Last Updated: October 8, 2025
1. Introduction
Mojay Global Holding Limited (“Mojay”, “we”, “us”, or “our”), a holding company registered in the DIFC with its address at No. 901A, Emirates Financial Towers, DIFC, Dubai, UAE, values your privacy and recognizes the importance of protecting the personal data of all individuals whose data it processes, whether collected directly or indirectly through its partners and affiliates (“Data Subjects”, “you” or “your”).
This Privacy Policy (“Policy”) explains:
How we collect your data
Categories of data we collect
How we use your data
Our legitimate interests
Sharing of data
Transfers outside the DIFC
Data retention
Your rights
Marketing purposes
Non-discrimination
Security measures
Complaints and contact information
This Policy supplements any other notices we may provide when collecting or processing your data. It does not override them.
We may update this Policy from time to time. Changes will be posted on this page and, where appropriate, you will be notified of material changes.
2. How We Collect Data
We collect data directly from you, from third parties (including affiliates and agents), and from publicly accessible sources. Examples include:
Vendors and partners (including consultants)
Current, former, or prospective employees and contractors of Mojay or the Mojay Group (“Workers”)
Dependents and emergency contacts of Workers
Affiliates (companies with shared ownership)
Investors and prospective investors
Collection methods include:
Direct submissions (documents, forms, applications)
Recruitment agencies and referees
Security clearance providers
CCTV images (from our premises or landlords)
Employers (for secondees)
Health and benefits providers
Telephone calls, virtual and physical meetings, emails, or postal correspondence
Where you provide us with the personal data of third parties (e.g., next of kin), you confirm that they have consented, and that you have provided them with a copy of this Policy.
3. Categories of Data Collected
We may collect the following categories of personal data:
Identity Data: Name, nationality, address, title, marital status, gender, date of birth, passport and ID copies.
Contact Data: Phone number, email address, physical address.
Financial Data: Payment records, bank account details, financial transactions.
Communications Data: Complaints, incident reports, correspondence history.
Security Clearance Data: Background checks, clearance results.
Employment Data (Workers): Role, designation, salary, benefits, attendance, contractual entitlements, references, qualifications, criminal conviction declarations.
HR Records (Workers): Leave records, performance reviews, disciplinary records, training records, grievances, complaints.
IT Usage Data: Records of use of Mojay’s IT systems (with legal safeguards in place).
Health Data: Sick leave certificates, fitness-for-work notes, occupational injury reports.
Special Category Data (where applicable): Racial/ethnic origin, disabilities (for equal opportunity monitoring and legal compliance).
4. How We Use Your Data
We process your data only where we have a lawful basis, including:
Consent: Where you have given explicit permission.
Contractual necessity: To perform or enter into a contract with you.
Legal obligation: To comply with applicable laws.
Legitimate interests: Where it does not override your rights (see Section 5).
Vital interests: To protect life or safety.
Worker-specific purposes include:
Recruitment, onboarding, and HR management
Salary, benefits, and leave administration
Performance assessment and training
Visa and immigration processing
Ensuring workplace and IT security
5. Legitimate Interests
We may process your data for legitimate interests, including but not limited to:
Authentication and background checks
Internal and external audits
Recruitment administration
Emergency contact and dependent records
Security and fraud prevention
Protecting our legal rights and complying with court orders
IT security and fraud detection
6. Sharing of Data
We share your data on a strict need-to-know basis with:
Mojay Group entities and Affiliates
Outsourced service providers
Professional advisors (legal, tax, audit, IT)
Reinsurers, insurers, and actuaries
AML/CFT compliance entities
Regulators and government authorities (DIFC, labor department, immigration, etc.)
Law enforcement, when required
Successors (in case of a merger, acquisition, or sale of assets)
7. Transfers Outside the DIFC
As part of a multinational group, data may be transferred outside the DIFC. We ensure safeguards are in place, including:
Transfers only to jurisdictions deemed adequate by the DIFC Data Protection Commissioner; or
Use of contractual safeguards with the receiving party.
8. Data Retention
We retain your data only as long as necessary, considering:
Legal and contractual obligations
Limitation periods for claims
Nature, sensitivity, and risk associated with the data
Example: Employment records (basic details such as name, role, and duration) are retained for at least 10 years post-termination unless you request otherwise.
9. Your Rights
You have the following rights under applicable law:
Withdraw consent
Access your data
Rectification (correct inaccuracies)
Deletion (where applicable)
Restriction of processing
Data portability (in machine-readable format)
Object to processing (on legitimate grounds)
Object to automated decision-making and profiling
Requests must be made using the contact details in Section 12. Verification of identity may be required.
10. Non-Discrimination
We will not penalize you for exercising your rights. However, refusal to provide necessary data may limit our ability to engage or employ you, or to provide services.
11. Security Measures
We implement reasonable and legally required technical and organizational measures to protect your data against unauthorized access, loss, or misuse.
In case of a data breach, we will notify you and the regulator where legally required.
12. Complaints & Contact
If you have any questions, concerns, or complaints about this Policy, please contact:
Contact Person: Nataliia Kuz
Telephone: +971 4 876 1992
Email: nataliia@mojay.com
Address: No. 901A, North Tower, Emirates Financial Towers, DIFC, Dubai, UAE
