Last updated: 1 November 2024

 

References to "our", "us" or "we" within this policy are to Jumeirah International LLC.

This Privacy Policy governs the collection and use of personal information by Jumeirah. For more information about Jumeirah please see: www.jumeirah.com.

We are committed to protecting and respecting your privacy.  This Privacy Policy explains the types of personal information we collect, how we use that personal information, who we share it with, transfers to other countries, how we protect that information, and your legal rights in relation to your personal information. We are committed to abiding by this Privacy 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 or using our services or facilities, you confirm that you have read this Privacy Policy in its entirety.  Please do not use Jumeirah’s website and services if you do not accept it.  This does not mean we are asking you for a consent (under data protection law) for everything that is described in this Privacy Policy.  If we need your consent we will ask for that separately.  If you do not accept the practices described in this Privacy Policy, you should not use our website or our services or facilities.

 

In some parts of this Privacy Policy we refer to the Jumeirah group of companies.  Here is a list of subsidiaries of Jumeirah’s parent company, Dubai Holding co:

  • TECOM Group an industry-specialized developer and operator of Dubai’s leading business communities
  • Dubai Properties one of the largest fully integrated real estate companies in Dubai
  • Arab Media Group one of the region’s leading media and entertainment organizations
  • Dubai Asset Management manages a diverse portfolio of resident focus communities for rent
  • Dubai Retail manages an extensive range of retail assets across destinations and communities

 

If you would like a list of all companies in the group please ask and we will provide it - see ‘Contacting us’ below.

 

Click on one of the links below to jump to a specific section:

 

Who we are

For the purpose of applicable data protection laws, the data controller is Jumeirah International LLC of PO Box 73137, Dubai, United Arab Emirates.

If you use our facilities and services, the entity which manages the relevant facility or service ("Country Manager") will also be a data controller in respect of your personal information. A list of such facilities and services and the respective Country Managers can be found here.

We have a data protection officer (DPO) and you can contact our DPO.  See ‘Contacting Us’ below for how to do this.

 

Information covered by this Privacy Policy

This Privacy Policy covers all personal information collected and used by Jumeirah.  In this Privacy Policy, "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 will generally include your name, date of birth, nationality, gender, postal address, email address, phone number, credit card number, details of the preferences you express to us during your stay at one of our hotels (e.g. room type) dietary requirements, and technical information from the devices you use to access our website (further details below).  In addition, we will ask you for a copy of your passport or other form of identification when you arrive at our hotels.

In this Privacy Policy we refer to ‘processing’ of your personal information.  This is a legal term.  We want to make sure you can understand what it means.  Process or processing includes everything we do with your personal information from its collection, right through to its destruction or deletion when we no longer need it.  This includes for instance collecting it (from you), obtaining it (from other organisations), using, sharing, storing, retaining, deleting, destroying, transferring it to other countries.

‘Legitimate interests’ is mentioned in this Privacy Policy because data protection laws allow the processing of personal information where the purpose is legitimate and is not outweighed by your interests, fundamental rights and freedoms.  Under data protection laws this is called the ‘legitimate interests’ legal basis for justifying the use of personal information.

 

Important information about marketing

When you are asked to give permissions for marketing you will be directed to this section of our Privacy Policy by a link.  Here is the full detail which you must read before you decide whether you wish to subscribe:

 

Part 1:  This is what you must read before you decide whether to tick the box about marketing from us:

We would like to provide you with information about Jumeirah’s products and services, including offers and promotional materials. You can opt-out of receiving further marketing at any time by using the unsubscribe link in each email.

 

Part 2:  This is what you must read before you decide whether to tick the box about marketing from Jumeirah’s parent company, Dubai Holding co., on its products and services or those of or its subsidiaries named here:

  • TECOM Group an industry-specialized developer and operator of Dubai’s leading business communities
  • Dubai Properties one of the largest fully integrated real estate companies in Dubai
  • Arab Media Group one of the region’s leading media and entertainment organizations
  • Dubai Asset Management manages a diverse portfolio of resident focus communities for rent
  • Dubai Retail manages an extensive range of retail assets across destinations and communities

You can opt out of receiving further marketing at any time by using the unsubscribe link in each email.

Please read Dubai Holding’s privacy notice for further information on how it processes your personal data.

 

What information do we collect from you?

We (Jumeirah International LLC) will be collecting personal information at every touch point or guest interaction.  We will generally collect information about you from the different sources as detailed below (some of these will not be relevant to you specifically).

 

Information you give us

You will need to provide information to us in relation to your reservation, stay or visit to a Jumeirah facility.   Otherwise we will not be able to service you properly when you are our guest.

You can also choose to 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 (e.g. in relation to guest registration cards, spa and fitness club membership applications, loyalty enrollment forms, or online booking forms).

The information you give us will generally include your name, postal address, email address, date of birth, payment card information, landline and/or mobile telephone number, preferences (e.g. room type), general feedback on your stay, dietary requirements, allergies, as well as other personal information.  In addition, please refer to the list of personal information above (including your passport or other ID).

 

Information we collect about you

We will collect information about your use of our facilities and services, your preferences in this regard, and details of purchases and bookings you make with us or which are made for you.

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

  • 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;
  • information about your visit, including the full Uniform Resource Locators (URL) clickstreams to, on and from our websites;
  • length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouseovers) and methods used to browse away from the page.

IP addresses and other online identifiers (i.e. those listed above) are your personal information.  This means that you have the same rights under data protection laws in relation to these as you do with other personal information.  For information about rights see below.

 

Information we receive and collect from other sources:

We will (except if you are unknown to Jumeirah group) receive information about you from other websites operated by the Jumeirah group or from the other services that we provide.  We also work closely with third parties such as airlines, travel agents, tour operators and third party agents and will (except if you are unknown to them) receive information about you from them.  We will (if permitted by data protection laws) also collect information about you from publicly available sources, including publicly available content on social media (consistent with your settings on such services) and (if you are a business traveler) publicly available directories such as LinkedIn.  We will also collect information about you in relation to your booking from your employer or the business for which you work (if you are travelling on business).

Other companies in the Jumeirah group will share your personal information with us (if permitted by data protection laws).  For example, if you contact a different Jumeirah company from us to stop all marketing from all parts of Jumeirah – that company will need to tell us so that we can respect your preferences.

 

Cookies Policy

Please read our separate Jumeirah Cookies Policy. or our JClub Cookies Policy.

 

How do we use your personal information?

Data protection laws require us to explain the legal basis to justify our processing of your personal information for clearly explained purposes. For some processing (though not where we rely on a consent) more than one legal basis will be relevant.

In this table we refer to ‘Profiling’.  This means any form of automated processing of your personal information to evaluate certain personal aspects about you, such as to analyse or predict aspects concerning your economic situation, personal preferences, interests, reliability, behaviour, location or movements.   There are two types of Profiling.  One type has a legal or other significant effect on you (eg. where different prices are given to different people) and we do not do this type of Profiling activity at this time.  The other type of Profiling does not have a legal or other significant effect on you.  This is the type we do.  This helps us to tailor our marketing to you.

 

We will use your personal data when:

We process the following personal data for these purposes:

What is the legal basis for us processing your information in this way?

Recruitment and recruitment planning

Evaluating your application for a job with us and considering your suitability for the relevant role

As appropriate this will include: Place of Birth, Date of Birth, Compensation and Benefits, Telephone Number, Name, Email Address, Passport, National ID, Nationality, Address, Curriculum Vitae / Application Information, Visa Information (Including Sponsor / Cancellation Information), Gender, Employment Information (Including Performance

We have a legitimate interest to process this personal data for recruitment purposes.

Obtaining, considering and verifying your employment references and employment history, as well as otherwise confirming your identity. We carry out a reference check by emailing the references stated in a candidate’s application or as provided to us later in the process.

We have a legitimate interest to process this personal data for recruitment purposes.

Reviewing and confirming your legal right to work in a particular country or geographic region

This processing is for compliance with our legal obligations.

Conducting verification and vetting, including criminal background checks where required by law

This processing is for compliance with our legal obligations.

Where we process special categories of personal data as part of these checks, we do so only because it is necessary to meet obligations and rights in the field of employment and social security and social protection law.

We also undertake security clearance checks for all successful candidates who will beemployed in UAE by Jumeirah. For employment contracts with Jumeirah outside of UAE we undertake security clearance checks where the role isaGeneral Manager,Director of Finance orwith the purpose to safeguard our guests and colleagues. This is in addition to the background checks stated above

We have a legitimate interest to process this personal data for recruitment purposes.

 

Conducting background checks, testing, verification and vetting which are not required by law but needed by us to assess your suitability for the role applied

For those candidates applying for senior roles, and prior to making a formal offer, we also undertake background checks. These checks may include engaging a third-party to undertake checks against a candidate’s criminal history, financial history and any gaps in their CV. We also carry out a reference check by emailing the references stated in a candidate’s application

It is in our legitimate interests to conduct such background checks.

It is in our legitimate interests to process personal data for such purposes.

We undertake psychometric and ability tests (including assessment centres, technical or trade evaluations, ability testing in regard to verbal, numerical and logical reasoning that may be required) to align candidates against our core competencies and technical requirements of a job

Name, Email Address, Report of Performance in Tests

It is in our legitimate interests to process personal data for such purposes.

We use artificial intelligence and machine learning to conduct profiling activities. This helps us make more informed decisions during the recruitment process.

Name, Address and Date of Birth, Video Recording, Curriculum Vitae / Application Information, Tone of Voice, Micro Facial Expressions and Body Language

It is in our legitimate interests to conduct such profiling using such technologies

Making an initial offer of employment to you and entering a contract of employment with you. This includes making reasonable adjustments to enable you to carry out a role offered to you. Such reasonable adjustments will be to your duties, responsibilities, and physical work location as appropriate.

As appropriate this will include: Religion, Compensation and Benefits, Employment History, Medical Information Forms and Notes, Bank Details, Health, Name, Reference Information, Photograph, Marital Status, Family, Passport, National ID, Address, Personal Certificates (e.g. Birth, Marriage), Qualifications / Grades, Visa Information (Including Sponsor / Cancellation Information), Title, Emergency Contact Details, Beneficiaries, Employment Information (Including Performance)

Using your personal data in this way will also be necessary for us to perform our contract with you

Where we process special categories of personal data we do so only because it is necessary to meet obligations and rights in the field of employment and social security and social protection law

General candidate management and administration

Communicating with you and providing you with information in connection with your application or engagement with us from time to time

Telephone Number, Name, Email Address, Interview Responses / Notes, Curriculum Vitae / Application Information

It is in our legitimate interests to communicate with our candidates during the application process

Determining whether any adjustments required by law are necessary during the interview process to enable you to carry out a role offered to you (which may include disabilities or dietary requirements)

Such adjustments specifically concern personal data relating to: Health

This processing is for compliance with our legal obligations

Where we process special categories of personal data we do so because it is necessary to meet obligations and rights in the field of employment and social security and social protection law

Determining whether any adjustments not required by law are necessary during the interview process to enable you to carry out a role offered to you (which may include disabilities or dietary requirements)

It is in our legitimate interests to process personal data for this purpose

As this relates to special categories of personal data we do so because we have obtained your explicit consent

Keeping your candidate information and resume on file to consider your suitability for existing and future vacancies

Employment History, Telephone Number, Reference Information, Email Address, Address, Gender, Curriculum Vitae / Application Information

We would only do this with your consent

Responding to feedback requests from you

Telephone Number, Name, Email Address, Interview Responses / Notes

It is in our legitimate interests, as well as the interests of our candidates and recruiters, to provide appropriate feedback on the application process

Developing, operating and collecting feedback on recruitment activities and employee selection processes

Name, Email Address

We have a legitimate interest to process this personal data for recruitment purposes

IT Security

Identifying, investigating, and mitigating incidents, such as where a personal data breach occurs.

As appropriate this will include: Email Address, Signature, Employment History, Telephone Number, Name, Reference Information, Email Address, Family, Passport, Address, Qualifications / Grades, Emergency Contact Details, Beneficiaries, Dietary Requirements, Date of Birth, Curriculum Vitae / Application Information, Gender

It is in our legitimate interests to ensure the safety and security Jumeirahs assets, systems, and platforms

Where we process special categories of personal data we do so only for the establishment, exercise or defence of legal claims

Legal and regulatory compliance and responsibilities

Managing and administering our equal opportunities reporting in line with our legal obligations

As necessary this will include: Place of Birth, Date of Birth, Religion, Signature, Compensation and Benefits, Employment History, Telephone Number, Bank Details, Health, Name, Reference Information, Marital Status, Email Address, Family, Passport, National ID, Nationality, Address, Curriculum Vitae / Application Information, Languages Spoken, Qualifications / Grades, Age, Visa Information (Including Sponsor / Cancellation Information), Gender, Travel History, Beneficiaries

This processing is for compliance with legal obligations

Where we process special categories of personal data we do so where this is in the substantial public interest

Comply with our legal requirements and to the extent necessary to exercise or defend legal claims should they arise.

Medical Information Forms and Notes, Name, National ID, Address, Age

It is in our legitimate interests to process personal data for this purpose

Where we process special categories of personal data we do so only for the establishment, exercise or defence of legal claims

Establishing and potentially contacting an emergency contact for individuals in case of emergency.

Name, Emergency Contacts’ Name, Email Address, Telephone Number, Address, Health

It is in our legitimate interests to process personal data for this purpose

It is necessary to protect the vital interests of a candidate (or those of someone else)

Responding to binding requests or search warrants or orders from courts, governmental, other regulatory and/or enforcement bodies and authorities

As appropriate this will include: Place of Birth, Date of Birth, Religion, Compensation and Benefits, Telephone Number, Photograph, Marital Status, Passport, National ID, Nationality, Qualifications / Grades, Visa Information (Including Sponsor / Cancellation Information), Gender, Title, Employment Information (Including Performance)

Processing personal data in this way is necessary to ensure compliance with Jumeirah’s legal obligations

Depending upon the nature of the request, we process special categories of personal data either in the substantial public interest or for the establishment, exercise or defence of legal claims

Responding to non-binding requests or search warrants or orders from courts, governmental, other regulatory and/or enforcement bodies and authorities

It is in our legitimate interests to process personal data for such purposes.

Day-to-day business operations / other purposes

Implementing, adapting and enhancing systems and processes to develop or improve our business and/or make the application process easier or more enjoyable

Name, Email Address, Curriculum Vitae / Application Information

It is in our legitimate interests to process personal data for such purposes

 

Supporting the sale, transfer or merging of part or all of our business or assets, or in connection with the acquisition of or by another business

In the scenario where part of our business is sold or transferred to another business, we may need to transfer any and all personal data listed in this table to that new business, or provide certain personal data (on a confidential basis) prior to a sale to support the transaction

It is in our legitimate interests to process personal data for the purposes of sale of part or all of our business or assets

To the extent this includes sensitive personal data we will only transfer this with your explicit consent

We process your personal data to improve your user experience when you are on our website. This includes ‘remembering you’ when you sign in each time (if you select that option). This also includes seeing the ways in which you navigate our website and seeing which pages are of interest to you

IP Address, Information about your visit, including the full Uniform Resource Locators (URL) clickstreams to, on and from our websites, Length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouseovers), methods used to browse away from the page

It is in our legitimate interests to process personal data for such purposes

For management and audit of our business operations including accounting

As appropriate this will include: Compensation and Benefits, Telephone Number, Name, Email Address, Languages Spoken, Visa Information (Including Sponsor / Cancellation Information), Gender, Title, Employment Information (Including Performance)

It is in our legitimate interests to process personal data for such purposes

 

To deal with complaints or questions from you

Telephone Number, Name, Email Address, Interview Responses / Notes

It is in our legitimate interests to process personal data for such purposes
                                                  

Who do we share your personal information with?

  • Jumeirah group of companies
    We will share your personal information sometimes with other members of the Jumeirah group of companies, including subsidiaries and holding companies, in order to enable you to request our services, to process your payments, understand your preferences, send you information about products and services that may be of interest to you and conduct the other activities described in this Privacy Policy. Some of those group companies will be located outside the European Economic Area ("EEA"), in which case the section "Where we store your data" below will apply.
    Our group companies can only send you their own marketing communications with your consent. In addition, please see ‘Profiling from Dubai Holding co. and its marketing communications’ below.

 

  • Our service providers
    We use other companies, agents or contractors ("Service Providers") to perform services on our behalf or to assist us with the provision of services to you. For example, we will usually engage Service Providers to provide concierge services, housekeeping and laundry services, marketing, advertising, communications, services in connection with your Jumeirah One and/or isme by Jumeirah membership, to provide IT services including suppliers of website hosting services, to personalise and optimise our service, to analyse and enhance data (including data about users' interactions with our services), and to provide legal, accounting, insurance, audit and other professional services, to host personal information in data storage facilities. In the course of providing such services, these Service Providers will usually have access to your personal information. However, these Service Providers are contractually bound only to use personal information to perform the services that we hire them to provide.  We will always use our best efforts to ensure that all the Service Providers we work with will keep your personal information secure.
    Our legal basis for sharing your personal information with our Service Providers is legitimate interests.  It is in our legitimate interests to engage these third parties to help us to run our business.

 

  • Our partners
    We will (where data protection law permits this) share your personal information with our key partners, which include certain airlines and financial partners. For example, our airline Frequent Flyer Programmes enables our guests to earn miles for every stay, as well as benefit from exclusive special offers. Jumeirah also has relationships with other companies including financial and luxury brands, whereby our customers can also benefit from exclusive experiences with our partnerships. A list of such key partners can be found online at http://www.jumeirah.com/en/jumeirah-group/about-jumeirah-group/strategic-global-partnerships/.  We will always use our best efforts to ensure that all partners we work with will keep your personal information secure.
    Our legal basis for sharing your personal information with our key partners is legitimate interests (the legitimate interests of those partners and of our own) in enabling the Frequent Flyer Programmes and the other experiences mentioned above to operate and for you to enjoy these (if you are signed up for them).

 

  • Third parties permitted by law
    In certain circumstances, we will be required to disclose or share your personal information in order to comply with a legal or regulatory obligation (for example, we could be required to disclose personal information to the police, counter-terrorist government authorities, or to judicial or administrative authorities).
    We will also disclose your personal information to third parties in order to enforce our terms and conditions or other agreements, or to protect the rights, property or safety of the Jumeirah group or the public, where that is necessary and where data protection laws permit this.
    Our legal basis for sharing your personal information with these third parties will be our legitimate interests (in complying with their requests for ourselves and Jumeirah group) or compliance with the Jumeirah group's legal obligations.

 

  • Third parties connected with business transfers
    We will sometimes transfer your personal information to third parties in connection with a reorganisation, restructuring, merger, acquisition or transfer of assets, provided that the receiving party agrees to treat your personal information in a manner consistent with this Privacy Policy.
    Our legal basis for sharing your personal information with these third parties will be our legitimate interests in being able to restructure and manage the Jumeirah businesses in this way.

 

  • Our legal counsel and other professional advisers
    We will sometimes share your personal information with firms and companies who provide legal, tax, accountancy and audit related services to us.
    Our legal basis for sharing your personal information with these third parties will be our legitimate interests in being able to properly manage the Jumeirah businesses and to seek professional advice in relation to those businesses.  We are not the data controller of what these professional services firms and companies do with your personal information.  They are data controllers.  They are subject to strict professional services regulatory regimes and confidentiality requirements.

 

Profiling by Dubai Holding co. and its marketing communications

We are part of the Dubai Holding group and Dubai Holding co. is our parent company.  Please see above for what ‘Profiling’ means.  Where permitted under data protection laws, we will share your personal information with Dubai Holding co. and it will in turn share it with other companies in the Dubai Holding group.  Dubai Holding co. and those other companies will do Profiling with your personal information about your bookings with us and how you use our website, in order to decide whether to up-sell to you.  For example, if they think you might be interested in purchasing real estate based on your nationality, where you live, how frequently you stay in Jumeirah hotels and what your spend is when you are there, they might look to up-sell to you about Jumeirah real estate.   Alternatively, they might wish to invite you to Jumeriah or Dubai Holding co. events or make certain offers to you which are not available to all Jumeirah customers (on the basis they wouldn’t be appealing or relevant to all customers).

Usually when they do this Profiling they will use a pseudonym instead of data which identifies you.  That pseudonym is still your personal information but for security reasons it has been masked so that during Profiling you cannot be identified.  Then when the outcome of the Profiling is known – the pseudonym will be linked back to you as an individual – and they will check whether they can lawfully send their marketing to you to up-sell based on what they have learnt about you from the Profiling.

Marketing from Dubai Holding co. and other companies in the Dubai Holding group who you do not have a customer relationship with already will only happen if you consent to this.  This is the lawful basis for it under data protection laws.  Since you are our customer, not theirs, they cannot send their direct marketing to you based on legitimate interests.

Dubai Holding co. (and these other companies) will be data controller for the use of your personal information described above.  Their contact details will be within their marketing communications.  If you wish to unsubscribe from their own marketing please use the unsubscribe link in their marketing messages.

 

Where we store your personal information/transfers

Some countries outside the EEA do have adequate protection for personal information by law.  We process your personal information in Dubai.  When you provide your personal information to us through this website there will necessarily be processing by us in Dubai, i.e. outside the EEA.  Your personal information is protected when we do this processing because we are subject to UK and European Union data protection laws.  Separately, when a Country Manager from inside the EEA sends personal information to us (Jumeirah International LLC) in Dubai that will be a transfer to outside the EEA.  In addition, if we transfer your personal information to someone else who is located in one or more countries or territories outside the EEA (for instance, to our service providers located in the UAE, to the US, or to anywhere where we have a Jumeirah hotel or residence outside the EEA if you are staying there), that will be a transfer outside the EEA.

Where this is required by data protection laws, we will make sure that suitable safeguards are in place for transfers.  Safeguards include EU standard contractual clauses (or equivalent measures) imposed on the recipients of your personal information which require the recipient to protect your personal information to the standard required in the UK/the European Union/the European Economic Area.  For more information about EU standard contractual clauses (or equivalent measures) and how to obtain a copy of them or to find out where they have been made available you can contact us – see ‘Contacting Us’ below.  Another type of safeguard is where the recipient of personal information is signed up to ‘international frameworks’ intended to enable secure data sharing and where the framework is the means of protection for the personal information.  As an example - the US Privacy Shield framework.

 

Monitoring (including recordings) of emails and telephone calls

For our legitimate interests of ensuring the highest level of quality control and the best possible service for our guests we do record telephone calls and we will read emails coming in to our guest services teams.  We do this to check that our guests are being serviced properly and in a timely manner.  We do this to have a record of what we have discussed with you and actions agreed with you, and for quality control and staff training purposes.  This involves processing of your personal information because your name and other identifiers will be mentioned on those calls/in those emails.

 

CCTV

For our legitimate interests of ensuring the safety and security of our guests and our staff we do use CCTV in the lobbies of our hotels, in all entrances, and in public areas such as our restaurants and lounges.  CCTV signage will be in place where that is required by local laws or regulations.

 

Security of personal information

All information you provide to us via our website is stored on our secure servers.  Any payment transactions carried out via our website will be encrypted using Transport Layer Security (TLS) technology.

Jumeirah has taken steps to safeguard the integrity of its communications and computing infrastructure, including by 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 information to these websites.

 

Your rights

You have the following rights with respect to the personal information that we hold about you.  They are relevant to us (Jumeirah International LLC) and to our relationship with individuals using our website and our processing of those individuals’ personal information because we are required to comply with the General Data Protection Regulation.   

Please also note that these rights are not engaged in all circumstances.  Some rights are only engaged (for example) where processing is based on your consent or on legitimate interests.  If you send us your rights request, we will respond and explain whether or not rights are engaged in your own case.

 

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 the contact details set out below. If possible, you should specify the type of information you would like to see – this will help us to ensure that our disclosure is in line with what you require.  Our file of your information will usually be made available to you within 30 days of when we receive your request, although occasionally we may be able to extent this period (if that is relevant we will contact you to explain why).  Occasionally we not be able to give you access to some of 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 data privacy rights 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 before providing you with access to your personal information.   If this charge is relevant we will contact you to explain why.  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 rights to have your information corrected or deleted

You may challenge the accuracy or completeness of your personal information and have it corrected or completed, as applicable.  If you have an account with us, you can sign into that account to update your personal information.  If you have problems updating the information on your account or if you would like us to delete your information, please email your request to the address set out below and we will action it as soon as possible.

Your right to have your personal information deleted is subject to certain conditions. We may not be in a position to erase your personal information, if for example:

  • We are unable to verify your identity;
  • We need it to comply with a legal obligation;
  • We need it to exercise or defend legal claims;
  • We need it to exercise freedom of expression and information;
  • We need it to carry out a task in the “public interest”; or
  • We need it to archive personal information in the public interest, or for scientific, historical, or statistical research purposes if those purposes would be seriously impaired by the erasure of the personal information.

 

Your right to object to us processing your personal information

You have the right to object to us processing your personal information where we have explained 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), including (but not only) the Profiling we undertake to send you personalised offers, product recommendations and similar content.  If you do this, we will need to show either a compelling reason why our processing should continue, which overrides your interests, rights and freedoms or that the processing is necessary for us to establish, exercise or defend a legal claim (or in some circumstances we may obtain a consent from you to continue our processing).

 

Your rights in relation to automated individual decision-making including Profiling

You 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 have the right to obtain human intervention from our side.  We do not do this type of Profiling activity at this time.

 

Rights in relation to direct marketing

You have the right to ask us to stop processing your personal information for direct marketing purposes including (but not only) any Profiling we undertake for the purposes of direct marketing.  We will in any case only send you marketing communications if you have previously consented to this or if we can do this based on legitimate interests (see the table above for more details).  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.  Alternatively contact us – see ‘Contacting Us’ below.

Please note that, if you have consented to receive offers from our partners, our partners are responsible for taking account of your rights, including your right to unsubscribe from receiving offers from them.  Their contact details should be included in their own communications to you / in their own privacy policies.

 

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.

If you exercise this right, please where possible specify the type of information you would like to receive (and where we should send it) so that we can ensure that our disclosure is in line with what you require.  This right only applies if the processing is based on your consent or on our contract with you and when the processing is carried out by automated means (i.e. not within paper records). It covers only the personal information that has been provided to us by you.

 

Your right to make a complaint

You have the right to lodge a complaint with your local data protection authority in the European Economic Area (EEA) if you believe that we have not complied with applicable data protection laws. If you are based outside of the EEA there may be other applicable supervisory authorities/regulators in your country to which you have the right to complain.

The local data protection authority will differ depending on the country you are in. Please contact privacyoffice@jumeirah.com if you require assistance in identifying your relevant data protection authority.

 

For processing that is based on your consent, you have the right to withdraw that consent at any time.  You can do this by contacting us using the details below.  The consequence would be that we cannot send you some marketing communications (in cases where we rely on consent for those instead of relying on our legitimate interests – see the table above for more information).

If you do decide to withdraw your consent we will stop processing your personal information for that purpose, unless there is another lawful basis we need to rely on – in which case, we will let you know. Your withdrawal of your consent won’t impact any of our processing up to that point.

We will not send you our Newsletter if you withdraw the consent for that, unless you decide to re-subscribe.   

 

Contacting us

If you want to exercise any of the rights set out above, 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 request a copy of the personal information we hold about you, please contact us privacyoffice@jumeirah.com or by writing to us at:

  • Jumeirah Privacy Office
    PO Box 73137
    Dubai
    United Arab Emirates

Please include your reply address when you write to us.

We have a data protection officer (DPO) and you can contact our DPO in this way.

 

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 (this means obligations under the contract we have with you or with the business/your employer who made the booking for you) 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 or where we need to retain it for the period during which claims can be brought under the contract).

Jumeriah group companies in other countries who are data controllers (independent from us) will maintain a local copy of your personal information when that is required by applicable laws or regulations.

 

Children

We do not target our website at children ie. individuals under 18 years of age.  It is intended as a ‘read only’ website for children who visit it under parent/guardian supervision.  For instance, children are welcome to look at the photographs on our website and the descriptions of our services with parent/guardian supervision.  We do not wish to hold any personal information about children.  If you are a child who is reading this Privacy Policy, you must not sign up for our Newsletter or submit any personal information about yourself to us.

 

Data anonymisation and use of aggregated information

Your personal information will sometimes be converted into statistical or aggregated data which cannot be used to re-identify you.  It may then be used to produce statistical research and reports. This aggregated data may be shared by us with other companies in the Jumeirah group of companies.

 

Changes to this Privacy Policy

We will update this Privacy Policy if we need to do that in response to changing legal, regulatory or operational requirements. We will notify you of any such changes (including when they will take effect) if we are required to do so by data protection laws. Your continued use of our website and / or services after any such updates have been brought to your attention (for example by a banner on our website to say ‘we have updated our Privacy Policy – click here’) will be taken by us to mean that you have read the revised Privacy Policy.  Please do not use Jumeirah’s website and services if you do not accept the changes.  This does not mean we are asking you for a consent (under data protection law) to the changes.  If we need any consents we will ask for those separately.