Last Updated: 27/08/2026

1. Purpose

Davies Group Limited with its registered office at 5th Floor, 20 Gracechurch Street, London, EC3V 0BG, United Kingdom, and its entities and subsidiaries (hereinafter referred to as ‘Davies Group’) is committed to being transparent about how it processes your personal data.

The purpose of this Privacy Notice is to outlines how Davies Group will collect, hold, process, and share your personal data, to assist you in making informed decisions when using our website and/or accessing our products and services.

The objective of this Privacy Notice is to ensure transparency in the handling of personal data and to support compliance with applicable data protection requirements in the UAE, including Federal Decree by Law No. 45 of 2021 Concerning the Protection of Personal Data and its implementing regulations, and, where applicable, the DIFC Data Protection Law No. 5 of 2020 and its related regulations, each as amended from time to time.

2. Scope

This Privacy Notice applies to all Davies entities, including all regulated entities, in the following territories:

In this Privacy Notice, the terms ‘we’, ‘our’ or ‘us’ are used to refer to Davies Group, who are the controller or processor responsible for processing your personal data.

3. Definitions

The following key terms and definitions are used in this Privacy Notice and should be interpreted in accordance with applicable privacy and data protection laws.

4. The types of personal data we collect

We collect and process the following types of personal data:

• When you browse our website, we use cookies to collect usage data, which may include, but is not limited to, your IP address, browser type/version, browsing behaviour on our site (including the pages that you visit, the time spent on those pages and the date and time of your visit) and your geolocation data. More information about the types of cookies we use and our reasons for using them can be in our Cookie Policy.
• Personal identifiers, contact details, and characteristics, such as your name, country of residence, address, phone number and email address.
• Transaction Data includes details about payments to and from you and other details of forensic accounting services which you have instructed us to provide.
• Due Diligence and Anti-Money Laundering (AML) Data, including documentation and information required for client onboarding, identity verification, and screening checks (e.g. passport details, national identification numbers, or information about political exposure or criminal convictions, where legally required).
• Legal and Contractual Information, including copies of correspondence, signed contracts, declarations, or dispute resolution materials containing personal identifiers, where necessary for fulfilling legal obligations or maintaining business records.
• Sensitive Categories of personal data including health and/or medical diagnosis information, which may be held, used, and processed for the purpose of providing the services offered by Davies Group.
• We may collect personal data relating to children, but only if consent has been obtained (where required) from a parent or guardian, and the information is relevant to the products and services we provide.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

5. Where we obtain your personal data from

The personal data we process may be collected from a variety of sources including, but not limited to:

• Experts.
• Fraud prevention agencies and organisations.
• Industry regulators, government authorities, supervisory bodies, and ombudsman services, including (where applicable) data protection authorities, financial regulators, and dispute‑resolution bodies that oversee our industry or operations.
• Insurance companies.
• Insurance industry databases.
• Intermediaries, such as claims management companies.
• Law enforcement agencies.
• Loss adjusters and claims investigators.
• Other third parties.
• Our clients.
• Our website cookies.
• Social media.
• Public sources.
• Third party data providers/search systems.
• Your Insurer/Underwriter.
• Send information to us as a part of our investigations into an investigation you have asked us to perform or an insurance claim you have made.
• Complete any form or create an account on our website i.e. direct interactions.
• Subscribe to our publications.
• When you subscribe to our publications, request to receive marketing materials, or provide feedback such as comments on our website blogs or articles.

During the course of providing our services, we may also collect personal data from you directly, for example when the information is needed to progress your claim.

6. How we use your personal data

The purpose for which we will use personal data will depend on your relationship with our organization. We may use personal data for the following purposes:

• To provide and manage our services, including claims handling, insurance support, and consulting services etc.
• To manage our relationship with clients and business partners.
• To comply with legal and regulatory obligations.
• To protect our business, systems, and data (including fraud prevention, security monitoring, complaint handling, maintaining or servicing accounts, operating user accounts for security purposes, providing customer service, processing or verifying customer information, processing payments, providing analytics services, providing storage, or providing similar services;) and to improve our services, systems, and customer experience.
• To manage recruitment and employment processes.
• To send marketing communications (where permitted by law).

We process personal data based on the lawful bases set out under applicable data protection laws.

7. Our lawful bases for processing your personal data

We may collect, use, disclose, store, transfer or otherwise process your personal data where permitted under applicable UAE data protection laws, in the following circumstances:

• Consent – you have given clear consent for us to process your personal data for a specific purpose. Please note – for any processing we undertake which relies on your consent, you are able to remove your consent at any time by contacting our Data Protection Officer at DPO@davies-group.com.
• Contract – the processing is necessary to enter into or perform a contract with you, or to take steps at your request before entering into a contract. Where we use personal data on behalf of our clients, we do so in accordance with their instructions and applicable legal requirements.
• Employment, social security or social protection obligations – the processing is necessary to carry out obligations or exercise legally established rights in employment, social security or social protection.
• Legal Obligation – the processing is necessary for us to comply with the applicable law.
• Protection of your interests – the processing is necessary to protect your interests.
• Public interest – the processing is necessary to protect the public interest.
• Legitimate interests – Processing is necessary for the purpose of legitimate interests.
• Legal claims and proceedings – the processing is necessary to initiate, exercise or defend legal claims, or is related to judicial or security procedures.
• Health and social care purposes – the processing is necessary for occupational or preventive medicine, medical diagnosis, provision of health or social care, or public health protection.
• Archival, scientific, historical or statistical purposes – the processing is necessary for such purposes in accordance with applicable laws.
• Publicly disclosed data – the processing relates to personal data made publicly available by the Data Subject.
• Other permitted cases – the processing is permitted under applicable UAE laws and implementing regulations.

8. Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note – we may process your personal data without your knowledge or consent in compliance with the above rules, where this is required or permitted by applicable law. For example, where the processing relates to the detection and prevention of crime.

9. Automated decision-making and profiling

In some circumstances, we may use automation technologies, AI systems and, where relevant, profiling tools to support the processing of personal data, improve operational efficiency, and enhance user experience. These technologies are used to assist internal workflows, customer interactions and data analysis, and are not currently used to make decisions about you without human involvement. Our current use of automation technologies includes:

• Robotic Process Automation (RPA) – Where virtual workers automate the copying and pasting of information from one system into another.
• Self-Service Platforms – Allows humans to directly interact with an RPA process, enabling human-in-the-loop processing of information.
• Artificial Intelligence (AI) and Machine Learning – To enable virtual workers to learn and understand the data presented and improve effectiveness.
• Intelligent Automation Digital Assistant – An AI supervisor that automatically manages, tracks, and orchestrates virtual worker schedules and activities.
• Computer Vision/Optical Character Recognition – Offers pattern matching within images and can be used to interpret complicated language-based text recognition.
• Natural Language Processing – Translates/extracts human language into computer readable information (think “Hey Siri”) for the purpose of classifying information.
• Conversational AI – Uses AI and Natural Language Processing to enable real-time conversations with customers via the use of chatbots.
• API End-points – Uses virtual workers to bridge the gap between old systems and new ones by copying and pasting information across.

We do not anticipate that any of the automation technologies described above will produce legal or similarly significant effects on you, however if this was to change in the future, we would only do so where it is:

• Necessary for the entry into or performance of a contract; and
• Required under applicable UAE laws.
• Based on your explicit consent.

10. Who we share your personal data with

Within Davies Group, your personal data will be shared with those team members who need to access it for the processing purposes outlined in this Privacy Notice.

We will only share your personal data with other parties where it is reasonable and necessary to accomplish the processing purposes outlined in this Privacy Notice. This may include (but is not limited to) where we:

• Are required to share information with law enforcement bodies and/or fraud prevention agencies for the purpose of preventing or detecting fraud or criminal activities; or
• Rely on the services of third-party service providers and hosting providers to carry out activities, provide services, or undertake business operations on our behalf. For example, we may use Hotjar in order to better understand our users’ needs and to optimise their service and experience when using our websites. Hotjar uses cookies and other technologies to collect data on our users’ behaviour and their devices, then stores this information on our behalf in a pseudonymised user profile. For further details, please see the ‘about Hotjar’ section of Hotjar’s support site.

In any such cases, the data we share will be limited to that which is strictly necessary and will be subject to appropriate contractual and confidentiality arrangements being in place.

Additionally, all of our third-party service providers are required to take appropriate security measures to protect your personal data, in line with Davies Group policies, and we do not allow them to use your personal data for their own purposes under any circumstances.

11. International transfers

Davies Group operates internationally and personal data may be transferred to, accessed from, or processed in countries other than the country in which it was collected, including by Davies Group entities, our Global Capability Centre in India, and authorised third-party service providers.
Where we transfer, disclose, store, or otherwise make personal data available outside the country in which it was collected, we will take appropriate steps to protect that data in accordance with applicable data protection laws. These steps may include:

• conducting due diligence on overseas recipients and service providers;
• relying on adequacy decisions, recognised comparable protection mechanisms, or equivalent legal safeguards where available;
• entering into appropriate contractual arrangements, such as standard contractual clauses, model contract clauses, intra-group transfer arrangements, data processing agreements, or other equivalent contractual protections;
• carrying out transfer risk assessments where required or appropriate;
• implementing supplementary technical and organisational measures;
• ensuring overseas recipients are required to protect personal data to a standard that is comparable or equivalent to the protection required under applicable data protection laws;
• limiting overseas transfers to what is necessary for the relevant purpose.

If you would like to understand more about this, please send an email outlining your query to DPO@davies-group.com.

For a list of Davies Group subsidiaries and legal entities, please refer to our Global Privacy Notice.

12. How long we keep your personal data for

We will keep your personal data for as long as necessary to fulfil the purposes that we describe in this Privacy Notice, including to satisfy any applicable legal, tax-related, forensic, and other legitimate business requirements.

To determine the appropriate retention period, we also consider a number of additional factors, such as the:

• Nature and sensitivity of the personal data.
• Potential risk of harm from unauthorised use or disclosure of the personal data.
• Requirements of the relevant controller, where we are acting in the capacity of processor.

13. How we keep your data secure

Davies Group has implemented an Information Security Management System (ISMS), which is globally certified to the International Organization for Standardization (ISO) 27001 standard for Information Security. This demonstrates our commitment to managing risks related to the security of the personal data we own and handle. We implement a range of technical, organisational, and physical security measures aligned with industry standards to protect your personal data from loss, misuse, unauthorised access, disclosure, alteration, or destruction. Our robust controls, policies, and procedures ensure that only authorised personnel have access to your information, maintaining its security throughout its lifecycle. These measures are further supported by an internal audit function and annual external certification.

14. Your rights

Davies Group is committed to processing your personal data in compliance with applicable UAE data protection laws, and you have certain rights in relation to your personal data; however, the exercise of these rights is subject to applicable legal conditions, exemptions, and limitations:

• Right to Receive Information: You have the right to request information about the purposes for which your personal data is being collected, used, or disclosed and how we process it. We are required to notify you of these purposes at the time of collection or before any use or disclosure, so that you can make informed decisions about your data.
• Right to Give and Withdraw Consent: Where we rely on your consent to process your personal data, you have the right to withdraw your consent at any time. Withdrawal of consent will not affect the lawfulness of processing carried out before the withdrawal. Once we receive your withdrawal request, we will stop processing your personal data for the relevant purpose unless continued processing is required or permitted under applicable law.
• Right to Request Transfer of Personal data: Where processing is based on your consent or is necessary for the performance of a contractual obligation and is carried out by automated means, you may request to receive the personal data that you provided to us in an orderly and machine-readable format. You may also request that your personal data be transferred to another Controller where technically feasible.
• Right to Correction or Erasure: You have the right to request the correction of inaccurate personal data and the completion of incomplete data or may request erasure of your personal data in certain circumstances, including where the personal data is no longer necessary for the purposes for which it was collected or processed, where you withdraw consent and processing is based on consent, where you object to processing and there are no lawful reasons to continue, or where the personal data has been processed in violation of applicable laws.
• Right to Restrict Processing: You have the right to request the restriction of processing of your personal data in certain circumstances, including where you contest the accuracy of the personal data, object to processing that is inconsistent with the agreed purposes, or where the processing is carried out in breach of applicable laws.
• Right to Stop Processing: You have the right to object to, and request that we cease processing your personal data where such processing is carried out for direct marketing purposes (including profiling related to direct marketing), for statistical or survey purposes (unless required for reasons of public interest), or where the processing does not comply with applicable data protection laws.
• Rights Related to Automated Processing and Profiling: You have the right to object to decisions based solely on automated processing, including profiling, particularly where such decisions have legal effects on you or otherwise significantly affect you. Where applicable, you may request human intervention in decisions made through automated processing.
• Right to Be Notified of a Data Breach: You have the right to be informed if your personal data is involved in a data breach that is likely to result in significant harm to you. We are legally required to notify you in such cases, so that you can take the necessary precautions.

To exercise any of the rights outlined above, please contact us at SAR@davies-group.com. We may request specific information from you to confirm your identity and to help us respond to your request securely.

We may refuse or restrict a request where permitted by applicable law, including where the request is unrelated to the rights available under applicable law, excessively repetitive, conflicts with judicial procedures or investigations, may negatively affects the privacy or confidentiality of personal data relating to others, or where we are required or permitted to retain or continue processing the personal data under applicable laws.

15. How to complain

We aim to meet the highest standards to safeguard your privacy. However, if you have any concerns about Davies Group use of your personal data, you can make a complaint to our Data Protection Officer by emailing DPO@davies-group.com, or by writing to:

Data Protection Officer
Davies Group
3rd, and 4th Floors
No.2 Smithfields
Stoke-on-Trent, ST1 3DH
United Kingdom

If you are not satisfied with our response, or if you believe that your personal data continues to be processed in violation of applicable UAE data protection laws, you may also have the right to lodge a complaint with the relevant data protection supervisory authority. Where the DIFC Data Protection Law No. 5 of 2020 applies, this may include the DIFC Commissioner of Data Protection. Where Federal Decree by Law No. 45 of 2021 Concerning the Protection of Personal Data applies, this may include the competent UAE data protection authority.

Where we become aware of a personal data breach, we will assess the incident and, where required by applicable law, notify the relevant supervisory authority and/or affected individuals.

Further information may be available through the official UAE Government, UAE Data Office and DIFC channels, which may be updated from time to time.

16. Contact us

Our Group Data Protection Officer is Adam B Smith.

If you have any questions that could not be answered by this Privacy Notice or if you wish to receive more in-depth information about any of the content within it, please contact us at:

Post: Data Protection Officer, Davies Group, 3rd, and 4th Floors, No.2 Smithfields, Stoke-on-Trent, ST1 3DH, United Kingdom

Email: DPO@davies-group.com

17. Changes to this privacy notice

We reserve the right to update this Privacy Notice at any time, and we will provide you with a copy of the updated Privacy Notice (displayed electronically) when we make any substantial changes. We may also notify you in other ways from time to time about changes to the processing of your personal data.