Privacy Policy


Reflechir Consultancy FZE does not accept any responsibility or liability for the actions or inactions on the part of any individual member firm or firms. Individual member firms do not accept responsibility or liability for actions or inactions on the part of any other individual member firm or firms.

Privacy Policy Statement

REFLECHIR is committed to protecting the privacy of the personal information of its clients, members, partners and employees. We value the trust of the public and those we deal with, and recognize that maintaining this trust requires transparency and accountability in how we treat personal information that is shared with us.  This Privacy Policy Statement (“Policy”) has been adopted to guide how we collect, use and disclose the personal information acquired during conducting our business and fulfilling our professional responsibilities.

When applied to REFLECHIR’s website, this Policy applies only to the specific web-pages of REFLECHIR.  Please be aware that REFLECHIR web site may contain links to other sites, including sites maintained by REFLECHIR member firms and REFLECHIR International that are governed by other privacy statements that may differ somewhat and/or contain information as required under local law applicable to each member firm.  We encourage users to review the privacy policy of each web site visited before disclosing any personal information.

We adhere to the requirements of the law and our professional standards, and as we conduct our business operations we frequently gather and use personal information. We seek consent to use this information when it is collected and recognize your expectation that it will be carefully protected. Our privacy practices require that we only use personal information outside of the original purpose for which it is collected after obtaining appropriate consent.


Personal information is defined as any information that can be used to distinguish, identify or contact a specific individual, including information about age, income, opinions or beliefs, home location and family. However, business contact and other information about individuals that is available in the public domain, such as names, addresses and telephone numbers published in directories, are not considered personal information. Public information is not subject to privacy legislation and therefore is excluded from this policy and is not subject to the same protections as is the case with personal information. However, we do not disclose personal information about our staff, members, partners and clients without consent.


We follow these policies when collecting, maintaining and using personal information:

Collection and use of personal information

When you visit our website, make an enquiry, order publications or request information, you may be asked to provide some personal data such as your name, address, telephone number and e-mail address. In the event you decide to provide personal data, this policy will apply. An IP address is a number assigned to your computer whenever you access the internet. It allows computers and servers to recognize and communicate with one another. IP addresses from which visitors appear to originate may be recorded for IT security and system diagnostic purposes. This information may also be used in aggregate form to conduct web site trend and performance analysis.

We obtain personal information about you only if you choose to provide it, such as contact information to register for certain services. In some cases, you may have previously provided your personal information to REFLECHIR (if, for example, you are a former employee). If you choose to register or login to our web site through a third-party single sign-in service (e.g., LinkedIn, Google, or Twitter), we may collect any information or content needed for the registration or log-in information that you permit the social media provider to share with us, such as your name and email address. Other information we collect may depend on the privacy settings you establish with your social media provider, so please review the privacy statement or policy of the applicable service.

By registering and/or submitting personal information to REFLECHIR, you are also agreeing to the use of this information in accordance with this Policy.

Your personal information is not used for other purposes, unless we obtain your permission, or unless otherwise required or permitted by applicable law or professional standards. For example, if you register on our web site and provide information about your preferences we will use this information to personalize your user experience. If you send us a resume to apply online for a position, we may use the information that you provide to match you with available job opportunities with REFLECHIR.


Legal grounds to use your personal information


REFLECHIR generally collects only the personal information necessary to fulfil your request. If we seek additional and optional information, we will notify you of this at the point of collection.

We are permitted by law to process personal information, if we have a ground under the law to do so. We are obliged to inform you by law as to what those grounds are. Consequently, when your personal information is processed by us, reliance will be placed on the following processing conditions. For example:

Performance of an engagement, agreement or contract: this is when the processing of your personal information is necessary to perform our obligations under an engagement letter, agreement or a contract;

Statutory/Legal obligation: this is when we are required to process your personal information to comply with a legal obligation, such as keeping records for tax purposes or providing information to a public body or law enforcement agency;

Legitimate business and other interests: when it is in our legitimate interest to operate a lawful business and to further that business. Under such circumstances we will process information about you so long as it doesn’t outweigh your interests; or

Your consent: in some instances, specific permission may be sought from you to process some of your personal information. We will only process your personal information in this way if you agree to us doing so. You may withdraw your consent at any time by contacting REFLECHIR at

Some examples of the ‘legitimate business and other interests’ referred to above include but are not restricted to:

Offering information and/or services to visitors to our web site or offer information about possible employment opportunities.

Safeguarding our IT infra-structure and prevent fraud or criminal activity

Customizing the visitors’ online experience and improve the performance, usability and effectiveness of REFLECHIR’s online presence.

Conducting and analyzing our marketing activities.

Meeting and enhancing our corporate and social responsibility obligations.

In some instances, personal data that we collect may also include data categories such as diversity related information (including information about ethnic and racial origin, religious and similar beliefs, political inclinations and opinions, membership to trade related bodies or health data and data about alleged or proven criminal offences in each case) where law permits us to do so, is permitted to be collected by professional standards and if you voluntarily provide it to us.


Please do not provide sensitive personal information to REFLECHIR, unless you consent to our use of that information for its legitimate business purposes and consent to the transfer and storage of the information to and in a REFLECHIR database. If you wish to question the necessity of providing sensitive information for any particular purpose, please contact us at

If you have any questions regarding this Policy, please contact webmaster services using the contact us link


Your consent is required for the collection and proposed use of personal information when information is collected. Consent can be either explicit or implied and can be provided directly to us by you or your authorised representative. We require your explicit consent in writing or electronically for the use of your personal information.


A cookie is a small piece of data or message that is sent from an organisation’s web server to your web browser and is then stored on your hard drive. Cookies cannot read data off your hard drive or cookie files created by other sites, and do not damage your system.


REFLECHIRUAE uses cookies to monitor the performance of our website and to improve user experience. If you choose not to accept our cookies, some of the features of our site may not work as well as we intend.

Cookies are commonly used by websites to remember some aspect of your current or previous visit.  This could include things like the choices you’ve made or preferences you’ve chosen during your visit. Websites commonly do this in order to improve or tailor your current and future visits to that site or other related sites.


One example may be when you visit a site that you have been to before, that site may use a cookie to check what information you’ve looked at previously to get an idea of the topics that may be of interest to you.


The information stored in a cookie can only be read by the website that placed the cookie or other sites that it has agreed to share information with.

Our policy on cookies

Our policy is to use cookies only to improve the way we do business with you or when they’re essential to the way the site works.

The types of activities we may use cookies for are to:


To find out how people use our sites, such as how often they visit, which pages they go to, and which links they click on, so that we can improve our websites

To help us to provide relevant information, such as details of products, services and other information that you may be interested in

We do not use any cookies to store any personal data or other data that could be used to identify you as an individual.


Whenever possible, we will list the cookies used on our websites (for example,, REFLECHIR will also use a Session ID cookie which is purely for collecting website performance- based metrics. REFLECHIR does not collect or store any personal data through our website.

How to turn off cookies

You can turn off cookies in your browser settings. If you do turn them off, it is important to remember that you may not be able to use all of the services on our websites.

You can find out more about turning off cookies at the independent website

Google Analytics

This website uses Google Analytics to track performance. For example, we may track visitor sessions and referral sources to our sites. We use this data to understand site performance to serve you better. We may also track the performance of promotional links to our site. No personal information is passed to Google Analytics. Note that Google Analytics stores its data within the United States of America and is therefore subject to US laws. Those wishing to opt out of Google Analytics data collection should use the Google Analytics Opt-out Browser Add-on.


REFLECHIR understands the importance of protecting children’s privacy, especially in an online environment. Our sites are not intentionally designed for, or directed at, children under the age of 13, and our policy is never to knowingly collect or maintain children’s information except where required as part of an engagement to provide professional services.

Sharing and transfer of Personal Information

In some instances, REFLECHIR may share your personal information with outside companies, service providers or vendors. This may include the transfer of this information across geographical borders to other REFLECHIR member firms or third parties working with us or on our behalf to help fulfil your requests. REFLECHIR generally stores personal information in the UAE but may also store personal information in other legal jurisdictions. By providing personal information online to us, you are consenting to the transfer and/or storage of your personal information in this manner. REFLECHIR does not sell personal information to any third parties, nor will REFLECHIR transfer your personal information to any third parties for their own direct marketing use.


Compliance with laws and regulations

REFLECHIR may be required to disclose personal information in response to requests of government or law enforcement agencies or where disclosure is required by applicable laws, court orders, or government regulations. These disclosures may also be needed for data privacy or security audits and/or to investigate or respond to a complaint or security threat.


You are not required to submit any personal information to REFLECHIR online, but certain personal information may be required for you to receive additional information about our services and events. REFLECHIR may also ask for your permission for certain uses of your personal information, and you can agree to or decline those uses. If you opt-in for services or to receive communications from us, you will be able to unsubscribe at any time by following the instructions included in each communication. Where you unsubscribe from a service or communication, we will try to remove your information promptly, but may require additional information to process your request.




Personal information will be maintained as completely, accurately and up-to-date as possible. You are encouraged to review, correct and update personal information. You can also make a request to update or remove information about you by contacting and we will make all reasonable and practical efforts to comply with your request, so long as it is consistent with applicable law and professional standards.

Your rights

If REFLECHIR processes personal information about you, you have the following rights:

Access and correction: “Subject Access Request” grants you the right to have access to that data. If REFLECHIR agrees that it is obliged to provide personal information to you, we will provide it to you free of charge. Before providing personal information to you, we may ask for proof of identity and sufficient information about your interactions with us that we can locate your personal information. If the information we hold about you is incorrect, you are entitled to ask us to correct any inaccuracies in the personal information.

Object to processing: If we are not entitled to process and use your personal information, you have the right to object and not permit it to be used any more.

Other Rights: in addition, you may have rights to have your information deleted if we are keeping it too long, have its processing restricted in certain circumstances and/or to obtain copies of information we hold about you in electronic form.

You can make a request or exercise these rights by contacting REFLECHIR at and we will make all reasonable and practical efforts to comply with your request, so long as it is consistent with applicable law and professional standards.

Information security

REFLECHIR has reasonable security policies and procedures in place to protect personal information from unauthorized loss, misuse, alteration, or destruction. Appropriate physical and electronic measures are also used to help ensure that personal information is secure. To the best of our ability, access to your personal information is limited to those who require the information to fulfil their job responsibilities. Those individuals who have access to the data are required to maintain the confidentiality of such information. However, despite our best efforts, security cannot be absolutely guaranteed against all threats.

Retention of personal information

Personal information will not be used or disclosed for purposes other than those for which it has been collected, except with your consent or as required by applicable law. We do not share personal information with unaffiliated third parties, except where necessary for legitimate professional and business needs, to carry out your requests, and/or as required and permitted by applicable law or professional standards. We also make reasonable efforts only to retain personal information so long as it is necessary to comply with your request and to delete personal information if you ask us to do so.


Changes to this policy


REFLECHIR may modify this Policy from time to time to advise of changes to our current privacy policies and practices. When changes are made to this Policy, the date of the update will be provided on this site, so we encourage you to review our site periodically for changes.


Policy questions and enforcement


REFLECHIR is committed to protecting the online privacy of your personal information. If you would like access to or a copy of the personal information we hold about you, to request a correction, or have any questions about how we may use it or to make a complaint, please contact the Data Protection Officer at the address shown below, or, email

We would like to keep your personal data accurate and up to date. If you become aware of any errors or inaccuracies please let us know by contacting us at our registered office.

Complaints will be dealt with by the Data Protection Officer and will be responded to within 30 days at the latest. If you are not satisfied with the way your complaint was handled, you may be able to refer your complaint to your local data protection regulator.

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