We process different categories of personal data to enable us to provide services to you, and as further described below.
Contact Details: Includes but is not limited to address, email address and telephone number.
Identification data: Includes but is not limited to name, title, company and individual physical description.
Personal Information: Includes but is not limited to date of birth, age, gender, nationality, passport, marital status, signature, country of residence, photograph, family, voice recording, religion, languages spoken, place of birth, emergency contact details, insurance details and driving licence number.
Web Data: Includes but is not limited to cookies, user activity logs, IP address, social media profile and website visitor interaction data.
Health Data: Includes but is not limited to health, allergies, dietary requirements, medical information forms and notes and disability records.
Travel / Stay Information: Includes but is not limited to travel history, loyalty scheme information, preferences, stay information, feedback / analysis (e.g. surveys), product purchase information, reservation history, VIP status, visa information and occupancy information.
Financial Data: Includes but is not limited to card details and bank details.
The reason these categories of personal data are processed, along with our legal basis for doing so, are set out in the table below.
Personal Data Directly Obtained from You
Description of Processing | Purpose for Processing | Category of Personal Data | Legal Basis |
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We process your personal data when managing and fulfilling bookings, reservations and requests. | Customer service and processing/fulfilling orders and transactions | Contact Details, Identification Data, Personal Information, Web Data, Health Data, Travel / Stay Information and Financial Data | Contract, Legitimate Interest and when processing special category personal data - Explicit Consent |
We process your personal data when facilitating the check-in and check-out process. | Customer Service | Contact Details, Identification Data, Personal Information, Health Data, Travel / Stay Information and Financial Data | Contract and when processing special category personal data - Explicit Consent |
We process your personal data during your stay on our premises (e.g. in order to provide Wi-Fi to you). | Customer Service | Contact Details, Identification Data, Personal Information, Web Data and Travel / Stay Information | Consent and Legitimate Interest |
We process your personal data in order to collect, manage and analyse membership information. | Maintaining / Servicing Accounts | Contact Details, Identification Data, Personal Information, Web Data, Travel / Stay Information and Financial Data | Consent, Legitimate Interest and when processing special category personal data - Explicit Consent |
We process your personal data in order to conduct surveys, obtain feedback and manage and progress complaints as necessary. | Customer Service | Contact Details, Identification Data, Personal Information, Web Data, Health Data, Travel / Stay Information and Financial Data | Legitimate Interest and when processing special category personal data - Explicit Consent |
We process your personal data for marketing purposes, such as personalising offers for you, as well as for analytics purposes. | Advertising / Marketing Services, Analytics Services | Contact Details, Identification Data, Personal Information, Web Data, Travel / Stay Information and Financial Data | Consent and Legitimate Interest |
We process your personal data for service and quality monitoring purposes. | Customer service | Contact Details, Identification Data, Personal Information and Financial Data | Legitimate Interest |
We process your personal data in relation to incidents and accidents. | Health and Safety | Contact Details, Identification Data, Personal Information, Web Data, Health Data and Travel / Stay Information | Legal obligation, Vital Interest, Legitimate Interest and when processing special category personal data - Heath Exemption |
We process your personal data for invoicing purposes. | Account Management | Contact Details, Identification Data, Personal Information and Financial Data | Contract |
We process your personal data in order to comply with legal requirements and exercise or defend legal claims. | Litigation & Disputes | Contact Details, Identification Data, Personal Information, Health Data and Travel / Stay Information | Legal obligation, Legitimate Interest and when processing special category personal data - Legal Claims Exemption |
We process your personal data for competition and event purposes. | Customer service and processing/fulfilling orders and transactions | Contact Details, Identification Data, Personal Information, Health Data, Travel / Stay Information and Financial Data | Contract, Legitimate Interest and when processing special category personal data - Explicit Consent |
We process your personal data in order to provide medical care where required. This includes COVID-19 processes and procedures | Health and Safety | Contact Details, Identification Data, Personal Information, Health Data and Travel / Stay Information | Consent, Vital Interest and Legal obligation and when processing special category personal data - Heath or Social Care Exemption |
We process your personal data in order to improve the services we provide. | Customer Service | Contact Details, Identification Data, Personal Information, Web Data, Health Data, Travel / Stay Information and Financial Data | Legitimate Interest and when processing special category personal data - Explicit Consent |
For management and audit of our business operations including accounting | Audit Purposes and Financial Management | Contact Details, Financial Details, Personal Information, Identification Data, Health Data, Travel / Stay Information | Legitimate Interest and when processing special category personal data - Heath Exemption |
We process your personal data for security purposes and to ensure secure backup and archival of IT Systems. | Security Purposes | Contact Details, Identification Data, Personal Information, Web Data, Health Data, Travel / Stay Information and Financial Data | Legitimate Interest and when processing special category personal data – Legal Claims Exemption |
Identifying, investigating and mitigating incidents, such as if a personal data breach occurred | Security Purposes | Contact Details, Identification Data, Personal Information, Web Data, Health Data, Travel / Stay Information and Financial Data | Legitimate Interest and when processing special category personal data – Legal Claims Exemption |
CCTV: We have CCTV cameras across our premises, in all entrances to our buildings and in public areas such as our restaurants and lounges. We use CCTV in order to better ensure the safety and security of our guests and our staff. It is in our legitimate interest to process any personal data captured. Your personal data will not be kept longer than necessary to meet the purposes detailed above. CCTV signage is in place where required by local laws or regulations
Personal Data Indirectly Obtained from Others
We also receive some information about you from third parties. These are further detailed below:
Medical Service Providers: As necessary, we obtain your personal data from medical service providers when accidents and incidents occur, as well as in order to provide medical care when required.
Airport Authorised Resellers: As necessary, we obtain your personal data from airport authorised resellers for membership information purposes and to manage and fulfil bookings.
Travel and Leisure Booking Websites: As necessary, we obtain your personal data from travel and leisure booking websites for membership information purposes, to manage and fulfil bookings, to facilitate the check-in and out process, to manage complaints, in relation to competitions and events and in order to provide medical care when required.
Financial Service Providers: As necessary, we obtain your personal data from financial service providers for membership information purposes and to manage and fulfil bookings.
Social Media Platforms: As necessary, we obtain your personal data from social media platforms for analytics purposes, in order to manage and progress complaints, for marketing purposes, in order to improve the services provided and to conduct surveys.
To the extent necessary, we may also receive your personal data from other entities within Dubai Holding Entertainment LLC’s holding company and/or group of companies.
Legitimate Interest
Where we rely upon legitimate interest as a lawful basis, we have balanced your rights and freedoms against our interests, or those of any third parties, and determined your rights are not infringed. Legitimate Interest is where your personal data is processed for either our own interests or the interests of third parties. This can include commercial interests, individual interests or broader societal benefits.