PRIVACY POLICY

LAST UPDATE: July 30, 2021

INTRODUCTION

This Privacy Policy explains our personal data practices and the choices you make regarding the use of your personal data.

TOPVIEW FZCO respects your privacy and is committed to protecting the privacy, confidentiality and security of the personal information you provide to us or that we collect about you when you use our websites, social network pages that we control and software applications available on computers and mobile devices that include a link to this Privacy Policy, as well as when you provide your information over the phone through our call centres or in person (collectively the “Contact Us”). Sites). Our privacy practices may vary from country to country to reflect local customs and regulations. We are aware of our responsibility to protect your personal data, to keep it safe and to comply with applicable privacy and data protection laws.

You may be asked to agree to the terms of this Privacy Policy when you make a reservation, register for events or promotions or communicate with us in any way through the Sites or if required by law. Otherwise, your continued use of the Sites will constitute your acceptance of the terms of this Privacy Policy.

PERSONAL INFORMATION WE COLLECT
Personal information you send us

When you use our Sites, you have the opportunity to voluntarily provide us with certain information about yourself or others, such as when you create an account or make a reservation. We may collect Personal Information about you or others (information that identifies or relates to you as an identifiable person) that you may provide via the Sites, such as :

• your name, date and place of birth, passport and visa information;
• your mailing address;
• your phone number;
• your e-mail address;
• information to enable us to provide you with specialist services or to meet special requests, such as health conditions or special dietary requirements, but we do not collect sensitive information about you, such as health information, except to reasonably enable us to provide you with certain services;
• your credit or debit card number, expiration date and security code;
• information and preferences regarding your stay or trip, such as your preferred locations/facilities, dates and number of people/children travelling with you ;
• demographic information (age, gender, nationality and desired language)

Automatically collected information

Our websites collect statistical information about users in order to provide a welcoming and accessible website. To do this, we may keep a record of your navigation on the Sites, the pages from which you were referred, the times of access and the type of browser. We only use this information in aggregate form and do not link it to you personally. To evaluate the effectiveness of our websites and analyze site traffic, understand customer needs and trends, we collect generic information about our visitors. Our web servers automatically recognize and record a visitor’s domain name, the web page from which a visitor enters our Web Sites, the pages a visitor views, the time a visitor spends on each page, and the visitor’s IP address. We may use anonymous tracking technologies to collect, store and sometimes keep track of information for statistical purposes or to improve our services, including to evaluate and improve our website. We also collect and store information automatically using cookies and similar technologies described below.

This data does not contain any Personal Information. If we combine anonymized or aggregated data with Personal Information, we will treat such combined information as Personal Information in accordance with this Privacy Policy.

USE OF YOUR INFORMATION

We may use the Personal Information you send to us, as well as the non-personal information we automatically collect, for the purposes described in this Privacy Policy in the general course of our business and in accordance with the legal bases set out, for example, to :

• to process, carry out and record reservations and/or purchases ;
• charge your credit card for bookings and advance payments;
• contact you for confirmation or to offer you services once reservations and purchases have been made or after you have registered for certain activities;
• follow the bookings and stays ;
• send you e-mails about your stay;
• send you communications such as customer surveys or promotional benefits and offers;
• send you special offers, contests and featured products, if you choose to receive such notifications;
• respond to your requests, complaints or other messages;

RELEASE OF YOUR INFORMATION

As an international tourism company, we need to share information between different countries so that we can provide you with our services in a consistent manner. Therefore, your Personal Information may be shared as often as reasonably necessary and as set out in this Privacy Policy with :

• tour operators, travel agencies, personal assistants, employers or spouses who have provided us with your Personal Information;
• third parties for whom we have received your consent;
• trusted partners who process them on our behalf in accordance with our instructions and our Privacy Policy and any other appropriate privacy and security measures, including ;
• our marketing and advertising partners, in order to provide you with more relevant advertising on our websites and to encourage you to return to our websites and to Cheetah Digital or MailChimp, which securely host e-mails and transmit our e-mail communications as our provider. We contractually require these service providers to keep your Personal Information secure and to use your Personal Information only for the purposes we specify.
• Third parties not affiliated with TOPVIEW FZCO if we believe in good faith that it is reasonably necessary for : (1) comply with applicable laws, regulations, legal processes or governmental requests; (2) implement the applicable terms of use, including investigating potential violations; (3) detect, prevent or resolve any illegal, fraudulent, security or technical issues; and (4) to guard against any infringement of the rights, property or security of TOPVIEW FZCO, our users or the general public when required or permitted by law; and (5) to the extent necessary for the sale of all or part of our business activities or our products and/or hosting which are no longer managed or owned by TOPVIEW FZCO.

DATA TRANSFER ABROAD

When you use and/or purchase our services or products, we may transfer your Personal Information to multiple countries. As a result, we may transfer and store your Personal Information:

• on our websites and servers located in Dubai, United Arab Emirates ;
• to or from Dubai, United Arab Emirates, where our headquarters are located;
• in the countries where we own and operate sales offices.
• in the countries where our third party service providers or consultants are located.

Some of these countries may not offer the same level of confidentiality, but we will take reasonable steps to ensure that transfers of information are made under appropriate security conditions so as to preserve your privacy.

EXPLANATION OF THE LEGAL BASIS OF THE PROCESSING OPERATION

The legal basis for the collection and processing of your Personal Information includes :

legal compliance – if required by applicable law (e.g., police requests, fraud investigations or court orders), we may collect and process your data.
legitimate interest – to pursue our legitimate interests, such as providing services and products that you have requested in a way that could reasonably be expected in the course of running our business and that does not materially affect your rights, freedom or interests.

SAFETY

We employ reasonable technical, administrative and physical measures to protect Personal Information contained in our system from misuse, loss or alteration. While we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security.

We are not able to ensure or control the security of the computers, electronic devices or electronic communication methods you use to send e-mails and transmit Personal Information to us via the Internet. It is your responsibility to ensure that the computers, electronic devices and electronic communication methods you use provide an adequate level of security for communicating with us. We are not responsible for any disclosure or interception of your Personal Information before we receive it.

WITHDRAWAL OF YOUR CONSENT

You are not obliged to provide us with your Personal Information. However, if you choose not to provide certain Personal Information that we request and/or require or do not consent to its use and disclosure, you will still be able to visit our Sites, but you may not be able to access certain options, products or services and, in some cases, we may not be able to process your booking.

You have the right to ask us to stop using your information for our direct marketing activities. Please send your written request with your name and contact details to the address below in Contact Us. We will respond to your request within 30 days of receiving your mail or sooner if required by law.

THIRD LINKS

We may allow third parties to link to our Sites or to post a link to their site on our Site. We do not endorse these sites and are not responsible for their privacy practices or those of other sites. We accept no responsibility for activities or information on third party websites.

CHILDREN’S PRIVACY

We do not knowingly collect any Personal Information from children under the age of 13, although we may collect Personal Information from a child as part of the process of participating in activities on the Websites, but always subject to the consent of a parent or guardian.

HOW LONG WE KEEP YOUR PERSONAL INFORMATION

Whenever we collect or process your Personal Information, we retain it only for the time necessary to fulfill the purposes for which it was collected, for active legal proceedings, for an identifiable and ongoing business need (such as record keeping) and to the extent permitted by applicable law.

If there is not sufficient justification to retain such Personal Information, it will be securely erased, eliminated, blocked and/or anonymized, for example by aggregation with other data so that it can be used in a non-identifiable manner for statistical analysis and business planning.

CHANGES TO THIS PRIVACY POLICY

We may change this Privacy Policy without notice. We may at any time use customer information for new, unanticipated purposes not previously disclosed in our Privacy Policy. If our information practices change in the future, we will post the changes to the Privacy Policy on our Sites to notify you and provide you with the ability to opt out of these new uses. Any revised Privacy Policy will apply only to Personal or Non-Personal Information collected or modified after the effective date of such revised policy.

HOW TO CONTACT US

Your main rights under the European Union’s General Data Protection Regulation are as follows: (a) right of access ; (b) right to correction ; (c) right of erasure ; (d) right to limit processing ; (e) the right to object to the processing; (f) right to data portability ; (g) right to complain to a supervisory authority; and (h) right to withdraw your consent. You may exercise these rights in relation to your Personal Information by contacting our Data Protection Officer. You may also contact the latter for any questions or complaints regarding this Privacy Policy or a privacy issue. Contact [email protected]

And please provide us with your full name, address, and telephone number, and a copy of proof of identity (such as an ID card or passport) so that we can verify your identity and verify that we have Personal Information about you or can contact you for further information.

You can also address your complaint/question to the applicable data protection authority.

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