Privacy Policy

For the purposes of this Privacy Policy, “Gargash Group” means and includes the Company, any legal entity or branch in which it directly or indirectly holds shares, any holding company, any entity owned or controlled by a holding company, and any entity or branch 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. Each time you access or use the Sites, our Services, or provide us with information, 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. This Privacy Policy supplements other notices and privacy policies and is not intended to override them.

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).

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 you may provide to us include:

• Your personal details, including your name, postal and billing address(es), phone number(s), date of birth, and passport or ID number.
• Transaction information, including 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, information contained in a résumé, C.V., application and/or recruitment template, employment history, education history, references, and transcripts.
• Your feedback and contributions to customer surveys and questionnaires.
• Other personal information you choose to provide 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 such processing is needed, we will obtain your prior explicit written consent. Special categories include, without limitation, data concerning racial or ethnic origin, communal origin, political affiliations or opinions, religious or philosophical beliefs, criminal record, health life, genetic data and biometric data used to uniquely identify a natural person.

We may combine the personal data you provide to us with information collected through automated methods and with information received from other sources.

Personal data we collect by automated means

When you visit one of our Sites or use our computer system or mobile device when visiting our locations or using our online services, we may collect certain information by automated means, such as cookies, web server logs, session details and web beacons.

• 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);
• Device and component identifiers;
• Advertising identifiers such as IDFA or similar identifiers;
• Referring webpage or application;
• Online activity on other websites, applications or social media;
• Activity related to how you use our online services or technology, such as the pages you visit on our Sites; and
• Activities related data.

A “cookie” is a small text file placed onto an Internet user’s web browser or device and used to remember and/or obtain information about the user.

A “web beacon” is a small object or image embedded into a web page, application, or email and used to track activity. They are also sometimes referred to as pixels and tags.

Both we and selected third parties, such as 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.

To enhance your experience and provide personalized Services, we have implemented cookie preferences to give you control over your online experience. Upon your first visit to our Sites, you will be presented with the option to accept or decline certain types of cookies. Your preferences will be stored for future visits.

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. 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 the Personal Data We Share section.
• We may also collect information from business partners and vendors, such as clients, food delivery platforms, data providers, or payment processors, or from public sources such as public social media posts.

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 and safety callbacks.
• Maintain contact with you.
• Manage our relationship with you, including feedback management and customer surveys.
• 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.
• Provide relevant marketing communications, including by email, post, telephone, SMS, or online advertising such as push notifications, relating to products and services we offer.
• 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 services, 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 websites and mobile applications; managing communications; analyzing our products and Services; and performing accounting, auditing and other internal functions.
• Undertake recruitment activities including processing employment applications, assessing qualifications, verifying information, and conducting reference or employment-related checks.

3. For personal data collected through automated means:

1. To customize users’ visits to our Sites.
2. To deliver content tailored to users’ interests and browsing behavior.
3. To manage our Sites and other aspects of our business.

Additional purposes

1. For other purposes as agreed with you.
2. 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 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 above.

You have the right to withdraw your consent at any time and contact us through the details in the How to Contact Us section.

We support your legal rights to opt-in or subsequently opt-out of receiving communications from us and our partners. You may ask us not to process your personal data for marketing purposes, to remove it from our database, and to stop future communications.

You may change your preferences at any time.

Please note that we may continue to send transactional or service-related emails despite your wish not to receive promotional or marketing communications. If you opt out from one of our Sites, you may still 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 professional advisers such as legal representatives, auditors and insurance providers, business partners involved in your customer experience, and service providers who perform services on our behalf based on our instructions. We do not authorize them to use or disclose the information except as necessary to perform services or comply with legal requirements. We may also share personal data with other Gargash Group business units for the purposes described in this policy.

In addition, we may disclose personal data if required by law or legal process, to law enforcement or government entities, or when disclosure is necessary 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 in the event we wish to sell or transfer all or a portion of our organization, business or assets, including in the event of reorganization, dissolution, or liquidation.

We offer you certain choices in connection with the personal data we collect about you. You may contact us to update your preferences, ask us to remove your personal data from mailing lists, or submit a request. 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 it. You may also withdraw any consent previously provided or object on legitimate grounds to the handling of your personal data. We will 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. In some cases, we may still be entitled to process your personal data on a different legal basis, such as performing a contract.

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 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, we will require the recipient to protect the personal data in accordance with the UAE Data Protection Law and may require appropriate safeguards. Details of such safeguards can be requested through the How to Contact Us section.

We maintain administrative, technical and physical safeguards designed to protect 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.

If you have 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. We will seek to promptly address your issue.

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes for which we collected it, including for legal, regulatory, tax, accounting or reporting requirements. We may retain it for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect of our relationship with you.

Our Sites may provide links to other websites or applications for convenience and information. These websites may operate independently from us and may have their own privacy notices or policies, which we strongly suggest you review. To the extent linked websites are not owned or controlled by us, we are not responsible for their content, use, or privacy practices.

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 you of any significant changes and indicate at the top of the notice when it was most recently updated.