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Privacy Policy

 

Privacy Notice

 

  1. 1. What we need

Our Personal Data Protection Policy governs the use and storage of your data. You can see our Personal Data Protection Policy by clicking here.

Fabulous Abu Dhabi Hotel Management LLC is a Controller of the personal data you provide us. We collect the following types of personal data from you:

  1. Your name, passport number or other identification number, telephone number(s), mailing address, email address and any other information relating to you which you have provided us in any form you may have submitted to us, or in other forms of interaction with you;
  2. Information about your use of our website and services, including cookies, IP addresses, subscription account details and membership details;
  3. Your employment history, education background, and income levels; and
  4. Your payment related information, such as your bank account or credit card information, and your credit history.

In addition, if you make a reservation to be a guest at on of our hotels; resorts or apartments, you may also be asked to provide further information including photo identification about yourself and your family members, such as the dates of your arrival and departure.  In order to provide you with better service, we may also collect your preferences, eg. The preferred location of your suite (high floor ect) type of bed, preferred newspaper ect.

 

  1. 2. Why we need it

We need your personal data in order to provide you with the following services:

Uniquely identifying a natural person, data concerning health, criminal convictions and offences and other information defined as personal data under GDPR such as internet protocol addresses and cookie identifiers (insofar as such information is capable of identifying individuals either directly or indirectly)

 

  1. 3. Purpose for collecting personal data

Your personal data is processed in Fabulous Abu Dhabi Hotel Management LLC – Head Office, located in UAE. Hosting and storage of your data takes place in

No third party providers have access to your data, unless specifically required by law.

When you submit forms, information or feedback relating to any of our products or services (including by use of our interactive IT touch screens such as iPads/Tablets), or submit any on-line queries;

Wen you register for or use any of our services on websites or apps owned or operated by us or when you register as a member owned and/or operated by us;

When you interact with our customer service officers or any of our staff, for example, via a face to face meeting, telephone calls, letters, online forms (such as any “contact us’ forms on our websites) reservation chat, social media platforms and emails;

  • When you use or purchase our services or products;
  • When you establish any online accounts with us
  • When you request that we contact you;
  • When you respond to our request for additional Personal Data;
  • When you ask to be included in an email or other mailing list;
  • When you respond to our promotions and other initiatives;
  • When you respond to our market surveys;
  • When you submit a job application or a scholarship application;
  • When you receive references from business partners, online travel agents and third parties, for example, where you have been referred by them;
  • When you submit your personal data to us for any reason
  • When you make a reservation; and
  • When you browse our website. Please refer to the Cookie Policy below for further information.

We may monitor or record phone calls and customer-facing interactions for quality assurance, employee training and performance evaluations, identify verification purposes, feedback, respond to your queries and requests and resolve complaints and other related purposes.  Such monitoring or recording will be in accordance with applicable law.

  • If you provide personal data of a third party (eg. Information of your dependent, spouse, children and or parents) to us, you represent and warrant that the collection, use and disclosure of that personal data to us, as well as the further processing of that personal data by us for the purposes set out below, is lawful.
  • In respect to our activities in the EU, Fabulous Abu Dhabi Management, the appointed representative for the registered entities of thelocal hotels are the primary data controllers for processing of the personal data.

 

  1. 4. Use and Disclosure for collecting personal data

4.1  Our business is to understand and meet your needs and provide you with the products and services that you require.  To this effectively, we need to collect a range of Personal Data about you as described in point 1 above.

4.2  In general, we will subject to applicable law, use and disclose your personal data for the following purposes:

  1. Provide you with the products or services you have requested;
  2. Help us review, develop, improve, manage the delivery of and – to the extent this requires the use of personal data – enhance our products and services, including analysing future customer needs, conducting market research, customer satisfaction surveys and data analytics for example to enable us to understand and determine customer location, preferences and demographics (which does not involve automated profiling or result in automated decision-making activity which is regulated under the GDPR);
  3. Communicate with you and respond to your queries, requests and complaints:
  4. Provide on-going information about our products and services which may be of interest to you;
  5. Handle disputes and conduct and facilitate investigations and proceedings;
  6. Protect and enforce our contractual and legal rights and obligations (including repayment obligations) and for credit and internal risk management;
  7. Prevent detect and investigate crime, including fraud and money laundering, and to analyse and manange other commercial risks;
  8. manage our infrastructure and facilitate business operations (including but not limited to billing, customer service and customer verification) and comply with internal policies and procedures;
  9. Facilitate business asset transactions (which may extend to any merger, acquisition or asset sale) involving any Fabulous Abu Dhabi entity; and
  10. Comply with any applicable rules, laws and regulations, codes of practice or guidelines or assist in law enforcement and investigations by relevant authorities.

4.3.    Generally, we process your Personal Data for one or more of the specific purposes identified in this Policy based on your consent obtained. Where GDPR applies, the legal basis for our processing of your Personal Data could also be that it is necessary for the legitimate interests pursued by us, or a third party which is described in paragraph 3.9 of this Policy. These legitimate interests include providing services to you where you are our client, managing the relationship between Fabulous Abu Dhabi Management and you and facilitating internal business purposes and administrative purposes. In some cases, the provision and processing of your Personal Data may be a statutory and/or contractual requirement, or may be necessary in order to perform any contract you have agreed with us or perform services that you have requested.

 

In addition, we may use and disclose your personal data for the following purposes, depending on the nature of the relationship with you:

 

  1. If you are a guest at one of our hotels or resorts, or an employee or an organisation which is a customer of our hotels: 

(i)    conduct due diligence checks;
(ii)    establish user profiles to improve services and for marketing purposes;
(iii)    meet quality assurance, employee training and performance evaluation purposes;
(iv)    maintain the client relationship;
(v)    prepare documentation as may be required;
(vi)    perform financial transactions such as payments for the period of stay, and enforce repayment                      obligations, credit and internal risk management;
(vii)    communicate with you changes and development to our policies, terms and conditions and other administrative information, and
(viii)   any other purpose related to any of the above.

  1. If you are a vendor, a prospective vendor or a contractor: 

(i)    evaluate your proposal and to conduct background checks on you;
(ii)    communicate with your deployed staff, after award of contract, who are in our properties to carry out work or services, and for any emergency or/and security concerns; and
(iii)    any other purpose related to any of the above.

  1. If you submit an application to us as a candidate for employment:

(i)    process your application including pre-recruitment checks;
(ii)    provide or to obtain references for background screening/vetting;
(iii)    collect information about your suitability for the position applied for;
(iv)    organise training and staff development programs;
(v)    assess your performance;
(vi)    administer benefits and payroll processing;
(vii)    provide you with tools to facilitate or as required for you to do your job;
(viii)    communicate with you to comply with our policies and processes, including for business continuity purposes; and
(ix)    any other purposes related to the aforesaid.

The above purposes are not exhaustive, and depending on the nature of your relationship with us we may collect, use and disclose your Personal Data for additional purposes which you will be notified of, in accordance with applicable terms and conditions.

 

  1. 5. Transfer of Personal Data

5.1    Your Personal Data may be stored in external servers located overseas. In addition, as described above, in carrying out our business, it may be necessary to share information about you with and between our related corporations and third-party service providers, some of which may be located in countries outside your country of residence. Such countries may not afford a standard of protection similar to those in your country of residence. However, we will take reasonable steps to ensure that your Personal Data transmitted outside of your country of residence is adequately protected. In addition, we will ensure that such transfers comply with the requirements of the applicable data protection laws.

5.2    In respect of our activities in EU, where your Personal Data is transferred to locations outside the European Economic Area, we have entered into a special type of contract (called European Commission Model Contractual Clauses) with the recipients of your Personal Data to ensure that they will provide adequate levels of protection for your Personal Data. If you wish, you may request for more information about the transfers of your Personal Data and/or a copy of the European Commission Model Contractual Clauses by contacting the relevant Data Protection Officer at the contact details provided in paragraph 12.1 below.

 

  1. 6. Retention of Personal Data

We are required to keep your personal data for as long as it is necessary for the purposes it has been collected, and

  • in most cases, up to 7 years; or
  • in respect of our activities in the EU, up to 10 years, unless otherwise permitted by applicable law or in order to defend a legal claim.

After this period, your personal data will be irreversibly destroyed. Any personal data held by us for marketing and service update notifications will be kept by us until such time that you notify us that you no longer wish to receive this information in accordance with our internal retention policy.

 

  1. 7. What are Your rights?

Should you believe that any personal data we hold on you is incorrect or incomplete, you have the ability to request to see this information, rectify it or have it deleted. This can be exercised through contacting the relevant data protection officer at the contact details provided below.

All countries except EU

Name: Malcolm Noronha, Group Data Protection Officer, Fabulous Abu Dhabi

Email:  FADdpo@fabulousabudhabi.com

Phone: +971 2 811 1272

 

All countries within the EU

Name: Maria Chiara Corona, Data Protection Officer,

Email:  dpo@thelocalhotels.com

Phone: +33 0789 30000

 

In the event that you wish to complain about how we have handled your personal data, please contact our Group Data Protection Officer at FADdpo@fabulousabudhabi.com or in writing at:

Fabulous Abu Dhabi Hotel Management LLC,

Royal Group Building, Ministries area

P.O. Box 53543, Abu Dhabi, UAE.

 

Our Legal Representative will then look into your complaint and work with you to resolve the matter.

If you still feel that your personal data has not been handled appropriately according to the law, you can contact The Information Commissioner’s Office in the UK and file a complaint with them.

 

  1.     8. Management and Security

8.1    We have appointed Data Protection Officers to oversee our management of your Personal Data in accordance with this Policy and the applicable data protections law. We train our employees who handle your Personal Data to respect the confidentiality of your Personal Data, and we regard breaches of all applicable data protection laws very seriously.

 

  1.  9. Cookie Policy

9.1    Please see our Cookie Policy for more details.

Use of Cookies

1.1  Our use of cookies on our websites is governed by our Cookie Policy set out here. By using, accessing or browsing our websites, you are consenting to our use of cookies in accordance with this Cookie Policy. This Cookie Policy may be updated from time to time and we will provide notice on website of such updates. It is your responsibility to check back regularly for updates to the same.

1.2  If you do not agree to our use of cookies as set out in this Cookie Policy, you should delete or disable the cookies associated with our website by changing the settings on your browser accordingly. Please refer to paragraph 1.10 below for more information on how to configure or disable cookies in each browser. However, you may not be able to enter or use certain part(s) of our websites, and some of the functions and services may not be able to function without cookies. This may also impact your user experience while on our websites.

1.3  What are Cookies: A cookie is a small file containing a string of characters that is sent to your computer when you visit our websites for record keeping purposes. Cookies are stored in your browser’s file directory, and the next time you visit the website, your browser will read the cookie and relay the information back to the website or element that originally set the cookie. Depending on the type of cookie it is, cookies may store user preferences and other information.

1.4  Which cookies are used on our website?

The information below explains the cookies we use on our website and why we use them:

Cookie Name Purpose
Google Analytics _utma
_utmb
_utmc
_utmz
These cookies are used to collect information about how visitors use our Site. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited.
Click here for an overview of privacy at Google
Session cookies These cookies are used to make the websites easier for you to use, and to enable you to navigate from page to page within each website more easily.

These cookies are automatically deleted once you close your browser.

Unique third-party persistent cookies, clear gifs or beacon gifs These cookies do not collect personally identifiable information on you. The information collected via these cookies are used to build profiles of different types of users in order to better tailor our products and services to each profiled group of visitors.

 

1.5 What do we use cookies for?

(a) We use cookies to track information such as the number of users and their frequency of use, profiles of users and their preferred sites.

(b) We use cookies to make the websites easier to use and to better tailor our products and services to your interests and needs. Cookies may also be used to help speed up your future activities and experience on our websites.

(c) When you interact with us on our websites, we may collect for the purposes of analysis statistical information from which individuals cannot be identified (“Aggregate Information”), such as number of users, their frequency of use, the number of page views (or page impressions) that occur on the websites and common entry and exit points into and out of the websites.

(d) We use such statistical information to understand how people use our websites and to help us improve their structure and contents. We cannot identify you personally from this information.

(e) We may use cookies that are necessary in order to enable our websites to operate, for example, cookies that enable you to log onto secure parts of our websites.

(f) We use cookies to track you as you navigate the websites and to enable the use of any e-commerce facilities.

(g) We use cookies to personalise the website for you, including targeting advertisements which may be of particular interest to you.

1.6 In addition to the cookies described above, we may also use other cookies on our website in future. These additional cookies will generally be used for the purposes described above. If the additional cookies are used for other purposes, or to collect other types of data, or provide new functionality, this section on cookies will be updated accordingly.

1.7 As we use Google Analytics on the website, a service provided by Google Inc, you should also review the Google Analytics security and privacy principles available at https://support.google.com/analytics/answer/6004245?hl=en. We use Google Analytics cookies to collect information about how visitors use our websites and the total number of times a visitor has been into our website. We use the information to improve the website and enhance the experience of our online visitors. You can, at any time, opt-out from the use of Google Analytics by either changing the settings on your browser accordingly or by clicking at the following link: https://tools.google.com/dlpage/gaoptout?hl=en

1.8 We use the cookies of third party social networking platforms and websites to enable you to interact with these platforms and websites to share information about our websites through them (e.g. through “Like” or “Share” buttons or through comment boxes, etc.). The social networking platforms in question will have access and use the information in these cookies for their own purposes and we invite you to consult their respective privacy and cookie policies.

1.9 Information stored in cookies on the website is used exclusively by Fabulous Abu Dhabi Management, except the one saved by Google Analytics, which is used and maintained by Google and Fabulous Abu Dhabi Management, for statistical purposes. Our third party ad-servers, if any, may also use the information stored in the cookies to customise your website experience. We do not have any direct control over the content of these adverts.

1.10 The way which cookies can be managed depends on your browser. The following links provide information on how to configure or disable cookies in each browser:

 

  1. 10. Third-Party Sites 

10.1    Our website may contain links to other websites operated by third parties, such as our business partners. We are not responsible for the privacy practices of websites operated by third parties that are linked to our website, unless that is a mandatory requirement by applicable data protection laws and regulations. We encourage you to learn about the privacy policies of such third parties. Once you have left our website, you should check the applicable privacy policy of such third parties at their respective websites to determine how they will handle any information they collect from you.

 

  1.  11. Third Party Modules

11.1    Our website uses the Google Maps API from Google Inc (“Google”). For more information about the privacy practices of Google, please see Google’s Privacy Policy available at https://www.google.com/policies/privacy or such other URL as Google may provide from time to time. Subject to the requirements of applicable data protection laws, by using our website and/or such functionality built into the website, you agree that Google’s Privacy Policy and this Policy shall apply to the collection, use and disclosure of your Personal Data by Google and Fabulous Abu Dhabi respectively.

 

  1.  12. Governing Law

12.1     This Policy and your use of this website shall be governed in all respects by the laws of the United Arab Emirates.

For the avoidance of doubt, the applicable data protection laws will apply to the processing of your Personal Data.

 

  1.    13. Review of this Policy

13.1     This Policy will be reviewed from time to time by us. We may also from time to time update this Policy to take account of new laws and technology, changes to our operations and practices and the changing business environment. If you are unsure whether you are reading the most current version, please contact us.

13.2     In the event of any inconsistencies between the English version and other translations of this Policy, the English version shall prevail.

Posted March 1st, 2020.

 

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