Privacy & Cookies Notice

This Privacy & Cookies Notice describes how we collect, process, use and disclose your personal data as a “data controller”, when you contact us, use our services or interact with our platforms including websites and mobile apps (together "Platforms"). As a “data controller” we determine how we collect and use the personal data that we obtain from you. “Personal data” means any information that relates to an identified or identifiable individual.

1- What this notice covers?

We are committed to adopting the highest standards of protection when it comes to how we collect, use and safeguard your personal data, and have accordingly developed this Notice, which:

sets out the types of personal data we collect from you.
explains how and why we collect and use your personal data.
explains when and why we may share personal data within the Group and with other organizations.
explains how we protect the personal data we collect; and
explains the rights and choices you can make, under certain circumstances, to us about your personal data. This Notice applies if you use our services (referred to in this Notice as "our Services").
Using our services means:
buying / ordering services or products from any of our Affiliates over the phone, in store, or online.
using any of our Platforms, including but not limited to websites ("our Websites"), such as our main website or our Affiliates' websites or the Happiness Lab website, public Wi-Fi networks in any of our locations, or any of our mobile applications ("our Mobile Apps").
being a member of any of our loyalty schemes (e.g. Othaim Rewards);
taking part in our promotions & competitions and registering to receive our newsletters and offers; and
engaging in any surveys or sharing content with us on Platforms and/or social media.

This Notice also applies if you contact us, whether online or through our call centers, or we contact you about our Services.

2- Personal data we collect

When you register for any of our Services, browse our websites, use our Mobile Apps or connect to our Wi-Fi networks that we provide in our locations, you may be asked to provide certain personal data. When you receive any of our Services, use our Platforms or otherwise interact with us, we may also automatically collect certain personal data with or without your consent pursuant to applicable laws and regulations. The personal data that we collect will depend on the Service that you are using. We may collect the following information from you:

When you register to our services:

your personal details, such as your postal and billing addresses, email address(es), phone number(s), date of birth, gender, your car number plate, passport or ID number, credit cards
your account login details, such as your username and the password (encrypted) that you have chosen.
and
your interests, preferences, income, and other profiling information.

When you shop with us in-store or visit our showrooms:

your personal details, such as including your postal and billing addresses, email address(es), phone number(s), date of birth.
your financial information (for example, credit card details, bank account); and
information relating to the purchase of our products or services.

When you shop with us online, browse our websites, use our Mobile Apps, or connect to our Wi-Fi networks:

information about your actual or potential online purchases (for example: what, when, where you ordered / bought and how you paid).
information about your online browsing behavior on our Websites, Mobile Apps and public networks and information about when you click on one of our adverts (including those shown on other organizations’ websites);
information about devices you have used to access our Services (including the make, model and operating system, IP address, browser type and mobile device identifiers); and information about your precise geolocation.

When you use any of our loyalty program(s)

your personal and demographic details as part of the joining process, including your first and last name, nationality, date of birth and family members that you provide.
transaction information, including the in-store and online purchases you earn points for and how you use your points, coupons, and vouchers within the Group or with our partners; and
the different experiences and promotions you interact with.

When you contact us or we contact you, or you take part in promotions, competitions, surveys or questionnaires about our services:

personal data you provide about yourself or that we may ask from you from time to time.
details of emails and other digital communications we send to you including information about the emails you open and links in them that you click on; and
your feedback and contributions, including through any voice interactions with our Platforms, call center recordings, video content, customer surveys and questionnaires.

When you use our services:

We may collect demographic information and details about your preferences when you use our Services and/or products to be able to better tailor these Services and/or products to particular groups of individuals.

This information may include your nationality, age, gender and interests. We may collect this information when you purchase the Services/products or using video imaging. Where required by applicable law, we will only use such data in an anonymized and aggregated format. For further information about aggregate data, see section 11.

Other sources of personal data

We may also obtain your personal data from other sources, such as specialist companies that supply information, online media channels, our partners and public registers. We may collect the following types of personal data about you from other sources: contact details, credit history, purchases, interests, preferences, or other types of procured or publicly available information. This other personal data helps us to:

(a) review and improve the accuracy of the data we hold; and

(b) improve and measure the effectiveness of our operations, marketing communications, including advertising.

We may be required by law to collect personal data about you or because of any contractual relationship we have with you, or where you have given your consent (if we expressly ask for consent to process your personal data for a specific purpose).

If you choose not to provide your personal data to be used in accordance with this Notice, you will still be able to visit our Platforms, but you may not be able to access certain options, products or services, and in some cases, we may not be able to fulfil a service you request.

3- Why and how we use your personal data

We may use or process your personal data for the following purposes:

To make our services available to you

We may use your personal data to personalize the marketing messages we send to you and to make them

more relevant and interesting. We may use your personal data for this purpose in the following ways:

processing your orders and refunds.
to process and respond to any enquiries you have about our Services.
to confirm your payment, any purchases or other information linked to your use of our Services.
for billing and payment processing.
managing the accounts, you hold with us; and
to provide you access to multiple Platforms and Services across the Group using the same account and login registration information.

This is so we can provide the services to you in line with our contractual obligations to you.

To personalize your experience

We may use your personal data to personalize the marketing messages we send to you and to make them

more relevant and interesting. We may use your personal data for this purpose in the following ways:

using your online browsing behavior as well as you’re in-store and online purchases to help us better understand you as a customer and provide you with personalized offers and services;
providing you with relevant marketing communications (including by email, post, telephone, SMS, or online advertising such as by way of push notifications), relating to products and services we offer, and
those of our suppliers and partners. As part of this, online advertising may be displayed on our websites and on other organizations’ websites and online media channels. We may also measure the effectiveness of our marketing communications and those of our suppliers and partners.
for market research and statistical and survey purposes; and
to help us to better understand you and provide you with Services and marketing communications that are relevant to your interests, we combine personal data we collect when you make purchases in-store with personal data collected from our Websites, Mobile Apps, together with your browsing or other behaviors, and other sources from our Group and third-party partners.

To contact and interact with you. We may use your personal data when we communicate with you to:

contact you about our Services, for example by phone, email or post or by responding to social media posts that you have directed at us.
manage promotions and competitions you take part in, including those we run with our suppliers and partners; and
invite you to take part in and manage customer surveys, questionnaires and other market research activities carried out by us and by other organizations on our behalf.

To manage and improve our day-to-day operations

We analyze information about how you use our Services to:

manage and improve our Platforms and Services.
help to develop and improve our product range, services, stores, information technology systems, know-how and the way we communicate with you;
detect and prevent fraud or other crime; and
we may anonymize or aggregate data, which are used to support our services to you

4- Sharing your personal data

We may share your personal data with third parties under the following circumstances:

Our Affiliates

We may share the personal data collected by any of our Affiliates with our other Affiliates for the purposes listed above.

Retail Partners

We may share your personal data with other companies that sell products through our Services ("Retail Partners"). We work closely with several trusted partners with whom we need to share information to

help provide our services. For example, when you shop online or in-store we will give the relevant Retail

Partner your name, contact details, and address so that they can deliver your items.

Service Providers

We work with carefully selected Service Providers that carry out certain functions on our behalf. These include,

for example, companies that help us with technology services, storing and combining data, processing payments and delivering orders. We only share personal data that enables our Service Providers to provide their services.

Some of the Service Providers we work with operate online media channels, and they place relevant online advertising for our products and services, as well as those of our suppliers and our Retail Partners, on those online media channels on our behalf. For example, you may see an advert for our products and services when you use a particular social media site.

Marketing, Security & Analytics Partners

We may share your personal data with third party marketing, security and analytics service providers to help us market, secure and understand the use of the Services and our Platforms.

Other

We may share personal data with other organizations in the following circumstances:

if any applicable law or a public authority says we must share the personal data.
if we need to share personal data 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 organization to which we sell or transfer (or enter 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 organization receiving your personal data may continue to use your personal data based on this Notice unless and until they agree 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.

5- Transfer of your personal data to other countries

Your personal data may be transferred to, stored, and processed in a country that is different from your country of residence or our country of incorporation. In any case we have put in place appropriate safeguards in accordance with applicable legal requirements to ensure that your data is adequately protected. These safeguards include ensuring that all such entities keep personal data confidential and secure and only use it for the purposes that we have specified and communicated to you. We also conduct due diligence on our partners and ensure that they employ adequate data protection safeguards.

In the event your personal data is transferred to a foreign jurisdiction, it may be subject to the laws of that jurisdiction, and we may be required to disclose it to the courts, law enforcement or governmental authorities in those jurisdictions but we will only do so where required by applicable laws.

6- How we protect your personal data

We are committed to protecting the information you provide to us. We maintain physical, technical, and organizational safeguards to secure your personal data from unauthorized access, improper use or disclosure, unauthorized modification or unlawful destruction or accidental loss. We limit access to your personal data to those employees, agents, contractors and other third parties who have a responsibility for your personal data and only on a need-to-know basis. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality. Other safeguards that we will use to safeguard your personal data include:

applying physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of personal data
protecting the security of your personal data during transmission by using encryption protocols and software
using computer safeguards such as firewalls, antivirus and other security technologies to keep the personal data secure; and
regularly monitoring our systems for possible vulnerabilities and attacks and carrying out penetration testing to identify ways to further strengthen our security.

While we will do our best to ensure the security and protection of your personal data, the security of your personal data will depend in part on the security of the computer and/or mobile that you use to communicate with us, and the security measures you use to protect your user ID and passwords. To ensure that your personal data is always kept safe, please take appropriate measures to protect your user ID and passwords, and any other information that is necessary to use our Platforms.

7- Social Media

We operate channels, pages and accounts on some social media sites to inform, assist and engage with customers. We monitor and record comments and posts made on these channels about us so that we can improve our services.

The Group is not responsible for any information posted on those sites other than information we have posted ourselves. We do not endorse the social media sites themselves or any information posted on them by third parties.

8- Retention

We keep records for as long as required to a) manage purchases, bookings, memberships and provide any other relevant products or services anticipated by this Notice, including keeping you up to date with our marketing and managing the platform; b) personalize the products, services and communications with you; c) comply with applicable record retention legal requirements. When deciding how long to keep your personal data after our relationship with you has ended, we take into account our legal obligations and regulators' expectations.

If you wish to request that we no longer use your information to provide you services, you may contact us in accordance with Section 13.

However, we will retain and use your registration information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

9- Marketing Communications

All marketing communications we send to you will provide you with a way to withdraw your consent to future marketing. If you no longer wish to receive promotional materials you may opt out from receiving these communications or change your account settings, this will remove you from marketing lists.

Please note that if you unsubscribe from marketing communications you will still receive operational and service messages from us regarding the services or products you bought from us and responses to enquiries made to us, we may hold your details on a suppression list, so we don't send you marketing communications in the future.

10- Cookies and Similar Technologies

We use cookies and similar technologies, such as tags and pixels ("Cookies"), to personalize and improve your customer experience as you use our Websites and Mobile Apps and to provide you with relevant online advertising. Cookies are small data files that allow a website or Mobile App to collect and store a range of data on your desktop computer, laptop or mobile device.

Cookies help us to provide important features and functionality on our Websites and Mobile Apps, and we use them to improve our customers' experience. For example, we use Cookies to do the following:

Improve the way our Websites and Mobile Apps work
Cookies allow us to improve the way our Websites and Mobile Apps work so that we can personalize your experience and allow you to use many of their useful features. For example, we use Cookies so we can remember your preferences and the contents of your shopping basket when you return to our Websites and Mobile Apps.
Improve the performance of our Websites and Mobile Apps
Cookies can help us to understand how our Websites and Mobile Apps are being used, for example, by telling us if you get error messages as you browse. These Cookies collect data that is mostly aggregated and anonymous.
Deliver relevant online advertising
We use Cookies to help us deliver online advertising that we believe is most relevant to you on our websites and other organizations’ websites.
Cookies used for this purpose are often placed on our websites by other organizations, and always with our permission. These Cookies may collect information about your online behavior, 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 organizations’ websites. You may also see adverts for other organizations on our 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).
Measuring the effectiveness of our marketing communications, including online advertising
Cookies can tell us if you have seen a specific advert, and how long it has been since you have seen it. This information allows us to measure the effectiveness of our online advertising campaigns and control the number of times you are shown an advert.
We also use Cookies to measure the effectiveness of our marketing communications, for example by telling us if you have opened a marketing email that we have sent you.
Your choices when it comes to Cookies
You can use your browser settings to accept or reject new Cookies and to delete existing Cookies. You can also set your browser to notify you each time new Cookies are placed on your computer or other device.

If you choose to disable some or all Cookies, you may not be able to make full use of our platforms. For example, you may not be able to add items to your shopping basket, proceed to checkout, or use some of our products and services that require you to sign in.

11- Aggregate data, data analytics and social media functionality

We may aggregate personal data (as set out in this section 11) and remove any identifying elements in order to analyze patterns and improve our marketing and promotional efforts, to improve our Services, to analyze Platform use, to improve our content and product offerings, and to customize our Platforms' 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 Platforms. 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 Platforms, and do research on our users' demographics, interests, and behavior to better understand and serve you.

If you use buttons on our Platforms linked to social media or similar sites (for example "Like" and/or "Share" buttons), content from our Platforms 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 anonymized information with our Affiliates, business partners and third parties to improve our Services and our marketing practices.

12- Access your data and other requests

Under certain circumstances and under certain applicable data protection laws, you may have the right to:

request access to your personal data, which enables you to receive a copy of the personal data we hold about you
rectify the information we hold about you, which enables you to have any incomplete or inaccurate information we hold about you corrected
erase your personal data, which enables you to ask us to delete or remove your personal data where there is no good reason for us continuing to process it
restrict our use of your personal data, which enables you to ask us to suspend the processing of personal data about you, for example, if you want us to establish its accuracy or the reason for processing it
object to our use of your personal data under certain circumstances, including where it is based on automated processing. You may also object where we are processing your personal data for direct marketing purposes
withdraw at any time any consents you have provided for our use of your personal data for a particular purpose (where we have asked you for consent to use your information for that particular purpose as required in accordance with applicable laws); or
receive your personal data in a usable electronic format and transmit it to a third party (also known as data portability).
To view your rights and make the above requests, please visit our Contact Us Form. While we will exercise reasonable endeavors to meet your request (where practicable) and comply with any applicable laws, it may not always be possible to do so.

You may also lodge a complaint with your local data protection authority, where applicable. If you are concerned that any of the information, we hold about you is incorrect, or out of date, please write to us in accordance with Section 13 to report your concerns and we will take appropriate steps to amend our records.

Please note that we may require additional information from you to respond to your requests or to confirm your identity.

13- How to contact us

If you have any questions about this Notice or if you become aware of any mishandling or breach of your personal data while using our Services, please visit our Contact Us Form and select ‘Contact Privacy Office’ to submit your inquiry. We will endeavor to respond to your concerns as soon as possible.

14- Notification of changes to this notice

We may update this Privacy Notice from time to time and will endeavor to communicate changes to registered users. All changes will become effective when posted unless indicated otherwise. If we are going to use your personal data in a manner different from that stated at the time of collection, we will notify you. Please review this Privacy Notice and all Supplementary Privacy Terms periodically for changes.

15- Links and third-party privacy policies

Our Platforms may contain links to other websites or platforms operated by third-party organizations that have their own privacy policies. Please make sure you read the terms and conditions and privacy policies of the third-party organization 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 organizations.

16- Children

Our platforms are not directed towards children. If you are providing personal data of children, 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 Notice.