ember Lifestyle Privacy Policy Introduction – Data controller and data protection Officer Ember respects your privacy and is committed to protecting your personal data This privacy notice explains how, what type and for what purposes, we use the information collected about you in connection with your use of the Concierge Service or our Platform. By using the Concierge Service, our Platform or Services offered by external Suppliers, you are agreeing to be bound by this Privacy Statement in respect of the information collected about you. We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below. Contact details • Full name of legal entity: Ember Lifestyle LLC • Name or title of DPO: [ ] • Email address: [ ] • Postal address: PO Box 111718, Abu Dhabi, UAE • Telephone number: +971 2 658 4200 1. How we collect data from you There are a number of ways in which we collect data from you in connection with your use of our concierge services in accordance with data protection Laws. (i) We collect your personal contact information (such as email address or phone number) provided to us when you first register for our service or when you contact us via the online form submission with an enquiry; through any telephone, SMS, WhatsApp conversation or email exchange with our representatives; or in response to a communication from us. Calls will be recorded for quality control and training purposes which includes the usage of the recordings for the handling of claims and fraud detection purposes. Recordings are kept for a limited amount of time and automatically deleted thereafter, unless we have a legitimate interest to keep such recording for a longer period, including for fraud investigation and legal purposes; (ii) Information provided when you visit our Platform. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies We capture access data such as: IP address; browser type and version; time zone setting, browser plug-in types and versions; operating system and platform; date and time of the access; articles you have read; requests made; or the amount of data transmitted and the requesting provider. From your IP address, we may be able to identify your city or country of location and this may be used to display geographically relevant information to you on our Platform. We may also receive personal data about your various third parties and public sources as set out below: ➢ Technical Data from analytics providers such as Google based outside the EU ➢ Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU a) Where you provide us with information about other people, you confirm that: (i) you have the consent or authorisation from the individuals to pass this information to us; and (ii) you have notified them of, and they have agreed to, the collection and use of their information as set out in this Privacy Statement. b) We are required to comply with certain legal and regulatory requirements, and may process your personal data for compliance with such legal or regulatory obligations, to which we or regulators or law enforcement agencies are subject. c) You may store your payment card details on our Platform. We reveal only the last four digits of your credit card numbers when confirming an order. However, we transmit the entire credit card number to the appropriate credit card company during order processing. It is important for you to protect against unauthorised access to your password and to your computer. 2. How your data is used We will only use your personal data when the law allows us to. We may use information you give us or that we collect from you (i) to allow us to perform the contract we are about to enter or have entered with you for concierge services or to allow suppliers to provide services to you. (ii) to manage our relationship with you such as informing you about changes to our Concierge Service and new and additional Services available from time to time: a) we may use personal data to inform you of information, suggestions, recommendations, products and services that may be of interest. You may be contacted by email, telephone, SMS, WhatsApp or such other means as we regard as appropriate and as legally permitted. You may opt out from this type of communication by calling us, emailing us or going to our Platform; We will contact you by e-mail only with information about products and services similar to those which you have previously shown an interest in or which you are likely to be interested in based on preferences you have expressed; b) to process and deliver your requests and orders including: fulfilment of requests placed by you or on your behalf; manage payments, fees and charges and collect and recover money owed to us. (iii) to use data analytics to improve our website, products/services, marketing, customer relationships and experiences. To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you a) we use “cookies” to monitor website user traffic patterns and website usage. This helps us to understand how visitors use our Platform so that we can develop and improve the design, layout and functionality of our Platform. Cookies make it easier for you to log on to and use the website during future visits. A cookie is a piece of information that is stored on your computer’s hard drive and which records your navigation of a website so that when you revisit that website it can present tailored options to you based upon the stored information about your last visit. You can normally alter the settings of your browser to prevent acceptance of cookies. If you do not want us to deploy cookies in your browser, you can set your browser to reject cookies or to notify you when a website tries to put a cookie on your computer. However, rejecting cookies may affect your ability to use some of the products and/or services at our Platform. We have a legitimate interest (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy (iv) to administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)We have a legitimate interest to process the personal data of our users for our internal operations; (v) to allow you to participate in interactive features of our Concierge Service. This processing is necessary for the performance of these Concierge Services to you; (vi) as part of our efforts to keep our Platform safe and secure. We have a legitimate interest to process the personal data of our users to keep our Platform safe and secure; and (vii)to comply with any legal or regulatory obligations to which we or regulators or law enforcement agencies are subject. This processing is necessary for compliance with a legal obligation to which we, our users or the regulator/law enforcement agencies are subject 3. Sharing your data 1. We may share your information (including any of the data we have collected as mentioned in section 1. above) third parties set out below in the course of or connected to providing the Concierge Services to
(i) Suppliers; (ii) Internal Third Parties; and (iii) External Third Parties such as: a) Franchise partners acting as joint controllers or processors who may provide services pursuant to the contract we are about to enter into or have entered into with you. b) Service providers acting as processors who provide IT and system administration services. c) Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services. d) HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances. 2. We may also share aggregated, anonymised information with your third parties to show trends about the general use of the Concierge Service 3. 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 data in the same way as set out in this privacy policy. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. 4. Data Security We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. 5. International transfers of your data In order to perform the Concierge Service or allow you to receive the Services from Suppliers in relation to the Concierge Service, we may need to transfer your personal data outside of your country to countries where we have a partner office or to countries where a Supplier is needed to fulfil a request for you. These countries may not have the same data protection laws as the country where you initially provided the information. When we transfer or disclose your information, we will protect that information as described in this Privacy Statement. Where we transfer your personal data outside of the country in which you are based, we will rely on appropriate safeguards to cover transfers of your personal data including, for example, signing standard contractual clauses/data protection clauses, or applicable data protection laws relevant to legally protect your personal data. 6. Retaining your data a) We take appropriate measures to ensure that any personal data is kept secure. We will store your personal data for the duration of your use of our Platform or the Concierge Service. b) If your access to the Concierge Service expires or is terminated, we will continue to store your personal data for a period of time in line with legal, regulatory, financial and business requirements. We also keep a record of correspondence in line with legal, regulatory, financial and business requirements. c) We will only retain your personal data 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. d) By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for seven years after they cease being customers for tax purposes. e) In some circumstances you can ask us to delete your data: see your legal rights below for further information. 7. Your Legal Rights As a result of us collecting and processing your information, you may have the following legal rights subject to the data protection laws in your country (i) to access personal data held about you; (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. (ii) to request us to make any changes to your personal data if it is inaccurate or incomplete; though we may need to verify the accuracy of the new data you provide to us. (iii) to request your personal data is erased where we do not have a compelling reason to continue to process such data in certain circumstances; You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. (iv) to receive your personal data provided to us as a data controller in a usable way in certain circumstances; We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, (v) machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. (vi) to object to, or restrict, our processing of your personal data in certain circumstances; (vii)to object to, and not be subject to a decision which is based solely on, automated processing (including profiling), which produces legal effects or could significantly affect you; (viii) where our processing of your personal data is based on your consent you have the right to withdraw consent at any time by contacting us; However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent and to lodge a complaint with a data protection supervisory authority. If you need the details of the data protection supervisory authority in your country, if any, please contact the Concierge Service and we will be able to provide this information. 8. Links Our Platform may, from time to time, contain links to and from other websites and services, for example third party payment processors. If you follow a link to any of these websites, please note that: (i) we are not responsible for the content or reliability of websites linked to or from our Platform; (ii) we do not necessarily support the views expressed within linked websites and our including a link to a website should not be taken as an endorsement of any kind; (iii) we cannot guarantee that these links will work all of the time and have no control over the availability of the linked pages; and (iv) these linked websites have their own privacy policies and we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites
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