Privacy Policy

When Do We Collect Information?

We may collect information, including Personal Data, when you: (i) place an order; (ii) participate in surveys, post on message boards or provide feedback; (iii) access or use our DM App; (iv) communicate with us; (v) respond to marketing communications; (vi) link your social media account to our services; or (vii) register for any service or programs (including loyalty programs) offered by us or our group companies.

For clarity, you are not obliged to provide your Personal Data to us. However, if you do not provide your Personal Data to us, we may not be able to fulfil your order or provide other services to you. If you are under the age of 18, you must ensure that your parents or legal guardian consent on your behalf to the processing of your Personal Data as described in this Privacy Policy. DM App is not intended for anyone who has not attained age of majority as per the relevant applicable laws that govern such individual. However, it is not possible for us to prevent certain users, including children, from fraudulently representing their age in order to gain access to the DM App. If you are a parent or guardian and believe we have collected information about your child, please contact us immediately as provided in this Privacy Policy.

What Information Do We Collect?

We may collect the following:

• Basic information (Name, age, gender, email address, phone number, etc.) including Identity information required for identity verification (such as copies of government issued identification, e.g. passport, ID cards, etc.);
• Technical information (including Internet protocol (IP) address, your login data, browser type and version, time zone setting and location, and other information and technology on the devices you use to access the DM App or in relation to marketing emails we send to you;
• Transaction information about payments made to and by you including but not limiting to your modes of payments, as well as details about products and services you have purchased from us;
• Usage data, such as information on how you use the DM App, products and services or view any content on the DM App, including the time spent on the DM App, items and data searched for on the DM App, access times and dates, as well as DM App you were visiting before you came to the DM App and other similar statistics; and
• Marketing and communications data, such as your preferences in receiving marketing from us and our third parties, your communication preferences and your chat, email or call history on the DM App or with third party customer service providers.

Why Do We Collect Information?

The purposes for which we use data, and the legal bases for such processing, are as follows:

• To manage our business operations and customer relationships;
• To fulfill orders and deliveries;
• To make our web sites more personalized and easier to use;
• To protect the security of our sites and information technology systems;
• To provide relevant marketing in tune with personal preferences;
• To ensure legal or regulatory compliance;
• To respond to inquiries and provide customer service;
• To consider individuals for employment opportunities and manage on-boarding procedures; and
• To manage your membership of our loyalty programs - ‘U BY EMAAR’.

Legal Bases for Processing

We rely on one or more of the following legal bases to process your Personal Data for the purposes listed above: (i) your consent; (ii) performance of a contract with you (e.g. to process and deliver your order); (iii) compliance with a legal or regulatory obligation to which we are subject; (iv) protection of your vital interests or those of another person; (v) our legitimate interests, or those of a third party, provided these are not overridden by your interests or fundamental rights; or (vi) another basis permitted under the applicable law. Where we rely on your consent, you may withdraw that consent at any time as set out under “How You Can Access, Change, Delete or Withdraw the Personal Data” below.

We may use your Personal Data to verify your identity, process orders and payments, communicate with you, provide marketing offers and conduct internal analysis to personalise your shopping experience. We may disclose your Personal Data to credit reference or fraud prevention agencies, which may retain such information, and to competent regulatory authorities where required by law.

Marketing

We may process your information to provide you with, or enable our related corporations to provide you with, information, promotions and updates including advertising and marketing materials about our and/or our related corporations’ products and/or services as well as products and/or services of our and/or our related corporations’ preferred merchants and strategic partners. Where required under the applicable laws, we will only send you direct marketing communications with your prior consent, and you may withdraw that consent or opt out at any time using the methods described below.

How & With Whom This Information May Be Shared

Your Personal Data is important to us to provide you with our Services, and we are not in the business of selling your Personal Data to others.

We may share data with affiliates, group companies, suppliers, delivery partners, service providers, banks and payment partners and with regulatory authorities (if required).

To offer you our Services, we may engage with other businesses who are affiliates of us and/or non-affiliated service providers (e.g. logistics businesses used to deliver products, marketing companies, payments processors to process online transactions, analysing data etc.) and share your Personal Data with such businesses.

You can ask us or third parties to stop sending you marketing communications at any time by selecting your marketing preferences on the Platforms or by following the opt-out links on any marketing message sent to you or by contacting us at [email protected] at any time.

Use of Google reCAPTCHA

We use Google reCAPTCHA on our DM App to help protect against spam and abuse and to ensure the security of our services. reCAPTCHA works by collecting hardware and software information, such as device and application data, and sending it to Google for analysis. The use of reCAPTCHA is subject to Google’s Privacy Policy and Terms of Service. By interacting with reCAPTCHA, your use of the service is governed by those policies.

Additionally, you may be asked to provide additional Personal Data to participate in some of our market research activities, including competitions and promotions. (e.g. further Personal Data to establish your eligibility to win a prize). This Personal Data may be collected by us or our co-sponsors or vendors for the promotion. If you choose not to provide certain Personal Data, you might not be able to take advantage of the competitions and promotions. In case you decide to participate, please note that you should review such third parties’ privacy policies to see how they may use any Personal Data that they collect.

Business Transfers

As our business evolves, we may engage in buying or selling other businesses or services. In these transactions, customer Personal Data is typically included among the transferred assets but will continue to be protected under any existing Privacy Policy(ies) (unless, of course, the customer does not consent). In an event wherein we are acquired or if a substantial portion of our assets are acquired, customer Personal Data will be included as part of the assets being transferred.

Protection of the Platforms and Others

We release Personal Data of users when we believe such a release is appropriate to comply with the law, law enforcement investigations and to protect the rights, property or safety of ourselves, our users or others. This includes exchanging Personal Data with other companies and organizations for various reasons, such as fraud protection and credit risk reduction.

What About Cookies?

By using our DM App, you agree that we can place these types of cookies on your device and access them when you visit the site in the future. Our site uses cookies (very small files that are sent by us to your computer or other access devices) which we can access when you visit our site in future.

You are not obliged to accept cookies. If you are concerned, you can set your computer or device either to accept all cookies, to notify you when a cookie is issued, or not to receive cookies at any time. However, rejection of cookies may affect your use of our DM App as we will be unable to personalize aspects of your use of the DM App.

How You Can Access, Change, Delete or Withdraw the Personal Data

If for any reason you are concerned that the Personal Data held by us is inaccurate, incomplete or, where relevant, not up-to-date, and you wish to correct such Personal Data, you may make a request to us by contacting us at [email protected]. In relation to either a data access request or a data correction or deletion request, you should quote your name, address and phone/account number and provide brief details of the information you want a copy of or, as the case may be, you want to have corrected, in any such request.

You have the right to withdraw consent at any time, although such withdrawal will not affect the lawfulness of processing occurring prior to such withdrawal; or request access to and rectification or erasure of Personal Data, or request that processing of your data may be restricted.

In addition, and to the extent provided under the applicable laws, you have the right to: (a) obtain a copy of your Personal Data in a structured, commonly used format and, where technically feasible, request that we transfer it to another controller; (b) object to the processing of your Personal Data, including for direct marketing purposes; (c) object to, and request human intervention in relation to, decisions based solely on automated processing (including profiling) that produce legal effects concerning you or similarly significantly affect you; and (d) lodge a complaint with the UAE Data Office if you believe your Personal Data has been processed in violation of the PDPL. We will respond to any request within the timeframe required under the PDPL.

Please note that we may decline to comply with your data access request in certain situations, for example when we are unable to confirm your identity or where information requested for is of a confidential commercial nature or in the event, we receive repeated requests from you for access to the same information which burden or expense of providing access is disproportionate to the risks to your privacy.

Safeguarding Your Data

We may transfer Personal Data to jurisdictions as necessary for the purposes described above. We will only transfer Personal Data outside the UAE where: (i) the destination jurisdiction is included on the UAE Data Office’s list of jurisdictions with an adequate level of protection; (ii) appropriate safeguards are in place (such as standard contractual clauses or binding corporate rules) and data subject rights and effective legal remedies remain available; or (iii) another derogation permitted under the applicable laws applies, such as your explicit consent to the transfer.

We take reasonable care to maintain appropriate safeguards to ensure the security, integrity and privacy of the information you have provided us with. When you place an order or access your account information, we use top notch secure encryption, which encrypts your information before it is sent to us to protect it from unauthorized use.

We retain your Personal Data only for as long as necessary to fulfil the purposes for which it was collected, including to satisfy any legal, accounting, tax or regulatory requirements. Retention periods vary depending on the type of data and purpose of processing; where no longer needed, we securely delete, anonymise or restrict access to your Personal Data.

Updates to Our Privacy Policy

We may amend this Privacy Policy from time to time and the updated version shall apply and supersede any and all previous versions, including, leaflets or hard copy versions. You are encouraged to check our DM App and re-visit this Privacy Policy periodically for our most up-to-date Privacy Policy (as reflected by the date of the update set out at the top of this Privacy Policy).

Disclaimers

Where we receive data from you about other customers or other individuals, you are responsible for ensuring that any such data is transferred to us in compliance with applicable data protection laws.

While we endeavor to always protect our systems, sites, operations and information against unauthorized access, use, modification and disclosure, due to the inherent nature of the Internet as an open global communications vehicle and other risk factors, we cannot guarantee that any information, during transmission or while stored on our systems, will be absolutely safe from intrusion by others or cyber threats.

You also have an important role in protecting Personal Data. You should not share any username, password or other authentication data provided to you with anyone, and we recommend that you do not re-use passwords across more than one DM App or application. If you have any reason to believe that your username or password has been compromised, please contact us as detailed below.

This Privacy Policy does not apply to DM Apps maintained by other companies or organizations to which we link and we or our group companies are not responsible for any personal information you submit to third parties via our DM App. Please ensure that you read the Privacy Policy of other such companies or organizations before submitting your details.

Jurisdiction

Your use of this DM App and any dispute arising out of such use is subject to the laws of the United Arab Emirates and any disputes arising hereof shall be presented solely before Courts of Dubai.

Where and How to Ask Questions or File Complaints

If you require more information, wish to exercise any of your rights, or wish to raise a complaint about our handling of your Personal Data, please go to the Contact Us section of the DM App or send an email to [email protected].