References to "our", "us" or "we" within this policy are to Jumeirah Beach Club LLC, and our affiliated businesses as described below.

Please read the following information carefully to understand our views and practices regarding your personal data and how we will look after it.

We take your privacy very seriously and we endeavour, where reasonably possible, to follow best practice in protecting your personal data.

INFORMATION WE MAY COLLECT ABOUT YOU

We may collect and process the following data about you:

• information including your name, address, telephone number, email address, date of birth and nationality and any other information which may appear in your formal identification;
• information that you provide by filling in forms (both online at websites relating to the facilities and services and offline), including, for example, customer satisfaction surveys, sign-up forms to newsletters, bulletins and the like, questionnaires in our facilities, and competition entry forms;
• information collected over the telephone and through written correspondence (both on and offline) when you make enquiries and when you use the facilities (including your credit or debit card details), during customer satisfaction surveys, market research and when you give us your business card;
• information about your use of our facilities and services and your preferences in this regard;
• details of purchases you make from us, such as food and beverages, retail purchases, and the preferences you express to us;
• CCTV footage obtained from cameras positioned in public areas throughout our facilities for your safety;
• details of your visits to our websites including traffic data and the resources that you access.

Some of the data we collect and process will include sensitive data. Sensitive data is data which, for example, relates to your health or religion.

We do not knowingly collect personally identifiable information from individuals under the age of 18 years. If you are under the age of 18, please do not provide your name and address or other contact details or any other personally identifiable information of any kind whatsoever. If you are a parent or guardian of someone under the age of 18 who has provided us information without your knowledge and consent, you may request that we remove this information by contacting us at info@shoreside.ae.

COOKIES AND ID NUMBERS

When you visit our websites, you are initially given a "cookie", and your computer is assigned an ID number. A cookie is a commonly used device which stores information placed on a website in a storage place on your own computer. Our cookies do not contain any personally identifying information.

We use cookies to track your computer's usage patterns on our websites, and to enhance your visits to the websites. We also use cookies to collect and maintain aggregate website data (such as the number of visitors to a particular site) which helps us see which areas are popular with our users and which are not. It also enables us to recognise you when you return to our websites and store information about your preferences allowing us to customise our websites according to your individual interests. Among other things, this helps us improve the content and services on our websites and speed up searches.

If you don't like cookies, your web browser includes an option that allows you not to accept them. Rejecting cookies will however make browsing our websites a less enjoyable experience because the websites are not able to recognise you and your preferences for information. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you log on to our site. The cookie file cannot retrieve information from other cookie files, nor any other information from your computer or personal device.

Once you have visited our websites and accepted our cookies, your ID number is automatically assigned to your computer whenever you surf our websites. Despite the fact that you remain anonymous until you enter personal information in the site, the ID number allows us to log your session, enabling us to better assist you should you need some individualised service or support. Once you enter personal information on a site, we associate your ID number with your contact information so we can recognise you on a future visit. We also use it to keep track of your "hot buttons" (information that appears to be of personal interest to you).

We may collect and report to third parties (such as advertisers and our creative agencies) aggregate depersonalised or anonymised statistics about our users in terms of numbers, traffic patterns and related site information.

HOW WE STORE AND USE YOUR PERSONAL DATA

Jumeirah Beach Club LLC is a Dubai-based organisation. You should note that your data may be transferred to and stored in Dubai as well as in various destinations outside the European Economic Area ("the EEA"), including at the location of the relevant facility or at the location of the owner or manager of the relevant facility. Your data may also be processed by third parties operating outside the EEA who supply services to us. Such third parties may be engaged in, among other things, the processing of payment details and the provision of other support services. In submitting your data and using our facilities and services, you are consenting to your data being used in the manner set out herein in countries which may not have data protection laws.

If you submit your resume through our website, we use your personal data only in considering your application for employment. The information you provide will not be given to any third parties.
All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using Secure Socket Layer technology.

Jumeirah Beach Club LLC has taken several steps to safeguard the integrity of its communications and computing infrastructure, including but not limited to authentication, monitoring, auditing, and encryption. Security measures have been integrated into the design, implementation, and day-to-day operations of this Site as part of our continuing commitment to the security of electronic content and the electronic transmission of information. 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. Any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Where we have given you (or where you have chosen) a password or code which enables you to access certain parts of our site, you are responsible for keeping this password or code confidential. You must not share a password or code with anyone.

Your data will be stored in a form that allows your identification for a period no longer than is necessary for the purposes for which they have been obtained and processed.

HOW WE USE YOUR PERSONAL DATA

We may use information collected about you in the following ways:

Transactional Purposes

We may use your data in order to respond to your queries and requests and to provide services and to manage transactions such as credit card payments for our goods and services or for the fulfilment of such transactions. We will need to use your data in order to carry out our obligations arising from any contracts entered into between you and us. We may also use your data in order to improve (or seek to improve) the services we provide to you and to enable us to provide you with a more personalised experience.

Marketing Communications

We may use your data in order to communicate with you about our products and services and those of specially selected third parties. However, if you are a new customer, you will be able to choose whether or not to receive such communications when you first provide us with your personal data. When we send marketing communications to you by email or mobile (SMS), you will also be given an opportunity to unsubscribe from such communications. You may also opt out of receiving marketing communications from us at any time by informing us at the following email address: info@shoreside.ae.

Marketing Analysis

We may use your information for internal marketing analysis, for example, to assess trends or to measure the amount of traffic to our websites.
We may collect and report to third parties (such as advertisers and creative agencies) aggregate depersonalised or anonymised statistics about our users in terms of numbers, traffic patterns and related site information.

DISCLOSURE OF YOUR DATA

Sale and Transfer

We may disclose your information to third parties (which third parties may be based in Dubai or elsewhere (including in various destinations outside the EEA)):

• in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets; and/or
• if an affiliated business (details of which are available on request) or substantially all of its assets are acquired by a third party, in which case your personal data will be one of the transferred assets.
  

Service Providers and Sub-Contractors

In addition to disclosures identified in the purposes above, from time to time we may disclose personal information to our service providers and sub-contractors retained to perform functions on our behalf or to provide services to us, such as marketing and advertising; data processing; software development; website hosting and management; market research; warehousing and delivery; information technology and office services; legal, accounting, insurance, audit and other professional service providers.

If you do not want us to use your data in the ways outlined, or to pass your details on to third parties for marketing purposes, please tick the relevant box situated on the form on which we collect your data.

Legal Purposes

We may collect, use or disclose your data (including CCTV footage) if permitted by law or required to do so by law or where we believe such action is necessary in order to protect or defend us or other third parties against error, negligence, breach of contract, theft, fraud and other illegal or harmful activity and to comply with our audit and security requirements (which may include the completion of incident reports containing your data). We may exchange information with other companies and organisations, for the purposes of fraud protection and credit risk reduction. If legally requested by the relevant authority, we may also disclose your data to the local police, CID and immigration authorities.

PERSONAL DATA RELATING TO THIRD PARTIES

Please ensure that any data you supply to us which relates to third parties is provided to us with their consent and knowledge of our proposed uses of their data.

THIRD PARTY LINKS

Jumeirah Beach Club LLC's website may from time to time provide links to or from third party websites or resources for you to access at your sole discretion. Please note that any such third party website or resource may collect and use your personal data in a different manner to us. We do not endorse or accept any liability for the data collection practices, privacy policies or the content of any website linked from Jumeirah Beach Club LLC's website or which links to it. You should contact the owner or operator of any such website directly if you wish to enquire about their privacy practices and policies, before providing your personal data to them.

YOUR RIGHTS

You may exercise your right of access, rectification and removal of your personal data by contacting us at info@shoreside.ae.

CORPORATE AND CONTACT DETAILS FOR DATA CONTROLLERS

Jumeirah Beach Club LLC is a limited liability company incorporated in Dubai, United Arab Emirates, with commercial registration number 72903, share capital Dhs. 300,000 fully paid up, of Al Sufouh Road, PO Box 73137, Dubai, United Arab Emirates.

Please contact info@shoreside.ae for the corporate and contact details of the relevant Country Manager which may also be a data controller.

CHANGES TO PRIVACY POLICY

We reserve the right to update this privacy policy from time to time as we expand our services and products, or to endeavour, where reasonably possible, to comply with applicable legislation. Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by email.

This privacy policy was last updated on 15th March 2009.