Privacy Policy

Last Updated: April 2025

Al Fardan Holding W.L.L. and its subsidiaries (collectively, "Al Fardan Holding", "we", "us", or "our") are committed to safeguarding the privacy of individuals who visit our website, interact with our services, or engage with us in any capacity. This Privacy Policy explains how we collect, process, store, and disclose personal data in accordance with the EU General Data Protection Regulation (GDPR), the Bahrain Personal Data Protection Law (PDPL), and other applicable international data protection legislation.

1. Data Controller

The data controller for the processing of your personal data is:

Al Fardan Holding W.L.L.
Bahrain Financial Harbour, Manama, Kingdom of Bahrain
Email: privacy@alfardan.co

2. Data We Collect

We may collect and process the following categories of personal data:

• Identity Data: Full name, title, nationality, and professional role
• Contact Data: Email address, postal address, telephone number, and business address
• Technical Data: IP address, browser type and version, operating system, device identifiers, and other technology-related data collected via cookies and similar technologies
• Usage Data: Pages visited, time spent on pages, navigation paths, referral sources, and interaction metrics
• Inquiry Data: Information provided when you contact us through forms, including your organisation, message content, and inquiry category
• Professional Data: CV/resumé information if submitted through our careers portal

3. Legal Basis for Processing

Under GDPR Article 6, we process your personal data on the following legal bases:

• Consent (Art. 6(1)(a)): Where you have provided explicit consent, e.g. subscribing to communications or accepting non-essential cookies
• Contractual Necessity (Art. 6(1)(b)): Where processing is necessary to perform a contract or take steps prior to entering into one
• Legitimate Interest (Art. 6(1)(f)): Where processing is necessary for our legitimate business interests, such as improving our website, analysing usage patterns, and ensuring network security — balanced against your rights and freedoms
• Legal Obligation (Art. 6(1)(c)): Where processing is required to comply with applicable laws, regulations, or legal proceedings

4. How We Use Your Data

Your personal data is used for the following purposes:

• To respond to inquiries and provide requested information about our services
• To maintain, improve, and optimise the performance and user experience of our website
• To analyse aggregate usage patterns and generate statistical insights
• To comply with applicable legal and regulatory obligations across the jurisdictions in which we operate
• To protect the security and integrity of our digital infrastructure and business operations
• To process employment applications submitted through designated channels

5. Cookies & Tracking Technologies

Our website uses cookies and similar tracking technologies to enhance user experience and analyse site performance. These are categorised as follows:

Essential Cookies

Required for core website functionality, including session management and security. These cookies cannot be disabled.

Analytics Cookies

Used to collect anonymised data about how visitors interact with our website, helping us improve usability and content. These require your consent.

Functional Cookies

Enable us to remember your preferences, such as language selection and cookie consent choices.

You may manage your cookie preferences using the cookie consent tool displayed on your first visit. You can also configure your browser to block or delete cookies at any time.

6. Data Sharing & Third Parties

We do not sell, rent, or trade your personal data. We may share your data with:

• Group Companies: Other entities within the Al Fardan Holding group for internal administrative purposes
• Service Providers: Third-party vendors who provide hosting, analytics, and IT services under strict data processing agreements
• Legal & Regulatory Authorities: Government bodies, law enforcement, or regulators where required by law
• Professional Advisors: Lawyers, auditors, and consultants where necessary for legitimate business purposes

7. International Data Transfers

As a multinational group operating across 30+ countries, your personal data may be transferred to and processed in jurisdictions outside the European Economic Area (EEA) or your country of residence, including the Kingdom of Bahrain, the United Arab Emirates, and other countries where our subsidiaries and service providers operate.

Where such transfers occur, we implement appropriate safeguards including:

• EU Standard Contractual Clauses (SCCs) approved by the European Commission
• Binding Corporate Rules within our group of companies
• Adequacy decisions recognised by competent data protection authorities

8. Data Retention

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable laws and regulations. Specific retention periods include:

• Inquiry Data: Retained for up to 24 months from the date of your last interaction, unless a longer period is required
• Technical & Usage Data: Retained for up to 12 months for analytics purposes
• Cookie Data: Consent preferences are stored for 12 months before re-confirmation is requested
• Employment Application Data: Retained for up to 36 months, unless consent is withdrawn

9. Your Rights Under GDPR

As a data subject, you are entitled to the following rights under GDPR and applicable data protection laws:

• Right of Access (Art. 15): Request confirmation of whether we process your data and receive a copy of it
• Right to Rectification (Art. 16): Request correction of inaccurate or incomplete personal data
• Right to Erasure (Art. 17): Request deletion of your personal data where it is no longer necessary or where consent is withdrawn
• Right to Restriction (Art. 18): Request limitation of processing in certain circumstances
• Right to Data Portability (Art. 20): Receive your data in a structured, machine-readable format and transfer it to another controller
• Right to Object (Art. 21): Object to processing based on legitimate interests or direct marketing
• Right to Withdraw Consent (Art. 7): Withdraw consent at any time, without affecting the lawfulness of processing based on consent before withdrawal

To exercise any of these rights, please contact us at privacy@alfardan.co. We will respond to your request within 30 days.

10. Data Security

We implement robust technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These include encryption of data in transit (TLS/SSL), access controls, regular security assessments, and employee training on data protection obligations.

11. Children's Privacy

Our website and services are not directed at individuals under the age of 16. We do not knowingly collect personal data from children. If we become aware that personal data has been collected from a child without appropriate consent, we will take steps to delete the data promptly.

12. Changes to This Policy

We reserve the right to update this Privacy Policy at any time. Material changes will be communicated through a prominent notice on our website. We encourage you to review this policy periodically.

13. Contact & Complaints

If you have any questions, concerns, or complaints regarding this Privacy Policy or our data processing practices, please contact:

Data Protection Officer
Al Fardan Holding W.L.L.
Bahrain Financial Harbour, Manama, Kingdom of Bahrain
Email: privacy@alfardan.co

You also have the right to lodge a complaint with a supervisory authority, such as the Personal Data Protection Authority (PDPA) in Bahrain or any relevant EU data protection authority.