1. Introduction
GoalPay Business Consulting ("GoalPay", "we", "our", or "us") is committed to protecting and respecting your privacy. This Privacy Policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.
This policy is prepared in compliance with the Abu Dhabi Global Market (ADGM) Data Protection Regulations 2021 and applies to all personal data collected through our website (www.goalpayconsulting.com), email communications, and direct business engagements.
By using our website or engaging our services, you acknowledge that you have read and understood this Privacy Policy.
2. Data Controller
The data controller responsible for your personal data is:
- Company: GoalPay Business Consulting
- Address: Abu Dhabi, United Arab Emirates
- Email: contact@goalpayconsulting.com
- Phone: +971 50 585 3455
3. Personal Data We Collect
We may collect and process the following categories of personal data:
- Identity Data: Full name, job title, company name
- Contact Data: Email address, telephone number, postal address
- Enquiry Data: Service interests, messages, and details provided via our contact form
- Technical Data: IP address, browser type and version, time zone, browser plug-in types, operating system and platform, and other technology on the devices used to access our website
- Usage Data: Information about how you use our website
- Marketing Data: Your preferences in receiving marketing communications from us
For clients engaged in our services, we may additionally collect financial data, employment data, and other business-related information strictly necessary for service delivery, as governed by our service agreements and applicable confidentiality obligations.
4. How We Collect Your Personal Data
We collect personal data through the following methods:
- Direct interactions: When you complete our contact form, email us, call us, or engage us as a client
- Automated technologies: When you browse our website, we may automatically collect Technical and Usage Data through cookies and similar tracking technologies
- Third parties: We may receive data from business partners, referrals, or publicly available sources
5. How We Use Your Personal Data
We use your personal data only for lawful purposes, including:
- To respond to enquiries and provide the information or services you have requested
- To fulfil our contractual obligations to you as a client
- To send administrative communications including service updates and invoices
- To send marketing communications about our services, where you have consented or where we have a legitimate interest
- To improve our website, services, and business operations through analysis of usage patterns
- To comply with legal and regulatory obligations under UAE and ADGM law
- To prevent fraud and ensure website security
6. Legal Basis for Processing
We process your personal data on the following legal grounds as set out in the ADGM Data Protection Regulations 2021:
- Consent: Where you have explicitly consented to processing (e.g., submitting our contact form)
- Contract performance: Where processing is necessary to fulfil a service agreement with you
- Legitimate interests: Where we have a legitimate business interest that does not override your fundamental rights and freedoms
- Legal obligation: Where processing is required to comply with applicable UAE federal or ADGM law
7. Data Retention
We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, including satisfying legal, accounting, or reporting requirements under UAE law. Specifically:
- Contact form enquiries: retained for 24 months from the date of submission
- Client service records: retained for 5 years after the conclusion of the engagement (as required by UAE Commercial Transactions Law and ADGM financial regulations)
- Marketing data: retained until you withdraw consent or opt out
8. Data Sharing & Disclosure
We do not sell, rent, or trade your personal data to third parties. We may share your data in the following limited circumstances:
- With service providers acting as data processors who assist us in operating our business (e.g., email hosting, cloud storage), under strict confidentiality and data processing agreements
- With professional advisers (lawyers, auditors) bound by professional confidentiality obligations
- With UAE federal authorities, ADGM regulatory bodies, or law enforcement where required by applicable law
- In the event of a merger, acquisition, or business sale, where data transfer is subject to continued protections consistent with these regulations
9. International Data Transfers
Where we transfer personal data outside of the UAE or the ADGM, we ensure that adequate safeguards are in place in accordance with the ADGM Data Protection Regulations 2021. Transfers will only occur to countries or recipients that provide an equivalent level of data protection, or where appropriate contractual safeguards (such as standard data transfer clauses) are in place.
10. Cookies
Our website uses cookies to enhance your browsing experience. Cookies are small text files placed on your device. We use:
- Strictly necessary cookies: Essential for the website to function properly
- Analytics cookies: To understand how visitors interact with our website (e.g., Google Analytics)
- Preference cookies: To remember your settings and preferences
You can control cookie settings through your browser. Note that disabling certain cookies may affect website functionality.
11. Your Rights Under ADGM Data Protection Regulations 2021
Under the ADGM Data Protection Regulations 2021, you have the following rights regarding your personal data:
- Right of access: To request a copy of the personal data we hold about you
- Right to rectification: To request correction of inaccurate or incomplete data
- Right to erasure: To request deletion of your personal data where there is no compelling reason for its continued processing
- Right to restriction of processing: To request that we restrict the processing of your data in certain circumstances
- Right to data portability: To receive your personal data in a structured, commonly used, and machine-readable format
- Right to object: To object to processing based on legitimate interests or for direct marketing purposes
- Right to withdraw consent: To withdraw consent to processing at any time (where processing is consent-based), without affecting the lawfulness of processing carried out prior to withdrawal
To exercise any of these rights, please contact us at contact@goalpayconsulting.com. We will respond to your request within 30 days as required under the ADGM Data Protection Regulations 2021.
12. Data Security
We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction, in line with the security requirements of the ADGM Data Protection Regulations 2021. These include:
- SSL/TLS encryption for data transmission via our website
- Restricted access controls and role-based permissions for client data
- Regular security assessments and staff data protection training
- Formal data handling and confidentiality policies for all consultants
In the event of a personal data breach that poses a risk to your rights and freedoms, we will notify the ADGM Office of Data Protection and affected individuals as required by the Regulations.
13. Third-Party Links
Our website may contain links to third-party websites. We are not responsible for the privacy practices or content of those websites. We encourage you to review the privacy policy of any third-party site you visit.
14. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. Material changes will be notified on our website. The "Last Updated" date at the top of this page indicates when the policy was most recently revised. Your continued use of our website or services after any changes constitutes acceptance of the updated policy.
15. Complaints
If you have concerns about how we handle your personal data, you have the right to lodge a complaint with the ADGM Office of Data Protection. We encourage you to contact us first so we can seek to resolve your concern directly.
16. Contact Us
If you have any questions about this Privacy Policy, wish to exercise your data rights, or have concerns about how we handle your personal data, please contact our Data Protection Officer: