Privacy Policy

Landmark Retail Investment Co. LLC, referred to herein as “LRIL”,  "we", "our" or "us") is a limited liability company incorporated in the United Arab Emirates and is a part of Landmark Group which, along with its affiliates and group companies, is a large retail group operating in the Middle East, Africa, India, and Southeast Asia with a diverse portfolio of retail businesses, shopping centres and hospitality brands across several countries (the “Landmark Group Entities”).

This Privacy Policy (the "Privacy Policy") discloses the privacy practices for LRIL and Landmark Group Entities’ websites, related sub-domains, sites, applications, services and tools, or any successor site (jointly or severally referred as "Participating Website/s", as the context so requires). It describes the ways in which we collect, store, use and protect the Personal Data.

PLEASE READ THIS PRIVACY POLICY CAREFULLY. BY ACCESSING OR USING OUR PARTICIPATING WEBSITE/S, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTAND, AND AGREE TO BE BOUND BY ALL THE TERMS OF THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THE TERMS AND CONDITIONS SET FORTH IN THIS PRIVACY POLICY, PLEASE REFRAIN FROM SHARING PERSONAL INFORMATION/DATA WITH US.

1. WHAT PERSONAL DATA WE COLLECT ABOUT YOU
   1. The Personal Data we collect, or may already have in our records, about you may be broadly described in following categories:
      1. Name including (username)
      2. Contact Information (Phone Number, Mobile Number, Email Address)
      3. Diversity (Nationality, Gender, Age)
      4. Location and address (Area, City, Region, Delivery Address)
      5. CCTV footage, photographs, biometrics, fingerprints, face recognition or any other security related measures
      6. Loyalty Program ID (Shukran ID)
      7. Technical Details including but not limited to Device Details, IP Address, Digital Device Name, make, model, operating system, browser type, mobile device identifier, cookies and similar technologies such as tags, pixels and/or SDK's.
      8. Financial information such as credit history, payment details, etc.
      9. Your purchases, interests, preferences, or other types of procured or publicly available information
      10. Information about your online browsing behaviour on our websites, mobile apps and public networks and information about when you click on one of our adverts (including those shown on other organisations’ websites)
      11. Transaction information such as the date of the transaction, total amount, transaction history and preferences and related details. In addition to your reviews, feedback and opinions about our products, and services
   2. This information helps us to better understand our users, improve the layout and functionality of the Participating Website/s usage habits, frequency of visits or characteristics of our customer base, and to serve any other business purposes.


2. FOR WHAT PURPOSES DO WE COLLECT YOUR PERSONAL DATA?

   We collect your Personal Data

   • to ship and deliver products and services;
   • to process your orders and refunds;
   • for billing and processing of payment, any purchases or other data linked to your use of services;
   • to operate, evaluate and improve our business and Participating Website/s;
   • to communicate with you (including to respond to your requests, questions, feedback, social media comments, claims or disputes);
   • to invite you to take part in and manage customer surveys, questionnaires and other market research activities carried out by us and/or by other organisations on our behalf;
   • to customize and improve our services;
   • to provide you with information about the products;
   • to develop/offer you new products and services;
   • for market research and analysis purposes;
   • for sending marketing communications and publications via SMS, email, push or any other channel about promotions, services, products and facilities offered by us. As part of this, online advertising may be displayed on our Participating Website/s including those of third parties. We may also measure the effectiveness of our marketing communications and those of our suppliers and partners.
   • to manage promotions and competitions you take part in, including those we run with our suppliers and partners;
   • to provide customer support;
   • to provide you with privileges and benefits, offers (including for vouchers, gifts, etc., and/or services), personalized services and recommendations and improve your experience on our Participating Website/s based on your profile;
   • to enhance your shopping experience and bring you access to membership programs, rewards and offers across our channels, Participating Website’s;
   • in connection with loyalty programs owned and operated by us or by other Landmark Group Entities;
   • to collaborate with our business partners, contractors, service providers to provide us services which include but are not limited to enhancing your experience; and 
   • to deliver online advertising that we believe is most relevant to you on our Participating Website/s and other organisations’ websites.


3. HOW WE COLLECT YOUR PERSONAL DATA

   We collect your Personal Data when you register online, update your account, log-in, place an order, communicate with our customer service representatives, interact with our staff/representatives, shop online, request a catalogue, opt-in to receive our marketing communications, participate in a contest, promotion or survey or join our social networking sites. We may also collect Data from you in our stores or through our catalogues or other marketing material.

4. SHARING YOUR PERSONAL DATA 

   We will not sell your Personal Data to third parties. We may, however, share selected Personal Data within Landmark Group Entities and with third parties (“Processors”) such as

   1. our franchisors;
   2. delivery companies and service providers for purposes including but not limited to
      • storage and analysis;
      • protecting and securing our systems;
      • providing search results and links;
      • providing customer service & credit analysis;
      • profiling, user analysis, software services and payment processing; and
      • providing warehousing service, processing your payment and managing your order including delivery and returns;
   3. retail, security, analytics and marketing partners;
   4. supplier of products and services;
   5. purchasers and their advisors following a sale of all or part of our business, so that they can continue to provide services to you
   6. third party databases to which Landmark Group and/or one of our brands subscribes;
   7. government bodies or other authorities if necessary to comply with regulations or law or to assist with law enforcement, or to protect our property and other rights;
   8. agencies who help us collate statistics about site traffic, sales, demographics and other commercial information to enable us to tailor the services we provide to you and other customers;
   9. advertising and media agencies – we partner with media agencies that run advertising campaigns. While we do not share your Personal Data directly with these agencies, we may securely share limited data with these advertising platforms to enable targeted advertising across our Participating Website/s and external platforms;
   10. in certain cases to Sub-processors through Processors; and
   11. other organisations in the following circumstances:
       • if any applicable law or public authority states we must share the Personal Data;
       • if we need to share Personal Data in order to establish, exercise or defend our legal rights (this includes providing Personal Data to others for the purposes of preventing fraud and reducing credit risk);
       • to an organisation to which we sell or transfer (or enter into negotiations to sell or transfer) any of our businesses or any of our rights or obligations under any agreement we may have with you. If the transfer or sale goes ahead, the organisation receiving your Personal Data may continue to use your Personal Data on the basis of this Notice unless and until they agree to other terms with you;
       • to any other successors in title to our business; or
       • to anyone to whom we transfer or may transfer our rights and duties under our agreement with you

   The Personal Data will be shared with the above on the condition that they have access to only such Personal Data required to fulfil their obligations and only on the agreement that they do not use your Personal Data for any other purposes.

5. FOR HOW LONG WE RETAIN YOUR PERSONAL DATA

   We will retain your Personal Data for as long as it is legally required, and to support the purposes for which it was obtained. We will then dispose of it promptly and securely.

6. WHERE WE PROCESS YOUR DATA

   Your Personal Data is processed/maintained in our country of incorporation, territory where Landmark Group Entities operate or in any other places where the parties involved in the processing are located. It means that your Personal Data may be transferred and maintained outside your country of residence or our country of incorporation. If the data is transferred to any third-party organization for processing, then the appropriate assessments will be conducted to ensure the organizations have implemented appropriate security and privacy controls. Your consent to this Privacy Policy followed by submission of requested Personal Data indicates assent for such data transfer.

7. MARKETING OPT-IN AND OPT-OUT PROVISIONS

   When you opt in for receiving marketing communications, you are consenting to receiving promotional communication from us. You can opt-out or unsubscribe from our marketing communications for products, new products, offers and promotions by following the OPT -OUT instructions in the e-mails or SMS or any other channel. In addition, at any time you may access the OPT OUT section on the Participating Website/s and choose to unsubscribe (opt-out) or send an e-mail to our Data Protection Team at privacy@landmarkgroup.com. We will make commercially reasonable efforts to implement your opt-out requests promptly.

8. PROTECTION OF PERSONAL DATA
   1. We store all Personal Data on a secure server, and we use procedures designed to protect Personal Data against accidental or unauthorized access, destruction, use, modification, alteration or disclosure. We will seek to ensure that your Personal Data is kept confidential and secure in accordance with this Privacy Policy, and that the appropriate technical and organizational measures to prevent unlawful or accidental destruction, accidental loss, unauthorized disclosure or access or other unlawful forms of processing are implemented.
   2. To keep your Personal Data safe, we ensure that sensitive and private data exchanges between you and Participating Website/s happen over a Secure Sockets Layer (SSL)-secured communication channel and are encrypted and protected with digital signatures. SSL-secured communication channels are specially designed to protect Personal and Sensitive Data (payment details), which is sent over the internet.


9. SPECIAL CATEGORY DATA
   1. We do not collect Personal Data from anyone under the age of 18 years without the consent of the parent / legal guardian. However, it is not possible for us to prevent children, from fraudulently representing their age in order to gain access to the Website/s. If you are a parent / legal guardian and you are aware that your child/ward has provided us with Personal Data without your consent, please contact us immediately as described in Clause 15 of this Privacy Policy.
   2. If you are providing or have already provided Personal Data of your child/ward, you are providing us with your affirmative parental consent as the legal parent or guardian to collect, use and process the information of the child, consistent with this Privacy Policy.
   3. In processing children's Personal Data, we ensure the following safeguards:
      • processing is clear, direct, safe, and free of fraud and is not misleading; and
      • the extent of Personal Data we process is strictly limited to the purposes for which we collect such child's Personal Data.
10. YOUR RIGHTS AND CHOICES

    You have the following rights in relation to your Personal Data and you can exercise them by accessing the Participating Website/s or submitting a request at privacy@landmarkgroup.com.

    • The Right to Be Informed

      You are entitled to be informed about how your Personal Data is used/processed in line with the Privacy Policy. Any use of Personal Data which is beyond the Privacy Policy shall be communicated to you.

    • The Right of Access

      You have the right to get a copy of your Personal Data being processed by us. Based on the request there might be reasonable fee proportional to the service you are receiving.

    • The Right to Rectification
      1. You have the right to update, amend, correct or request the deletion of the Personal Data collected by us about you.
      2. It is important that the Data we hold about you is accurate and current. Please keep us informed if your Personal Data changes during the period for which we hold it.
    • The Right to Erasure (Right to Be Forgotten)

      You have the right to have your Personal Data erased/deleted. Your request for the deletion of your Personal Data may not be entertained if we need to retain certain Personal Data to implement a legal obligation or when we have a lawful basis to do so.

    • The Right to Lawful Processing

      You have the right to have your Personal Data protected and lawfully processed. We are responsible for protecting your Personal Data that we process, or that is processed on our behalf in accordance with the Applicable Data Protection Law and regulations.

    • The Right to Withdraw Consent

      You have the right to withdraw your consent at any time. Upon withdrawal, we will cease processing your data.

    • The Right to Object
      1. You have the right to object to processing your Personal Data if such processing is not necessary to achieve the purposes for which such Personal Data has been collected or where such collected Personal Data is beyond the extent required, discriminatory, unfair or illegal.
      2. In the event of objection, we will verify and confirm if the objection is valid. If valid objection exists, we will erase such data.
      3. Your objection may not be entertained if we need to retain the data for a contractual or legal obligation, or to demonstrate that explicit consent was obtained.
    • Rights in Relation to Automated Decision Making and Profiling

      We might use your Personal Data for profiling through internal mechanisms of filtering and Artificial Intelligence so we can recommend you better products and combinations.

11. COOKIES
    1. We may use cookies, or other technologies, to remember Personal Data or to provide you with relevant online advertising, when you use the Participating Website/s. Cookies are small files or records that we may place on your web browser for collecting information about your activities on the Participating Website/s, preparing reports, assessing trends, in order to determine relevant interest-based advertisements to serve the customers and otherwise monitor the way in which the Participating Website/s is being used.
    2. These Cookies may collect information about your online behaviour, such as your IP address, the website you arrived from and information about your purchase history or the content of your shopping basket. This means that you may see our adverts on our websites and on other organisations' websites. To help us to deliver online advertising that is relevant to you, we may also combine data we collect through Cookies in the browser of your desktop computer or other devices with other data that we have collected (e.g. Loyalty program).We may also use services hosted by third parties, to assist for these matters which may collect information, such as your IP address, sent by your browser or via cookies.
    3. This is intended to enhance convenience for you, and to assist us to run an efficient operation. The use of cookies is relatively standard. Most browsers are initially set up to accept cookies. However, if you prefer not to store cookies, you can choose to:
       1. not use Participating Website/s;
       2. set your browser to notify you when you receive a cookie;
       3. set your browser to refuse to accept cookies;
       4. delete our cookies after visiting Participating Website/s; or
       5. browse our Participating Website/s using your browser’s anonymous usage setting.
    4. By accepting the Privacy Policy, you confirm your consent to our use of cookies, and other such technologies, for these purposes. Any information that we collect and store that is personally identifiable is protected using appropriate means. The Participating Website/s may contain links to other websites. Please be aware that we are not responsible for the privacy practices of third-party websites (Participating Website/s excluded) not operated by us, and cannot guarantee the security of any of your Personal Data collected there. We encourage you to read the privacy statements of each and every third-party website that collects your Personal Data.
12. AGGREGATE DATA, DATA ANALYTICS AND SOCIAL MEDIA FUNCTIONALITY
    • We may aggregate your Personal Data and remove any identifying elements in order to analyse patterns and improve our marketing and promotional efforts, to improve our Services, to analyse Participating Website use, to improve our content and product offerings, and to customise our Participating Website’s content, layout, products and services, and we may appoint third parties to do this on our behalf, as set out above.
    • We gather certain usage information like the number and frequency of visitors to our Participating Website/s. This information may include which webpage you just came from, which webpage you next go to, what browser you are using, your device and your IP address. We only use such data in the aggregate. This collective data helps us to determine how much our customers use parts of our Participating Website/s, and do research on our users' demographics, interests, and behaviour to better understand and serve you.
    • If you use buttons on our Participating Website/s linked to social media or similar sites (for example "Like" and/or "Share" buttons), content from our Participating Website/s may be sent back to that other website or service and, depending on your privacy settings, may be privately or publicly visible (for example to friends, followers, or generally to anyone who has access to your profile page).
    • We may also use demographic information and details about your preferences that we collect when you use our services and/or our products, in aggregate form, to help us determine which customers use certain services and products, and to allow us to tailor these services/products and our marketing to specific user demographics and interests.
    • We may share aggregate and anonymised information with our affiliates, business partners and third parties to improve our services and for advertising business and marketing practices.
13. LINKS AND THIRD-PARTY PRIVACY POLICIES

    Our Participating Websites may contain links to other websites or platforms operated by third-party organisations that have their own privacy policies. Please make sure you read the terms and conditions and privacy policies of the third party organisation carefully before providing any Personal Data on a website or platform as we do not accept any responsibility or liability for websites or platforms of other organisations.

14. CHANGE IN THE PRIVACY POLICY

    Changes in law or changes in our business may require changes to be made to the terms of this Privacy Policy from time to time so we encourages you to review this Privacy Policy updates periodically for any such changes. It is your responsibility to carefully read, agree to the Privacy Policy on each occasion you use the Participating Website/s, and your continued use of the Participating Website/s shall signify your acceptance to be bound by the latest Privacy Policy.

15. CONTACT US

    If you have any concerns or comments about the processing of your Personal Data or this Privacy Policy, or if you want us to change information or preferences you provided to us, please contact us at: privacy@landmarkgroup.com.

16. COMPLAINTS
    • If you think your rights have been breached in any way by us, you can write to us at privacy@landmarkgroup.com.
    • If you feel that we do not comply with applicable privacy rules you have the right to lodge a complaint with a competent data protection authority in your country of residence.