myAlfred LLC
Privacy Policy

1. INTRODUCTION

   Welcome to MYALFRED LLC’s privacy policy.

   myAlfred LLC (myAlfred LLC, we, us,or our) respects your privacy and is committed to protecting the personal data of all persons who access or use, whether as a guest or a registered user of member of the myAlfred LLC (myAlfred), our websites, any webpages or any content or function or services offered on or through our online or offline mobile applications, which provide dedicated non-browser interaction between you and our sites (together our Sites.

   This privacy policy will inform you as to how we look after your personal data when you visit our Sites (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

2. IMPORTANT INFORMATION AND WHO WE ARE

   Purpose of this Privacy Policy

   This privacy policy aims to give you information on how myAlfred LLC collects and processes your personal data through your use of any of the Sites, including any data you may provide through our Sites when you register or sign in on any of our Sites or become a member of myAlfred.

   This Sites are not intended for children and we do not knowingly collect data relating to children.

   It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

   Controller

   myAlfred LLC is the controller and responsible for your personal data.

   We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

   Contact details

   Attention: Data Protection Officer

   Email address: [email protected]

   You have the right to make a complaint at any time to the relevant supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the relevant supervisory authority so please contact us in the first instance.

   Changes to the privacy policy and your duty to inform us of changes

   We keep our privacy policy under regular review. This version was last updated on December 2021. Historic versions can be obtained by contacting us.

   It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

   Third-party links

   Our Sites will include links to third-party websites, plug-ins and applications, including websites and mobile applications of our Program Partners. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

3. THE DATA WE COLLECT ABOUT YOU

   Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

   We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

   • Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
   • Contact Data includes billing address, delivery address, email address and telephone numbers.
   • Financial Data includes bank account and payment card details
   • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
   • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location data, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our Sites.
   • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
   • Usage Data includes information about how you use our website, products and services.
   • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
   • Third party partner information related to how you use our third party partners, including our Program Partners, such as your reviews of such partners’ goods and services.

   We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Site feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

   We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, information about your health and genetic), except to the extent required by law.

   if you fail to provide personal data

   Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services or to permit you to be a member of our myAlfred). In this case, we may have to cancel a product or service or membership of our myAlfred you have with us but we will notify you if this is the case at the time.

4. HOW IS YOUR PERSONAL DATA COLLECTED?

   We use different methods to collect data from and about you including through:

   • Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
     • apply to become a member of our myAlfred;
     • redeem an offer made by a Program Partner through our myAlfred;
     • apply for our products or services;
     • create an account on our Sites;
     • subscribe to our service or publications;
     • request marketing to be sent to you;
     • enter a competition, promotion or survey; or
     • give us feedback or contact us.
   • Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below
     • Technical Data from the following parties: (a) analytics providers such as Google; (b) advertising networks; (c) search information providers; (d) third parties we contract with and/or their subsidiaries and affiliates to provide you with a service.
     • Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
     • Identity and Contact Data from data brokers or aggregators.
     • Identity and Contact Data from publicly available sources.
   • Automated technologies or interactions. As you interact with our Sites, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
   • Cookies: We automatically capture some information through the use of cookies. A cookie is a small file that is placed onto your desktop or mobile device when you visit our Sites in order to enable certain features and functionality of our Sites. Our cookies can be categorized into four types, each of which is outlined below
     • Category 1: Strictly necessary cookies. These cookies are essential for enabling our Sites to provide certain of your requested services such as retaining your shopping bag items.
     • Category 2: Performance cookies. Performance cookies collect anonymous information on the users of our Sites to enable us to improve the operation of our Sites. For example, we utilise cookies to help us understand how customers arrive at and browse or use our Sites, and highlight improvement areas such as navigation, shopping experience and marketing. The data stored by these cookies does not include personal details from which an individual's identity can be established.
     • Category 3: These cookies retain choices you make such as member ID, email ID and other preferences in order to help you avoid having to re-enter the information as you navigate through our Sites, including the shopping cart.
     • Category 4: These cookies collect information about your browsing habits to allow us to provide advertising relevant to you and your interests. The cookies retain information about the websites you have visited. This information is shared with other parties such as advertisers on an anonymous basis. Your personally identifiable information such as your name and address is not shared with such third parties. For example, we use third party companies to provide you with more personalised advertisements when you visit certain third party websites.
   • Web beacons: Pages of our Sites and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an e-mail and collect other related website and app statistics (for example, recording the popularity of certain app content and verifying system and server integrity).
   • We do not collect personal information automatically, but we may tie this information to personal information about you that we collect from other sources or you provide to us.
   • Log files: We may use log files to capture your activities on our apps as they interact with our Sites. Information captured in such log files may include the types of content you view or engage with and the frequency or duration of your activities

5. HOW WE USE YOUR PERSONAL DATA

   We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

   • where we need to perform the contract we are about to enter into or have entered into with you.
   • where we need to perform a contract we have with a third party to provide you with a product or service or a special offer in relation to a product or service, including agreements with our Program Partners.
   • where we need to perform a contract we have with a third party to provide you with a product or service or a special offer in relation to a product or service, including agreements with our Program Partners.
   • where we need to comply with a legal obligation.

   Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message at the time that you sign up to become a member of myAlfred. You have the right to withdraw consent to marketing at any time by contacting us.

   Purposes for which we will use your personal data

   We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

   Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

   Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
   To register you as a new customer or member of myAlfred	Identity Contact	Performance of a contract with you
   To process your redemptions of offers and rewards on our myAlfred: manage redemption and earning of rewards points; manage payments, fees and charges collect and recover money owed to us	Identity Contact Financial Transaction Marketing and Communications	Performance of a contract with you Necessary for our legitimate interests (to recover debts due to us)
   To manage our relationship with you which will include: Notifying you about changes to our terms or privacy policy Asking you to leave a review or take a survey	Identity Contact Profile Marketing and Communications	Performance of a contract with you Necessary to comply with a legal obligation Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
   To enable you to partake in a prize draw, competition or complete a survey	Identity Contact Profile Usage Marketing and Communications	Performance of a contract with you Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
   To administer and protect our business and our Sites (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	Identity Contact Technical	Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) Necessary to comply with a legal obligation
   To deliver relevant Site content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	Identity Contact Profile Usage Marketing and Communications Technical	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
   To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	Technical Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
   To make suggestions and recommendations to you about goods or services that may be of interest to you	Identity Contact Technical Usage Profile Marketing and Communications	Necessary for our legitimate interests (to develop our products/services and grow our business)

   Marketing

   We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

   Direct Marketing by the Company.

   If you do not wish to have your personal data used by myAlfred LLC to promote our own or third parties' products or services, you can opt-out by contacting us. If we have sent you a promotional e-mail, you will be given the option to opt out or unsubscribe from future emails by clicking on a link or button which will be included in the relevant email.. This opt out does not apply to information provided to the Company as a result of a product or service purchase, product service experience or other transactions.

   Targeted Advertising.

   If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers' target-audience preferences, you can opt-out by contacting us.

   Promotional offers from us

   We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

   You will receive marketing communications from us, including by way of email, sms push notifications, telemarketing calls or if you have agreed to become a member of myAlfred or have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.

   Third-party marketing

   We will get your express opt-in consent before we share your personal data with any third party for the purposes of allowing them to market their goods and/or services.

   Opting out

   You can ask us to stop sending you marketing messages at any time by logging into our Sites and checking or unchecking relevant boxes to adjust your marketing preferences OR by following the opt-out links on any marketing message sent to you OR by contacting us at any time.

   Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

   Cookies

   You can set your browser to refuse all or some browser cookies, or to alert you when our Sites set or access cookies. If you disable or refuse cookies, please note that some parts of our Sites may become inaccessible or not function properly. For more information about the cookies we use, please see Section 4 above.

   Change of purpose

   We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

   If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

   Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

6. WHO MAY WE SHARE YOUR PERSONAL DATA WITH

   We may share your personal data with the persons set out below for the purposes set out in the table set out in Section 5. above:

   • Internal Third Parties as defined in Section 10 below.
   • External Third Parties as defined in Section 10 below.
   • Specific third parties listed in the table in Section 5 above.

   We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

   In some cases, we may choose to buy or sell business assets. In these types of transactions, user information is typically one of the transferred business assets. If we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy or insolvency, user information would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur and that any acquirer of us or our assets may continue to use your personal information as set out in this privacy policy.

7. DATA SECURITY

   We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

   We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. DATA RETENTION

   We only retain your information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements or fulfilling our contractual obligations.

   To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

9. YOUR LEGAL RIGHTS

   Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

   • Request access to your personal data.
   • Request correction of your personal data.
   • Request erasure of your personal data.
   • Object to processing of your personal data.
   • Request restriction of processing your personal data.
   • Request transfer of your personal data.
   • Right to withdraw consent.

   If you wish to exercise any of the rights set out above, please contact us.

   No fee usually required

   You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

   What we may need from you

   We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

   Time limit to respond

   We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. GLOSSARY

    Comply with a legal obligation

    means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

    External Third Parties

    means:

    • Service providers who provide IT and system administration services.
    • Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
    • The Federal Tax Authority of the United Arab Emirates and other regulators and other authorities.
    • Our Program Partners.
    • Marketing and advertising agencies and service providers that we engage to assist us with our marketing and advertising, including to facilitate and implement marketing campaigns.
    • Any other third party, their subsidiaries and affiliates which we have contracted with to provide you with a service and/or product or special offer.

    Internal Third Parties

    means our affiliates and group companies who provide IT and system administration services and undertake leadership reporting.

    Legitimate Interest

    means the interest of our business in conducting and managing our business to enable us to operate myAlfred and give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

    Performance of Contract

    means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

    Program Partners

    means the third party companies and organisations who we partner with to provide you with offers, and offer their goods or services, through myAlfred.

    Your legal rights

    You have the right to:

    • Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
    • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
    • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request
    • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
    • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
      • If you want us to establish the data’s accuracy.
      • Where our use of the data is unlawful but you do not want us to erase it.
      • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
      • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
    • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
    • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.