Privacy Policy

Summary

ADGM's Online Consultation Portal (the “Portal”) is a free service provided to enable participation in public consultations. The Portal publishes consultations to which you can make submissions, receive messages about consultations, read and interact with published submissions.

ADGM fully respects your right to privacy. ADGM will not collect any personal information about you on its websites other than as set out in this privacy statement. Any information, which you submit via ADGM's websites will be treated with the levels of security and confidentiality prescribed by the Abu Dhabi Global Market (“ADGM”) Data Protection Regulations (2021) (the “DPR21”).

This privacy statement sets out how ADGM (data controller) and CiviQ (the data processor and the company that runs the Portal) process your personal data.

ADGM reserves the right to amend the scope of this privacy statement at any time which may include or exclude other sites or platforms.

Identity and the contact details of the controller:

The data controller is ADGM, The Data Protection Officer, Abu Dhabi Global Market, PO Box 111999, Abu Dhabi, UAE

Data Protection Officer email:  dpo@adgm.com

Identity and the contact details of the processor:

The data processor is Aphelion Ltd. t/a CiviQ,  Digital Office Centre, Maynooth Business Campus, Straffan Road, Maynooth, Co. Kildare, Ireland

email: info@civiq.eu

How we collect your information

The Platform and the data processor, CiviQ, collect personal information from you on our behalf, to facilitate your responses to public consultations and engagement with other respondents. Your data is collected in the following ways:

  • Directly from your written input to the Platform via the registration form, submission forms, survey forms and comment boxes;
  • Automatically through the platform’s technologies including tracking online, such as by web cookies (which are small text files created by websites and stored on your computer).
     

The information you provide

We collect the following information about you from your use of the Platform:

Information you provide directly to us:
  • Contact details, including your name, email address
  • Organisational affiliation if you are registering an organisation or a company
  • Usernames and passwords
  • Website security roles to allow you to securely perform some limited functions within the CiviQ platform
  • Data that you submit in your consultation submissions, survey responses, application form submissions, comments, emails, feedback about the platform, and other content you provide via the platform
  • Consent to receive emails from subscriptions, notifications and messages including date and time of consent
  • Logging acceptance of this privacy statement and other Terms and Conditions;
  • Audit of moderation tasks on your submission
  • If you make a submission to some types of consultation, there is or may be a requirement to provide your name and address. The platform therefore requests these details at log in to facilitate your participation in all types of consultation, in an efficient and effective manner

Some types of communications from the Platform require your consent.  These include messages and notifications. You may choose to receive notifications about consultations; system messages and notifications or withdraw consent to the same. We will be asking you to consent to these communications.

Information that is automatically collected

We may automatically collect certain information about the computer or devices (including mobile devices or tablets) you use to access the Portal services. Such information includes:

  • Account information and last log-in date and time
  • Tracking codes, such as cookies. A cookie is a small text file that is placed on your computer when you visit a website. Cookies enable us to: (a) recognise your computer; (b) store your preferences and settings; (c) understand the web pages of the Portal services you have visited and the referral sites that have led you to our Portal services; (d) perform searches and analytics; and (e) assist with security administrative functions
  • IP address


With your consent, using optional analytics cookies, device information such as:

  • Location information (by country and city)
  • Unique device identifiers
  • IMEI and TCP/IP address
  • browser types
  • browser language
  • screen resolution
  • operating system
  • mobile device carrier information
     

With your consent, using optional analytics cookies, information related to the ways in which you interact with the Portal services such as:

  • city, region, country, longitude/latitude (latitude and longitude are often near the centre of population. These values are not precise and cannot be used to identify a particular address or household)
  • browser, browser version, device type, operating system, user agent
  • date, time, time zone
  • pages visited (page URLs and page titles)
  • screens visited
  • referrer URL
  • marketing campaign URL parameters
  • files clicked and downloaded
  • links to an outside domain that were clicked
  • screen resolution
  • session recording storing the HTML page, and all mouse events (movements, scrolls, locations and clicks), and keypresses
  • search terms used on an internal mobile’s or web properties’ search engine
  • custom dimensions and custom variables (any personal or non-personal data the controller wishes to process)
  • custom events
  • content pieces
  • JavaScript errors
  • User ID
     

The Platform uses third party service provided by MTCaptcha to ensure the security of the Platform and protect against spam and abuse. The cookies we use do not track individuals and do not collect or store personally identifiable information. Data collected is used solely for security purposes and to prevent fraudulent activities.  See MTCaptcha's Captcha Plugin Privacy Policy

What we use the information we collect about you for

We may use information we hold about you in the following ways:

Information you give us. We will use this information:

  • to carry out our obligations to process your responses to public consultations
  • to provide you with information
  • to notify you of confirmation that we have received your response to a consultation
  • to notify you about changes to any of the Platform services
  • to ensure that content from the Platform is presented in the most effective manner for you and for your computer
     

Information collected about you by the Platform. This information is used:

  • to administer the Platform and for internal operations, including troubleshooting and testing;
  • to improve the Platform to ensure that content is presented in the most effective manner for you and for your computer or mobile device
  • to keep the Platform safe and secure
  • to help improve the reach and inclusiveness of public consultations using third party services such as Matomo Analytics. 


Our legal basis for using your information

We collect your personal data only where it is relevant to and necessary for specified, explicit and legitimate purposes determined at the time of collection. 

We process your personal data on one or more of the following grounds set out in Section 5 of DPR21:

  • in the exercise of ADGM’s or any of it Authority’s functions
  • for the performance of a task carried out by ADGM or any of its  Authorities  in the interests of ADGM
  • in the exercise of official authority by ADGM or any of its Authorities under applicable laws
  • where processing is necessary for ADGM and/or any of its Authorities to comply with applicable laws
  • in certain circumstances, we may rely upon the consent of an individual given for specific purposes in accordance with the DPR21

We ask for your consent with regard to certain types of communications and notifications. You can manage your consent settings for communications, notifications and messages via the Manage Consent page on the platform at https://raconsultations.adgm.com/en/user/consent.

We do not ask for any special categories of personal data from individuals for the purposes of the Platform services.

How long we hold your data

We will retain your data for such periods as is necessary to fulfil our statutory functions and for the purposes set out in this privacy statement, unless a longer period for the retention of personal data is required by law. 

Personal data processed based on consent will be retained and processed until you withdraw your consent. 

You may exercise any of your rights outlined in this privacy statement by emailing us at dpo@adgm.com.

Sharing of your information

We may share your personal data between the ADGM and its Authorities.

We may share your personal data in the following circumstances:

  1. to our third-party professional advisors, service providers, agents, subcontractors and other organisations for the purposes of providing services to us or to you on our behalf, who are under a duty of confidentiality with ADGM
  2. any court, tribunal, or regulatory, supervisory, law enforcement, governmental or quasi-governmental authority
  3. third parties in an aggregated and/or anonymised form which cannot reasonably be used to identify you

We may share your Personal Data with any other person if we notify you and obtain your consent to the disclosure.

Your Personal Data may be processed by us and those other parties described above, outside of the ADGM. Where the ADGM Commissioner of Data Protection has not issued an adequacy decision in relation to the jurisdiction where your personal data is processed, we will ensure that there are adequate mechanisms in place to protect your personal information in accordance with applicable data protection and privacy law. We will do this through use of data transfer agreements implementing standard data protection clauses. 

Storage of your information

The Personal Data that we collect from you may be securely transferred to and securely stored on our databases, located on our secure servers both in ADGM and in backup locations in the United Arab Emirates or abroad. 

We store Personal Data in electronic, digital and paper format. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected or actual personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. Where a direct communication to you will involve disproportionate effort, we may instead inform you via a public communication or other similar measures that are equally effective. 

Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Platform, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

The transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of data whilst in transit to or from our Platform. Any transmission is at your own risk.

Automated decision-making

Your personal data is not used for any automated decision-making.

Cookies

Please note that you can change your settings to notify you when a cookie is being set or updated, or to block cookies altogether. Please consult the “Help” section of your browser for more information. Please note that by blocking any or all cookies, you may not have access to certain features or offerings of the Platform services. Information on how to change your cookie preferences is available in the Cookie Policy.

Your rights

You have certain rights in relation to your personal information that is processed by us. These rights are listed below. These rights are not absolute and apply subject to certain conditions. For example, your rights may include:

  • the right to access personal data held by us about you
  • the right to require us to rectify any inaccurate personal data held by us about you
  • in certain circumstances, the right to require us to erase personal data held by us about you
  • in certain circumstances, the right to restrict our processing of personal data held by us about you
  • in certain circumstances, a right to receive personal data which you have provided to us in a structured, commonly used and machine readable format. You may also have the right to require us to transfer this personal data to another organisation, at your request
  • the right to object to our processing of personal data held by us about you (including for the purposes of sending marketing materials to you)
  • the right to withdraw your consent, where we are relying on it to use your personal data. The withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal

To exercise these rights please contact dpo@adgm.com. For further information please visit the Data Protection section of ADGM’s website: https://www.adgm.com/information/privacy-policy

Some rights you can exercise directly on the Platform via your Personal Account page; My Submissions Page; Manage Subscriptions page; and by checking certain boxes on the consent forms we use when collecting your personal information. These facilitate you keeping your personal details up to date and prevent certain types of processing.

With regard to communications, if at any point you wish to review or change your preferences, you can use the ‘opt-out’ or 'unsubscribe' mechanism or other means provided within the communications that you receive from us. Note that you may still receive transactional communications regarding your submissions.

To inquire about or exercise other rights please email the data controller on dpo@adgm.com.  CiviQ will action any instructions from the data controller with respect to your request.

Obligation to provide personal data

In order to provide certain services to you, ADGM requires your personal data, and cannot provide the services without this data. Where ADGM requires this data it will be made clear to you on application for these services, what personal data will be required to be held and processed by ADGM.

Changes to this policy

We reserve the right to modify this privacy statement at any stage. If and when we make changes to this privacy statement, we will share details of these changes on this page. Please continue to check this page to ensure that you are always aware of any changes.


Date: 16 December 2025