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Privacy Policy
 

Effective Date: 07/07/2026 |  Last Updated: 07/07/2026
 

DRAFT FOR LEGAL REVIEW: This document has been prepared as a working draft based on UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (“PDPL”), the UAE’s child digital safety legislation, and general UAE consumer protection principles, and has been benchmarked against published policies of comparable UAE nursery groups. It must be reviewed and approved by Dibber’s UAE legal counsel before publication. Bracketed placeholders [ ] must be completed with accurate company details before this policy goes live.


1. Who We Are

This Privacy Policy explains how Dibber UAE, a company licensed in the United Arab Emirates with its registered office at Jumeirah Golf Estates (“Dibber”, “we”, “us”, or “our”), collects, uses, stores, and protects personal data when you visit www.edu.dibber.com (“the Site”), enquire about our nurseries, book a tour, apply for admission, or apply for a franchise opportunity.

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This Policy is prepared in accordance with UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (“PDPL”) and its implementing regulations and takes into account UAE legislation governing the protection of children in digital environments. Where Dibber processes data of individuals located in jurisdictions with their own data protection laws (for example, the European Economic Area), this Policy operates alongside, and does not replace, any rights you may hold under those laws.

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By accessing and using the Site, or submitting any form on the Site, you acknowledge that you have read and understood this, Policy.


2. Personal Data We Collect

Information you provide to us. We may collect the following categories of personal data when you submit a form, contact us, or communicate with our teams:

  • Contact details name, email address, phone number, postal address

  • Child information child’s name, date of birth, nationality, and any health, dietary, or developmental information voluntarily provided by a parent or legal guardian as part of an admissions or tour enquiry

  • Enquiry and booking details nursery location of interest, preferred tour dates, admission preferences

  • Franchise enquiry details business background, investment capacity, and related information submitted via our franchise enquiry form

  • Communications records of correspondence between you and Dibber, including emails, web forms, WhatsApp or telephone enquiries, and call notes


Information collected automatically. When you visit the Site, our servers and analytics tools automatically record certain technical information sent by your browser or device. This may include your IP address, browser type and version, operating system, device information, language preferences, referring pages, the pages you visit on the Site, the time and date of your visit, and time spent on pages. This information is used to secure and operate the Site, identify potential misuse, and generate aggregated statistics about Site usage. It is not used to personally identify individual visitors, except where necessary to investigate abuse or security incidents. See also Section 8 (Cookies).


3. How We Use Your Personal Data

We use personal data for the following purposes, each grounded in a lawful basis under the PDPL (consent, contractual necessity, legal obligation, or legitimate interest, as applicable):
 

  • To respond to enquiries about nursery admissions, tours, and programmes

  • To process admission applications and manage the parent-nursery relationship

  • To evaluate and respond to franchise enquiries

  • To send marketing communications where you have provided consent, which you may withdraw at any time

  • To operate, secure, and improve our Site, services, and nursery operations

  • To administer promotions, competitions, or events, where you choose to take part

  • To comply with legal and regulatory obligations applicable to childcare providers in the UAE, including requirements of the Ministry of Education and relevant local authorities (such as KHDA in Dubai and ADEK in Abu Dhabi)

If you do not provide the personal data we reasonably require, we may not be able to respond to your enquiry or provide the requested service. We will only use personal data for the purposes for which it was collected, unless we reasonably consider that we need to use it for a compatible purpose or are required to do so by law.


4. Children’s Data

Given the nature of our services, we collect and process personal data relating to children as part of the enquiry, admissions, and enrolment process.

We are committed to holding children’s data to the highest standard of care, and we apply the following principles:
 

  • Collected from parents only we collect children’s data directly from parents or legal guardians, not from children themselves, and only to the extent necessary to assess admission, ensure child safety and wellbeing, and meet our childcare and educational obligations

  • Verifiable parental consent consistent with UAE legislation on the protection of children in digital environments, we process children’s personal data only on the basis of explicit, documented, and verifiable consent from a parent or legal guardian, or where processing is otherwise required to meet our legal and regulatory obligations

  • No targeted advertising we do not use children’s personal data for targeted advertising, profiling, or commercial tracking of any kind

  • No direct collection from minors the Site is intended for use by adults. We do not knowingly collect personal data directly from anyone under 18 through the Site. If you believe a minor has submitted personal data to us, please contact us and we will delete it

  • Parental control parents and legal guardians may contact us at any time to review, correct, or request deletion of their child’s data, and to withdraw consent, subject to our obligations to retain certain records under applicable childcare regulations

 

5. Sharing of Personal Data

We do not sell personal data, and we do not share children’s personal data with third parties for marketing purposes under any circumstances. We may share personal data with:
 

  • Dibber group entities including our parent company in Norway, for group-wide administration and reporting purposes

  • Service providers who support our operations (for example, IT hosting, CRM, analytics, and email service providers), under contractual confidentiality and data protection obligations, and only to the extent needed to perform their designated functions

  • Regulatory or governmental authorities where required by UAE law, or where we believe in good faith that disclosure is necessary to protect the safety of a child, our staff, or others, or to respond to a lawful request

  • Professional advisers including legal and financial advisers, where necessary


Business transfers. If Dibber is involved in a merger, acquisition, restructuring, or sale of some or all of its assets, personal data may be transferred as part of that transaction. We will ensure that any successor entity remains bound by obligations consistent with this Policy, and we will notify you of any material change in how your data is handled.


6. International Data Transfers

As part of a global organisation headquartered in Norway, personal data collected in the UAE may be transferred to and processed in other countries, including within the European Economic Area. Where such transfers occur, we take appropriate steps to ensure the data continues to receive an adequate level of protection, consistent with the requirements of the PDPL, including through contractual safeguards with receiving entities where required.


7. Data Retention

We retain personal data only for as long as necessary to fulfil the purposes described in this Policy, including any legal, accounting, or reporting requirements applicable to childcare providers in the UAE. As a guide:
 

  • Enquiry data enquiry and tour data that does not result in enrolment is retained for [Insert Period, e.g. 24 months] before being securely deleted, unless you have asked us to retain it for ongoing communication

  • Enrolment records retained in accordance with regulatory requirements applicable to licensed childcare providers

  • Marketing data retained until you withdraw consent or unsubscribe


Once the applicable retention period expires, personal data is securely deleted or anonymised. We may continue to use aggregated, anonymised data that does not identify any individual.


8. Cookies

Our Site uses cookies and similar technologies. A cookie is a small text file placed on your device by a web server. We use the following categories:
 

  • Essential cookies required for the Site to function (for example, security and form submission). These cannot be switched off

  • Analytics cookies help us understand how visitors use the Site so we can improve it. Data is aggregated and does not directly identify you

  • Marketing cookies used, with your consent, to measure campaigns and show relevant Dibber content on other platforms. Marketing cookies are never used in connection with children’s personal data


You can manage your cookie preferences at any time through the cookie consent banner on our Site or through your browser settings. Disabling certain cookies may affect Site functionality.


9. Your Rights

Under the PDPL, you have the right to:
 

  • Request access to the personal data we hold about you or your child, and receive a copy of it

  • Request correction of inaccurate or incomplete data

  • Request deletion of your data, subject to our legal retention obligations

  • Request transfer (portability) of your data in a structured, commonly used, machine-readable format, where technically feasible

  • Withdraw consent at any time, including consent to marketing communications

  • Object to, or request restriction of, certain processing activities, including any processing based on legitimate interest and any automated processing

  • Lodge a complaint with the UAE Data Office if you believe your data has been processed in breach of the PDPL


To exercise any of these rights, please contact us using the details in Section 14. We may ask you to verify your identity (or your authority as a parent or legal guardian) before responding to a request, to protect your data and your child’s data from unauthorised access. We will respond within the timeframes required by the PDPL.


10. Data Security

We implement appropriate technical and organisational measures to protect personal data against unauthorised access, loss, misuse, or alteration, in line with PDPL requirements. These include access controls, staff confidentiality obligations, and secure hosting environments. However, no transmission of data over the internet can be guaranteed to be completely secure, and any transmission is at your own risk to the extent permitted by law.
 

Data breach notification. In the event of a personal data breach that is likely to result in a risk to your privacy or your child’s privacy, we will notify the UAE Data Office and, where required, affected individuals, in accordance with the PDPL and applicable regulations.


11. Third-Party Links

The Site may contain links to websites or resources operated by third parties (for example, social media platforms or partner organisations). We are not responsible for the privacy practices or content of those third parties. We encourage you to review the privacy policy of every site you visit after leaving ours.


12. Changes to This Policy

We may update this Policy from time to time to reflect changes in our practices, services, or legal requirements. When we do, we will revise the “Last Updated” date at the top of this page, and where changes are material, we will take reasonable steps to bring them to your attention. The latest version will always be available on the Site. We will not use your personal data in a manner materially different from what was stated at the time of collection without obtaining your consent.


13. Contact Us

For any questions about this Privacy Policy, or to exercise your data protection rights, please contact our Data Protection Officer / privacy contact:
 

  • Phone: 800-DIBBER

  • Address Jumeirah Golf Estates, B1, FLOOR

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