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Policy on personal data processing

1. General provisions
 

This Personal Data Processing Policy is drawn up in accordance with the requirements of The Personal Data Protection Law, Federal Decree Law No. 45 of 2021 regarding the Protection of Personal Data and defines the procedure of personal data processing and measures to ensure the security of personal data taken by letoile.ae (hereinafter referred to as the Operator).

1.1. The Operator sets as its most important goal and condition of its activity the observance of human and citizen's rights and freedoms when processing his/her personal data, including the protection of the rights to privacy, personal and family secrecy.

1.2.This Operator's policy on personal data processing (hereinafter referred to as the Policy) applies to all information that the Operator may obtain about the visitors of the letoile.ae website.

 

2. Basic concepts used in the Policy
 

2.1. Automated processing of personal data - processing of personal data by means of computer equipment.

2.2. Blocking of personal data - temporary cessation of personal data processing (except for cases when processing is necessary to clarify personal data).

2.3. Website and mobile apps - a set of graphic and informational materials, as well as computer programs and databases, ensuring their availability on the Internet at the network address httpsː//letoile.ae or in google play or Apple Store.

2.4. Personal data information system is a set of personal data contained in databases and information technologies and technical means ensuring their processing.

2.5. Personal data depersonalization - actions as a result of which it is impossible to determine without using additional information whether personal data belong to a particular User or other subject of personal data.

2.6. Processing of personal data - any action (operation) or set of actions (operations) performed with the use of automation means or without the use of such means with personal data, including collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.

2.7. Operator - a state authority, municipal authority, legal entity or individual, independently or jointly with other persons organizing and (or) carrying out processing of personal data, as well as determining the purposes of personal data processing, composition of personal data subject to processing, actions (operations) performed with personal data.

2.8. Personal Data - any information relating directly or indirectly to a certain or defined User of the website letoile.ae or mobile apps.

2.9.Personal data authorized by the subject of personal data for dissemination - personal data to which the subject of personal data provides access to an unlimited number of persons by giving consent to the processing of personal data authorized by the subject of personal data for dissemination in the manner prescribed by the Personal Data Law (hereinafter - personal data authorized for dissemination).

2.10. User - any visitor of the website letoile.ae or mobile apps.

2.11. Provision of personal data - actions aimed at disclosure of personal data to a certain person or a certain circle of persons.

2.12. Dissemination of personal data - any actions aimed at disclosure of personal data to an indefinite number of persons (transfer of personal data) or familiarization of personal data to an unlimited number of persons, including disclosure of personal data in mass media, placement in information and telecommunication networks or providing access to personal data in any other way.

2.13. Cross-border transfer of personal data - transfer of personal data to the territory of a foreign country to a foreign government authority, a foreign individual or a foreign legal entity.

2.14. Destruction of personal data - any actions, as a result of which personal data are irretrievably destroyed with the impossibility of further recovery of the content of personal data in the information system of personal data and (or) material carriers of personal data are destroyed

 

3. The Operator's basic rights and obligations
 

3.1. The Operator has the right to:

3.1.1. To receive from the subject of personal data reliable information and/or documents containing personal data;

3.1.2. In case the personal data subject revokes his/her consent to personal data processing, the Operator has the right to continue processing personal data without the consent of the personal data subject if there are grounds specified in The Personal Data Protection Law, Federal Decree Law No. 45 of 2021 regarding the Protection of Personal Data;

3.1.3. Independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of the obligations stipulated by the Personal Data Protection Law, Federal Decree Law No. 45 of 2021 regarding the Protection of Personal Data;

3.2. The Operator shall:

3.2.1. Provide the personal data subject, upon his/her request, with information regarding the processing of his/her personal data;

3.2.2. Organize the processing of personal data in accordance with the procedure established by the current legislation;

3.2.3. Respond to appeals and requests of personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Protection Law, Federal Decree Law No. 45 of 2021 regarding the Protection of Personal Data;

3.2.4. Publish or otherwise provide unrestricted access to this Policy on personal data processing;

3.2.5. Take legal, organizational and technical measures to protect personal data from unlawful or accidental access to them, destruction, modification, blocking, copying, provision, dissemination of personal data, as well as from other unlawful actions in relation to personal data;

3.2.6. Stop transfer (dissemination, provision, access) of personal data, stop processing and destroy personal data in the manner and cases provided by the Personal Data Protection Law, Federal Decree Law No. 45 of 2021 regarding the Protection of Personal Data;

3.2.7. Fulfill other obligations provided for by The Personal Data Protection Law, Federal Decree Law No. 45 of 2021 regarding the Protection of Personal Data

 

4. Basic rights and obligations of personal data subjects
 

4.1. Personal data subjects have the right to:

4.1.1. To receive information regarding the processing of his/her personal data, except for cases provided for by the laws. Information shall be provided to the subject of personal data by the Operator in an accessible form and shall not contain personal data relating to other subjects of personal data, except in cases where there are legal grounds for disclosure of such personal data. The list of information and the procedure for obtaining it is established by The Personal Data Protection Law, Federal Decree Law No. 45 of 2021 regarding the Protection of Personal Data;

4.1.2. Demand from the operator to clarify his personal data, block or destroy it in case the personal data is incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing, as well as to take measures provided by law to protect his rights;

4.1.3. To impose the condition of prior consent when processing personal data in order to market goods, works and services;

4.1.4. To revoke the consent to the processing of personal data;

4.1.5. To appeal to the authorized body for the protection of the rights of personal data subjects or in court against unlawful acts or omissions of the Operator in the processing of his/her personal data;

4.1.6. To exercise other rights provided for by the legislation.

4.2. Personal data subjects shall be obliged to:

4.2.1. Provide the Operator with data about themselves;

4.2. 2. Notify the Operator about clarification (update, change) of their personal data.

 

5. The Operator may process the following personal data of the User
 

5.1. Surname, first name, patronymic.

5.2. Date of Birth.

5.3. e-mail address.

5.4. Phone numbers.

5.5. Address;

5.6. Type of user: tourist, local, resident

5.7. The website or mobile apps also collects and processes anonymized visitor data (including cookies) using Internet statistics services 

5.8. The aforementioned data are hereinafter in the text of the Policy united by the general term Personal Data.

5.9. The Operator does not process special categories of personal data relating to race, nationality, political views, religious or philosophical beliefs, intimate life.

5.10. Processing of personal data authorized for dissemination from among special categories of personal data.

5.11. The User's consent to the processing of personal data authorized for dissemination is executed separately from other consents to the processing of his/her personal data.

5.11.1. The consent to the processing of personal data authorized for dissemination is provided by the User directly to the Operator.

5.11.2. The transfer (dissemination, provision, access) of personal data authorized by the subject of personal data for dissemination shall be terminated at any time at the request of the subject of personal data. This request shall include the surname, first name, patronymic (if any), contact information (telephone number, e-mail address or postal address) of the personal data subject, as well as a list of personal data whose processing is to be stopped. The personal data specified in this request may be processed only by the Operator to whom it is sent.

5.11.3. Consent to the processing of personal data authorized for dissemination shall be terminated from the moment the Operator receives the relevant request.

 

6. Principles of personal data processing
 

6.1. The processing of personal data shall be carried out on a lawful and fair basis.

6.2. The processing of personal data is limited to the achievement of specific, predetermined and legitimate purposes. Processing of personal data incompatible with the purposes of personal data collection is not allowed

6.3. It is not allowed to merge databases containing personal data processed for incompatible purposes.

6.4. Only personal data that meet the purposes of their processing shall be processed.

6.5. The content and scope of processed personal data correspond to the stated purposes of processing. The redundancy of the processed personal data in relation to the stated purposes of their processing is not allowed.

6.6. When processing personal data, the accuracy of personal data, their sufficiency and, where necessary, relevance to the purposes of personal data processing shall be ensured. The Operator shall take the necessary measures and/or ensure that they are taken to delete or clarify incomplete or inaccurate data.

6.7. Storage of personal data is carried out in a form that allows to identify the subject of personal data, not longer than required by the purposes of personal data processing, unless the period of storage of personal data is established by law, contract to which the subject of personal data is a party, beneficiary or guarantor. Processed personal data shall be destroyed or depersonalized upon achievement of the purposes of processing or in case of loss of necessity to achieve these purposes, unless otherwise provided by law.

 

7. Purposes of personal data processing
 

7.1. The purpose of processing the User's personal data:

7.1.1. Creating an order on the web site and mobile apps;

7.1.2. Keeping You Informed: Informing the User by sending e-mails, sms, push, call center operator calls or delivery company calls;

7.1.3. Participating in the loyalty program;

7.1.4. Opportunity to leave reviews on products;

7.1.5. Cultural Sensitivity;

7.1.6. Conclusion, execution and termination of offer contracts;

7.1.7. Providing the User with access to services, information and/or materials contained on the website letoile.ae

7.2. The Operator is also entitled to send the User notices of new products and services, special offers and various events. The User may always opt out of receiving notifications by sending an e-mail to the Operator at [email protected] with the notation "Opt out of notifications of new products and services and special offers".

7.3. The anonymized data of Users collected through Internet statistics services serve to collect information about Users' actions on the website, to improve the quality of the website and its content.

 

8. Legal basis for personal data processing
 

8.1. The legal grounds for processing of personal data by the Operator are:

8.1.1. Operator's statutory documents;

8.1.2. Contracts concluded between the Operator and the subject of personal data;

8.1.3. laws, other regulatory legal acts in the field of personal data protection;

8.1.4. Users' consent to the processing of their personal data, to the processing of personal data authorized for dissemination.

8.2. The Operator processes the User's personal data only if it is filled in and/or sent by the User himself/herself through special forms located on the website httpsː//letoile.ae or mobile apps or sent to the Operator by e-mail. By filling in the relevant forms and/or sending his/her personal data to the Operator, the User expresses his/her consent to this Policy.

8.3. The Operator processes anonymized data about the User if this is allowed in the User's browser settings (cookies and JavaScript technology enabled).

8.4. The subject of personal data independently decides on the provision of his/her personal data and gives consent freely, of his/her own free will and in his/her own interest.

 

9. Conditions of personal data processing
 

9.1. The processing of personal data is carried out with the consent of the personal data subject to the processing of his/her personal data.

9.2. The processing of personal data is necessary for the execution of an agreement to which the personal data subject is a party or a beneficiary or guarantor, as well as for the conclusion of an agreement at the initiative of the personal data subject or an agreement under which the personal data subject will be a beneficiary or guarantor.

9.3. The processing of personal data is necessary for the exercise of the rights and legitimate interests of the operator or third parties or for the achievement of socially important purposes, provided that the rights and freedoms of the personal data subject are not violated.

9.4. Processing of personal data to which the subject of personal data has unrestricted access or at his/her request (hereinafter referred to as publicly available personal data) is carried out.

9.5. Processing of personal data subject to publication or mandatory disclosure in accordance with the law.

 

10. Procedure for collection, storage, transfer and other types of personal data processing
 

The security of personal data processed by the Operator is ensured by implementing legal, organizational and technical measures necessary for full compliance with the requirements of the current legislation in the field of personal data protection.

10.1. The Operator ensures the safety of personal data and takes all possible measures to exclude access to personal data by unauthorized persons

10.2. The User's personal data will never, under no circumstances, be transferred to third parties, except in cases related to the execution of the current legislation or if the subject of personal data has given his/her consent to the Operator to transfer the data to a third party for the fulfillment of obligations under a offer contract.

10.3. If any inaccuracies are detected in the personal data, the User may update them independently by sending a notice to the Operator to the Operator's e-mail address [email protected] with the remark "Personal Data Update".

10.4.  The term of personal data processing is determined by the achievement of the purposes for which the personal data were collected, unless another term is stipulated by the contract or applicable law. 
-Data processed for contract performance is stored for the term of the contract and additional 5 years after its termination.
-Data used for marketing and informational mailings is processed for 3 years after obtaining consent.
-Website visitor data (IP addresses, cookies) is stored maximum 6 months."
The User may withdraw his/her consent to the processing of personal data at any time by sending a notice to the Operator by e-mail to the Operator's e-mail address [email protected], marked "Withdrawal of consent to the processing of personal data".

10.5. All information that is collected by third-party services, means of communication and other service providers is stored and processed by these persons (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data and/or the User is obliged to familiarize himself/herself with the said documents in a timely manner.
The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.

10.6. The prohibitions established by the personal data subject on the transfer (except for granting access), as well as on the processing or conditions of processing (except for obtaining access) of personal data authorized for dissemination shall not apply in cases of personal data processing in the state, public and other public interests.

10.7. The Operator shall ensure confidentiality of personal data when processing personal data.

10.8. The Operator shall store personal data in a form that allows identification of the personal data subject for no longer than required for the purposes of personal data processing, unless the period of personal data storage is established by law, contract to which the personal data subject is a party, beneficiary or guarantor.

10.9. The condition for termination of personal data processing may be the achievement of the purposes of personal data processing, expiration of the personal data subject's consent or withdrawal of consent by the personal data subject, as well as detection of unlawful processing of personal data.

 

11. List of actions performed by the Operator with the received personal data
 

11.1. The Operator shall collect, record, systematize, accumulate, store, clarify (update, change), extract, use, transfer (disseminate, provide, access), depersonalize, block, delete and destroy personal data.

11.2. The Operator performs automated processing of personal data with or without receiving and/or transmitting the received information via information and telecommunication networks.

 

12. Confidentiality of personal data
 

The operator and other persons who have access to personal data are obliged not to disclose to third parties and not to disseminate personal data without the consent of the subject of personal data, unless otherwise provided by law.

 

13. Final Clauses
 

13.1. The User may obtain any clarifications on issues of interest regarding the processing of his/her personal data by contacting the Operator via e-mail at [email protected].

13.2. This document will reflect any changes in the policy of personal data processing by the Operator. The Policy is valid indefinitely until it is replaced by a new version.

13.3. The current version of the Policy is freely available on the Internet at letoile.ae/help/privacy-policy

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