PRIVACY POLICY

1. Introduction

The Al Futtaim group (the “Group”) recognises the importance of protecting the privacy of Our customers’ (“you” or “your”) personal information.

2. Purpose of this Privacy Policy

This Privacy Policy aims to give you information on how the Group collects and processes your personal information. It is important that you read this Privacy Policy together with any other privacy notice or fair processing notice a Group company may provide on specific occasions when we are collecting or processing personal information about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements these other notices and is not intended to override them.

3. Controller

The Group is made up of different legal entities, details of which can be found here: [LINK]. This Privacy Policy is issued on behalf of the Group so when We mention we mention "Company", "We", "Us" or "Our" in this Privacy Policy, We are referring to the relevant Group company or companies responsible for processing your data.

4. Contact Details

You have the right to make a complaint at any time to the relevant supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach th

For any questions or comments relating to this Privacy Policy or the manner in which We collect and use your personal information, please contact Us at 800332 or CustomerRelations.DFC@alfuttaim.ae.

5. Changes to the Privacy Policy and Your Duty to Inform Us of Changes

This version was last updated on 31 July 2024.

It is important that the personal information We hold about you is accurate and current. Please keep Us informed if your personal information changes during your relationship with Us.

6. Requests Made by You under Applicable Data Protection Laws

Requests relating to your personal information that We collect, which are made by you pursuant to Applicable Data Protection Law will be attended to by Us in accordance with this Privacy Policy and Applicable Data Protection Law.

7. Third-Party Links

Our websites and mobile apps (“Apps”) may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. We encourage you to read the privacy policy of every website or other site you visit.

8. The Data We Collect about You

Personal information means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (i.e. anonymous data).

- Identity Data: includes first name, last name, address, username or similar identifier, marital status, title, date of birth and gender.

- Contact Data: includes billing address, delivery address, location, email address and/or telephone numbers.

- Financial Data: includes bank account and payment card details, payment history.

- Transaction Data: includes details about payments to and from you and other details of products and services you have purchased from Us.

- Technical Data: includes internet protocol (IP) address, your login data, browser type and version, make and model (mobile phones only), operating system, hardware version, platform, device settings and other technology identification on the devices used to access the App, file and software names and types, device identifiers, time zone setting and location, device locations such as through GPS, Bluetooth or WiFi signals, browser plug-in types and versions, operating system and platform, connection information such as the name of your mobile operator or ISP, browser type, language and time zone, mobile phone number and IP address.

- Profile Data: includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.

- Usage Data: includes information about how you use the App, and how you use your devices to access the App, including the screens you visit and searches you make.

- Special Categories of Personal information: includes details about your race or ethnicity or religion

- Other Data: includes:

> photos or other data uploaded onto the App by you or shared with other users of the App via the App.

> communications with Us via social media platforms, email, electronic messages and other electronic and non-electronic communications.

> third party partner information related to how you use Our third-party partners, such as your reviews of Our merchant partners or other service providers.

> your networks and connections made available to Us, depending on the permissions you have granted, from your mobile and desktop devices' address book contacts, and other social media such as Facebook, Instagram, Pinterest and Twitter.

- Marketing and Communications Data: includes your preferences in receiving marketing messages 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 varied purposes. Aggregated data may be derived from your personal information but is not considered personal information 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 App feature. However, if We combine or connect aggregated data with your personal information so that it can directly or indirectly identify you, We treat the combined data as personal information which will be used in accordance with this Privacy Policy.

We do not collect the following Special Categories of Personal information: your philosophical beliefs, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. Nor do We collect any information about criminal convictions and offences.

Where required under Applicable Data Protection Law, We will also obtain your consent prior to processing or transferring your data for the purposes set out under this Privacy Policy.

9. If You Fail to Provide Personal Information

Where We need to collect personal information by law, or under the terms of a contract We have with you and you fail to provide that data when requested, We may not be able to perform the contract We have or are trying to enter into with you (for example, to provide you with goods or services). In this case, We may have to cancel a product or service you have with Us but We will notify you if this is the case at the time.

10. How is Your Personal Information Collected?

We use different methods to collect data from and about you including through:

- Direct interactions: You may give Us your identity, contact and financial data by filling in forms or by corresponding with Us by post, phone, email or otherwise. This includes personal information you provide when you:

> apply for or purchase Our products or services;

> create an account or register on the App;

> subscribe to Our service or publications;

> request marketing to be sent to you or further services to be provided to you;

> enter a competition, promotion or survey;

> correspond with Us (online or offline including via email addresses and phone numbers), if you contact us;

> post material on the App; or

> give Us some feedback.

You may also provide information to be published or displayed (hereinafter, “posted”) on public areas of the App or transmitted to other users of the App or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk

Automated technologies or interactions: As you interact with the App , We may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal information by using cookies, server logs, web beacons, and other similar technologies. We may also receive technical data about you if you visit the App employing Our cookies. We do not collect personal information automatically, but We may tie this information to personal information about you that We collect from other sources or you provide to Us.

Log files: We may use log files to capture your activities on Our apps as they interact with the App. Information captured in such log files may include the types of content you view or engage with and the frequency or duration of your activities.

Third parties or publicly available sources: We may receive personal information about you from various third parties and public sources as set out below:

  > Technical data from the following parties:

  - analytics providers;

  - advertising networks;

  - search information providers; or

  - third parties We contract with and/or their subsidiaries and affiliates to provide you a service.

  > Contact, financial and transaction data from providers of technical, payment and delivery services.

  > Identity and contact data from data brokers or aggregators.

  > Identity and contact data from publicly availably sources.

11. How We Use Your Personal Information

We will only use your personal information when the law allows Us to. Most commonly, We will use your personal information in the following circumstances:

  - Where We need to perform a contract We are about to enter into or have entered into with you.

  - Where We need to perform a contract We have with a third party to provide you with a product or service.

  - Where We need to comply with a legal or regulatory obligation that We are subject to.

By consenting to us processing your personal information you agree to Us sending third party direct marketing communications to you via email, text message or other means. You have the right to withdraw consent to marketing at any time by contacting us at  CustomerRelations.DFC@alfuttaim.ae.

12. Purposes For Which We Will Use Your Personal Information

We have set out below, in a table format, a description of all the ways We plan to use your personal information, and which of the legal bases We rely on to do so.

Note that We may process your personal information for more than one lawful ground depending on the specific purpose for which We are using your data. Please contact Us at 800332 or CustomerRelations.DFC@alfuttaim.ae if you need details about the specific legal ground We are relying on to process your personal information where more than one ground has been set out in the table below.

PURPOSE/ACTIVITY TYPE OF DATA LAWFUL BASIS FOR PROCESSING
To register you as a new customer/user (a) Identity
(b) Contact
(c) Profile
(d) Special categories of personal information
(a) Consent
To process and deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and communications
(a) Performance of a contract with you
(b) Consent
To manage Our relationship with you which will include:
(a) Notifying you about changes to Our terms or privacy policy
(b) Asking you to leave a review or take a survey
(c) communicating with you about Our products and services and responding to you when you contact us
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and communications
(a) Performance of a contract with you
(b) Consent
To enable you to partake in a prize draw, competition or complete a survey (a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and communications
(a) Consent
To administer and protect Our business and the App (including troubleshooting, improvement, data analysis, testing, system maintenance, security, support, reporting and hosting of data) (a) Identity
(b) Contact
(c) Technical
(a) Consent
To deliver relevant App content and advertisements to you and measure or understand the effectiveness of the advertising We serve to you (a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and communications
(f) Technical
(a) Consent
To deliver a better and more personalised App content so that you have a beneficial and valuable experience when using the App, products and/or services (a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and communications
(f) Technical
(a) Consent
(b) Performance of a contract with you
To enable you to utilise a feature of a product or service provided to you. (a) Identity
(b) Contact
(c) Profile
(a) Consent
To use data analytics to improve the App , products/services, marketing, customer relationships and experiences (a) Identity
(b) Technical
(c) Usage
(d) Transaction
(e) Special Categories of Personal information
(a) Consent
To make suggestions and recommendations to you about goods or services that may be of interest to you (a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
(a) Consent
Any other purpose disclosed by Us when you provide the personal information As applicable (a) Consent

13.Promotional Offers From Us

We may use your Identity, Contact, Technical, Usage and Profile data and Special Categories Of Personal Information to form a view on what We think you may want or need, or what may be of interest to you. This is how We decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from Us if you have requested information from Us or purchased goods or services from Us or if you provided Us with your details when you enrolled in in any loyalty program, entered any competition or registered for any promotion and, in each case, you have not opted out of receiving that marketing.

14. Third-Party Marketing

We will get your express opt-in consent before We share your personal information with any company outside the Group or its partnership network for marketing purposes. We do not control third parties' collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way

15. Opting Out

You can ask Us to stop sending you marketing messages at any time by logging into the App and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting Us at CustomerRelations.DFC@alfuttaim.ae at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal information provided to Us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

16. Location Information

You can choose whether or not to allow the App to collect and use real-time information about your device's location through the device's privacy settings. If you block the use of location information, some parts of the App may then be inaccessible or not function properly.

17. Change Of Purpose

We will only use your personal information 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 to the extent permitted by law. 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 at CustomerRelations.DFC@alfuttaim.ae.

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

18. Disclosures Of Your Personal Information

To the extent permitted by law, We may have to share your personal information with the parties set out below for the purposes set out in the table in paragraph 12 above.

  - Internal Third Parties as set out in Section 21 – Glossary below.

  - External Third Parties as set out in Section 21 – Glossary below.

  - Third parties listed in the table in Section 11 – How We use your Personal information above;

  - Third parties to whom We may choose to sell, transfer, or merge parts of Our business or Our assets. Alternatively, We may seek to acquire other businesses or merge with them. If a change happens to Our business, then the new owners may use your personal information in the same way as set out in this Privacy Policy.

  - To a third party you nominate to fulfil the purpose for which you provide it. For example, if you give Us an e-mail address to use the “e-mail a friend" feature of the App or you nominate another person to become a secondary member in family account, We will transmit the contents of that e-mail and your e-mail address to the recipients.

We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We do not allow Our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with Our instructions.

19. Data Security

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, We limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on Our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal information breach and will notify you and any applicable regulator of a breach where We are legally required to do so.

20. Data Retention

We will only retain your personal information for as long as necessary to fulfil the purposes We collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal information, We consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which We process your personal information and whether We can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances We may anonymise your personal information (so that it can no longer be associated with you) for research or statistical purposes in which case We may use this information indefinitely without further notice to you.

21. Glossary

Applicable Data Protection Law means any applicable data protection or privacy laws relating to the processing of personal information and privacy from time to time that relate to the parties’ respective obligations under this Privacy Policy.

Performance of contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Third Parties means:

  - Internal third parties: Group companies acting as joint controllers or processors who provide IT and system administration services and undertake reporting.

  - External Third Parties: (i) service providers acting as processors who provide IT and system administration services or who We use to support Our business and who are bound by contractual obligations to keep personal information confidential and secure and use it only for the purposes for which We disclose it to them, (ii) professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services, (iii) regulators and other authorities acting as processors or joint controllers who require reporting of processing activities in certain circumstances, and (iv) any other party, their subsidiaries and affiliates which We have contracted with to provide you with a service and/or product.

22. Your Legal Rights

You have certain rights relating to your personal data. However, these rights can differ depending upon the country in which you are located.

Where you have provided your consent to us, you will always have the right to withdraw this at any time. You can do this by either following the information provided at the time you provided your consent, or by contacting us using the following email address CustomerRelations.DFC@alfuttaim.ae.

You will always have the right to request that we correct any personal data that we process about you that is inaccurate or incomplete. You can do this by contacting us at CustomerRelations.DFC@alfuttaim.ae.

To the extent permitted by Applicable Data Protection Law in the country where you are located, you have additional rights that allow you, upon sending Us a request at CustomerRelations.DFC@alfuttaim.ae to:

  > withdraw or cancel your consent;

  > restrict the processing of your personal data;

  > delete your personal data which we process (i.e. the right to be forgotten); and/or

  > be provided access to, or copies of, your personal data that we process and to obtain a copy of your personal data which we process in a commonly used and machine-readable format.

You also have the right to object to our processing of your personal data and to object to decisions resulting from automated processing, including profiling, that affect you or have legal consequences. Furthermore, you have the right to file a complaint with the relevant data office in the country where you are located if you feel your personal data has not been processed in accordance with the Applicable Data Protection Law, after discussing your complaint with us by contacting us at CustomerRelations.DFC@alfuttaim.ae.

It is important to understand that these rights are not absolute (e.g. their application may depend upon the legal basis we rely upon to process your personal data) and that we may require further information from you (e.g. to confirm your identity) in order to action your request.

23. Changes to Policy

We reserve the right to change this Privacy Policy at any time by posting an update on the App. By using the App you agree to be bound by any such changes or revisions and you explicitly agree to periodically visit this page to determine the then current Privacy Policy to which you are bound. You agree that use of the App without periodic review of the Privacy Policy shall be at your own risk.

CONSENT

Your privacy is very important to us and in order to comply with relevant privacy legislation, we are now reaching out to you to obtain your consent in relation to the processing operations set out below.

This consent form includes consent to Al Futtaim Group, including all its subsidiaries and affiliates, (so when we mention “AFG”, "Company", "Us" or "Our", we are referring to the relevant Group company or companies responsible for processing your data) for the processing activities carried out in their roles as independent data controllers. Please refer to our privacy policy [INSERT LINK) (“Privacy Policy”), where you can find more information about the processing and use of your personal data, including your rights.

Based on your consent, your name, phone number, home address and email address will be processed by Us. This personal information will be used for administrative purposes in order to be able to contact you.

By indicating with an [X] in the boxes below you consent to the processing of your personal information as set out in the Privacy Policy.

consent to the Al Futtaim Group to process my personal information for:   [X]  
To register me as a new customer/user.   
To register me as a new customer/user.   
To process and deliver my order including to:
(a) Manage payments, fees and charges;
(b) Collect and recover money owed to us.
  
To manage AFG’s relationship with me, which will include AFG:
(a) Notifying me about changes to their terms or privacy policy;
(b) Asking me to leave a review or take a survey;
(c) Communicating with me about their products and services and responding to me when I contact AFG.
  
To enable me to partake in a prize draw, competition or complete a survey.   
To administer and protect AFG’s business and the App (including troubleshooting, improvement, data analysis, testing, system maintenance, security, support, reporting and hosting of data).   
To deliver relevant App content and advertisements to me and measure or understand the effectiveness of the advertising AFG serves to me.   
To deliver a better and more personalised App content so that I have a beneficial and valuable experience when using the App, products and/or services.   
To enable me to utilise a feature of a product or service provided to me.   
To use data analytics to improve the App, products/services, marketing, customer relationships and experiences.   
To make suggestions and recommendations to me about goods or services that may be of interest to me.   
Any other purpose disclosed by AFG when I provide the personal information.   

In addition to the above, if applicable, we may also gather and process the same type of information about your child/children (below the age of 16) if they utilise our services or visit our Apps. To process such information, we need parental consent. If you consent to us processing your child/children’s personal data, please indicate your consent with an [ X ]. The consent includes all the purposes and actions you have consented to for yourself above.

I / We consent to the Al Futtaim Group processing the personal information of my/our child/children   

You will be able to withdraw your consent at any time by requesting Us to stop the processing. This will not affect the legitimacy of the personal data processing that took place prior to the withdrawal of your consent.

Request to withdraw consent can be done by sending an email to CustomerRelations.DFC@alfuttaim.ae.