Privacy Policy
PERSONAL DATA PROTECTION & PRIVACY POLICY
1. Landmark Hospitality Holding Investment LLC – Statement of Privacy
Landmark Hospitality Holding Investment LLC a company incorporated under the laws of Dubai, United Arab Emirates (referred to herein as “LMH”, “we”, “our” or “us”) is committed to protecting your privacy online and security of your personal data in accordance with the Personal Data Protection Law hereinafter referred to as (‘PDPL’) 1 of UAE, read with the Implementing Regulations 2 Published by the UAE.
Our Personal Data Protection & Privacy Policy specifies the purpose of collection, nature of personal data collected, the means used for collection of your personal data, processing, storage and destruction of your personal data and information on your rights as Personal Data Owner / Data Subject and how you can exercise your rights.
LMH is committed to processing your personal data in a manner that upholds your right to privacy and confidentiality of the highest degree, in accordance with the provisions of the laws applicable in the region we operate.
2. Interpretations and Definitions
a) Actual Interest refers to any moral or material interest of yours (Data Subject’s) that is directly linked to the purpose of the Processing of Personal Data, and the Processing is necessary to achieve that purpose.
b) Controller means LMH and its holding companies, subsidiaries and affiliates and any natural persons associated with the Group that specifies the purpose and manner of collection and processing the Personal Data.
c) Collection means the collection of Personal Data by the Controller in accordance with the provisions of the law either from you (Data Subject) directly, or from your (Data Subject’s) representative any legal guardian over the Data Subject or any other party.
d) Disclosure means enabling any person other than the Controller and Processor, as the case may be to access collect or use personal data by any means and for any purpose.
e) Destruction means any action taken on Personal Data that makes it unreadable and irretrievable, or impossible to identify your or the Data Subject / Personal Data Owner to whom it relates.
f) Explicit Consent means direct and explicit consent given by the Personal Data Owner / Data Subject in any form that clearly indicates your (the Data Subject’s) acceptance of the Processing of your (Data Subject’s) Personal Data in a manner that cannot be interpreted otherwise and whose obtention, can be proven.
g) Health Data means Any Personal Data related to an individual's health condition, whether their physical, mental or psychological conditions, or related to Health Services received by that individual.
h) Legitimate Interest refers to any necessary interest of the Controller that requires the Processing of the Personal Data, for a specific purpose, if it does not adversely affect your (Personal Data Owner’s / Data Subject’s) rights and interests.
i) Personal Data means any data regardless of its source or form, that may lead to identifying you (an individual) specifically, or that may directly or indirectly make it possible to identify you (an individual) including, name, personal identification number, records, personal assets, bank and credit card numbers, photos and videos of you (an individual) and any other data of personal nature.
j) Processor means any Public Entity, natural person or private legal person (including holding, subsidiaries or affiliates of LMH) that processes the Personal Data for the benefit and on behalf of the LMH (Controller).
k) Processing means any operation carried out on Personal Data by any means, whether manual or automated including collecting, recording, saving, indexing, organizing, formatting, storing, modifying, updating, consolidating, retrieving, using, disclosing, transmitting, publishing, sharing, linking, blocking, erasing and destroying Personal Data.
l) Sensitive Data means Personal Data revealing racial or ethnic origin, or religious, intellectual, or political belief, data relating to security criminal convictions and offenses, biometric or Genetic Data for the purpose of identifying the person, Health Data, and data that indicates that one or both of the individual’s parents are unknown.
m) Transfer means the Transfer of Personal Data from one place to another for Processing.
n) Vital Interest means any interest necessary to preserve your life.
o) You / Your means an individual who is Personal Data Owner / Data Subject to whom the personal data relates.
The terms used in this Personal Data Protection & Privacy Policy shall have the same meaning as used in common parlance as specified in the PDPL and its Implementation Regulations, unless specifically specified as otherwise.
3. Purpose of Collection of Personal Data
Personal data refers to data that lets LMH know the specifics of who you are and which may be used to identify, contact or locate you (e.g., name, age, gender, mailing address, telephone number and e-mail address). LMH may ask you to provide your personal data relevant for being able to serve you in a manner that enables us to enhance your experience by creation of awareness of opportunities with us, and / or update you on new arrivals, sales promotions, discount campaigns on products and services that may interest you based on your previous interaction with us. We may use a third-party service provider to assist us with some features of our service. Our service provider will receive your information on our behalf and will not be permitted to use it for any other purpose.
4. Nature of Personal Data Collected
Your Personal Data collected may be in physical and / or electronic form and may include name, address, contact information (telephone / mobile number), e-mail address, National ID, Passport, Bank Account / Credit card / Debit card details, age, gender, health data, etc. which is most relevant to the scenario. For instance, an applicant to a job opening with us may share his / her resume with us, and post selection other necessary personal data for processing his / her application for employment visa, employee insurance etc., Similarly our potential customers / repeat customers may share their personal data as described hereinabove during / after the purchase or while considering availing our product(s) / service(s) in future.
5. Means Used for Collection of Personal Data
LMH collects your personal data when you provide us in scenarios such as a job seeker applying directly through our website, or other social media channels / indirectly through a third-party recruiting agency engaged by us to help us identify suitable candidates for a job opening with us. Similarly, as an employee of LMH, your personal data may be shared / acquired within the Company / intra-group or from / with an external firm in connection with your employment. In capacity of a potential or repeat customer subscribing to our Shukran Loyalty Program, respond to a survey, register for events or campaigns, and / or register for
personalised services, and / or visit our websites, stores, and / or contact our customer support. Not all the personal data LMH holds about you, may always come directly from you. It may, for example, come from your employer or other organizations to which you belong or have interacted with. We collect your personal data if you wish to do business with us in the form of dealership / distributorship (through dealer / distributor / vendor on boarding applications). We also collect personal data from our group companies (holding, subsidiaries and affiliates), partners, third parties such as service providers, and publicly available websites, to offer opportunities to work with us, products and services we think may be of interest and provide and enhance your experience of dealing with us. LMH websites may collect your personal data including your location data, IP Address, Device ID etc., in addition to any other information that you share with us while interacting with us.
6. Processing of Personal Data
The meaning of Processing Data is specified in clause 2 (k) of this Personal Data Protection & Privacy Policy, LMH may process / use your Personal Data for the following purposes:
a) To provide our products and maintain our service including to monitor your buying preferences and choice of services to enable us offer you an update on better deals emerging from our campaigns and promotions.
b) To manage your account – to manage your registration as a beneficiary of the Shukran Loyaly Programme.
c) For performance of contract the development, compliance and undertaking of the purchase contract for the products, items or services you have purchased or of any other contract with us through our previous interaction in any form.
d) To contact you by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
e) To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information.
f) To manage your request to attend and manage any requests you’ve communicated to us.
g) For other purposes we may use your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our products, services, marketing, and your experience.
7. We may share Your personal data / information in the following situations:
a) With Service Providers:
We may share your Personal Data / Personal Information with Service Providers to monitor and analyze the use of our products, service, and / or to contact you.
b) For business transfers:
We may share or transfer your Personal Data / Personal Information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of our business to another company.
c) With business partners and group companies:
We may share your Personal Data / Information with our business partners and group companies (holding, subsidiaries and affiliates) to offer you certain products, services or promotions.
d) With companies within Landmark Group:
We may share your Personal Data / Information within Landmark Group companies (holding, subsidiaries and affiliates) to offer you certain products, services, or promotions.
e) With other users:
When you share Personal Data / Personal Information or otherwise interact in the public areas with others, such information may be viewed by all and may be publicly distributed outside.
f) With Your consent:
We may disclose your Personal Data / Personal Information for any other purpose with your consent.
8. Retention of your Personal Data
LMH will retain your personal data only for as long as necessary for the purposes set out in this Personal Data Protection & Privacy Policy. We will retain and use it to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies which is subject to instruction from regulators, any other Government Authority and other applicable Rules & Regulations applicable within the UAE.
9. Transfer of your Personal Data
Your information, including Personal Data, is processed at Dubai, United Arab Emirates (‘UAE’) offices and in any other places where the parties involved in the processing are located. It means that your Personal Data may be transferred and maintained outside the region. Your consent to this Personal Data Protection & Privacy Policy followed by submission of requested Personal Data / Personal Information indicates assent for such data transfer. LMH will take all steps reasonably necessary to ensure that personal data provided to us is treated securely and in accordance with this Personal Data Protection & Privacy Policy and that such Personal Data shall not be transferred or shared to an organization or a country unless there are adequate controls in place to ensure security of your personal data and information.
10. Right to update, amend or request deletion of your Personal Data
As a Data Subject / Personal Data Owner you have the right to delete or request that LMH assist in deleting the Personal Data collected by us about You. You may update, amend, or delete your information at any time by e-mailing us and requesting for the same. Please note, however, that we may need to retain certain information when we have a legal obligation or lawful basis to do so.
11. Disclosure of your Personal Data
Under certain circumstances, LMH may be required to disclose your Personal Data if required to do so by law or in response to valid requests from public entities (e.g. a court or a government agency). The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:
– In interest of protecting the sovereignty of local region.
– Comply with a legal obligation.
– Protect and defend the rights or property of the LMH.
– Prevent or investigate possible wrongdoing in connection with the products / services.
– Protect the personal safety of customers of LMH or the public at large.
– Protect against legal liability.
12. Security of your Personal Data
Personal data security is a top priority for LMH, and it is safeguarded by physical, technical, and administrative protections that comply with existing Regulations. LMH will take reasonable efforts and procedures to secure the personal data of our customers against misuse and loss, as well as unauthorized access, modification, or disclosure. LMH maintains security measures to ensure that your Personal Data is safeguarded and that standard encryption norms for data transmission are adhered to. At LMH, we ensure that our employees and affiliates are made aware of the significance of protection of Personal Data and maintaining its confidentiality.
13. Right of Legal Guardians
LMH does not collect Personal Data from anyone under the age of 18 years, without the consent of the parent / legal guardian. If you are a parent / legal guardian and you are aware that your child has provided us with Personal Data, please contact us. If LMH become aware that it has collected Personal Data from anyone under the age of 18 years without verification of parental consent, LMH shall take the necessary steps to remove that information from our data base.
14. Amendments to this Policy
Any amendments (addition / deletion / modification) to this Policy shall be updated and published on our website at www.landmarkgroup.com
15. Contact Us
If you have any concerns or comments about the processing of your Personal Data or this Policy, or if you want us to change information or preferences you provided to us, please contact us by e-mail at: privacy@landmarkgroup.com
