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Privacy and Cookies Policy

Website Privacy and Cookies Policy

References to “our”, “us” or “we” within this policy is to Meraas Holding LLC and its subsidiaries (the Meraas
Group) (excluding any joint venture company and excluding DXB Entertainments PJSC and its subsidiaries).

We are committed to protecting and respecting your privacy.  This policy explains the types of personal information
we collect, how we process and use that personal information, who we share it with, how we protect that information,
and your legal rights in relation to your personal information. We are committed to abiding by this policy, as well
as the requirements of applicable laws, in the operation of our business.

Please read the following carefully as it explains our views and practices regarding your personal information, and
how it is handled. By accessing or browsing our website, you confirm that you have read, understood and agree to
this policy in its entirety.  If you do not agree with the practices described in this policy, you should not use
our website.

For the purpose of this Policy a “third party” or “third parties” is/are limited to service providers who assist us
to provide our services to you, our agents and operators of our facilities.

Who we are

For the purpose of applicable data protection laws, the data controller is Meraas Group, PO Box 123311, Dubai,
United Arab Emirates.

Information covered by this Policy

This policy covers all personal information collected and used by us.  In this policy, “personal data” or “personal
information” means information that (either in isolation or in combination with other information held by us)
enables you to be identified as an individual or recognised directly or indirectly.  This may include your name,
date of birth, nationality, gender, postal address, email address, phone number, and technical information from the
devices you use to access our website.

What information do we collect from you?

We may collect information about you from different sources as detailed below.

Information you give us

You may give us information about yourself 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.
The information you give us may include your name, postal address, email address, date of birth, landline and/or
mobile telephone number, as well as other personal information.

Information we collect about you

When you visit our website, we may use cookies and other technologies to automatically collect the following
information:

  1. Technical information, including the Internet Protocol (IP) address used to connect your computer to the
    internet, your login information, browser type and version, device identifier, location and time zone
    setting, browser plug-in types and versions, operating system and platform, page response times, and
    download errors;
  2. Information about your visit, including the full Uniform Resource Locators (URL) clickstreams to, on and
    from our websites;
  3. Length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouseovers)
    and methods used to browse away from the page.

Information we receive and collect from other sources

We may receive information about you from other websites operated by us or from the other services that we provide.
We may also collect information about you from publicly available sources, including publicly available content on
social media.

 

Cookies

Our website uses cookies and similar technology. A cookie is a small file of letters and numbers that our website
places on your computer, or other equipment which you use to access our website. These cookies allow us to
distinguish you from other users of our website.

You can read more about cookies and how to recognise them at www.aboutcookies.org.

Cookies perform many functions, such as allowing you to navigate between pages efficiently, remembering your
preferences, and generally improving the user experience. They can also help to ensure that advertising that you see
online is more relevant to you and your interests.

Your use of our website indicates your consent to the cookies described in this policy. Please see “How you can
control cookies” below for more information on how to withdraw your consent at any time.

Type of cookie What does it do?
Strictly necessary cookies These cookies are essential in order to enable you to move around the website and use its features, such as accessing secure areas of the website. Without these cookies services you have asked for, like room bookings or e-payment, cannot be provided.

 

Performance cookies These cookies collect information about how you use our website, for instance which pages you go to most often, and if you receive error messages from certain web pages. These cookies do not collect information that identifies you. All information these cookies collect is aggregated
and therefore anonymous. It is only used to improve how the website works. By using our website, you agree that we can place these types of cookies on your device.
Functionality cookies These cookies allow the website to remember choices you make (such as your language of choice or the region you are in) and provide enhanced, more personal features. These cookies can also be used to remember changes you have made to text size, fonts and other parts of the web pages
that you can customise. The information these cookies collect may be anonymised and they cannot track your browsing activity on websites operated by third parties. By using our website, you agree that we can place these types of cookies on your device.
Targeting or advertising cookies These cookies are used to deliver adverts more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help 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.

 

Please note that third parties (for example, advertising networks and providers of external services like web
traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be
analytical/performance cookies or targeting cookies.

How you can control cookies

Your web browser includes an option that allows you to refuse the setting of all or some cookies. However, if you do
so, you may not be able to access parts of our website and it may make your browsing experience less enjoyable.
Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies as
described above when you access our website. If you would like to delete any cookies on your computer please refer
to your browser manufacturer’s instructions by clicking ‘help’ in your browser menu.

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 afterwards. 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.

The following information, in particular, is stored in the log files:

  1. IP address (Internet protocol address) of the end device from which the online offer is accessed;
  2. Internet address of the website from where the online offer has been accessed (so-called origin or referrer
    URL);
  3. Name of the service provider through which access to the online offer is achieved;
  4. Name of the retrieved files or information;
  5. Date and time as well as duration of the access;
  6. Transferred data volume;
  7. Operating system and information on the Internet browser used, including add-ons (e.g. for the flash
    player);
  8. http status code (e.g. “Inquiry successful” or “Requested file not found”).

 

How do we use and process your personal information?

We process and use your personal information only when there is a legal basis for doing so or if you have given us
your consent to do so by sharing your information with us and agreeing to and accepting this policy, and for the
following purposes:

  1. Delivering our services to you;
  2. Processing your reservations and/or bookings, including payments and refunds, issuing documentation to you
    and addressing your queries.;
  3. Meeting our compliance obligations in relation to corporate systems and/or for audit purposes;
  4. Providing information to you in relation to our products and/or services, promotions and benefits, corporate
    events, reward programs and including improvements, updates and revisions to the same, as well as new
    products and services;
  5. Performing data analytics and customer profiling for marketing and advertising purposes;
  6. Conducting customer satisfaction surveys to enable us to obtain a better understanding of how we can
    continue to improve our products and services; and
  7. Tailoring the way we provide our products and services to you to best meet your requirements and
    preferences.

Processing purposes and legal bases

 We may use your personal information to: How do we use personal information for this purpose? What is the legal basis for us processing your information in this way?
Comply with legal requirements and exercise or defend legal claims. We may sometimes need to process personal information to comply with legal requirements
to which we are subject.
It is in our legitimate interests to process personal information for the purposes of
exercising and defending legal claims. Processing personal information may also be necessary to
ensure compliance with our legal obligations.
Process your personal information where this is to keep our website safe and secure. We may need to process your personal information in order to keep our website safe and
secure and protect against illegal or fraudulent activity such as cyber-attacks.
It is in our legitimate interests to monitor how our website is used to detect and
prevent fraud, other crimes and the misuse of our website. This helps us to ensure that you can
safely use our website.
Keep an up to date suppression list where you have asked not to be contacted, so we do
not inadvertently re-contact you.
We understand that you may prefer for us not to contact you. We keep records of your
preferences to ensure that we do not contact you if you have asked us not to. We may need to process
certain of your personal information (such as your name and email address) in order to do this.
It is in our legitimate interests to process personal information in order to maintain
an up to date suppression list and ensure that we do not contact you where you have asked us not to.

Transfer of your personal information

We may transfer your personal information to third parties and statutory authorities only if you have given us your
consent to do so by sharing your information with us and agreeing to and accepting this policy , or if there is an
obligation to do this on the basis of statutory regulations or due to an enforceable official or judicial order.

Transfer of personal information to other responsible parties may include:

  1. third parties in order to deliver our services to you;
  2. Judicial and regulatory authorities whom we are obliged to share information with,
    as required or permitted by law;
  3. Banks and payment providers, to process and authorize payments;

 

Storage of your personal information

Where we store your personal information

The personal information that we collect from you will be stored in Dubai, although it could be transferred to any
Company within the Meraas Group, regardless of geographic location, in the process of our business operations. We
will take all steps that are reasonably necessary to ensure that your personal information is treated securely and
in accordance with this policy and applicable data protection laws.

 

Security of personal information

All information you provide to us via our website is stored on our secure servers.
We have taken steps to safeguard the integrity of our communications and computing infrastructure, which includes
implementing authentication, monitoring, auditing, and encryption technology. Security measures have been integrated
into the design, implementation, and day-to-day operations of this website as part of our continuing commitment to
the security of electronic content and the electronic transmission of information. Despite our best efforts
unfortunately the transmission of information via the internet is not completely secure.  Although we have strict
procedures and security measures in place, we cannot guarantee the security of your data transmitted to our site.

Third party websites and apps

Our websites may contain links to and from third party websites.  Please note that if you follow a link to any of
these websites, these websites will have their own terms of use and privacy policies and that we do not accept any
responsibility of liability for these policies.  Please check these policies before you submit any personal data to
these websites.

Your rights

You have the following rights with respect to the personal information that we hold about you.

Your right to access the information we hold about you

You can request access to the information we hold about you by contacting us using this link.

Our file of your information will usually be made available to you within 30 days, although occasionally we may not
be able to give you access to the personal information we hold about you (for example, we may not be able to give
you access if it would unreasonably affect someone else’s privacy or if giving you access poses a serious threat to
someone’s life, health or safety).  Please note that we may apply an administrative charge for providing access to
your information in certain circumstances. Any such charge will be reasonable, and we will advise you of the charge
and obtain your consent before providing you with access to your personal information.

Please note that if you request a copy of your data using electronic means (such as email), then we will provide a
copy of your information in electronic form unless you ask us to do otherwise.

Your right to object to us processing your personal information

You have the right to object to us processing your personal information, even where that processing is necessary for
our legitimate interests (for example, where the processing is necessary for the legitimate commercial objectives we
pursue in the course of our business). You also have the right to object to any results of a processing activity
that prejudice your rights and that are conducted exclusively through automated systems.

You also have the right to ask us to stop processing your personal information for direct marketing purposes,
including any profiling we undertake for the purposes of direct marketing.  We will in any case only send you
marketing communications if you have previously agreed to this, but if you change your mind you can easily
unsubscribe from our marketing communications at any time by following the instructions included in these marketing
communications:

(http://customer.meraas.com/profile_preference)

Please note that, if you have consented to receive offers from third parties, those third parties  are responsible
for taking account of your rights, including your right to opt-out of receiving offers from them.

Your right to have your personal information transmitted to another organisation

Where we hold personal information about you with your consent or for the performance of a contract with you, you
also have the right to ask us to provide you with the personal information we hold about you in a structured,
commonly used and machine-readable format and, where technically feasible, to transmit that personal information to
another organisation.

Your right to make a complaint

You have the right to lodge a complaint with a local data protection authority in the EEA if you believe that we
have not complied with applicable data protection laws.
The local data protection authority will differ depending on the country you are in.

 

Contacting us

If you have any questions or concerns about how we treat your personal information, you wish to ask us to stop
processing your personal information, or you would like to generate a Subject Access Request, please contact us or by writing to us at:

Meraas Holding LLC
PO Box 123311
Dubai
United Arab Emirates

(Kindly include your reply address when you write to us.)

 

How long do we keep your personal information?

Your personal information is stored by us and/or our Service Providers, strictly to the extent necessary for the
performance of our obligations and strictly for the time necessary to achieve the purposes for which the information
is collected, in accordance with applicable data protection laws.  When we no longer need to use your information,
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 (unless we need to keep your information to comply with legal or regulatory obligations to
which we are subject). For more information, please contact us.

Changes to this Policy

We may update this policy from time to time in response to changing legal, regulatory or operational requirements.
Any changes will be updated on our website.  Your continued use of our website and/or services after any such
updates take effect will constitute acceptance of those changes.

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