Data Protection in UAE - Dubai (DIFC)

Electronic marketing in UAE - Dubai (DIFC)

The DPL requires Controllers to provide Data Subjects with various pieces of information when they process their personal data (typically by way of a privacy notice, which must meet the detailed requirements set out Part 5 of the DPL), including whether the personal data will be used for direct marketing purposes.

Whilst consent is not expressly required (implying that one of the other legal bases can potentially be relied upon), Data Subjects do have the right to:

  • be informed before Personal Data is disclosed for the first time to third parties or used on their behalf for the purposes of direct marketing, and to be expressly offered the right to object to such disclosures or uses; and
  • where Personal Data is Processed for direct marketing purposes, object at any time to such Processing, including Profiling to the extent that it is related to such direct marketing.

(Article 34 DPL)

The Controller should also make clear in its Notification to the Commissioner that one of the purposes for which it Processes Personal Data is that of direct marketing.

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