Privacy Notice

Last Updated: 27th January 2022

INTRODUCTION

We are committed to protecting and respecting your privacy. This Privacy Notice (the “Notice”) governs the collection and use of personal data by DH Loyalty LLC (“DH”), when you use the DH Loyalty Programme (currently known as “TICKIT”) and the DH Loyalty Programme (“DHLP”) App. It explains how and why we use your personal data and applies to the personal data that you provide us directly, or which we may obtain from other sources.

We may use your personal data for any of the purposes described in this Notice, or as otherwise stated at the point of collection. For more information about the DH Loyalty Programme see https://www.gettickit.com

References to "our", "us" or "we" within this Notice are to DH Loyalty LLC, Dubai Holding Privacy Office, P.O. Box 66000, Um Suqeim Street, Dubai, United Arab Emirates, privacyoffice@dubaiholding.com , +971 4 362 2000

WHO WE ARE

DH Loyalty LLC is the data controller of your personal data. We decide how and why your personal data is processed, either alone or jointly with others.

If you use our facilities and services, the entity which manages the relevant facility or service will also be a data controller in respect of your personal information. The data controllers of the following entities compose the ‘Data Controller List’ of Dubai Holding LLC: Dubai Holding Commercial Operations Group LLC, Meraas Holding LLC, DH Investments LLC, DHAM LLC, DH Real Estate LLC, DH Entertainment LLC, DH Hospitality LLC. Further details of the ‘Data Controller List’ of each entity are available on the privacy notices of their respective websites. This will enable you to identify the relevant Dubai Holding LLC entity that holds, processes, and secures your personal data and is the data controller in relation to your personal data.

If you have any questions about this Notice, the use of your data, or would like to be directed to our Data Protection Officer, please contact privacyoffice@dubaiholding.com.

INFORMATION COVERED BY THIS PRIVACY NOTICE

In this notice we refer to “processing” your “personal data”.

Processing is taken to mean anything that is done to or with personal data (including simply collecting, storing or deleting that data).

Personal data is any information relating to an identified or identifiable living person. When “you” or “your” are used in this statement, we are referring to the relevant individual who is the subject of the personal data.

WHAT WE COLLECT FROM YOU AND HOW WE USE IT

We process different categories of personal data to enable us to provide services to you, and as further described below.

Contact Details: Includes but is not limited to address, email address and telephone number.

Identification Data: Includes but is not limited to name, title, company and individual physical description.

Personal Information: Includes but is not limited to date of birth, age, gender, nationality, passport, marital status, signature, country of residence and family details.

Web Data: Includes but is not limited to cookies, user activity logs, IP address, location, social media profile and website visitor interaction data.

Spend Information: Includes but is not limited to travel history, loyalty scheme information, preferences, stay information, feedback / analysis (e.g., surveys), product purchase information, tenancy contract and occupancy information.

Financial Data: Includes but is not limited to card details, details of transactions and bank details.

The reason these categories of personal data are processed, along with our legal basis for doing so, are set out in the table below.

Personal Data Directly Obtained from You

Description of Processing Purpose for Processing Category of Personal Data Legal Basis
We process your personal data when facilitating payment at programme participating venues Maintaining / Servicing Accounts
Contact Details, Identification Data, Personal Information, Web Data, Spend Information and Financial Data We process personal data in line with our contractual obligations
We process your personal data in order to collect, manage and analyse membership information. Maintaining / Servicing Accounts Contact Details, Identification Data, Personal Information, Web Data, Spend Information and Financial Data We process personal data in line with our contractual obligations
We process your personal data in order to conduct surveys, obtain feedback and manage and progress complaints as necessary. Customer Service Contact Details, Identification Data, Personal Information, Web Data, Spend Information and Financial Data We rely upon legitimate interest to process your personal data
We process your personal data for marketing purposes, such as personalising offers for you, as well as for analytics purposes. Advertising / Marketing Services, Analytics Services Contact Details, Identification Data, Personal Information, Web Data, Spend Information and Financial Data We rely upon legitimate interest to process your personal data
We process your personal data for service and quality monitoring purposes. Customer service Contact Details, Identification Data, Personal Information and Financial Data We rely upon legitimate interest to process your personal data
We process your personal data in order to comply with legal requirements and exercise or defend legal claims. Litigation & Disputes Contact Details, Identification Data, Personal Information, with our legal obligations. We may also rely upon legitimate interest to process your personal data.
We process your personal data in order to improve the services we provide. Customer Service Contact Details, Identification Data, Personal Information, Web Data, Spend Information and Financial Data We rely upon legitimate interest to process your personal data
For management and audit of our business operations including accounting Audit Purposes and Financial Management Contact Details, Financial Details, Personal Information, Identification Data, Spend Information We rely upon legitimate interest to process your personal data
We process your personal data for security purposes and to ensure secure backup and archival of IT Systems. Security Purposes Contact Details, Identification Data, Personal Information, Web Data, Spend Information and Financial Data We rely upon legitimate interest to process your personal data
Identifying, investigating and mitigating incidents, such as if a personal data breach occurred Security Purposes Contact Details, Identification Data, Personal Information, Web Data, Spend Information and Financial Data We rely upon legitimate interest to process your personal data

Personal Data Indirectly Obtained from Others

We receive some information about you from other companies within the Dubai Holding Group of companies. These are further detailed below:

  • Dubai Holding Real Estate: As necessary we obtain your personal details in relation to the purchase of real estate
  • Dubai Holding Asset Management: As necessary we obtain your personal details in relation to the lease of real estate asset:

Programme participants: As necessary, we obtain your personal data from Partner Outlets who participate in the DHLP for membership information purposes, to manage and fulfil DHLP Points and Tier Points allocation.

Financial Service Providers: As necessary, we obtain your personal data from financial service providers for membership information purposes, to manage and fulfil DHLP Points and Tier Points allocation and understand your spend with us vs. competitors.

Social Media Platforms: As necessary, we obtain your personal data from social media platforms for analytics purposes, to manage and progress complaints, for marketing purposes, in order to improve the services provided and to conduct surveys.

Legitimate Interest
Where we rely upon legitimate interest as a lawful basis, we have balanced your rights and freedoms against our interests, or those of any third parties, and determined your rights are not infringed. Legitimate Interest is where your personal data is processed for either our own interests or the interests of third parties. This can include commercial interests, individual interests, or broader societal benefits.

HOW LONG DO WE KEEP YOUR PERSONAL DATA?

Your personal data will not be kept longer than necessary to meet the purposes detailed above. The criteria that we use to determine how long we will keep your personal data includes the period of time during which we have an ongoing relationship with you, and whether we have a legal obligation to store it (for example, for accounting purposes or for litigation, or regulatory investigations purposes).

Should retention of your personal data no longer be required we will remove it from our systems and records and/or take steps to properly anonymise it so that you can no longer be identified from it.

WHO DO WE SHARE YOUR PERSONAL DATA WITH?

Where necessary to fulfil the purposes described in this Notice, we shall disclose your personal data to certain third-parties, vendors and service providers or affiliated employees, contractors and entities as described below.

To the extent necessary, and where we have a legal basis to do so, we will also share your personal data with other entities within Dubai Holding LLC’s group of companies, including to Dubai Holding LLC’s subsidiaries.

Where we share personal data, we do so with the following parties for the following purposes:

Category of Third-Party Purpose for Disclosure
Legal and professional advisers Comply with legal requirements and exercise or defend legal claims, Competition and events and IT security
Finance Providers Comply with legal requirements and exercise or defend legal claims and IT security, provision financial services requested by you
IT, digital, technology and telecoms Analytics, Marketing and Memberships

PROFILING

Where we have a lawful basis to do so, we will use your personal data to evaluate certain personal aspects about you, such as to analyse or predict aspects concerning your economic situation, personal preferences, interests, reliability, behaviour, location or movements. This is known as “Profiling”. We only conduct profiling where it will not have a legal or other significant effect on you. We undertake profiling to help tailor our marketing to you.

WHERE WE STORE/TRANSFER YOUR PERSONAL DATA

When processing your personal data, we may transfer this to third parties based in other countries, to the extent necessary to fulfil the purposes described in this Notice. To the extent necessary, and where we have a lawful basis to do so, we will also share your personal data with other entities within Dubai Holding LLC’s group of companies, including Dubai Holding LLC’s subsidiaries and holding companies. Such transfers shall always be done in compliance with relevant data protection laws.

To the extent required, we will also transfer your personal data to third parties in connection with a reorganization, restructuring, merger, acquisition or transfer of assets, provided that the receiving party agrees to treat your personal data in a manner consistent with applicable laws and requirements.

SECURITY OF PERSONAL DATA

DH Loyalty LLC has implemented technology and operational security measures in order to protect personal data from loss, misuse, alteration or destruction. Only authorised persons are provided access to personal data; such individuals have agreed to maintain the confidentiality of this personal data.

YOUR RIGHTS

You have certain rights relating to your personal data. However, these rights can differ depending upon the country in which you are located. That country’s law will determine which rights apply and in what instances.

Right to withdraw consent
Where you have provided your consent to us, you will always have the right to withdraw this at any time. You can do this by either following the information provided at the time you provided your consent, or by contacting us using the following email address privacyoffice@dubaiholding.com

Right to request correction of your personal data
You will always have the right to request that we correct any personal data that we process about you that is inaccurate or incomplete. You can do this by contacting us at privacyoffice@dubaiholding.com.

European Data Protection Rights
Where the General Data Protection Regulation applies, you are also provided with additional rights. This allows you, subject to certain conditions, to:

  • upon request, be provided access to, or copies of, your personal data that we process;
  • upon request, restrict the processing of your personal data;
  • upon request, delete your personal data which we process;
  • object to our processing of your personal data; or
  • upon request, obtain a copy of your personal data which we process in a commonly used and machine-readable format.

It is important to understand that these rights are not absolute (e.g. their application may depend upon the legal basis we rely upon to process your personal data) and that we may require further information from you (e.g. to confirm your identity) in order to action your request.

If the General Data Protection Regulation applies, you also have the right to lodge a complaint with the supervisory authority in your country of residence, place of work or the country in which an alleged infringement of data protection law has occurred within the EU.

CONTACTING US

If you want to exercise any of the rights set out above or have any questions or concerns about how we treat your personal data, please contact us at privacyoffice@dubaiholding.com or by writing to us at DH Group Privacy Office, P.O. Box 66000, Um Suqeim Street, Dubai, United Arab Emirates,. Please include your reply address when you write to us.

CHANGES TO THIS PRIVACY NOTICE

We keep this Notice under regular review. We reserve the right, at our discretion, to change, modify, add or remove sections of this Notice at any time. You are also encouraged to review this Notice from time to time for updates. We will notify you of any changes (including when they will take effect) if we are required to do so by data protection laws.