We take your privacy seriously and are committed to safeguarding your personal information at Emaar Malls Group PJSC (which term includes all subsidiaries of Emaar Malls Group PJSC). (“Company”, “we” or “us” or “Emaar”) values you as our guest, respect your privacy and are committed to protecting it through our compliance with this policy.
This policy describes the sources of your personal information that we may collect from you or that you may provide to us, our purposes for collecting and processing your information, and our practices for collecting, using, maintaining, retaining, protecting and disclosing that information.
2. What information we collect about you?
2.1 Personal information you give us
The personal information we collect on or through our platforms may include:
- Information that you provide by filling in forms. This may include information provided at the time of registering to use our Website, subscribing to our service, registering for newsletter, using the ‘contact us’ form, using the “Enquiry” forms, using the ‘WeCare’ form, using the careers portal or requesting further services, register for ‘Emaar Gift Card’, entering a contest or promotion sponsored by us, reporting a problem with our Website or services. The personal information that you provide us with may include your name, email address, phone number, nationality, residential address, identification proof (such as Emirates ID, or Passport), credit card details, partner issued membership ID etc
- Records and copies of your correspondence (including e-mail addresses), when you contact us.
- Information that you provide when you contact us via social media, web chats, ‘WhatsApp’ chat or directly call our customer service team for general enquiries, register complaints, request for any assistance/ services. Information may include your name, email ID, contact number and call recordings (in case your call our customer service team).
- Information that you provide to surveys that trigger for feedback to help us improve ourselves, details of transactions you carry out through our Website and of the fulfilment of your orders. You may be required to provide financial information before placing an order or making payment through our Website.
- Information obtained through any system operated for the security, safety and access management (CCTV, access right system) when you visit our malls.
- Vehicle registration number and details recorded through Automatic Number Plate Recognition (ANPR) systems at our Centre car parks and any other usage of our Parking management systems.
- Information recorded when you sign up for the internet WIFI service when you visit our malls and any usage details of WIFI including information about your device and internet connection, including your IP address, device ID, operating system, browser type and webpages visited.
- Information collected to contact you when you enter or renew a tenancy contract on behalf of the Organization you represent.
- Information recorded during any events, games or contests taking place in the mall.
- Medical and health information of accidents and injuries occurring in the mall as well as accident records and other relevant information.
- Information collected when you utilize any of our services available for visitors of the Malls such as porter service, delivery service, gift cards purchase, etc.
2.2 Other information we collect
There is other information we may collect that does not directly reveal your specific identity or does not directly relate to you as an individual. We may automatically collect the following information when you visit our website or use Emaar mobile applications or utilize our services:
- Your equipment, browsing actions and patterns collected automatically as you navigate through our websites.
- Usage details, time of requests, browser types, operating system, IP addresses and information collected through cookies, web beacons and other tracking technologies.
- Details of your visits to our website, including traffic data, location data, logs and other communication data and the resources that you access and use on the website.
The information we collect automatically is statistical data. It helps us to improve our Website and to deliver a better and more personalized service by enabling us to:
- Estimate our audience size and usage patterns.
- Store information about your preferences, allowing us to customize our Website according to your individual interests.
- Speed up your searches and recognize you when you return to our Website.
The technologies we use for this automatic data collection may include:
- Flash Cookies: Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies.
- Web Beacons: Pages of the Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs. pixel tags and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an e-mail and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
We use these cookies for the following purposes:
- To identify you when you visit our platforms and to help you navigate through our platforms;
- To help determine if you are logged into our platforms:
- To store information about your preferences and to personalize our platforms for you;
- To secure and protect your user account and our platforms; and
- To analyse the use and performance of our platforms.
We also use Bluetooth (BLE) Beacons, Wi-Fi, and similar technologies: These technologies that may communicate with your (mobile) device and identify its location if the device has Bluetooth and/or Wi-Fi enabled and is properly configured. We use location information to analyse the footfall of the mall’s visitors, movement of visitors through our mall to improve the shopping experience and mall operations. We do not link this information to a visitor or device, but instead measure general traffic patterns. All such data shall be anonymized during storage and retention.
2.3 Information we receive from others
We work closely with third parties and receive information about you from them as well. We also collect personal information from individuals who may refer you as a friend to our loyalty schemes or products or services. We ask these individuals to confirm that you are happy to hear from us.
3. What are the sources of your personal data?
The sources of your personal data collected (collectively referred as “Platforms” in this policy) may include without limitation the following:
- Emaar websites: These are websites we created for you that are operated by us, they include websites operated by Emaar under our own domains and web addresses (URLs) and our own micro-sites that are part of a third-party social media networks such as Facebook, Twitter, or Instagram.
- Emails, text messaging services, and other electronic messages: These are the electronic text-based interaction between you and Emaar.
- Emaar mobile applications: These are smartphone applications created for you and operated by Emaar or one of our partners.
- Emaar customer service: Any communication between you and our customer service center (e.g. phone, chatbot, email, etc.).
- Offline registration forms: These include printed registrations, surveys, or questionnaires Emaar collects via registration forms, contests, events, and various promotions.
- Advertising: You might interact with one of our or our partners’ advertisements on our websites and apps and we might receive and collect this information.
- Career Portal: These includes recruitment portal across Emaar.
- Data we create: Emaar may also create data about you, when you avail our services.
- Data from other sources: These include social media networks, market research agencies, Emaar promotional partners, public sources, and data received when we acquire other companies.
- CCTV cameras: Security footage (image and video) from CCTV cameras placed across the shopping Centre.
- Automatic Number Plate Registration: Vehicle registration number and details recorded through Automatic Number Plate Recognition (ANPR) systems at our Centre car parks.
- Emaar Loyalty Program: Once you register for our loyalty program, we would collect and process your personal information and transaction history.
- Emaar Public Wi-Fi: Any usage of the Emaar public WIFI network.
This policy does not apply to information collected:
- through any other means, including any other website operated by any third party; or
- by any third party, including through any application or content (including advertising) that may link to the Website.
4. Why do we collect and how we use your personal information?
We use personal information for several legitimate interests, including providing and improving our services, administering our relationship with you and our business.
4.1 To provide, develop and improve Emaar Services:
We use the personal information (such as device ID, IP address, web-pages visited, geo-location details, CCTV footage etc.,) we collect to perform essential business operation purposes pursuant to our legitimate business interests, for example to understand usage patterns (such as foot traffic) within our malls; and to develop, provide, improve, and personalize Emaar services. We do not link this information to a visitor, shopper or device, but instead measure general traffic patterns and other analytics to help us improve our customer experience and service offerings. All such data shall be anonymized during storage and retention.
4.2 To manage your membership of our loyalty programs – ‘U BY EMAAR’:
We encourage and invite you to join our loyalty program, so that you may benefit from exclusive offers, discounts, and promotions available to members. You may join our loyalty program by registering online on the ‘U BY EMAAR’ webpage – https://www.ubyemaar.com.
Once you register for our loyalty program, we would collect and process the following personal information: name, telephone number, email ID, ‘U BY EMAAR’ ID and transaction history. We would need to collect and use your personal information to fulfil our contractual obligations under the loyalty program.
As part of the loyalty program, we would also send our members information regarding special offers, discounts and promotions in pursuit of legitimate business interests. In the event you prefer not to receive such information, you may opt-out by following the instruction provided Section – “How to opt-out?”.
4.3 To respond to any queries made by you:
We would need to collect and use the following personal information: name, email address, phone number, nationality and details of your enquiry.
In certain cases, your enquiry may relate to a specific service request, for example: requesting a ‘shop and drop service’. For such requests, we need to use your personal information to help us respond to your request and to fulfil our contractual obligations under the requested service.
Additionally, when you call our customer service centre, we would maintain a record of the communications, including call recordings, in pursuit of our legitimate business interest to monitor and improve the quality of our guest support.
4.4 To provide you with information about services and latest offers of Emaar Malls Group:
It is in our legitimate business interests to send you information about Emaar’s services and latest offers. We use your personal information such as email ID and/ or contact number to share information relating to Emaar’s services and latest offers that may be of interest to you. In the event you prefer not to receive such information, you may opt-out by following the instruction provided Section – “How to opt-out?”.
4.5 To personalize the information, we send you:
We may combine the information we receive and collect about you to better understand your interests and preferences so that we can provide you with an experience that is tailored to those interests and preferences. For example, we may do this by notifying you of any events conducted in the mall, or sending you personalized offers, discounts or promotions by our mobile application, or email (where you have agreed to receive our emails), or advertising content that is relevant to your interests. In the event you prefer not to receive such information, you may opt out by following the instruction provided Section – “How to opt out?”.
4.6 To facilitate Advertisements:
4.7 To enable you to avail special offers and benefits from our business partners:
We have strong and longstanding partnerships with business partners across sectors including Travel, Entertainment, and Lifestyle. Our partnerships allow you to avail special benefits and offers from our business partners. For example, Emirates Skyward members can avail Skywards Miles when they shop (above a pre-determined value) at one of the outlets available within our malls.
To help you avail of these benefits, we would need to collect and share the following personal information: name, Partner issued Membership ID and transaction history, with our business partners. We would need to collect and process your personal information to fulfil our contractual obligations towards our business partners and to ensure you avail the best of benefits and offers.
4.8 To manage your Emaar Gift Card:
Emaar Gift Card is like a cash voucher that can be loaded only once with a set amount of funds on. It is accepted as a payment mechanism at outlets across Emaar, which means that the gift card can be used at multiple locations across the Emaar group. For customers availing the Emaar Gift Card, we collect and use personal data such as Name, Email, Contact Details, Date of Birth, Nationality, Payment Card details and transactions (carried out using the Emaar Gift Card). We collect and use your personal information to fulfil our contractual obligations towards you and to ensure you avail the best of benefits and offers.
4.9 To request your feedback, and to respond to complaints:
Your satisfaction is our utmost priority and we proactively take necessary steps to ensure you are well satisfied with our services.
To help us respond to your feedback or complaints, we would need to collect the following personal information: name, email ID, transaction details (such as service you availed at the mall) and your feedback/ complaints in the “We Care submission form”, through a survey conducted within our malls or after the completion of your call with our customer service team.
We collect and use your personal information in pursuit of our legitimate business interests to address your concerns and to take necessary steps towards continual improvement. In the event you prefer not to receive such information, you may opt out by following the instruction provided Section – “How to opt out?”.
4.10 To establish a working relationship with our Tenants and Business Partners:
We collect/ receive personal information about you through one of the following channels:
- When you send us an enquiry for Tenancy or if you were previously engaged under a Tenancy arrangement with us.
- When you participate in any of our sales, marketing and thought leadership events organized or hosted by Emaar;
- When our sales executive or business leaders visit events organized by external organizations (including the company you represent);
- We collect from our sales executives or business leaders who share a professional/ personal relationship with you; or
- We collect from publicly available information that you have shared on professional networking platforms such as LinkedIn.
We collect the following personal information: name, email ID, contact number, designation, and the company you represent. We use this information for the purposes, listed below, in pursuit of our legitimate business interests:
- To share information relating to Emaar services, and possible tenancy opportunities;
- To invite you to future events, that may be of interest to you and/ or the company you represent; and
- To establish a working relationship with the company you represent.
4.11 To enter into, renew or fulfil service contracts with our Tenants and Business Partners:
We collect and use personal information such as name, email ID, contact number and in certain cases passport/ government ID proof to facilitate the performance of the tenancy contract between Emaar and the Organization you represent. We may also collect personal information (such as Name, contact details, passport/ government ID etc.,) of the employees of your Organization that would be stationed within our malls to facilitate security pass clearance pursuant to our legitimate business interest and to fulfil our contractual obligations.
4.12 To facilitate email campaigns carried out by our sales and marketing departments:
As part of our email campaigns, we track whenever you receive, open, click a link, or download any attachments from an e-mail you receive from Emaar. We will carry out automated profiling of such information to evaluate your interest in our service offerings or promotions. This processing will enable us to identify and target potential guests or business partners, tailor our marketing and provide you with relevant and timely content based on your interests, in pursuit of our legitimate business interests. In the event you prefer not to receive such information, you may opt out by following the instruction provided Section – “How to opt out?”.
4.13 To comply with legal requirements and exercise or defend legal claims:
We may need to process and retain your personal information to comply with legal requirements to which we are subject (for example in relation to licensing, health and safety). 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 the relevant legal and regulatory obligations.
4.14 To process your payments and protect against fraudulent transactions:
We may need to process your personal information to keep your payments safe and secure and protect against fraudulent transactions. It is in our legitimate interests to process personal information to keep your payments secure and to prevent fraud. We may also require your personal information to send payment reminders and legal intimations in case of overdue payments. Processing personal information in this way may also be necessary to ensure compliance with the relevant legal and regulatory obligations.
4.15 To comply with any opt-out or do not disturb requests we receive from you:
We understand that you may not prefer for us to contact you with any offers, promotions or details of our products and services. In the event you opt-out, we may be required to maintain information such as name, email ID/contact number and the subscription(s) that you have opted out of to ensure compliance with your requests. Also, in the future, if you wish to hear from us, you may at any time, contact us to opt-in and we would happy to keep you posted about our latest offers, promotions and/ or details of our products and services.
4.16 To manage and administer any of our events and competitions which you enter:
We collect and use the personal data provided by you when you participate in any of the events/ competitions hosted within our malls. The information may include name, email ID, contact details and government ID proof/ passport details. We use the personal information in pursuant to our contractual obligations and to ensure we can successfully process any awards/ gifts/ offers that you may win in such events.
We may also collect and use personal data of event management representatives to plan and conduct events within our malls. We collect and use the personal information to maintain contact, co-ordinate support and to obtain necessary local clearance to manage and administer the event.
4.17 To maintain security within our malls and keep the public safe:
We may need to process your personal information obtained through any system operated for the security, safety and access management (CCTV, access rights system, Automatic Number Plate Recognition (ANPR)) when you visit our malls or any of its stores. Security footage may include access logs, image, video, audio, license plates, etc. from any of the security systems placed across our malls. We collect and process such information pursuant to our legitimate business interest to maintain security and ensure public safety and to ensure compliance with local laws and regulations.
4.18 To comply with health and safety obligations:
We may be required to process your medical information or any other health related information in the event of an accident or injury at our malls. It is our legitimate interest for the management of accidents and injuries occurring in our malls. This information would also be required for the improvement of the accident prevention system (including fire protection and prevention against foreseeable natural and technological risks). It could also possibly be required for legal purposes or to prepare for and defend against legal claims.
4.19 To manage vehicle parking:
We would be required to record license plates through Automatic Number Plate Recognition (ANPR) systems and other vehicle details as well as parking records where it is in operation at our malls car parking facilities. These would be required for the management of our parking system as well as to maintain security within it and fulfil our contractual obligations effectively.
5. How to opt out?
1. Email: You can click on the unsubscribe link provided in the email you receive from us.
2. SMS: you can follow the instruction provided in the messages you receive from us
3. Applications: You may use the “opt out” option provided within the Emaar Mall Group applications
4. Contact us: You may contact us using the details provided in Section – ‘How do you contact us?’.
6. Who might we share this information with?
- We may use carefully selected third parties to perform services on our behalf or to assist us with the provision of services to you. For example, we may engage cloud service providers, IT service providers and other third parties to provide concierge services, security services, brand promotions, marketing, advertising, communications, to personalize and optimize our service, to analyze and enhance data (including data about users’ interactions with our services), and to provide legal, accounting, insurance, audit and other professional services. While providing such services, these third parties may have access to your personal information.
- We may share your personal information with select business partners in sectors including travel, entertainment, lifestyle, and other industries to enable our guests to avail special offers. For example, our partnership with our airline partner enables our guests to earn miles for every purchase (exceeding a specific value) at our Emaar Mall outlets.
- Where required or permitted by law, personal information may be provided to others, such as regulators and law enforcement agencies.
- We may share to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by the Company about our Website users is among the assets transferred.
- We may share with government or regulatory request to comply with any court order, law or legal process
- We may share with other companies and organizations for the purposes of fraud protection and credit risk reduction if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers or others.
If you would like more information on protection measures and transfer mechanisms, please contact us using the details provided in Section – ‘How do you contact us?’.
7. How long do we keep information about you?
We will only keep your personal information for as long as is reasonably necessary taking into consideration our need to answer queries or resolve problems, any other purpose outlined above or to comply with legal requirements under applicable law(s). This means that we may retain your personal information for a reasonable period, for example, till the end of the leasing contract with the organization you represent, or after your query has been addressed, CCTV footage is held for a period of 30 days before being deleted unless legitimate access is required (for example by the police). In certain cases, we may retain your personal information for a longer period where extended retention periods are required by law or regulation and to establish, exercise or defend our legal rights. We will ensure that it is disposed in a secure manner when it’s no longer needed.
For more information on where and how long your personal information is stored, and for more information on your rights of erasure and portability, please contact us using the details provided in Section – ‘How do you contact us?’.
8. How secure is your information?
Your personal data security is an important concern to us. We provide the utmost care in secure transmission of your personal information from your computer, smartphone, and other electronic devices to our servers. We use industry security standards to safeguard the confidentiality of your information (e.g. firewalls, Transport Security Layer (“TLS”) etc.) and to make sure that your personal information is secure with us.
We have implemented and maintained appropriate technical and organizational security measures, policies and procedures to protect your personal information from the accidental loss, unauthorized access, use, alteration and disclosure. All information you provide to us is stored on our secure servers behind firewalls. All payment transactions are encrypted using TLS technology. Ex: Measures we take includes:
- Placing confidentiality requirements on our staff and service providers;
- Restriction of access to your personal information to employees and third parties strictly on a need to know basis, such as to respond to your enquiry or request;
- Destroying or anonymizing personal information if it is no longer needed for the purposes for which it was collected; and
- Using secure communication channels for transmitting personal data.
The safety and security of your information also depend on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.
9. What are your rights?
If you are subject to laws that provide you with such rights, you may have certain rights in relation to your personal information given below.
If you wish to access any of these rights, we may ask you for additional information to confirm your identity and for security purposes, before disclosing personal information to you. We reserve the right to charge a fee where permitted by law, for example, if your request is manifestly unfounded or excessive.
If you would like to access the below rights, you may contact us by completing a form on our website or by mailing us at firstname.lastname@example.org or sending us a communication to Data Privacy Office, PO Box 191741, Dubai, United Arab Emirates . We shall aim to comply with all requests within reasonable time in-line with applicable laws. We may not always be able to fully address your request, for example,
- if it would impact the confidentiality we owe to others, or
- if we are legally entitled to deal with the request in a different way. or
- if your request involves deletion of information that are required to comply with the legal requirements.
We will make every reasonable effort to honour your request in-line with applicable laws. In the event we require additional time due to the complexity of the request, we shall promptly inform you of the same.
The right to access
You have the right to obtain confirmation as to whether we process personal data about you, receive a copy of your personal data held by us, and obtain certain other information about how and why we process your personal data (like the information provided in this privacy statement).
The right to rectification
You have the right to request for your personal data to be amended or rectified where it is inaccurate (for example, if you change your name or address) and to have incomplete personal data completed.
The right to restrict processing of personal data
You have the right to restrict our processing of your personal data in the following cases:
Temporarily for a period when you have contested for the accuracy of the personal data;
Temporarily for a period when you have objected for the legitimate interest identified by us,
Your personal data have been unlawfully processed and you request the restriction of processing instead of deletion;
The personal data are no longer necessary in relation to the purposes for which they were collected and processed but the personal data are required by you to establish, exercise or defend legal claims;
We can continue to use your personal information following a request for restriction, where:
- we have your consent; or
- to establish, exercise or defend legal claims; or
- to protect the rights of another natural or legal person.
The right to erasure (also known as ‘the right to be forgotten’)
You have the right to obtain deletion of your personal data in the following cases:
- The personal data are no longer necessary in relation to the purposes for which they were collected and processed;
- Our lawful basis for processing is consent, you withdraw consent and we have no other lawful basis for the processing;
- Our lawful basis for processing is that the processing is necessary for a legitimate interest pursued by us, you object to our processing and we do not have overriding legitimate grounds;
- You object to our processing for direct marketing purposes;
- Your personal data have been unlawfully processed; and
- Your personal data must be erased to comply with a legal obligation under EEA to which we are subject.
We are not required to comply with your request to erase personal information if the processing of your personal information is necessary:
- For compliance with a legal obligation; or
- For the establishment, exercise or defence of legal claims.
The right to object to the processing of personal data
You have the right to object to our processing of your personal data in the following cases:
our lawful basis for processing is that the processing is necessary for a legitimate interest pursued by us; and our processing for direct marketing purposes.
The right to data portability
You have the right to receive your personal data provided to us and have the right to send the data to another organization (or ask us to do so if technically feasible) where our lawful basis for processing the personal data is consent or necessity for the performance of our contract with you and the processing is carried out by automated means.
The right to withdraw consent at any time (where processing is based on consent)
Where we process personal data based on consent, individuals have a right to withdraw consent at any time.
The right to lodge a complaint with a supervisory authority
If you are not content with how we manage your personal information, you can lodge a complaint with a 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 EEA. We sincerely hope that you will never need to, but if you do want to complain about our use of personal data, you can contact us in one of the ways mentioned in Section – ‘How do you contact us?’. We will look into and respond to any complaints we receive.
10. Updates on Policy
This policy may change from time to time. Your continued use of our platforms after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.
11. How do you contact us?
In case of any queries related to this policy, you can contact our Data Privacy Office in one of the following ways.