Privacy Policy – shishaart.com

1.      INTRODUCTION

Welcome to the privacy policy of PVG Trading LLC, the operator of shishaart.com.

We respect your privacy and are committed to protecting your personal data. This privacy policy tells you about how we collect, process and look after your personal data when you visit and use our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you. By using this website, users signify their acceptance of this privacy policy.

2.      IMPORTANT INFORMATION

2.1.    This website is intended for users aged 18 and above and we do not knowingly collect data relating to children.

2.2.    It is important that you read this privacy policy together with any other privacy or fair processing notice 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.

3.      WHO WE ARE AND HOW TO CONTACT US

3.1.    The controller and company responsible for the collection and use of your personal data is PVG Trading LLC, a Dubai mainland company with trade license number 1024490, (“shishaart”, "we", "us" or "our"). PVG Trading LLC trades as “shishaart” and forms part of the AIR Global group of companies.

3.2.    If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager on data.privacy@air.global.

3.3.    You have the right to make a complaint at any time to your local regulator for data protection issues. If you are resident in the UAE this is the UAE Data Office established under Federal Decree-Law No. 44 of 2021, the UAE regulator for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the data regulator so, please contact us in the first instance.

4.      CHANGES TO THIS PRIVACY POLICY AND YOUR INFORMATION

4.1.    We may update this privacy policy from time to time by posting a new policy on this website.  Changes will not have retroactive effect so you will only be bound by them from the date on which the new terms are posted on our website.  Please refer to the date of this privacy policy at the bottom of the text so you are aware if the terms have changed. Historic versions can be obtained by contacting us at data.privacy@air.global.

4.2.    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.

5.      THIRD-PARTY LINKS

5.1.    This website may include links to third-party websites, plug-ins and applications. 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.

6.      THE DATA WE COLLECT ABOUT YOU

6.1.    When you access or are directed to our website, various information is exchanged between your terminal and our server. This may include personal data. The information collected in this way is used, among other things, to implement a contract we may have with you, or to optimise our website or to display advertising in the browser of your terminal.

6.2.    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).

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

6.3.1.    Identity Data includes first name, last name, username (if you choose to set up an account) date of birth, age and gender.

6.3.2.    Contact Data includes email address and telephone numbers.

6.3.3.    Financial Data includes bank account and payment card details (to the extent the website offers paid for services/ online sales).

6.3.4.    Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.

6.3.5.    Profile Data includes your username and password, your interests, preferences, feedback and survey responses. 

6.3.6.    Usage Data includes information about how you use our website, products and services.

6.3.7.    Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

6.4.    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 website 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.

6.5.    We do not collect any Sensitive Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, political opinions, criminal record, biometric data or information about your health.

6.6.    Please be aware that if you fail to provide personal data that we need to collect by law, or under the terms of a contract we have with you 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). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

7.      HOW IS YOUR PERSONAL DATA COLLECTED?

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

7.1.1.    Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by email. This includes personal data you provide when you:

7.1.1.1.     request our products or services;

7.1.1.2.     create an account on our website;

7.1.1.3.     subscribe to our service or publications;

7.1.1.4.     request marketing to be sent to you;

7.1.1.5.     enter a competition, promotion or survey; or

7.1.1.6.     give us feedback or contact us.

7.1.2.    Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. If we collect this personal data we will do so by using cookies, server logs and other similar technologies and will provide information about the specific cookies used and how you can adjust your cookie settings in a cookie policy. There is some more information about cookies set out in section 10 below.

7.1.3.    Third parties or publicly available sources. We will receive personal data about you from various third parties as set out below:

7.1.4.    Technical Data from analytics providers such as Google; and

7.1.5.    Contact, Financial and Transaction Data from providers of technical, payment and delivery services (if the Website offers paid for services/ online sales).

8.      HOW WE USE YOUR PERSONAL DATA

8.1.    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:

8.1.1.    Where we need to perform the contract we are about to enter into or have entered into with you.

8.1.2.    Where we need to comply with a legal obligation.

8.2.    Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time for the future free of charge by contacting us at data.privacy@air.global.

8.3.    We set out below a description of the ways we plan to use your personal data, and which of the legal bases we rely on to do so. 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 at data.privacy@air.global 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.

9.      MARKETING/ PROMOTIONAL OFFERS FROM US

9.1.    We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

9.1.1.    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.

You will receive marketing communications from us if you have:

-    given your consent,

-    requested information from us, or

-    purchased goods or services from us and you have not opted out of receiving that marketing.

9.1.2.    Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out. You can ask us or third parties to stop sending you marketing messages at any time for the future free of charge by following the opt-out links on the footer of any marketing message sent to you or by contacting us at any time at data.privacy@shisha.com.

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, product/service experience or other transactions.

10.   COOKIES

Cookies are small files automatically created by your browser and stored on your end device when you visit or are redirected to a website. The use of cookies serves to make the use of our website more pleasant and relevant for you. Most browsers accept cookies automatically. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of a website may become inaccessible or not function properly.

11.   SHARING YOUR PERSONAL DATA

11.1.  We may share your personal data with the parties set out below for the purposes set out in the table above and any other reasons set out:

11.1.1.     Our Other Group Companies - other companies in the AIR group which PVG Trading LLC is part of who are based both in and outside of the UAE for the provision of IT and system administration services, for audit and reporting purposes and so that our group companies can share with you information about new initiatives and/or product launches that they are involved in.  

11.1.2.     External Third Parties

·       Service providers acting as processors based in and outside of the UAE who provide IT and system administration services, a secure payment gateway and marketing communications automation.

·       Professional advisers acting as processors including lawyers, bankers, auditors and insurers based in both in and outside of the UAE) who provide consultancy, banking, legal, insurance and accounting services.

·       Regulators and other authorities based both in and outside the UAE who require reporting of processing activities in certain circumstances.

·       Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

11.2.  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. Our current service partners and their tasks can be made available to you on request at the e-mail address data.privacy@air.global.

12.   INTERNATIONAL TRANSFERS

12.1.  We may share your personal data within the global AIR Global group. This may involve transferring your data outside the UAE.

12.2.  In addition, some of our external third parties are based outside the UAE so their processing of your personal data will involve a transfer of data outside the UAE.

12.3.  Whenever we transfer your personal data out of the UAE, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

12.3.1.     We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data; or

12.3.2.     Where we use certain service providers, we may use contractual protections to give personal data the same protection it has in the UAE. 

12.4.  Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UAE.

13.   DATA SECURITY

13.1.  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.

13.2.  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.

14.   DATA RETENTION– HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

14.1.  We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for.  Unless we are required to keep it longer to comply with any legal, regulatory, tax, accounting or reporting requirements, we will review the personal data we hold every 2 years. If users have been completely inactive during the previous 2-year period, we will delete your data.

14.2.  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.

14.3.  Details of retention periods for different aspects of your personal data are available by contacting us at data.privacy@air.global.

14.4.  In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

15.   YOUR LEGAL RIGHTS

15.1.  You have the right to:

15.1.1.     Access your personal data and information on the personal data stored, the purpose of processing, the category of personal data and recipients to whom the data have been or will be disclosed, the planned storage period and eventually the origin of your data if not collected directly from you;

15.1.2.     Request correction of inaccurate personal data or completion of accurate personal data;

15.1.3.     Request deletion of your personal data, insofar as no legal or contractual retention periods are to be observed;

15.1.4.     Object to processing of your personal data or request restriction of processing your personal data (e.g. for marketing purposes); and/or

15.1.5.     Request transfer of your personal data to another controller.

15.2.  If you wish to exercise any of the rights set out above, please email us at data.privacy@air.global. In addition, in any case data processing may be objected to on grounds arising from reasons of overriding importance (e.g. possible risk to life or health). In addition, you have the option of contacting the supervisory authority responsible, or the data protection officer(s).

15.3.  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.

15.4.  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.

Version 1 – September 2022