Dubai Telegraph - PRIVACY POLICY

PRIVACY POLICY

Privacy policy of "DUBAI TELEGRAPH"
Status: 1. January 2026

Contact:
"DUBAI TELEGRAPH"
A department of the Media Division of:
SCANDIC ASSETS FZCO
Dubai Silicon Oasis DDP
Building A1/A2
Dubai — 342001
United Arab Emirates

Represented by:
SCANDIC TRUST GROUP LLC
IQ Business Centre
Bolsunovska Street 13-15
Kyiv — 01014, Ukraine
Mail: [email protected]

In cooperation with:
LEGIER Beteiligungs mbH
Kurfürstendamm 14
10719 Berlin
Federal Republic of Germany
Commercial register: HRB 57837
Register court Berlin-Charlottenburg
VAT ID: DE 413445833
Telephone: +49 (0) 30 99211 - 3 469
Telephone: +49 (0) 30 99211 - 3 225
Mail: [email protected]

Legal notice:
SCANDIC ASSETS FZCO and LEGIER Beteiligungs mbH do not act as operational service providers. All operational and responsible activities of and for "DUBAI TELEGRAPH" are carried out by SCANDIC TRUST GROUP LLC.

Thank you for your interest in our services. This privacy policy informs you about the type, scope and purpose of the personal data we process and your rights as a data subject.

Introduction
This privacy policy informs you about how and for what purpose we collect, process and use personal data when you use our websites, apps and other services and benefits offered by us. The protection of your personal data is very important to us. We always treat it confidentially and in accordance with the applicable data protection regulations, in particular the EU General Data Protection Regulation (GDPR), the German Federal Data Protection Act (BDSG), the German Digital Services Act (DDG, formerly TMG) and the German Telecommunications Digital Services Data Protection Act (TDDDG).

About applicable laws:

General Data Protection Regulation (GDPR): EU-wide regulation that standardises and regulates the protection of personal data.
Federal Data Protection Act (BDSG): National supplement to the GDPR for Germany.
Digital Services Act (DDG, formerly TMG): Regulates, among other things, the obligations of providers of digital services (e.g. imprint obligations, liability issues).
Telecommunications Digital Services Data Protection Act (TDDDG): Regulates data protection and privacy in the area of telecommunications and digital services.

A) General information on data processing
We collect, process and use personal data only insofar as this is necessary for the provision of our services or you have given us your consent to do so. Personal data is information that relates to an identified or identifiable natural person, e.g. name, address, e-mail address, telephone number or IP address.

Purposes and legal bases:
We process your data for the following purposes:

Fulfilment of contracts (Art. 6 para. 1 lit. b GDPR - General Data Protection Regulation)
Fulfilment of legal obligations (Art. 6 para. 1 lit. c GDPR - General Data Protection Regulation)
Safeguarding legitimate interests (Art. 6 para. 1 lit. f GDPR), e.g. to ensure a secure online offering
Based on your consent (Art. 6 para. 1 lit. a GDPR), e.g. when using cookies for analysis purposes

You can view the data protection provisions of these providers here:

Data protection at X: https://x.com/de/privacy
Data protection on Instagram: https://help.instagram.com/519522125107875
Data protection with Amazon Alexa: https://www.amazon.de/gp/help/customer/display.html/ref=footer_privacy?ie=UTF8&nodeId=3312401&pop-up=1
Data protection for Google Play/Android TV/Google Assistant: https://policies.google.com/privacy
Data protection on Facebook: https://de-de.facebook.com/help/568137493302217
Data protection on YouTube: https://policies.google.com/privacy?hl=de
Data protection with Telegram: https://telegram.org/privacy
Data protection with Apple Messages/Apple Watch: https://apple.com/de/legal/privacy
Data protection for Amazon Fire TV/Fire Tablet: https://www.amazon.de/gp/help/customer/display.html?nodeId=GQFYXZHZB2H629WN
Data protection at Roku: https://docs.roku.com/published/userprivacypolicy/en/gb
Data protection with Telekom Magenta: https://www.telekom.de/ueber-das-unternehmen/datenschutz
Data protection at Huawei: https://consumer.huawei.com/de/privacy/
Data protection at Spotify: https://www.spotify.com/de/legal/privacy-policy/
Data protection at Audio Now: https://audionow.de/datenschutz
Data protection at TikTok: https://www.tiktok.com/legal/privacy-policy?lang=de

When using programme content via smart speakers (Alexa, Google Play), the "DUBAI TELEGRAPH" website is accessed directly. Our system automatically collects the following data from the computer system of the accessing device and stores it in log files:

Name of the retrieved file,
Date and time of the call,
amount of data transferred,
Notification of successful retrieval,
Type of browser and version used,
IP address (identifier of the user's device),
Operating system of the users,
Internet service provider of the users,
Websites from which the user's system accesses our online offering,
Websites that are accessed by the user's system via our website.

This data is not merged with other data sources. The legal basis for the collection of data and its storage in log files is Art. 6 para. 1 sentence 1 lit. f GDPR (General Data Protection Regulation). What you communicate with voice assistants is recorded by your device and stored as an audio file in a cloud. When using the other platforms and services, it cannot be ruled out that personal data will also be transferred to the USA, as these providers store data on servers there. According to the findings of the European Court of Justice in its ruling on the Privacy Shield (judgement in case C-311/18 "Schrems II"), the level of data protection in the USA is lower than within the scope of the GDPR. "DUBAI TELEGRAPH" does not transfer any personal data from you or initiate such a transfer, as you have regularly consented to such data processing by the service providers on the basis of your registration or registration with them.

At the time of data collection, for example in the context of a contractual relationship for the fulfilment of mutually owed services and obligations or in the exercise of domiciliary rights and any associated legitimate security interests, "DUBAI TELEGRAPH" stores your personal data. This may be, for example Name, contact details, date of birth, bank details, employer, client, identity card or driving licence data, data relevant to house security such as personal images from video-monitored access areas and other access data, images or film recordings at concerts or other "DUBAI TELEGRAPH" events.

Personal data is processed for very different purposes and always on a lawful basis, for example Contract initiation and fulfilment (Art. 6 para. 1 lit. b) GDPR - General Data Protection Regulation), e.g. to provide you with:

to be able to grant access to our property and premises within the scope of contractual relationships or at events or also for the use of the canteen, to be able to provide a service requested by you (e.g. newsletter, programme booklet, personalised access to certain Internet offers),
to enable participation in a competition or prize draw,

Protection of vital interests of a data subject (Art. 6 para. 1 lit. d) GDPR - General Data Protection Regulation), e.g. inspection and disclosure of personal data in the event of an accident if the data subject is unable to provide information themselves; fulfilment of the broadcasting and programming mandate of the "DUBAI TELEGRAPH" as a task in the public interest (Art. 6 para. 1 lit. e) GDPR), for example processing listener mail or programme complaints; safeguarding the legitimate interests of "DUBAI TELEGRAPH" in consideration of the fundamental rights and freedoms of the data subjects (Art. 6 para. 1 lit. f) GDPR), for example processing personal data for the external presentation of "DUBAI TELEGRAPH" or in the exercise of domiciliary rights (in particular security interests).

B) Making contact
For enquiries by e-mail or telephone, we process your details (name, contact details, content of the enquiry) to answer your request (Art. 6 para. 1 lit. b GDPR).

C) Reservations and orders
For reservations and online orders, we process your data (name, contact details, payment details) in order to fulfil your orders (Art. 6 para. 1 lit. b GDPR).

D) Accounting and legal obligations
Data from business transactions (e.g. invoices) are stored in accordance with legal requirements (Art. 6 para. 1 lit. c GDPR - General Data Protection Regulation).

E) Technical provision of the website
When you visit our website, technical data such as IP address, time and browser type are automatically collected. These serve the security, stability and functionality of the website (Art. 6 para. 1 lit. f GDPR).

F) Cookies and tracking technologies
Our websites may use cookies and similar technologies, e.g. to improve the user experience or for statistical analyses. If your consent is required for this, we will obtain it via a corresponding cookie banner (Art. 6 para. 1 lit. a GDPR - General Data Protection Regulation). You can withdraw your consent at any time by adjusting your browser settings. Partners or third-party providers outside the IAB standard are labelled as such in the privacy policy (*third-party providers outside the IAB standard).

Cookies and similar technologies are sometimes required to collect personal data or store it on your end device in order to subsequently process personal data, including for the following purposes:

Use of reduced data for the selection of adverts
Creation of profiles for personalised advertising,
Use of profiles to select personalised advertising,
Creation of profiles to personalise content,
Use of profiles to select personalised content,
Measurement of advertising performance,
Measuring the performance of content,
Analysing target groups using statistics or combinations of data from different sources,
Development and improvement of offers and
Use of reduced data for the selection of content (so-called "IAB processing purposes").

G) Recipients of data
Your data will only be passed on to third parties if this is necessary to fulfil the contract, to fulfil legal obligations or to protect legitimate interests (e.g. IT service providers, tax consultants, authorities).

H) Storage period
Personal data is only stored for as long as is necessary for the respective purposes. Once the purpose no longer applies or statutory retention periods have expired, the data will be deleted.

If "DUBAI TELEGRAPH" also receives and processes personal data from you on the basis of voluntary consent (Art. 6 Para. 1 a), Art. 4 No. 11 GDPR - General Data Protection Regulation), you have the right to revoke such consent at any time for the future without giving reasons. This does not affect the lawfulness of the processing carried out before consent was withdrawn. Revocation declarations must be addressed to the controller.

I) Your rights as a data subject
You have the following rights:

Information (Art. 15 GDPR)
Rectification (Art. 16 GDPR)
Erasure (Art. 17 GDPR)
Restriction of processing (Art. 18 GDPR)
Data portability (Art. 20 GDPR)
Objection to the processing (Art. 21 GDPR)
Revocation of consent (Art. 7 para. 3 GDPR)

You have the right to request information from "DUBAI TELEGRAPH" about the personal data concerning you and, if necessary, correction, deletion and restriction of processing or, if applicable, the right to object (data subject rights pursuant to Art. 15 ff. GDPR - General Data Protection Regulation). Under the conditions of Art. 20 GDPR (General Data Protection Regulation), a right to data portability may come into consideration. Contact options can be found above under Contact.

Finally, you have the right to complain to the data protection officer of "DUBAI TELEGRAPH" at [email protected] if you believe that there has been a breach of data protection law. To exercise your rights, please use the contact details above. You also have the right to lodge a complaint with a data protection supervisory authority.

J) Security
We use technical and organisational measures to protect your data from unauthorised access, loss or manipulation.

K) Online dispute resolution
The European Commission provides a platform for online dispute resolution (OS): http://ec.europa.eu/consumers/odr.

L) Explanation of the legal basis

GDPR: European regulation for the protection of personal data within the EU.
BDSG: National supplement to the GDPR in Germany.
DDG (formerly TMG): Regulates, among other things, provider labelling obligations and liability for own and third-party content.
TDDDG: Regulates data protection and privacy in telecommunications and online services.

M) Additional information on processing at "DUBAI TELEGRAPH"
Our privacy policy also contains detailed information on the individual processing activities, including cookies, newsletters, tracking and analysis tools, social media plug-ins and affiliate networks.

We only use and process your personal data if you have given us your consent to do so or if there is a legal basis for doing so. We will announce any changes to our privacy policy; if you do not agree to these changes, you can withdraw your consent within two weeks.

Please note that extensive and detailed information on the tools used, plugins, social media services, analysis methods, tracking technologies and international data transfers is contained in this privacy policy. All the laws mentioned, in particular the GDPR, BDSG, DDG and TDDDG, ensure that the collection, processing and use of personal data is carried out at a high level of protection. If you have any questions or suggestions regarding data protection, please contact us at [email protected].