1. INTRODUCTION
We are committed to protecting and respecting your privacy. This Privacy Notice (the “Notice”) governs the collection and use of personal data by CAPRI L.L.C (the “Company”) and its affiliates or any company it controls. It explains how and why we use your personal data and applies to the personal data that you provide us directly, or which we may obtain from other sources.
We may use your personal data for any of the purposes described in this Notice.
References to “our”, “us” or “we” within this Notice are to CAPRI L.L.C.
2. WHO WE ARE?
CAPRI L.L.C is the data controller of your personal data. We decide how and why your personal data is processed, either alone or jointly with others.
If you have any questions about this Notice, the use of your data, please contact support@jarc.ae
3. WHAT ARE THE SOURCES OF YOUR DATA?
Directly from you
We collect your Personal Data directly from you in the following instances:
· Registration or Sign-up: When you register or sign up on our app.
· Content Creation: When you share or create any content or information within our app.
· App Usage: Through your access and utilization of our app.
· Interactions with Representatives: During conversations between you and our representatives.
· Subscription: When you subscribe to receive offers, newsletters, and marketing information.
From third parties
Additionally, we might gather Personal Data from third parties, which may include:
· Law Enforcement and Government Entities: Information provided by third-party companies such as law enforcement agencies and other government entities.
· Social Media Accounts: Data from social media accounts (Facebook, Google, Twitter, or Apple ID) that you have linked to the use of our app via single-sign-on.
· Event Organizers: Information from organizers or co-organizers of events, schemes, or initiatives, as well as service providers assisting in the organization of such events.
· Advertisers: Data obtained from advertisers.
· Mailing Lists: Information sourced from mailing lists.
· Contractors and Business Partners: Personal Data collected from contractors and business partners.
This policy does not apply to information collected:
· through any other means, including any other website operated by any third party; or
· by any third party, including through any application or content (including advertising) that may link to the Website.
4. WHAT INFORMATION WE COLLECT ABOUT YOU AND HOW WE USE YOUR PERSONAL INFORMATION?
We process various categories of personal data to enable the provision of services, as described below:
· Contact Details: Includes but is not limited to address, email address, and telephone number.
· Identification Data: Includes but is not limited to name, title, company, and individual physical description.
· Web Data: Includes but is not limited to cookies, user activity logs, IP address, social media profile, and website visitor interaction data.
The reasons for processing these categories of personal data, along with our legal basis for doing so, are outlined in the table below:
| Purpose of processing | Personal Data | Legal Basis |
| Customer Service | Contact Details, Identification Data, Personal Information, Web Data | Consent and Legitimate Interest |
| Advertising / Marketing Services, Analytics Services | Contact Details, Identification Data, Personal Information, Web Data | Consent and Legitimate Interest |
| For competition and event purposes. | Contact Details, Identification Data, Personal Information | Contract, Legitimate Interest and when processing special category personal data there must be Explicit Consent |
| For security purposes and to ensure secure backup and archival of IT Systems & for investigative purposes during a data breach | ensure secure backup and archival of IT Systems & for investigative purposes during a data breach Contact Details, Identification Data, Personal Information, Web Data, | Legitimate Interest and Consent |
OTHER INFORMATION WE COLLECT
There is other information we may collect that does not directly reveal your specific identity or does not directly relate to you as an individual. We may automatically collect the following information pursuant to our legitimate business interests when you visit our website or utilize our services:
· Your equipment, browsing actions and patterns collected automatically as you navigate through our websites.
· Usage details, time of requests, browser types, operating system, IP addresses and information collected through cookies, web beacons and other tracking technologies.
· Details of your visits to our website, including traffic data, location data, logs and other communication data and the resources that you access and use on the website.
The information we collect automatically is statistical data. It helps us to improve our Website and to deliver a better and more personalized service by enabling us to:
· Estimate our audience size and usage patterns.
· Store information about your preferences, allowing us to customize our Website according to your individual interests.
· Speed up your searches and recognize you when you return to our Website.
The technologies we use for this automatic data collection may include:
· Cookies: A cookie is a small piece of data, which includes an identifier made of letters and numbers that is sent by a web browser and stored on your computer. Cookies are used as a reliable mechanism to remember information about you, so your interaction with our website is seamlessly simple. Cookies typically do not contain any information that personally identify you, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
· Flash Cookies: Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies.
· Web Beacons: Pages of the Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs. pixel tags and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an e-mail and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
We use these cookies for the following purposes:
· To identify you when you visit our platforms and to help you navigate through our platforms;
· To help determine if you are logged into our platforms:
· To store information about your preferences and to personalize our platforms for you;
· To secure and protect your user account and our platforms; and
INFORMATION WE RECEIVE FROM OTHERS
We work closely with third parties and may, from time to time, receive information about you from them as well. We also collect personal information from individuals who may refer you as a friend to our loyalty schemes or third-party agents (to whom you may have expressed interest about our properties) or products or services. We ask these individuals to confirm that you are happy to hear from us.
5. HOW TO OPT OUT?
· Email: You can click on the unsubscribe link provided in the email you receive from us.
· SMS: You can follow the instruction provided in the messages you receive from us
· Applications: You may use the “opt out” option provided within the applications
· Contact us: You may contact us using the details provided in the Section titled “How do you contact us?”.
6. WHO MIGHT WE SHARE THIS INFORMATION WITH?
We may disclose personal information that we collect, or you provide as described in this privacy policy as follows:
· We may share your personal information with any member of the Company, including subsidiaries, affiliates and holding companies, in order to enable you to request our services, to process your payments, understand your preferences, conclude a lease, facilitate any maintenance/ service requests, send you information about products and services that may be of interest to you and conduct the other activities described in this privacy policy.
· We may use carefully selected third parties to perform services on our behalf or to assist us with the provision of services to you. For example, we may engage third party agents, distribution partners cloud service providers, IT service providers and other third parties to support and facilitate property leasing and bookings, property handover, security services, brand promotions, marketing, advertising, communications, to personalize and optimize our service, to analyze and enhance data (including data about users’ interactions with our services), and to provide legal, accounting, insurance, audit and other professional services. While providing such services, these third parties may have access to your personal information.
· Where required or permitted by law, personal information may be provided to others, such as regulators and law enforcement agencies.
· We may share with government or regulatory authorities upon request to comply with any court order, law or legal process
· We may share with other companies and organizations for the purposes of fraud protection and credit risk reduction if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers or others.
If you would like more information on protection measures and transfer mechanisms, please contact us using the details provided in the Section titled “How do you contact us?”.
7. HOW LONG DO WE KEEP INFORMATION ABOUT YOU?
We will only keep your personal information for as long as is reasonably necessary taking into consideration our need to answer queries or resolve problems, any other purpose outlined above or to comply with legal requirements under the Federal Decree-Law No. 45 of 2021 regarding the Protection of Personal Data and other relevant local laws of the United Arab Emirates (“Applicable Law”). This means that we may retain your personal information for a reasonable period, for example, till the end of the leasing contract with the organization you represent, or after your query has been addressed. In certain cases, we may retain your personal information for a longer period where extended retention periods are required by law or regulation and to establish, exercise or defend our legal rights. We will ensure that it is disposed in a secure manner when it’s no longer needed.
For more information on where and how long your personal information is stored, and for more information on your rights of erasure and portability, please contact us using the details provided in the Section titled “How do you contact us?”.
8. HOW SECURE IS YOUR INFORMATION?
Your personal data security is an important concern to us. We provide the utmost care in secure transmission of your personal information from your computer, smartphone, and other electronic devices to our servers. We use industry security standards to safeguard the confidentiality of your information (e.g. firewalls etc.) and to make sure that your personal information is secure with us.
We have implemented and maintained appropriate technical and organizational security measures, policies and procedures to protect your personal information from the accidental loss, unauthorized access, use, alteration and disclosure. All information you provide to us is stored on our secure servers behind firewalls. All payment transactions are encrypted using TLS technology. Examples of measures we take include:
· Placing confidentiality requirements on our staff and service providers;
· Restriction of access to your personal information to employees and third parties strictly on a need to know basis, such as to respond to your enquiry or request;
· Destroying or anonymizing personal information if it is no longer needed for the purposes for which it was collected; and
· Using secure communication channels for transmitting personal data.
The safety and security of your information also depend on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
9. WHAT ARE YOUR RIGHTS?
If you are subject to laws that provide you with such rights, you may have certain rights in relation to your personal information given below.
If you wish to access any of these rights, we may ask you for additional information to confirm your identity and for security purposes, before disclosing personal information to you. We reserve
the right to charge a fee where permitted by law, for example, if your request is manifestly unfounded or excessive.
If you would like to access the below rights, you may contact us by mailing us at info@jarc.ae or sending us a communication to Jebel Ali Racecourse, Dubai-Abu Dhabi Road, Beside Emirates Golf Club - Dubai - United Arab Emirates. We shall aim to comply with all requests within reasonable time in-line with Applicable Law. We may not always be able to fully address your request, for example,
· if it would impact the confidentiality we owe to others, or
· if we are legally entitled to deal with the request in a different way. or
· if your request involves deletion of information that are required to comply with the legal requirements.
We will make every reasonable effort to honor your request in-line with Applicable Law. In the event we require additional time due to the complexity of the request, we shall promptly inform you of the same.
THE RIGHT TO ACCESS
You have the right to obtain confirmation as to whether we process personal data about you, receive a copy of your personal data held by us, and obtain certain other information about how and why we process your personal data (like the information provided in this privacy statement).
THE RIGHT TO RECTIFICATION
You have the right to request for your personal data to be amended or rectified where it is inaccurate (for example, if you change your name or address) and to have incomplete personal data completed.
THE RIGHT TO RESTRICT PROCESSING OF PERSONAL DATA
You have the right to restrict our processing of your personal data in the following cases:
· Temporarily for a period when you have contested for the accuracy of the personal data;
· Temporarily for a period when you have objected for the legitimate interest identified by us,
· Your personal data have been unlawfully processed and you request the restriction of processing instead of deletion;
· The personal data are no longer necessary in relation to the purposes for which they were collected and processed but the personal data are required by you to establish, exercise or defend legal claims;
We can continue to use your personal information following a request for restriction, where:
· we have your consent; or
· to establish, exercise or defend legal claims; or
· to protect the rights of another natural or legal person.
THE RIGHT TO ERASURE (ALSO KNOWN AS ‘THE RIGHT TO BE FORGOTTEN’)
You have the right to obtain deletion of your personal data in the following cases:
· The personal data are no longer necessary in relation to the purposes for which they were collected and processed;
· Our lawful basis for processing is consent, you withdraw consent and we have no other lawful basis for the processing;
· Our lawful basis for processing is that the processing is necessary for a legitimate interest pursued by us, you object to our processing and we do not have overriding legitimate grounds;
· You object to our processing for direct marketing purposes;
· Your personal data have been unlawfully processed; and
· Your personal data must be erased to comply with any legal obligation to which we are subject.
· We are not required to comply with your request to erase personal information if the processing of your personal information is necessary:
· For compliance with any legal obligation; or
· For the establishment, exercise or defence of legal claims.
THE RIGHT TO OBJECT TO THE PROCESSING OF PERSONAL DATA
You have the right to object to our processing of your personal data in the following cases:
· our lawful basis for processing is that the processing is necessary for a legitimate interest pursued by us; and
· our processing for direct marketing purposes.
THE RIGHT TO DATA PORTABILITY
You have the right to receive your personal data provided to us and have the right to send the data to another organization (or ask us to do so if technically feasible) where our lawful basis for processing the personal data is consent or necessity for the performance of our contract with you and the processing is carried out by automated means.
THE RIGHT TO WITHDRAW CONSENT AT ANY TIME (WHERE PROCESSING IS BASED ON CONSENT)
Where we process personal data based on consent, individuals have a right to withdraw consent at any time.
THE RIGHT TO LODGE A COMPLAINT
We sincerely hope that you will never need to, but if you do want to complain about our use of personal data, you can contact us in one of the ways mentioned in the Clause 13 titled “How do you contact us?”. We will look into and respond to any complaints we receive.
10. PRIVACY NOTICE CHANGES
In the future, we reserve the right to modify or update this Privacy Notice at any time by making revisions to this page. All alterations will be documented here to ensure that you are consistently informed about the information we collect, its potential uses, and any disclosures. It's important to note that certain aspects of this Privacy Notice might be replaced by provisions or notifications available on other sections of our websites. We will notify you of any revisions to the Privacy Notice through pop-up messages, email communications, or push notifications via our mobile applications.
11. SECURITY OF YOUR PERSONAL DATA
We are committed to taking all reasonable measures to safeguard the Personal Data in our possession against misuse, loss, or unauthorized access. These protective measures include the implementation of firewalls, password access, and secure servers. Specifically, we regularly review our practices related to the collection, storage, and processing of information, incorporating physical security measures to prevent unauthorized access to our systems.
It's pertinent to acknowledge that sending information over the internet involves inherent risks. While we make every effort to secure your Personal Data, we cannot guarantee the absolute security of data transmitted via the internet. We do not provide assurances regarding the security of any information, including Personal Data, transmitted to us over the internet. Should you suspect any misuse, loss, or unauthorized access to your Personal Data, we urge you to promptly inform us. Your vigilance is crucial in ensuring the security of your information.
12. DISCLAIMER
To the full extent permissible by Applicable Law, we disclaim all warranties, express or implied, including, but not limited to, implied warranties of merchantability and fitness for a particular purpose. We do not warrant that the services, information, content, materials, products (including software) or other services included on or otherwise made available to you through the services, our servers or electronic communications sent from us are free of viruses or other harmful components. We will not be liable for any damages of any kind arising from the use of any service, or from any information, content, materials, products (including software) or other services included on or otherwise made available to you through any service, including, but not limited to direct, indirect, incidental, punitive, and consequential damages.
13. HOW DO YOU CONTACT US?
Your privacy matters to us so if you have any questions regarding your privacy, please contact us at info@jarc.ae
If you have any general enquiries, complaints or suggestions, please contact us at info@jarc.ae. Ths Privacy Notice should be read together with our Terms of Use and any other documents referred to in it