This document is entitled the privacy notice (the “Privacy Notice”) and is valid from the date it is published.
Shamal Leisure and Entertainment LLC (“SLE”) operates this Website/Platform. When you use this Website/Platform or interact with any of our brands, venues or services (including, for example, XDubai, Skydive Dubai and Deep Dive Dubai), your personal data will be collected and processed by the Shamal group, the entity responsible for the relevant brand/venue/service and/or by SLE (together, the “Relevant Shamal Entity”).
In this Privacy Notice, “we”, “us”, and “our” refer to the Relevant Shamal Entity (not every company within the wider Shamal group). We respect your privacy and recognise the importance of protecting the personal data we collect and process.
This Privacy Notice provides guidance on how we collect, store, and use the information that you provide when you (i) visit this Website/Platform, (ii) download and/or use any of the mobile applications or other digital platforms utilised or offered by us (together referred to as the “
Website” or “
Platform”) and/or (iii) when visiting one of our venues.
This Privacy Notice provides information to enable you to be fully informed of how we collect and process your personal data.
ROLE PLAYERS
SLE is responsible for operating and administering this Website/Platform.
Controller(s): The controller of your personal data is the Relevant Shamal Entity—i.e., the Shamal group company that provides the brand/venue/service you are interacting with(and, in some cases, SLE where it determines the purposes and means of processing).
Intra‑group sharing/shared services: Your personal data may be shared between Relevant Shamal Entities and/or Shamal group of companies where it is necessary for the purposes described in this Privacy Notice (for example: group administration, customer support, bookings and fulfilment, information technology, security, finance, compliance, analytics, and group marketing/customer relationship management). Depending on the activity, the Relevant Shamal Entity receiving your personal data will act either:
(a) as a processor ; or
(b) as a separate controller (where they independently determine how and why they use the data); or
(c) as a joint controller with another Relevant Shamal Entity (where they jointly determine the purposes and means of processing).
How we manage responsibility: Where joint controllership applies, the Relevant Shamal Entities will maintain an internal arrangement allocating responsibilities for compliance and handling of rights requests. You may exercise your rights and raise enquiries via the contact details set out in the Contact Us section of this Privacy Notice.
THIRD PARTIES
The Website and Platforms may contain links to and from Websites belonging to other companies or organisations. This Privacy Notice does not apply to Websites or other platforms maintained by those third parties to which any of the Websites or Platforms link, and we are not responsible for any personal information you submit to third parties via the Websites and/or Platforms. Third-party tools and plugins on our Website, for example,Facebook “Like” buttons, may also gather information on your interactions with these features.
If you follow any link to another Website, that Website may have its own privacy policy. We do not accept any liability or responsibility for the privacy policies of third parties. It is recommended that you read the privacy policies of other companies or organisations before submitting any personal details.
WHAT PERSONAL INFORMATION IS COLLECTED ABOUT YOU?
When you visit this Website, use or download any of the Platforms, visit any of our venues, or interact with any products or services, some or all of the following information may be collected about you:
Personal Details
• You may give us information about your self when you respond to a communication from us or by filling in forms (both online and offline), over the telephone and through written correspondence with us. This can include your name, title, residential or office address, date of birth, billing address, email address, phone number, and/orlocation; and/or
• Transcripts of any live chat communications, including functionality that allows you to correspond via WhatsApp.
Family, Lifestyle, and Social Circumstances
• If you choose to interact with us via a social media platform, information provided through that platform; and/or
• Information about your preferences, memberships, and loyalty programs.
Financial Details
• Financial information such as your bank account or credit card details; and/or
• Information related to a purchase of products (including invoices and records of purchase).
Other
• Geolocation data;
• Communication preferences;
• Video footage or video recordings for customer experience documentation; and/or
• Photographs.
Sensitive Personal Data
• Dietary, disability or similar requirements for events and meetings. If you do not provide this information, we may be unable to address your specific needs or preferences; and/or
• Health information necessary to assess suitability for certain activities.
Automated Information
In addition, we may automatically collect information about you when you visit a Website or Platform. This may include technical information such as the internet protocol (“IP”) address used to connect your computer to the internet, browser type and version, time zone setting, cookies (please refer to the “What About Cookies?” section below), browser plug-intypes and versions, unique device identifiers and details of the device, operating system, and platform that you use. Additional information may include page response times, download errors, length of visits to certain pages on websites and platforms, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to navigate away from a Website or Platform.
Log Files
Whenever you use the Internet, specific information will be automatically transmitted from your Internet browser and stored by us in files known as “log files”. We save the log files in order to identify system malfunctions and for system security reasons (e.g. for the investigation of attempted cyber-attacks) for a short period and delete them after wards. If a further retention of log files is required for evidence purposes, these will not be deleted until we have identified the cause of the respective incident and may transferred to investigating authorities as evidence.
HOW WE MAY COLLECT YOUR PERSONAL DATA
Directly from you when you:
• Visit this Website, fill in any forms, or generally interact with the Website;
• Visit, download, or interact with any of the Platforms;
• Make bookings, or sign up for subscriptions or memberships through a Website or Platform;
• Purchase goods through this Website/Platform or in person by visiting any of the venues;
• Correspond by phone or in writing (including by email);
• Participate in surveys;
• Register for events;
• Enter into any competition run by us;
• Request information or marketing materials be sent to you or sign up for any newsletters;
• Visit any of the venues and interact with the staff;
• Using our venues technologies, Wi-Fi networks;
• Participating in contests, competitions, prize draws; and
• Providing feedback or using interactive features on our Website/Platform.
Indirectly:
• From affiliated entities, social media platforms or third-party business partners to whom you share information with;
• Through any live chat provider available on the Website or Platform (including WhatsApp);
• From your membership or loyalty programs; and
• From cookies on this Website or Platform (please refer to the “What About Cookies?” section below) or similar technologies.
WHAT ABOUT COOKIES?
This Website and Platforms may use
cookies. A cookie is a very small data file that the Website asks your browser to store on your computer or mobile device. A cookie allows a Website or Platform to "remember" your actions or preferences when you visit this Website or Platform in the future. A cookie may transmit information via your browser in order to authenticate or identify either the computer (for example, via the IP address) or the user.
Additionally, cookies may contain other information, such as registration data or user preferences. When our servers receive a request from a computer that stores a cookie from a Website or Platform, the servers can use the information stored in the cookie in combination with the information that we store on our servers.
There are four (4) types of cookies:
(i) Functional cookies:
These cookies enable you to browse the Website and Platforms and use their associated features.
(ii) Analytical cookies:
These cookies are used to measure and analyse how visitors use the Website and Platforms. This allows us to continuously improve the Website and Platforms and your experience.
(iii) Preference cookies:
When browsing, the Website and Platforms remember the preferences you make (for example: your username, language or location). This makes your browsing experience simpler, easier and more personal to you.
(iv) Targeted cookies or advertising cookies:
These cookies are used to deliver advertisements (when used) that are relevant to you. They limit the number of times you see an advertisement and help us measure the effectiveness of our advertising campaigns. They also remember when you have visited the website before. Sometimes we share anonymised information about your browsing activity with our advertising and creative partners. They may use this information to advertise products, which may interest you, on other websites or to assist us develop future advertising campaigns.
By using any of this Website or Platforms, you agree to the placement of these types of cookies on your device and access to them when you visit the Website or Platforms in the future.
HOW DO I DELETE OR REJECT COOKIES?
You can delete cookies at any time. If you want to delete any cookies that are already on your computer, please refer to the help and support area on your internet browser for instructions on how to locate the file or directory that stores cookies.
If you use the Websites or Platforms without deleting or rejecting some or all cookies, you agree that any cookies you have not deleted or rejected may be placed by us on your computer or on your device.
You may change your cookie preferences (and withdraw your consent to the use of non-essential cookies that collect your Personal data) at any time by amending your cookie preferences.
HOW WE MAY USE YOUR PERSONAL DATA
Necessary Administration
• Processing, fulfilling, and delivering orders for products and services;
• Processing, fulfilling, and providing e-tickets for experience-based products;
• Taking payments for products purchased and processing refunds;
• Creating and managing customer accounts on the Website and Platforms;
• Receiving and handling customer inquiries, complaints, issues, and requests;
• Addressing business client and service provider requests;
• Managing relationships with clients and service providers; and
• To provide and operate the sites, enable bookings and purchases, manage accounts, and deliver customer support;
Marketing
• Sending updates, news, and promotional messages (including special offers);
• Sending targeted advertising;
• To send service messages and, where you opt in or where otherwise permitted, to send marketing communications about Shamal brands, products, events, and promotions, including joint offers with our affiliates; and
• To personalise content, remember preferences, create look-alike audiences and improve user experience and functionality
Analytics
• Analysing Website and Platform data to improve products and services;
• Analysing your consumption behaviour for the purposes of providing you with special offers or promotions;
• Analysing consumption patterns, response times, and other metrics to improve our products and services; and
• Utilising survey feedback to improve products and services.
Legal and Regulatory
• Responding to requests by government or law enforcement authorities or regulators conducting any investigation;
• Cooperating with government, taxation, or law enforcement authorities or regulators on any information request;
• Complying with any applicable legislation;
• Combating money laundering and fraud; and
• Preventing and detecting crime.
SECURITY OF YOUR PERSONAL DATA
We take the security of your personal data seriously. It has internal policies and controls in place and implements technology measures to ensure that your personal data is not lost, accidentally destroyed, misused, disclosed, or subject to unauthorised access.
We will update these policies, controls, and measures from time to time as appropriate, including when new technology becomes available.
RETENTION OF YOUR PERSONAL DATA
We will only retain your personal data for as long as necessary to fulfil the purposes for which the personal data is collected, including satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period, we will consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which the personal data is processed, and whether such purposes can be achieved through other means, as well as the applicable legal requirements.
In some circumstances, for example, where the basis for processing your data has changed or ceased to exist, your personal data may be anonymised so that it can no longer be associated with you, in which case we may use such information without further notice to you.
If you have elected to receive marketing communications from us , we will retain personal information about your marketing preferences for a reasonable period of time, which will be determined based on the date you last expressed interest in our content, products, or services.
YOUR RIGHTS
We aim to keep the personal data that is held about data subjects as accurate as possible. As a data subject, you may have a number of statutory rights available to you. The actual rights available to you will depend on the data protection regime applicable to you and/or your personal data. The rights available to residents of the United Arab Emirates (“UAE”) are set out below.
If you wish to exercise any of your rights, please fill out the Data Subject Request Form, available here:
https://www.shamalholding.com.
If you wish to enquire about your rights or exercise any of your rights, please follow the instructions in the ‘Contact Us’ section on
https://www.shamalholding.com.
Where you make any request to us, we reserves the right to request further details from you to evidence your identity before processing your request.
• The Right to Withdraw Consent
Where your consent is relied upon as the lawful ground for processing your personal data, you may withdraw your consent at any time.
Any withdrawal of consent must:
• be in writing (either in hard copy or electronic form);
• notified by one of the methods set out in the section entitled ‘Contact Us’ on
https://www.shamalholding.com; and
• clearly set out the processing for which consent is withdrawn.
In the event that the applicable legislation or regulations set out any additional requirements to which a withdrawal of consent must adhere, then such additional requirements shall apply in addition to the above requirements.
The withdrawal of consent will not affect the validity of the processing of your personal data that occurred prior to the withdrawal of your consent. Depending on the nature of the processing for which consent is withdrawn, this may affect your ability to receive certain products, services or functionality.
Even if you opt out of marketing, we may still send service messages related to your bookings or use of the Website/Platform
• The Right to Access, Rectification and Erasure
You may request a number of details about how your personal data is being processed, including, but not limited to, the types of personal data that are being processed and whether decisions are made about you using automated processing or profiling.
In some cases, you may also request for your personal data to be corrected or erased.
• The Right to Restriction of Processing
In some circumstances, you may restrict the processing of your personal data. Please get in touch using the details provided in the ‘Contact Us’ section on
https://www.shamalholding.com to find out more about what restrictions you may request and the circumstances in which the processing of your personal data may continue, irrespective of such a request.
• The Right: Request Transfer of personal data
Where the processing is carried out on the grounds of consent or the performance of a contract and is carried out by automated means, you may have the right to receive such data in a machine-readable format, provided that it is technically feasible to do so, and such disclosure will not infringe the rights of any other natural person.
• The Right to Object to any Decision Based Solely on Automated Processing
You have the right to object to any decision that is made based solely on automated processing, including profiling, which produces legal consequences upon you or other seriously impactful consequences. You may also require such decisions to be reviewed manually.
• The Right to Lodge a Complaint
You may lodge a complaint with the UAE Data Office or the UAE Ministry of Economy’s Consumer Complaints Department at
https://www.moec.gov.ae/en/complaints-service.
We encourage you to first raise any complaints directly with us by utilising the contact methods under the ‘Contact Us’ section on
https://www.shamalholding.com.
MARKETING OPT-IN AND OUT
When you register on any of the Website or Platform , you may be given the opportunity to subscribe to a regular update service, which may send you alerts for new products, features, enhancements, special offers, upgrade opportunities, contests, events of interest, and one-off marketing promotions (“
Alerts”).
Alerts may be sent by email, SMS, WhatsApp, push notification, website forms, or other electronic communications means.
Alerts which you subscribe to will only be sent to us.
You may unsubscribe from any Alerts at any time. All electronic Alerts will contain an easy automated unsubscribe link so that you can opt out of that particular Alert. To opt out of direct mail Alerts, please use the email addresses listed above.
CHILDREN
We do not knowingly collect information from children or other persons (by reference to the legal age of majority in the United Arab Emirates from time to time).
PERSONAL DATA ABOUT OTHERS
In some cases, you may provide personal data to us about other people (such as referrals). You must ensure that you have given those individuals an appropriate notice that you are providing their information to us and have obtained their consent to that disclosure.
SHARING YOUR PERSONAL DATA
Your personal data may be shared within the Shamal group of companies for the purposes described in this Privacy Notice. Your personal data may also be shared with:
• Third parties that process data for the purposes of providing services to us such as website hosting, data storage, software services, email services, marketing, fulfilling customer orders, providing payment-related services including payment aggregation, data analytics, data mining, providing customer services, and conducting surveys, as permitted by applicable law. These companies may be located within or outside the UAE, but in any case, they are obligated to protect your data;
• Regulatory authorities or other government entities to ensure compliance with legaland professional obligations, including in response to a request made by a government authority;
• Law enforcement authorities and courts;
• Financial institutions;
• Professional advisors providing services to us, such as legal and accounting services;
• Third-party social media advertising partners or other third-party digital marketing providers should allow advertising to be tailored to you to ensure that you only receive targeted marketing that is relevant to you. Where targeted advertising is undertaken, the social media company and/or digital advertising companies will only be able to see your email address if you already have an account with the mand they already have your address themselves;
• If it is necessary to arrange the receipt of a prize you have won after entering into a competition run by us and by the third-party with whom we have run the competition in conjunction; and/or
• Third parties to whom we may pass on information about our Platform or Websitetraffic and other commercial information, but this information will not include any information which can identify you personally.
All unsolicited/public information shall be deemed to be non-confidential, and we shall be free to reproduce, use, disclose, and distribute such unsolicited/public information to others without limitation or attribution.
TRANSFER OF YOUR PERSONAL DATA TO OTHER COUNTRIES OR JURISDICTIONS
The majority of information we collect, including your personal data, is stored in the UAE. However, some personal data may be stored and/or transferred, where required. For example, third-party providers or facilities may be outside the UAE.
In such circumstances, we will take such organisational, contractual, and legal measuresas required under applicable legislation or regulations to ensure that your personal data is processed only for the purposes mentioned above and that, where required, adequate levels of protection have been implemented in order to safeguard your personal data.
Where your personal data will be transferred to a jurisdiction that does not have an adequate level of protection, we may be required to enter into a contract with the recipient or ensure other requirements have been met in accordance with applicable legal requirements.
DATA BREACH
In the event that the security of the Website, Platforms, or services is compromised or your personal data has been disclosed to unrelated third parties as a result of external activity, including, but not limited to, security attacks or fraud, we reserves the right to take reasonably appropriate measures, including, but not limited to, investigation and reporting, as well as notification to and cooperation with law enforcement authorities. In the event of a data breach, we will make reasonable efforts to notify affected individuals if the breach would prejudice the privacy and confidentiality of the user or if notice is otherwise required by law. If, for any reason, you have a reason to believe that your personal data shared is no longer secure, you may contact us using one of the methods set out in the ‘Contact Us’ section on any of the Websites or Platforms.
CHANGES TO OUR PRIVACY NOTICE
If possible, you will be notified of any changes to this Privacy Notice using the contact information you have provided, and you consent to us contacting you for this purpose. This Privacy Notice will be updated on this Website and Platforms, which you can refer to at anytime, and in certain cases, you may be asked to accept the new Privacy Notice when you next visit the Website or Platform.
CONTACT US - TO ASK QUESTIONS OR FILE COMPLAINTS
The Relevant Shamal Entity is responsible for responding to requests and enquiries under this Privacy Notice. SLE may receive and coordinate such requests on behalf of the Relevant Shamal Entity.
Please contact us in regard to any concerns in relation to this Privacy Notice or to exercise your rights:
• By submitting a Data Subject Request Form, which can be found
https://www.shamalholding.com; or
• By email to
dataprivacy@shamal.com with the subject "Data Protection".
SEVERABILITY
If any term or condition of this Privacy Notice is deemed invalid or unenforceable by a court of law or tribunal with binding authority, then the remaining terms and conditions shall not be affected.
GOVERNING LAW AND DISPUTE RESOLUTION
This Privacy Notice shall be governed by the laws of the Emirate of Dubai and the federal laws of the UAE, and the courts of Dubai have exclusive jurisdiction. Nothing in these terms affects any legal right that can not be legally excluded. In the event of any dispute, we will first attempt to resolve the dispute amicably and in good faith. If that is not possible, either party may refer the dispute to be finally settled exclusively by the courts of Dubai.
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