Privacy Policy

Introduction

This Privacy Notice ("Notice") outlines how Galadari Ice Cream Co. Ltd. LLC collects, uses, and protects your personal data. This Notice applies to the parent company, Galadari Brothers Co. LLC (incorporated in the Emirate of Dubai, United Arab Emirates), as well as Galadari Ice creams’ affiliated entities, which may collect and process your personal data as data controller.

Our commitment is to process your personal data transparently, securely, and in accordance with applicable privacy laws and best practices. Your personal data may be processed for the purposes specified in this Notice, or for other purposes that we will communicate to you at the time of collection.

In this Notice, "we," "us," and "our" refer to Galadari Ice Cream Co. Ltd. LLC and its affiliates. The terms "you" and "“your" refer to the individual whose personal data is being collected or processed.

Our goal is to ensure that you feel confident in how we handle your personal data, and we encourage you to read this Notice carefully to understand our privacy practices. If you have any questions or concerns about how your personal data is being used, please contact us using the details provided at the end of this Notice.

Who are we?

Galadari Ice Cream Co. Ltd. LLC is the data controller for the purposes of the applicable data protection laws.

Definitions Covered in this Notice

When we refer to "processing" your "personal data" in this Notice, we qualify this as any action done with or in connection with your personal data (this includes gathering, storing, and deleting such personal data). Any information that can be used to locate or (in)directly identify you is considered as “personal data”. Examples of personal data are name, address, email address, mobile number, age, gender just to name a few

What this Notice Covers

• The types of personal data we collect from you;
• How and why, we collect and use your personal data;
• When and why, we may share your personal data within Galadari Brothers Co. LLC or with other third parties;
• How we safeguard the personal data we collect; and
• The rights and choices you have regarding your personal data.

This Notice applies whenever you use our services, including:

• Purchasing products from Galadari Ice Cream Co. Ltd. LLC by phone, in-store, or online;
• Using any of our platforms, including websites or mobile apps;
• Participating in any of our loyalty programs;
• Taking part in our promotions, competitions, or surveys, and subscribing to our newsletters and offers; and
• Contacting us or when we contact you about our services.

This Notice also covers interactions with us online, through call centers, or any other means related to our services.

Types of Personal Data Collected

We process different categories of personal data further described below.

1. Contact Details

   Contact details is personal data that helps us to contact you, such as your address, email address and phone number.

2. Identification Data

   Identification Data is personal data that helps us identify you, such as first name, last name and title, and mobile number.

3. Web Data

   Web data is personal data collected via our websites such as cookies, user activity records, IP addresses, social media profiles, and information about your interactions on our websites.

4. Geolocation Data

   Geolocation data is personal data such as the location of your device.

5. Financial Data

   Financial data is personal data such as your bank and card information.

Why and How we Use Your Personal Data

Description of Processing	Category of Personal Data	Legal Basis
We process your personal data when we offer our products and services such as food and beverages.	Contact Details, Identification Data, and Financial Data	Consent, Performance of Contract
We process your personal data so we can monitor the quality of our products and services to you, to conduct surveys, obtain feedback and manage and progress complaints as necessary.	Contact Details	Consent
We process your personal data for marketing and analytical purposes, including managing our loyalty programs and customizing offers for you. This may include the transfer and processing of your personal data to and by our affiliates for their loyalty programs.	Contact Details, Identification Data, Web Data, and Financial Data	Consent, Legitimate Interests, Performance of a Contract
We process your personal data to fulfil our legal obligations and to investigate or defend legal claims.	Contact Details, Identification Data, Sensitive Personal Data, Web Data, and Financial Data	Legal obligation
We process your personal data for accounting, administration, and auditing purposes related to our business operations.	Contact Details, Identification Data, and Financial Data	Performance of Contract
We process your personal data to protect and secure our IT systems or for backup and archiving purposes or to prevent a potential data breach.	Contact Details, Identification Data, Sensitive Personal Data, Web Data, and Financial Data	Consent
We process your personal data to safeguard the safety and security of all customers and employees in our buildings or properties either owned or rented.	Identification Data and Sensitive Personal Data	Protection of the interest of the data subject
We process your personal data to communicate with you about our services through phone or email.	Contact Details, Identification Data, and Financial Data	Consent

Sharing Your Personal Data

We may share your personal data with third parties under the following circumstances:

Our Affiliates

We may share personal data collected by any of our affiliates with other affiliates for the purposes mentioned above.

Retail Partners

We may share your personal data with companies that sell our products through their platforms ("Retail Partners"). We collaborate closely with trusted partners who need your information to help provide our services. For example, when you shop online or in-store, we provide the relevant Retail Partner with your name, contact details, and address so they can deliver your items.

Service Providers

We work with carefully selected service providers who perform certain functions on our behalf. These include companies that assist with technology services, data storage and integration, payment processing, and order delivery. We only share the personal data necessary for our service providers to perform their duties.

Some service providers manage online media channels, where they place ads for our products and services, as well as those of our suppliers and Retail Partners. For example, you might see an ad for our products and services on a social media site.

Marketing, Security & Analytics Partners

We may share your personal data with third-party marketing, security, and analytics service providers to help us market, secure, and understand the use of our services and platforms.

Other Circumstances

We may share personal data with other organizations in the following situations:

• When required by applicable law or a public authority;
• When we sell or transfer (or negotiate to sell or transfer) any part of our business or our rights and obligations under any agreement with you. If the transfer or sale proceeds, the receiving organization may continue to use your personal data based on this Notice until they agree to new terms with you;
• With any successors in title to our business; or
• With anyone to whom we transfer our rights and duties under our agreement with you.

Sharing Your Personal Data with Other Organisations

We may share your personal information in the following situations:

• When required to do so by applicable law or a public authority;
• When it is necessary to share personal information to establish, exercise, or defend our legal rights (this may include sharing information to prevent fraud or reduce credit risk);
• If we sell or transfer (or enter into negotiations to sell or transfer) any part of our business or any of our rights or obligations under an agreement with you. If such a sale or transfer occurs, the receiving organization may use your personal information in the same manner as we do;
• To any successors in title to our business; or
• To any party to whom we transfer or may transfer our rights and responsibilities under our agreement with you.

Transfer of Your Personal Data to Other Countries

When processing your personal data, we might share it with third parties in other countries to the extent required to achieve the purposes stated in this Notice. Your personal data may be shared within this group of companies, as well as with Galadari Brothers Co. LLC's subsidiaries located in countries outside of the UAE. Such transfers shall be continually done in accordance with applicable data protection laws. We transfer personal data from the United Kingdom and the European Economic Area ("EEA") to organizations outside the EEA in accordance with the EU Standard Data Protection Clauses. For more information regarding transfers, please contact us at dpo@galadaribrothers.com.

How We Secure Your Personal Data

We are committed to protecting the information you provide us. We have adopted appropriate technological and operational security measures to protect your personal data against accidental loss, abuse, alteration, or destruction. Only authorized people have access to personal data, and these individuals are contractually bound to keep it confidential. We require our suppliers and vendors to implement appropriate safeguards when they access or use personal data that we share with them.

While we strive to ensure the security and protection of your personal data, its security also depends on the safety of the computer or mobile device you use to communicate with us, as well as the security measures you take to protect your user ID and passwords. To keep your personal data safe, please take appropriate steps to safeguard your user ID, passwords, and any other information needed to access our platforms.

Retention of Personal Data

We only retain your personal data for as long as necessary to carry out the purposes indicated in this Notice. After this period, we will securely delete your personal data, unless we are obligated to retain your personal data to comply with a legal or regulatory requirement or to deal with any potential disputes.

If we no longer need to keep your personal data, we will delete it from our systems and records and/or take steps to properly anonymize it so that you cannot be identified from it.

Marketing Communications

All marketing communications we direct at you we will provide you with a way to withdraw your consent to future marketing. If you no longer wish to receive promotional materials you may opt-out from receiving these communications or change your account settings, this will remove you from marketing lists.

Please note that if you unsubscribe from marketing communications you will still receive operational and service messages from us regarding the services or products you bought from us and responses to enquiries made to us.

Cookies and Similar Technologies

We use cookies and similar technologies to personalize and enhance your experience on our websites and mobile apps, as well as to deliver relevant online advertising. Cookies are small data files that allow a website or app to collect and store information on your computer or mobile device.

Cookies enable us to provide important features and improve the functionality of our websites and mobile apps. For instance, we use cookies to:

Improve Functionality

Cookies help us enhance how our websites and mobile apps operate, allowing us to personalize your experience and enable useful features. For example, cookies remember your preferences and keep the contents of your shopping cart when you return to our sites or apps.

Enhance Performance

Cookies help us understand how our websites and mobile apps are being used, such as alerting us to error messages. The data collected is typically aggregated and anonymous.

Deliver Relevant Advertising

We use cookies to show you online ads that are most relevant to you on our websites and others. These cookies, sometimes placed by other organizations with our permission, may track your online behaviour, like your IP address, browsing history, and shopping cart contents. This means you might see our ads on other websites, and ads from other organizations on our websites.

We may also combine data from cookies on your computer or other devices with other information we have, such as loyalty program data, to deliver more relevant advertising.

Measure Marketing Effectiveness

Cookies help us track whether you’ve seen a particular ad and how long it’s been since you last saw it. This allows us to measure the effectiveness of our advertising and limit the number of times you see the same ad. We also use cookies to see if you’ve opened a marketing email from us.

Your Privacy Rights

You have certain rights that you can exercise. Please send an email to dpo@galadaribrothers.com to exercise your rights. The following rights may be applicable to you, depending on the jurisdiction where your personal data is processed:

Data Privacy Right	What does it mean?
Right to access your data	You have the right to request from us a summary or a copy of the personal data that we have on file about you.
Right to have your data updated or deleted	You have the right to request that we immediately amend any inaccurate or missing personal data we may have about you along with the right to request that your personal data be deleted if it is no longer needed or processing it is prohibited by law.
Right to limit or stop data processing	You have the right to limit how your personal data is processed in certain situations.
Right to request transfer of personal data or data portability	You have the right to obtain your personal data in an organized, machine-readable manner, or request to transfer it to a third party.
Right to raise objections to data processing	You have the right to raise an objection to the processing of your personal data.
Right to revoke consent	You have the right to revoke your consent at any point The legitimacy of processing done using your consent prior to its revocation will remain unaffected by the withdrawal of your consent.
Right to file a complaint	You have a right to file a complaint with the Emirates Data Office or the relevant supervisory authority in your country if you believe that we have not complied with the applicable data protection laws.

It is important to note that the rights stated above are not absolute and that not every request can be fully granted. In certain cases, for instance where we are required to retain your personal data by contracts or the law, we might not be able to delete it or limit its processing.

Automated Decision Making/Profiling

Our artificial intelligence technologies may enable automated data processing in several fields. This is called “profiling”. If we make use of profiling, we will always obtain your consent. We will also conduct privacy impact assessments to implement appropriate measures to protect your rights.

When we make use of profiling, you have the right to object against it. This right can be invoked by using the contact details provided in the "Contact Us" section below.

Personal Information from Minors

Our platform is not directed towards children. We do not knowingly collect personal information from a child under the age of 16, such as a name, email, telephone number, or any other information, without the consent of a parent or guardian. If parent or guardian consent is required, we will collect the email address of the parent or guardian so we can provide notice of our information and/or seek the parent's or guardian's consent.

Privacy Center

Our Privacy Center enables you to customize your consent preferences. By clicking on Privacy Center, you can manage the consent given to us.

Contact Us

If you have any questions or concerns about this Notice, please contact us at dpo@galadaribrothers.com.

Updates to the Notice

This Notice may be updated on a regular basis to reflect new developments. We reserve the right to update, add, or remove portions of this Notice at any time. You are also advised to revisit this Notice periodically for updates.

The most recent update to this Notice will be indicated below.

Date of Publication –14 October 2024