Privacy Policy

1. WHAT IS THE OBJECT AND SCOPE OF THIS PRIVACY POLICY?

1.1 This Policy applies to data collected in-store, by mail or by telephone when you contact our customer service department, as well as when you use our website or mobile app. These rules relate to the personal data collected directly from our customers and prospects, regardless of the data collection channel.

1.2 This Privacy Policy (Policy) informs you of the conditions under which DPAM collects and uses your personal data. DPAM acts as data controller in respect of the personal data that we process. This means that we are responsible for deciding how we hold and use personal data concerning you.

1.3 This Policy applies to data collected in stores, by mail or by telephone when you contact our Customer Service, as well as when you use our website or our mobile application (Application). These rules apply to the processing of the personal data of all our customers and prospects, regardless of the data collection channel.

1.4 This Policy is permanently accessible to everyone at: www.dpam.ae . This Policy is independent of any other document that may apply within the contractual relationship between DPAM and our customers and prospects, in particular, our General Conditions of Sale and our Cookies Policy.

1.5 This Policy was last updated on 10/10/2023 and we reserve the right in our sole discretion to amend and / or delete this Policy at any time without providing prior notice to you. We therefore encourage you to review this Policy when you visit our website and / or Application from time to time to stay informed about how we are using your personal data.

1.6 We recognise and respect the importance of the privacy of the users of our website and Application. This Policy accounts for the personal data used / collected via our website and Application. If you do not agree with the terms of this Policy, please do not use our website or Application and delete the cookies placed by us.

2. WHAT PERSONAL DATA DO WE COLLECT AND USE?

2.1 We only collect and process the personal data that is necessary for us in the context of our activities, particularly in order to offer you personalised and quality products or services.

2.2 We may need to collect different types of personal data concerning you, in particular:

- Identifying information about you and your family (e.g. name, surname, date of birth, gender, IP address, number of children, birth of a child);

- Contact details (for example, postal address and e-mail address, telephone number);

- Banking, financial and transactional data (for example information related to means of payment, etc.);

- Information related to your digital activities (for example, IP address, browsing activity, geolocation, connection data);

- Commercial data: for example customer number, purchase history, information relating to your customer account and your loyalty account, opinions on our products, purchasing habits, recordings of telephone conversations, etc;

- Data relating to your habits and preferences;

- Data collected as part of our interactions with you, our websites, our applications, our pages on social networks, customer service calls, chats, emails, telephone conversations.

2.3 The mandatory or optional nature of our collection and processing of your personal data is indicated to you on each collection form, with mandatory personal data being represented by an asterisk.

3. HOW AND WHEN DO WE COLLECT YOUR PERSONAL DATA?

We collect the personal data you provide to us from various sources, including:

• on our website:

(a) in the “Create an account” section;
(b) in the “Newsletter” section;
(c) in the “Loyalty Programme” section;
(d) in the “Contact us” form; and
(e) at the time of your order, requiring an account creation in advance, particularly to be able to ensure delivery;
(f) within the application form within DPAM or
• in stores, when paying for my purchases, when requesting electronic receipts ; or
• during your discussions with customer service.

4. COOKIES, GEOLOCATION AND NOTIFICATIONS

A cookie is a small file that is stored and read on our website during your consultation. A cookie can also be used when reading an email, installing or using a mobile application from your computer, smartphone, tablet, etc. Learn more

You can, if you wish, decide to activate the “geolocation” functionality of our Application. The purpose of this functionality is to improve the use of the “find a store” search service offered by the Application, by making it easier for you to find the nearest store. This feature can be activated or deactivated by the user at any time and without charge.

You can, if you wish, during the download or the first connection, authorise the Application to send you notifications. You can also allow the website to do the same. By activating the "notifications" feature, you can receive DPAM commercial offers and information related to your profile. This functionality can be deactivated by the user at any time and free of charge.

By authorising notification and / or geolocation, you can also receive push notifications of information on our offers, or products related to DPAM stores in the UAE. So, you can receive mobile notifications even when the Application is in “standby” or “cache” mode.

5. WHY AND ON WHAT LEGAL BASES DO WE PROCESS YOUR PERSONAL DATA ?

We will only process your personal information when the law allows us to. In most cases, we will process your personal information where it is necessary:

• to comply with our legal or regulatory obligations: we use your personal data to comply with various legal and regulatory obligations to which we are required, including: financial regulations: under which we put in place security measures to prevent abuse and fraud; for accounting purposes and monitoring of purchases made; and to respond to official requests from duly authorised public or judicial authorities; or

• to keep records of consents received to our processing of personal data (e.g., cookies acceptance, receipt of commercial offers, etc.);

• to enter a contract with you or to contact you, at your request: we use your personal data to conclude and perform our contracts, particularly to provide you with information about our products; deliver your purchases to you; respond to your requests and complaints; provide you with after-sales service; and to have recourse against you for unpaid bills; or

• for the pursuit of our legitimate interests as a business: we use your personal data for the purpose of setting up and developing our products or services, optimising our risk management, defending our rights, and also in order to: keep proof of operations or transactions; manage information technology, including infrastructure management (e.g., shared platforms), service continuity and IT security; select candidate profiles for a job or the opening of a shop; establish anonymised statistical models, tests, for research and development, in order to optimize the risk management of DPAM or to improve our offer of new or existing products; and personalise the products or services we offer you.

• We pursue our legitimate interests through: our analysis of your habits and preferences on our various channels of communication with you (visits to our stores, emails or messages, visits to our websites, Application, etc.); the correspondence made between the products from which you already benefit and the data concerning you that we hold; the management of games, sweepstakes, gifts, contests or other similar marketing campaigns or the offering of promotional games or the organization of events; communications about our products, news and what we do at DPAM; customer service management, including answering your questions; the improvement and personalisation of your experiences on our sites and applications; managing your accounts, including administering any loyalty or reward program that may be linked to your account(s); and the management and sending of prizes won by participating in one of our promotional offers.

Your personal data may be aggregated into anonymised statistics to be offered to our business customers in order to help them develop their activities. In this case, our business customers will not be able to identify you, and your personal data will never be disclosed to them.

In certain cases, your consent is necessary for us to be able to process your personal data for a specific purpose, in particular:

• to improve your experience when you use our websites and Application;

• to implement direct marketing operations and offer you offers tailored to your needs, send you communications and commercial offers and conduct satisfaction surveys;

• to manage and publish customer reviews on our products, inform you of new services or changes to our sites and applications; and

• for certain interactions on social networks, for the purpose of administering contests or other marketing operations of this type.

6. WITH WHOM DO WE SHARE YOUR PERSONAL DATA?

In order to accomplish the aforementioned purposes, we may disclose your personal data only to:

• other DPAM entities;
• providers performing services on our behalf;
• judicial or financial authorities, state agencies or public bodies, at their request and within the limits of what is authorised by the data protection regulations; and
• regulated professionals such as lawyers, notaries or auditors.

7. HOW LONG DO WE KEEP YOUR PERSONAL DATA?

We keep your personal data for as long as necessary to comply with applicable regulations, or for a period defined with regard to our operational constraints, such as good account management, efficient customer relationship management, as well as to respond to requests. in court or at the request of authorities and regulators.

Most of the personal data relating to our customers is kept for a maximum of three (3) years following the last contact (order, wishlist, request for product alerts, click on a newsletter, etc.). The data concerning your advertisements published on the second-hand module of the mobile application will be kept for a maximum of five years following the expiration of the advertisement. Any financial data relating to orders will be kept for ten (10) years following the closing of the accounts.

Personal data concerning applications for a position or the opening of a store will be kept for a maximum of two (2) years following the application.

8. WHAT ARE YOUR RIGHTS AND HOW CAN YOU EXERCISE THEM?

You have the following rights in respect of your personal data:

• right of access: you can obtain information concerning the processing of your personal data as well as a copy of this data;

• right to rectification: if you believe that your personal data is inaccurate or incomplete, you can request that this data be modified accordingly;

• right to erasure: you can request the deletion of your personal data, within the limits of what is permitted by the regulations;

• right to restriction of processing: you can request restriction of processing of your personal data;

• right to withdraw your consent: if you have given your consent for the processing of your personal data, you can withdraw this consent at any time;

• right to portability of your data: when this right is applicable, you can request the communication of the personal data that you have provided to us, or, when technically possible, the transfer of this to a third party;

• right to object to processing of your personal data: you have the absolute right to object at any time to your personal data being used for commercial prospecting purposes, or for profiling purposes if this profiling is linked to commercial prospecting; and

• right to lodge a complaint by sending it by email to the following address: info@dpam.ae or via the Online chat on our website,

You are not required to pay any charge for exercising your rights. If you make a request, we have one (1) month to respond to you.

9. WILL YOU RECEIVE COMMERCIAL OFFERS?

Where you have provided your consent to marketing, or you are an existing customer who has bought products from us previously and have not opted-out of receiving marketing, we may use your contact details to send you marketing materials, particularly by post, email or SMS as follows:

• marketing by post: we may send you marketing materials for our products and services by post. You may also receive offers by post from our partner companies; and

• marketing by email or SMS: you may receive marketing materials by email or SMS for our products and services, as well as offers for products and services from partner companies.

If you do not wish to receive such marketing materials, you may withdraw your consent at any time, or if you have opted-in to receive marketing information, you may opt-out at a later date, by:

• contacting our Customer Service at : info@dpam.ae

• for marketing materials by email, you may click on the “unsubscribe” link in each email or by contacting our Customer Service using the contact details above; or

• for marketing by SMS, by replying “STOP SMS” to the number appearing in each SMS or by contacting our Customer Service using the contact details above,

We will only seek and rely on your consent where you are fully informed and your consent can be freely given.

There may be limited circumstances where we will approach you to obtain your explicit consent to allow us to process certain particularly sensitive data, or other personal information. If so, we will provide you with full details of the information that we require and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that you do not have to provide your consent and it will not impact on your contract with us if you do not consent.

10. PROTECTION OF MINORS

If you send us the contact details of your children as part of our loyalty programme, our objective is to offer you products adapted to the needs of your children. You can exercise your rights described in paragraph 9 above at any time.

A child may wish to provide us with their contact details directly to subscribe to our newsletter, create a customer account or become a member of our loyalty programme. For those children who are under the age of 16, we will ask them to verify that they have permission from their parents or legal guardians before providing us with their personal data. In our stores, we also ensure that this authorization takes place (e.g., by requiring the presence of a parent or legal guardian when opening the loyalty card).

In the case of children who we are aware are under the age of 13, we will not communicate any news or offers from our brand with them.

11. HOW DO WE ENSURE THE SECURITY OF YOUR DATA?

We have security measures in place to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, or inappropriately altered or disclosed. In addition, we limit access to your personal data to those who need to process that information for business reasons. They will only process your personal data on our instructions and are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach as appropriate and in accordance with our legal obligations.

12. HOW CAN YOU STAY INFORMED ABOUT CHANGES TO OUR DATA PROTECTION POLICY?

We undertake to update this Policy as necessary, and make it available on our website accessible to all.

13. HOW TO CONTACT US?

If you have any questions regarding the processing of your personal data, you can contact our Customer Service at: info@dpam.ae