Privacy notice for Dubai Calendar App

Department of Economy and Tourism (“DET”) and its affiliates, including,  but  not  limited  to,  Dubai Corporation for Tourism and Commerce Marketing and Dubai Festivals and Retail Establishment (collectively, “Dubai DET”, “We”, “we”, “our” or “us”) are committed to providing excellent service to all their customers, including respecting their concerns about privacy and taking the relevant measures to safeguard their personal data  in accordance with applicable data protection legislation. We have provided this Privacy Notice to help you, the user, understand how we collect, use and protect your information when you visit and use the mobile ticketing services made available via our downloadable Dubai Calendar mobile application and related services (collectively, the “Dubai Calendar Services”). Please read the following carefully to understand our views and practices regarding your information and how we will treat it.  If you are not familiar with certain terms, please familiarise yourself with such in the key terms section of this Notice

This Privacy Notice should be read together with our Terms of Use and any other documents referred to on it. By accessing or using the Dubai Calendar Services, you are accepting the practices described in this Privacy Notice and the Terms of Use.

About Dubai Calendar

Dubai Calendar is the official calendar of year-round events happening in Dubai, where event organisers may list events and promotions, and ticket sellers may offer tickets for such events and promotions for users of the Dubai Calendar to purchase.

Definitions

Non-personally identifiable information

This is information that is recorded about users so that it no longer reflects or references an individually identifiable user.

Personal data

This is information which you provide to us which personally identifies you, such as your name, email address, billing information, credit card information, or other data which can be reasonably linked to such information by Dubai DET, such as information we associate with any accounts you may hold with Dubai DET.

Sensitive personal data

This is a particular category of personal data, which includes confidential medical facts, racial or ethnic origins, political or religious beliefs.

What information do we collect?

If you use our Dubai Calendar Services, we will collect, use and otherwise process your information (both non-personally identifiable information and personal data) in a range of different ways in accordance with the terms of this Privacy Notice. More specifically, we will:

• collect information you give us when you download and sign up to our app to create an account such as your name, email address, nationality, age, country of residence, contact number;
• collect your contact and billing information such as your name, phone number, email address, credit card number, billing and home address when you buy a ticket to process your payments;
• collect information about the services that you use and how you use them. This information may include (i) internet protocol address, (ii) device-specific information (such as your hardware model, operating system version, unique device identifiers, and mobile network information), (iii) device event information such as crashes, system activity, hardware settings, the date and time of your request, (iv) cookies or similar technologies that may uniquely identify your accounts, (v) information (including personal data) locally on your device using mechanisms such as application data caches, vi) photos and videos. We may also collect and process location information when you use our mobile application through various technologies such as Wi-Fi access points and cell towers.
• collect information such as your age range, gender, nationality or information about events you like or products and services you buy. This information may for example be collected as part of a user survey.

How do we collect your information?

Directly from you

We collect your information (both non-personally identifiable information and personal data) directly from you unless it is unreasonable or impractical to do so.  We do this in ways including:

• through your download and use of our app and avail any of the Dubai Calendar Services including ticket purchases and registration for event(s) or promotion(s);
• during conversations between you and our representatives and customer support; and/or
•  Any images or photos you choose to share with us when you use our mobile application. We will not access your photos or camera without first getting your explicit permission. If you give us permission to access photos or your camera, we will only use images that you specifically choose to share with us. You may use our application to select the photo or photos you choose to share, but we will never import the photos you review except those you explicitly share. At any time, you can manage your photos and camera preferences by turning off this feature in the device settings of your mobile device.

From third parties

We may also collect your information (both non-personally identifiable information and personal data) from third parties including:·      

• advertisers;
• mailing lists;
• contractors and business partners and/or
• social media platforms you elected to use in order to access or use our app (such as Facebook, Google, Twitter).

We may combine information we receive from third parties with information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out in this Notice (depending on the types of information we receive).

Indirectly from you

We may also collect your information (both non-personally identifiable information and personal data) directly from you or passively via tracking tools such as cookies and similar technologies that uniquely identify your accounts.

Data controller and Data Processor

Please note that Dubai DET acts as a controller of your personal data processed in accordance with this Privacy Notice except for any of your personal data processed in relation to a ticket sale on our ticketing system in which case we are the processor and the ticket sellers are the controllers.

How can you contact us?

Dubai DET has appointed a Data Protection Officer (DPO). You can reach our DPO at dpo@dubaitourism.ae or at privacy@dubaitourism.ae.

How do we use your information and why?

Applicable data protection laws require that we can use your personal data only where we have a valid purpose to do so and legal basis. We use your personal data and information as described here.

Purposes and legal bases table

Where you have indicated your consent, we (and permitted third parties) may contact you for direct marketing purposes via post, telephone, email, SMS/MMS, push notifications, and social media channels such as Facebook, Twitter and Whatsapp.

This marketing may relate to:

• additional products and services we (or permitted third parties) feel may interest you;
• information about other goods and services we offer that are similar to those that you have already used or enquired about;
• upcoming events, promotions and new products/services or other opportunities as well as those of selected third parties; and
• information about events, promotions and products/services related to topics you have indicated your interests or preferences.

If you are an existing customer, we will only contact you by electronic means without seeking your consent in advance (including but not limited to telephone, e-mail, SMS/MMS, push notifications, and social medial channels such as Facebook, Twitter and Whatsapp) with information about services similar to those which were the subject of a previous dealing with you.

If you no longer wish to receive marketing communications from us you may unsubscribe by following the unsubscribe link in our email communications or by requesting us to remove you and your personal data collected electronically from our database(s) by emailing privacy@dubaitourism.ae.

Push Notifications: If you are a registered user of the app, you may receive push notifications. With your consent, we may send push notifications or alerts to your mobile device even when you are not logged in. At any time, you can manage your push notification preferences or deactivate these notifications at any time by turning off the notification settings in the app or in the Device Settings of your mobile device.

In some cases, we or our authorised service providers may also collect your personal data through the use of cookies and other similar technologies to help provide you with an improved user experience, and for advertising and marketing purposes. For example, when you access the Dubai calendar app, we may send a “cookie” (which is a small summary file containing a unique ID number) to your device. This enables us to recognise your device and customise the user experience. It also helps us keep track of services you view, so that we can send you news about those services. We also use cookies to measure traffic patterns, to determine which areas of our app have been visited, and to measure transaction patterns in the aggregate.

When you use our mobile application, we may also collect device identifier for advertisers that allow to anonymously track user ad activity on mobile devices.  At any time, you can manage your preferences by turning off this feature in the Device Settings of your mobile device.

For further information on the cookies we use, please refer to our Cookie Notice.

We use Google Firebase service on our mobile application. You can read how Google uses data when you use our mobile application here: www.google.com/policies/privacy/partners/, or any other URL Google may provide from time to time.

We are not responsible for the practices employed by websites or services linked to or from our mobile application, including the information or content contained therein or the data collection practices or privacy policies therein. Please remember that when you use a link to go from our mobile application to another website, our Privacy Notice does not apply to third-party websites or services. Your browsing and interaction on any third-party websites or service, including those that have a link or advertisement on our mobile application, are subject to that third party’s own rules and policies. In addition, you agree that we are not responsible and we do not have control over any third-parties that you authorise to access your user content. If you are using a third-party website or service (like Facebook, Twitter, Instagram, or Google groups etc.) and you allow such a third-party access to your user content you do so at your own risk. This Privacy Notice does not apply to information we collect by other means (including offline) or from other sources other than through our mobile application.

With ticket sellers and event organisers

When you purchase tickets or make reservations for events through the mobile application, your personal data will be shared with ticket sellers and event organisers that are responsible for that particular reservation, promotion or event. The data shared will be limited to those strictly necessary to complete your reservation or purchase. The Ticket Seller's or Event Organiser’s Privacy Notice will separately apply to all the information that you provide when purchasing tickets or registering yourself for events. At the time of purchasing tickets or registration for events, the Ticket Seller's or Event Organiser’s Privacy Notice, or a link to it, will be provided.

With our affiliates

When we collect and process your personal data, we might also share your personal data with our Dubai DET affiliates who may sometimes need to access your information to provide services to you on our behalf. Because Dubai DET is passionate about your privacy, we have made a decision to ensure the same level privacy protection throughout our business.

Legally, other Dubai DET affiliates will then be acting as ‘data processors’ to process your personal data on our behalf and based on our specific instructions. These processors will also be subject to data protection laws and will only process your personal data in compliance with our Privacy Notice and any other appropriate confidentiality and security measures.

With our service providers

We provide your information to our service providers who may receive or otherwise have access to your personal data or non-personally identifiable information, depending on the nature of their services and purposes in facilitating and enhancing the Dubai Calendar Services, and may only use it for such purposes. These include ticketing platform provider (such as Softix), payment processors (such as Network International), data analytics services (such as Google Analytics and Google Firebase), app analytics tools that monitor app functionality and performance (such as Crashlytics), email marketing services (such as Oracle Eloqua), and other service providers. Dubai DET as the controller of the information collected from you in connection with the use of the Dubai Calendar Services remains responsible for the any personal data processing done by such service providers on our behalf, except for ticketing sale transactions completed on our ticketing system on behalf of ticket sellers where we act as the processor and the ticket sellers are the controllers, and events outside our control or where you have shared your personal data to such service providers where they act as separate controllers.

With your consent for marketing purposes

We will share personal data with companies, organisations or individuals outside of Dubai DET (and the parties and bodies referenced in this section of the Privacy Notice) for marketing purposes when we have your express opt-in consent to do so. If you have specifically consented to share your personal data with one or more of such third party companies, organisations or individuals outside of Dubai DET identified on our app for the purposes set out in such consent, each such third party will act as a data controller in relation to the data that we supply to it; and upon contacting you, each such third party will supply to you a copy of its own privacy notice, which will govern that third party's use of your personal data.

Where required by applicable law

We will disclose personal data when required by any applicable law, or in good faith believe such action is necessary or desirable to comply with the applicable laws, or to protect or defend the rights or property of Dubai DET, any of our digital platforms or our users. We will only fulfil requests to share personal data where we are permitted to do so in accordance with applicable law or regulation. Only those personal data that are strictly required by law will be disclosed.

With selected third parties

We may disclose your personal data to other selected third parties in the following circumstances:

• In the event that Dubai DET sells or buys any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
• If Dubai DET or substantially all of its assets are acquired by a third party, in which case personal data held by it will be one of the transferred assets;
• Agents, service providers and third parties who provide services relating to the purpose for which the personal data is collected including data processing services, whether or not such agents, service providers and third parties are based in the UAE;
• any person who is under a duty of confidentiality and has undertaken to keep such data confidential.

How do we ensure your information is protected?

Where we share your personal data, within Dubai DET or with third parties we implement robust contractual agreements with third parties (including service providers) to confirm that your personal data will be handled in compliance with relevant data protection laws, for example, the GDPR or the UK GDPR. Where we do this, we will use appropriate safeguards to protect any personal data being transferred.

We use approved Standard Contractual Clauses for the international transfer of personal data collected in the European Economic Area, the UK and Switzerland.

You can find information on Standard Contractual Clauses on the EU Commission and the ICO websites.

How long we keep your data for?

Any personal data we collect about you will only be retained for as long as it takes for the purposes for which such information is required to be completed. If we no longer need to use or disclose your personal data for the purposes set out in this Notice and we are not legally required to retain that information, then we will take reasonable steps to destroy your personal data or ensure it is rendered anonymous (i.e. turned into non-personally identifiable information).

Where we store your personal data?

The data that we collect from you may be transferred to, stored and otherwise processed on servers located outside the country in which you reside and which may be based in locations both within and outside of the UAE.

Under certain circumstances, you have a number of rights with regard to your Personal Data that we must comply with. The rights you have are:

The right to be informed

You have the right to be informed about the collection and use of your personal data by us or, on our behalf, by a third party.

The right to access

You have the right to obtain from us confirmation as to whether or not your personal data is being processed and, if so, the right to access that personal data. This right does not apply where it would adversely affect the rights and freedoms of another person.

The right to rectification

You have the right to request that we correct any inaccurate personal data and we must comply in a timely manner. Taking into account the purposes of the processing, you shall have the right to have incomplete personal data completed.

The right to erasure

You have the right to request the erasure of your personal data, in our possession, in a timely manner.

The right to restrict processing

You have the right to request the restriction of use of your personal data, where the data is not being used for the purpose it was collected for.

The right to object to processing

You have the right to object at any time to our use of your personal data where (i) the processing is carried out for direct marketing purposes including profiling relating to direct marketing; (ii) the processing is carried out for statistical surveys purposes; or (iii) that use is based on legitimate interest* or the public interest.

 *‘Legitimate interest’ is a lawful basis for processing personal data where (i) the use of data has a limited impact on you, (ii) you should reasonably expect us to use your data in such a way, or, (iii) where we do not deem it appropriate to contact you with disruptive consent requests.

The right to data transfer or data portability

Where you have provided personal data for us to use with your consent** or as required for us to fulfil our contractual obligations to you, you have the right to receive personal data that you have provided from us in a structured, commonly used format in order for you to provide that personal data to another organisation for use as you so wish. This right does not apply where we are using the personal data to carry out a public duty (e.g. security or compliance).

**This includes sensitive personal data such as biometric, health or political or religious beliefs provided with your explicit consent.

The right to complain to a supervisory authority

You have the right to submit a formal written complaint to a regulator in your country who can resolve any complaints regarding the transfer of personal data that we cannot resolve with you directly.

The right to withdraw consent

When we process your personal data based on your consent, you have the right to withdraw it and inform us that you no longer wish us to collect, store, or use your personal data, where there is not a business or legal reason for us to do so.

Dubai DET has procedures in place to ensure that it deals with any requests it receives in an efficient manner.  You can exercise any of the above rights by contacting us at: dpo@dubaitourism.ae or privacy@dubaitourism.ae. We might need to ask you to provide some personal data in order to confirm your identity and to properly identify you throughout our systems.

If you have any general enquiries, complaints or suggestions, please contact us at info@dubaitourism.ae or click here

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We regularly review our compliance with our Privacy Notice. When we receive formal written complaints, we will contact the person who made the complaint to follow up. We work with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of personal data that we cannot resolve with our users directly.

In the future, we may revise or amend this Privacy Notice at any time by amending this page. All changes will be made here so you will always know what information we gather, how we might use that information and whether we will disclose it to anyone. Some of the provisions contained in this Privacy Notice may also be superseded by provisions or notices published elsewhere on our websites. Your continued use of the mobile application following the posting of changes to these terms will mean you accept those changes.

Your privacy concerns are important to us. We hope this Privacy Notice has been helpful to you.

Questions Concerning this Privacy Notice

If you have questions regarding this Privacy Notice, please feel free to e-mail us at privacy@dubaitourism.ae.

Last modified: 28^th June 2022