We believe in the importance of an individual's right to keep their personal information safe and secure. We are committed to protecting and maintaining the privacy, accuracy and security of your personal and financial information. We operate in adherence with current privacy principles in the UAE.
To find out more about the Principles, contact us on 8000 311 0085 or email@example.com.
This website is not intended for children (i.e. below 18 years of age) and we do not knowingly collect data relating to children.
IMPORTANT INFORMATION AND WHO WE ARE
- The information we collect and how we collect your information
- We will only collect information relevant to our business relationship with you. The information we collect will include contact details, your date of birth, personal details, IP addresses, financial information, information about your dealings with our company, and other personal information (“personal information”).
- We will collect personal information directly from you where possible. However, we may also use external sources to collect personal information. Information collected directly from you include where you give us personal information by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- a) apply for our products or services;
- b) create an account on our website;
- c) subscribe to our service or publications;
- d) request marketing to be sent to you;
- e) enter a competition, promotion or survey; or
- f) Give us feedback or contact us.
- We may also collect technical data about you through public sources such as analytics providers such as Google based outside the EU, advertising networks and search information providers.
- We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. If the information that we request from you is not provided, we may not be able to promote products to you and you may not be able to use our websites or create an account with us.
- How we use your information
We will limit the use of your personal information to:
- Promoting products and services to you
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Carrying out our business, which includes marketing, sales, distribution and all activities that relate to this.
- Fulfilling our legal requirements (for example, disclosure to law enforcement agencies or the courts).
- Where it is necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise, recover debts due to us, etc.)
- Using your information to promote products and services that we believe meet your needs.
- To manage our relationship with you which will include:
- b. Asking you to leave a review or take a survey;
- c. Manage payments, fees and charges; or
- d. Collect and recover money owed to us.
However, you can notify us at any time if you do not wish to receive these offers by requesting to opt out or by contacting us by emailing firstname.lastname@example.org. We will act promptly on any such request.
If you fail to provide personal data: Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
- Who will use your information?
- We provide your personal information to other select organizations that perform certain functions or operations for us with your consent. These organizations include, but are not limited to, legal representative, accountants, third party providers.
- We bind these companies to the same high standard of care as we do ourselves. They are not permitted to provide your personal information to anyone else. We enforce these requirements through contractual agreements.
- We may share your personal information with Imperial Brands PLC and its subsidiaries, partnerships, associates and joint ventures (“Imperial Brands”)
- We may disclose your information to overseas recipients. If we do disclose your information to an overseas recipient, it will be to Imperial Brands or to another entity in the course of providing our products and services to you. However, such overseas recipients must, in our reasonable opinion, be subject to a law or binding scheme that has the effect of protecting the information in a way that overall is at least substantially similar to the protection afforded by the Principles. Should we disclose your personal information to an overseas recipient and that recipient breaches a Principle, we will be held accountable for that breach.
- Your information is secure
- We will use up-to-date techniques and processes which meet current industry standards to ensure that your personal information is securely stored, and we take steps to ensure that your personal information is protected from misuse, loss, or unauthorized access or disclosure.
- Only our employees, the parties mentioned under 1.3 above, and those who perform services on our behalf, and are authorized to handle your information, will have access to your personal information.
- We will not retain any of your information for any longer than is required by us, except to fulfil our legal obligations.
- As a guide, the law generally requires us to retain account information for five years after an account is closed. However, we may retain some information for shorter or longer periods than this, depending upon any specific legal requirements and the needs of our business.
- We will, with your help, keep your personal information accurate, complete and up to date.
- Before we disclose your information to an overseas recipient we will take reasonable steps to ensure that the overseas recipient will not breach the Principles.
- You have access to your information
- You can access most of the personal information we hold about you and request corrections in the event that you believe the information we hold about you is incorrect.
- This right is subject to some exceptions. For example, you may not obtain access to information relating to existing or anticipated legal proceedings.
- You can request access to your information by visiting any of our branches or contacting us on email@example.com. This service is free unless the information you request requires significant research or preparation time. Before we act upon requests of this nature, we will tell you how much this service will cost.
- If we refuse access or refuse to make a correction, you may contact us and ask us to review the decision.
- What to do if you think we've made an error?
- We are committed to the protection of your privacy, and our policies, processes and systems have been developed with this intention. We have developed strict guidelines in order to be better placed to protect your personal information.
- However, sometimes human errors do occur. If you think we have not lived up to our commitment, we invite you to contact us by emailing firstname.lastname@example.org.
- Our objective is to respond to any complaint within five working days and to take all reasonable action to correct the error.
- In the event of a data breach, we have systems and processes in place which are designed to mitigate the impact of the breach. If we determine that the breach could result in serious consequences for the owner of that information, we will take steps to advise the owner of the information of the breach as soon as possible to assist in the mitigation of risk.
- For more information about our commitment to securing your personal information, contact us by emailing email@example.com.