REAL ESTATE HOSPITALITY EDUCATION COMPANY BLOG PRIVACY POLICY PRIVACY POLICY This Privacy Policy explains how personal information is collected, used and disclosed by Seven Tides International, including all its entities, plus rights and choices you have in relation to the personal data we hold and process. This Privacy Policy applies to our clients, customers, homeowners, suppliers, employees and other third parties (e.g. professionals such as lawyers, accountants, surveyors, consultants etc.) and visitors to our websites (individuals) as set out below: seventides.com seventides.com/seven-palm seventides.com/golf-views anantararesidences.com dukeshotel.com dukesdubai.com dukescollection.com west14th.ae gbrrestaurantslondon.com By instructing us to act on your behalf and by visiting or using our websites, you are consenting, to the extent permitted by applicable law, to us gathering and processing information about you in accordance with this Privacy Policy, although consent may not be required for all the elements described in this Privacy Policy. For particular types of information or processing, we may provide you with choices or request your further consent related to the information that we collect and how we may process it. This Privacy Policy is separate and in addition to confidentiality obligations we owe to our clients, customers, homeowners, suppliers, employees and other third parties (e.g. professionals such as lawyers, accountants, surveyors, consultants etc.) and you should also refer to our terms of appointment for further details. About Us Seven Tides is a Dubai-based, privately owned property development and holding company established in 2004. Currently focusing on luxury hospitality and residential real estate sectors, Seven Tides thinks progressively, works creatively, partners strategically and acts quickly. The result is a current portfolio of offerings in the gateway cities of Dubai and London. Data That We Hold We may hold data about the following individuals: Employees Customers and clients Suppliers and service providers Advisors, consultants and other professional experts Complainants and enquiries Information of individuals gathered through marketing and advertising campaigns Information of brokers / agents who have signed agreements with us Information of individuals who visits our websites and submits their data either via the Contact Us forms or subscribing to our Newsletters Data We Collect – Real Estate We will only collect information that is relevant to the contract signed with you or information you have provided us with pursuant to an enquiry. In particular we may collect the following information from you which is defined as ‘personal data’: Personal details, including identity data and contact details Financial details Business activities of the person whose details we are processing We never collect any personal data from you when you view one of our websites unless you expressly register through our Contact Us forms, subscribe to our newsletter or send us an enquiry via email. We never collect information that is referred to as being in a ‘special category’ under the General Protection Regulation 2016/679 (GDPR). We also operate a client relationship management email mailing list programme, which we use to inform clients and other contacts about our services, properties and special promotions. Such marketing activities may contain tracking technologies in order for us to track subscriber activity relating to engagement, demographics and other data. If you would like to stop receiving marketing materials from us at any time, please contact sales@seventides.com. You can also change your preferences for receiving our marketing emails and updates from us at any time, simply unsubscribe by following the instructions specified in our marketing emails or via the websites. Data We Collect – Hotels The personal information we collect when you interact with us through any of our hotel websites includes: When you make a booking, we need to know your name, address, username, password, telephone number, email address and card details. This allows us to process and fulfill your booking. You have the option to withhold personal information that is not required for the booking process. We do not sell, rent or exchange personal information with any third party for commercial reasons, beyond the essential requirement for credit/debit card validation during purchase. We may be required to give information to third parties such as expert witnesses, law enforcement agencies, courts and other professional advisers. We never send emails asking you to provide personal or credit card information nor do we disclose buyer’s information to third parties. Web Browser Cookies Our websites use “cookies” to enhance your user experience. Cookies are small text files that the browser places on your hard drive. These are for record-keeping purposes, with shopping carts to track the contents of your shopping cart, to store delivery addresses if the address book is used and to store your details if you use the “Remember Me” option. You may choose to set your web browser to refuse cookies, or to alert you when cookies are being sent. You can turn off cookies within your browser by going to Tools – Internet Options – Privacy, and selecting to block cookies. If you turn off cookies, you will be unable to place bookings or benefit from other features that use cookies. Google Analytics Our websites use Google Analytics, a web analytics service provided by Google Inc. Google Analytics uses “cookies”, which are text files placed on your computer, to help the website analyse how users use our sites. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers outside of the EEA. Google will use this information for the purpose of evaluating your use of the websites, compiling reports on website activities for website operators and providing other services relating to website activity and internet usage. Google may also transfer information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser; however please note that if you do this you may not be able to use the full functionality of our websites. By using our websites, you consent to the processing of data about you by Google in the matter and for the purposes set out above. Data Collection – Real Estate When your organization seek our services When you or your organization make an enquiry (including, without limitation, in person, through email, via our website and/or social media platforms or over the phone) When you attend any events (including, without limitation, project launches, exhibitions, seminars and conferences) or sign up to receive communication from us When you or your organization provide services to us, or otherwise offer to do so When you register on any of our websites through completing our Contact Us forms or subscribing to our newsletters Data Collection – Hotels Data collected by our corporate websites, as listed in our Privacy Policy, is used to: Take and fulfill customer bookings Administer and enhance the sites and services Only disclose information to third parties for goods delivery purposes Any information stored by Seven Tides is encrypted for your protection Your personal information is used in a variety of ways, including but not limited to, when you visit our websites, place bookings, subscribe to our newsletter and in connection with other activities, services, features or resources we make available on our sites. You may be asked for, as appropriate, name, email address, mailing address, phone number etc. You may, however visit any of our sites anonymously. We will collect personal identification information from you only if you voluntarily submit such information to us. Credit Card Information Our payment processes are PCI DSS compliant. In booking to process credit and debit card transactions, the bank or card processing agency may require to verify your personal details for authorization. We do not store credit card information which is passed directly to our payment service provider. We follow strict security procedures in the storage and disclosure of information which you have given to us to prevent unauthorized access in accordance with the GDPR regulations. Emails We will send emails to you, for the purpose of informing you of new products, offers and services. You may have consented to us sending you newsletters from time to time as part of the registration process. You may opt out of this notification service by clicking on the unsubscribe button on the newsletter and/or email communication received from us alternatively you can send an email with the word ‘unsubscribe’ in the subject line to sales@seventides.com Basis For Processing The basis on which we process your personal data is one or more of the following: It’s necessary for the performance of our contract with you It’s necessary for us to comply with a legal obligation It’s in our legitimate interests to do so You have given us consent (this can be withdrawn at any time upon request by sending an email to sales@seventides.com) How We Use Your Data – Real Estate We may use your information for the following purposes: Provision of real estate services including advising and acting on behalf of clients (including where we are acting on your behalf on a sales/leasing transaction in the land department or any government or semi-government department responsible for real estate transactions in the relevant emirate of the United Arab Emirates) Promotion of our products and services Maintaining accounts and records Supporting and managing employees Managing and administering your or your organization’s business relationship with us, including processing payments, accounting, auditing, billing and collection or support of services Complying with our legal and regulatory obligations (such as record keeping obligations) and for insurance purposes Communicating with you through appropriate channels to keep you up to date on the latest developments, announcements, and other information about our services, properties as well as events and exhibitions we may organize For any purpose related and/or ancillary to any of the above or any other purpose for which your personal data was provided to us How We Use Your Data – Hotels We will use your personal information to manage bookings, provision of services, offers, surveys and newsletters you have requested. Specifically: To keep you informed of any special offers, company news, updated product information or events that we believe might be of particular interest to you To administer and operate your account and to fulfill bookings placed through our websites For payment processing associated with the fulfillment of bookings To respond to your customer service requests To track activity on our websites For record-keeping purposes For market research To confirm your identification when you contact us Automated Decision Making We do not undertake any automated decision, excluding Google Analytics, making using your data, nor do we use your data for profiling or any other investigative purposes Sharing Information We may share your personal information outside our company and this may include: Third party agents/suppliers or contractors, bound by obligations of confidentiality, in connection with the processing of your personal information for the purposes described in this Policy. This may include, but is not limited to, IT service providers Third parties relevant to the real estate services that we provide. This may include, but is not limited to, professional service providers, regulators and government authorities (land departments of relevant emirates) To the extent required by law, regulation or court order, for example, if we under duty to disclose your personal information in order to comply with any legal obligation Where you authorize us, we may also disclose your information to your family, associates or representatives and we may also disclose your information to debt collection agencies if you do not pay our invoices How Long We Keep Your Information For We will normally keep your information throughout the period of time that we do work for you and afterwards for such period as we are required to do so by law and also by the regulations and insurance requirements that apply to us Usually this will be for a period of six years after we conclude the work we have carried out for you, but may be for a longer period in specific cases (including and in particular with regards to real estate transactions) Transfers To Third Countries We may from time to time transfer your personal data to a country outside of the United Arab Emirates (UAE) and United Kingdom (UK). Normally this will be necessary for the performance of your contract with us. Sometimes we may transfer for other reasons and we will ensure that appropriate safeguards are in place at all times. These safeguards may include: You have explicitly consented to the transfer of your personal data Security Arrangements We take appropriate technical and organizational measures to keep your personal data confidential and secure, in accordance with our internal policies and procedures regarding storage of, access to and disclosure of personal data We may keep your personal data in our electronic systems, in the systems of our contractors, or in paper files We have security measures in place to ensure that we can effectively identify report, manage and resolve personal data breaches We have procedures to deal with key data subject rights, like subject access requests and the right to request erasure We are reviewing our key third party vendor arrangements to ensure that we have the appropriate contractual protection in place to satisfy GDPR requirements We regularly review our data security procedure to ensure they are kept up-to-date Your Rights You have the following rights under the GDPR: Right to be informed Right of access Right to rectification Right to erasure – complete deletion of your personal data Right to restriction of processing Right to data portability Right to object Rights concerning automated decision-making and profiling Subject To Access Request Under GDPR, individuals are entitled, subject to certain exceptions, to request access to information held about them. This is called a Subject Access Request. The information that you are entitled to is: What information the company holds about you and why How you can gain access to it How to keep it up to date How the company is meeting its data protection obligations We will usually process your request free of charge and within 30 days however we reserve the right to charge a reasonable administration fee and to extend the period of time a further 60 days if the request is manifestly unfound or vexatious and/or is very complex Right to Erasure You have the right to ask us to erase your personal data in certain cases We will deal with your request free of charge and within 30 days but reserve the right to refuse to erase information that we are required to retain by law or regulation, or that is required to excise or defend legal claims To exercise your right to erasure, please contact us by email on info@seventides.com together with proof of identity Complaints If you are dissatisfied with our handling of your requests about the protection of your data, you have the right to complain to us by emailing info@seventides.com Changes To Our Privacy Policy This Privacy Policy was last updated on 30th September 2019. We have the right to update the contents of this Privacy Policy from time to time to reflect any changes in the way in which we process your personal data or to reflect legal requirements as these may change. If we update the Privacy Policy, we will post the revised Policy on our website. Changes will take effect as soon as the revised version is made available on our website. About Terms of use Privacy Policy FAQ Careers Contact us © 2018 Seven Tides International. All Rights Reserved.