External Privacy Policy
Last updated: January 2023
Gargash Group (referred to as “we,” “our,” or “us” in this document) is committed to protect and respect the privacy of your personal data, whether collected in our stores, by phone or other means through our customer services, as well as through your use of any website/mobile applications owned by Gargash Group, or via any other applications or channels related to the business of Gargash Group (“Sites”).
For the purposes of this Privacy Policy, “Gargash Group” means and includes, (i) Gargash Enterprises LLC (“Gargash”); (ii) any corporation, association or other legal entity or branch in which Gargash directly or indirectly holds shares; (iii) any corporation, association or other legal entity or branch which directly or indirectly holds shares in Gargash (“Holding Company”); (iv) any corporation, association or other legal entity which is owned or controlled by any Holding Company; and (v) any corporation, association or other legal entity (including any sole establishment) or branch which is owned or controlled by any person who holds shares in a Holding Company.
This Privacy Policy explains our practices for handling personal data in accordance with Federal Decree Law No. 45 of 2021 on Personal Data Protection(UAE Data Protection Law).
You should review this Privacy Policy every time you provide us with personal data to make sure you agree with it. Each time you access or use the Sites, our Services (as described below) or provide us with information, by doing so you acknowledge and agree to the practices described in this Privacy Policy.
YOU CONSENT TO THE COLLECTION AND USE OF INFORMATION AS SET FORTH IN THIS PRIVACY POLICY, WHICH YOU HAVE READ, UNDERSTOOD AND AGREED TO ABIDE BY.
It is important that you read this Privacy Policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements other notices and privacy policies and is not intended to override them.
- Personal data you provide to us:
We may collect personal data about you when:
- you visit any of our locations and/or shops whether in person or online;
- buy/order services or products from us and/or any of our group companies in store, over the phone, or online;
- you use our Sites; and
- otherwise interact with us as part of other activities for operating our business (e.g., via livechat and whatsapp);
(collectively, “Services”).
Generally, you are under no obligation to provide your personal data. However, in certain cases, we may be unable to provide you with our Services unless you provide your personal data.
The main types of personal data that you may provide to us (depending on how you interact with us) are:
- Your personal details (including your name, postal and billing addresses(s), phone number(s), date of birth, and passport or ID number);
- Transaction information, including information about the products you buy, prices, method of payment and payment details;
- Login credentials for our Sites;
- For former employees, information regarding their employment with us;
- For job applicants, personal information contained in a résumé, C.V., application and/or our recruitment template, employment history, education history, references, transcripts;
- Your feedback and contributions to customer surveys and questionnaires; and
- Other personal information you choose to provide us when you interact with us (including through social media).
As a matter of practice, we will not collect any special categories of personal data relating to you. To the extent that there is a need for us to process such personal data, we will obtain your prior explicit written consent. “Special categories of personal data” cover, without limitation, personal information concerning racial or ethnic origin, communal origin, political affiliations or opinions, religious or philosophical beliefs, criminal record and health life and including genetic data and biometric data where it is used for the purpose of uniquely identifying a natural person.
We may combine the personal data you provide to us with information that we collect through automated methods, and with information we receive from other sources (please see below for further details).
When you visit one of our Sites or use our computer system or mobile device when you visit any of our locations, use our online services, we may collect certain information as per the below by automated means (using technologies such as cookies, web server logs, session details, web beacons as further detailed below):
- Internet protocol (IP) address;
- Computer or mobile-device operating system and browser type;
- Type of mobile device and its settings;
unique device identifier (UDID) or mobile equipment identifier (MEID) of your mobile device;
- Device and component identifiers;
- Advertising identifiers (for example, an Identifier for Advertising (IDFA) on Apple devices) or similar identifiers;
- Referring webpage (a page that has led you to ours) or application;
- Online activity on other websites, applications or social media;
- Activity related to how you use our online services or in-restaurant technology, such as the pages you visit on our Sites; and
- Activities related data.
A “cookie” is a small text file that is placed onto an Internet user’s web browser or device and is used to remember and/or obtain information about the user.
A “web beacon” is a small object or image that is embedded into a web page, application, or email and is used to track activity. They are also sometimes referred to as pixels and tags.
Both we and selected third parties (such as our advertising networks) may use these technologies to collect information about your online activities, over time and across third-party websites and devices, and when using our online services to further personalize your experience with us.
Use the options in your web browser if you do not wish to receive a cookie or if you wish to set your browser to notify you when you receive a cookie. Select the “Help” section of your browser to learn how to change your cookie preferences. If you disable all cookies, you may not be able to take advantage of all the features available on a website.
- Other sources:
We may collect personal information from other Gargash Group business units as further described in “Personal Data We Share” section.
We may also collect information about you from our business partners and vendors (e.g., client, food delivery platforms, data providers, or payment processors) or from public sources (e.g., your public social media posts).
How We Use the Personal Data We Collect
- We use personal data we have collected for the following purposes:
1-To conduct our business and provide our Services, including:
- Perform a contract and/or sale transaction;
- Provide our products and services (including payment processing, customer support, safety callbacks);
- Maintain contact with you;
- Manage our relationship with you, including feedback management and for customer surveys; and
- Respond to inquiries and other communications;
2-For the following purposes, subject to your consent:
- Communicate with you about, and administer your participation in, special events, programs, offers, surveys, marketing and advertising services, and market research;
- Perform data analysis (including anonymization and aggregation of personal data) about use of our Sites and social media accounts; including consumer and operations research, to assess the effectiveness of our sales, online service, marketing, and advertising, and to analyze market trends and (future) customer demand;
- Operate, evaluate, and improve our business (including developing new products and services; enhancing and improving our products, services, websites and mobile apps; managing our communications; analyzing our products and services; and performing accounting, auditing and other internal functions); and
- Undertake recruitment activities including process employment applications and assessing qualifications, verifying information, conducting reference or other employment-related checks;
3-For personal data collected through automated means: to (i) customize users’ visits to our Sites, (ii) to deliver content tailored to users’ interests and the manner in which users browse our Sites, and (iii) to manage our Sites and other aspects of our business;
4-For other purposes as agreed with you; and
5- To meet our legal obligations or enforce our legal rights and for purposes permitted by law.
We may use the personal data we collect about you in other ways, which we will obtain consent for at the time we collect it or before we begin using it for those other purposes.
- Purpose & legal basis for processing:
Generally, our lawful basis for processing your personal data is the performance of a contract with you. However, in some cases, we may process your personal data on the basis of your consent for other purposes as set out in paragraphs 2,3, 4 and 5 above of this section which you agree and consent to by reading this Privacy Policy.
You have the right to withdraw your consent at any time and contact us (to find out how to contact us, please see the “How to Contact Us” section at the end of this document).
Marketing Practices
We support your legal rights to opt-in or subsequently opt-out of receiving communications from us and our partners. You have the option to ask us not to process your Personal Data for marketing purposes and to remove it from our database, and to not receive future communications.
You may change your preferences at any time.
Please note that we may continue to send you transactional or service-related e-mails despite your desire to not receive promotional or marketing communications. Additionally, please note that if you elect to opt-out of or unsubscribe from receiving marketing, promotional or other similar communications or messaging from one of our Sites, you may continue to receive promotional emails from our other Sites, providers, or other, non-affiliated marketers, who received your personal data through your request or election and whose services you may have accessed via our Sites .
We do not sell or otherwise disclose personal data we collect, except as described in this Privacy Policy.
We may share personal data with our professional advisers (such as our legal representatives, auditors, and insurance providers), business partners who are involved in your customer experience (including product or services delivery), and service providers who perform services on our behalf based on our instructions. We do not authorize these advisers, partners and service providers to use or disclose the information except as necessary to perform the services or comply with legal requirements. We may also share personal data we collect with other Gargash Group business units for the purposes described in “How We Use the Personal Data We Collect” section.
In addition, we may disclose personal data (i) if we are required to do so by law or legal process, (ii) to law enforcement authorities or other government entities, or (iii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity. We also reserve the right to transfer personal data we have to a party or prospective party in the event we wish to sell or transfer all or a portion of our organization, business or assets (including in the event of a reorganization, dissolution, or liquidation).
We offer you certain choices in connection with the personal data we collect about you. To update your preferences, ask us to remove your personal data from our mailing lists or submit a request, please contact us. To the extent provided by law, you may request access to the personal data we maintain about you or request that we correct, amend, rectify, erase, delete, block, or move the personal data by contacting us. You may also contact us to withdraw any consent you previously provided relating to our handling of your personal data or object on legitimate grounds to the handling of your personal data. We will also ensure that you are not discriminated against for exercising any of your rights described in this Privacy Policy.
Unless there is a legal reason not to, we will apply your preferences going forward.
To find out how to contact us, please see the “How to Contact Us” section at the end of this document.
You also have the right to lodge a complaint with the Data Office.
In order to undertake some of our activities, we may transfer personal data we collect to recipients in countries other than the country in which the data was originally collected. Where we transfer personal data to another country for processing by a recipient, we will require the recipient to protect the personal data received in accordance with the data protection requirements under the UAE Data Protection Law. This may include the requirement to put appropriate safeguards in place to protect the personal data. Details of any such appropriate safeguards can be requested via the “How to Contact Us” section below.
We maintain administrative, technical and physical safeguards designed to protect the personal data against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure, or use. We also maintain safeguards to delete or de-identify personal data no longer required in accordance with law. We store your personal data for as long as necessary to fulfill the purposes for which we collect the personal data (see “How We Use the Personal Data We Collect”), except as otherwise required by law.
If you have any questions or comments about this Privacy Policy or wish to make a complaint about our handling of your personal data, you can contact us as indicated below in the “How to Contact Us” section. We will seek to promptly address your issue.
Data Retention
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
Links to Other Websites and Apps
Our Sites may provide links to other websites or apps for use convenience and information. These websites may operate independently from us. Linked sites and apps may have their own privacy notices or policies, which we strongly suggest you review. To the extent any linked websites are not owned or controlled by us, we are not responsible for such websites’ or apps’ content, any use of such websites or apps, or the privacy practices of such websites or apps.
This Privacy Policy may be updated periodically and without prior notice to reflect changes in our personal data practices. We will post a prominent notice on our Sites to notify of any significant changes to our Privacy Policy and indicate at the top of the notice when it was most recently updated.
Please contact us by email at: [email protected]
You also may write to us using the address below:
Gargash | Waterview, Port Saeed
P.O. Box 1047 Dubai, UAE
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