This Privacy Policy sets out how Al Zanabaq Ship Management (the 'Company," "we," "our," or "us")collects, processes, stores, and discloses personal data in connection with its crew recruitmenttechnology platform AllCrewAllCrew (the "Platform").By registering an account, uploading a profile, or otherwise using the Platform, you expresslyacknowledge and agree to the terms of this Policy.
1. Governing Law
This Policy, and all matters relating to data handling on the Platform, shall be governed by the laws ofthe Emirate of Dubai and the applicable federal laws of the United Arab Emirates, including FederalDecree-Law No. 45 of 2021 on the Protection of Personal Data (PDPL). Users are solely responsible forcompliance with the laws of any other jurisdiction in which they operate or reside. The Companyexpressly disclaims responsibility for compliance with non-UAE legal requirements.
2. Scope
This Policy applies to all individuals and entities accessing or using the Platform, including:• Candidates / Crew Members – individuals who upload CVs, profiles, or related materials;• Employers / Recruiters – entities or persons accessing candidate data for recruitment purposes;and• Other Users – any party using the Platform in any capacity.• Candidates must be at least 18 years old.
• Recruiters must act on behalf of a legitimate business and for genuine recruitment purposes.
• By using the Platform, you confirm all information you provide is accurate, truthful, and kept up todate.
3. Categories of Data Collected
The Company may collect, store, and process the following types of data:
• Candidate Data: names, contact details, CVs, qualifications, employment history, certifications.
• Employer Data: company details, authorised personnel information, account details.
• Technical Data: device identifiers, cookies, IP addresses, system logs, and browsing activity.
• Financial Data (Employers only): billing and payment information.
4. Purposes of Processing
Personal data is processed strictly for legitimate purposes, including:
• facilitating recruitment connections between Candidates and Employers;
• operating, maintaining, and improving the Platform;
• verifying identities and accounts;
• preventing fraud and misuse;• processing subscription payments;
• meeting legal and regulatory obligations under UAE law.
5. Disclosure of Data
We may share data with:Employers/Recruiters – subject to Candidate visibility settings.
Once disclosed, the Company has no control or responsibility for how Employers use such data.
2. Service Providers – including hosting, IT support, analytics, and payment processors.
3. Regulators or Authorities – if disclosure is required under applicable law.
4. Corporate Transactions – in connection with a merger, acquisition, or restructuring.
Disclaimer: Users acknowledge that once personal data leaves the Platform, the Company bears noresponsibility for third-party use, retention, or disclosure.
6. User Responsibilities
All Users agree to:
• submit only lawful, accurate, and up-to-date information;
• use data obtained from the Platform solely for legitimate recruitment purposes;
• comply with all applicable data protection, employment, and labour laws.
The Company shall not be liable for any misuse, unauthorized disclosure, or unlawful processing carried
out by Users or third parties.
7. Data Retention
• Personal data is retained while the account remains active.
• Upon account deletion, the Company will take commercially reasonable steps to erase or anonymise data, subject to technical and legal limitations.
• Residual data may persist in backups, caches, or third-party systems beyond the Company's control, for which no liability shall attach.
8. International Transfers
Data may be transferred or stored outside the UAE. By using the Platform, Users expressly consent tosuch transfers and acknowledge that such transfers occur at their own risk.
9. Security
The Company applies reasonable technical and organisational safeguards. However, no system is fullysecure. We do not warrant or guarantee protection against all cyberattacks, breaches, or unauthorizedaccess. Users access and use the Platform at their own risk.
10. User Rights
Subject to PDPL, Users may request to:
• access, correct, or delete personal data;
• withdraw consent to processing;
• restrict processing in limited statutory cases.Requests must be submitted in writing to contact@alzanabaq.com.
The Company reserves the right torefuse unfounded, excessive, or unlawful requests.
11. Disclaimer of Fiduciary or Employment Agency Role
• The Company is a technology platform only, not a recruitment agency, labour supplier, oremployment intermediary under UAE law.
• The Company is not a party to any employment arrangement between Candidates andEmployers.
• The Company makes no guarantees as to:
o whether a Candidate will secure employment;
o whether an Employer will locate a suitable Candidate; or
o the accuracy, legality, or reliability of information uploaded by Users.
12. Limitation of Liability
To the fullest extent permitted by law:
1. The Company shall not be liable for any indirect, consequential, punitive, or incidental damages,including loss of profit, business, goodwill, or data.
2. The Company's aggregate liability for any claim shall not exceed the greater of:
- the total subscription fees paid by the User in the preceding twelve (12) months, or €100 (or local currency equivalent).
3. Users acknowledge and agree that they use the Platform entirely at their own risk.
13. Indemnity & Waiver
• Users shall fully indemnify and hold harmless the Company, its affiliates, officers, employees,and agents against all claims, costs, damages, or liabilities arising from their use of the Platform,data disclosures, or breach of law.
• Users expressly waive any right to initiate or participate in class, group, or representative actionsagainst the Company in any jurisdiction.
14. Children
The Platform is not directed at, nor intended for, individuals under 18 years of age.
15. Changes to this Policy
The Company reserves the right to amend or update this Policy at any time. Continued use constitutesacceptance of the revised Policy.
16. Dispute Resolution – Arbitration
Any dispute, controversy, or claim arising out of or in connection with this Policy, the Platform, or the Company shall be referred to and finally resolved by arbitration under the Dubai InternationalArbitration Centre (DIAC) Rules, which are incorporated by reference.
• Seat of Arbitration: Dubai, United Arab Emirates.
• Language: English.
• Tribunal: Sole arbitrator, appointed under DIAC Rules.
• The arbitral award shall be final and binding on the parties.For issues not capable of arbitration under UAE law, the exclusive jurisdiction shall rest with the Courtsof Dubai.