ENVI GROUP PRIVACY POLICY
ENVI FZ-LLC, its mother company ENVI Holding LTD, as well as all companies whose shares are held, in whole or in part, whether directly or indirectly, by ENVI Holding LTD (collectively, the “ENVI Group”, “we”, or “us”) take your privacy very seriously. This privacy policy (this "Privacy Policy") describes how we collect, store, use and share your personal information (“Personal Data”). It also explains your rights in relation to your Personal Data and how to contact us in the event you have a complaint.
This Privacy Policy applies when you visit or use our website, apps and social media platforms (the “Online Services”) as well as when you visit or stay as a guest at one of our lodges and use our various hospitality services including Spa centers, restaurants, boutiques or when you have other offline interactions with us (the “Offline Services”, together with the Online Services, the “Services”). This Privacy Policy may be supplemented by additional privacy statements, terms or notices provided on certain areas of the Services or during our interactions with you.
By using the Services, you consent to our collection, use and disclosure of your Personal Data in accordance with the terms of this Privacy Policy. You may withdraw such consent at any time, however this will not affect the lawfulness of the processing based on your consent prior to the withdrawal.
1. Collection of Personal Data
We may collect, use, store and transfer different kinds of Personal Data about you which we have categorised as follows:
· Identity and Contact Data including first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, gender, nationality, passport number and country of residence, billing address, delivery address, email address and telephone numbers.
· Financial and Transaction Data including bank account, payment card details, details about payments to and from you and other details of products and services you have purchased from us.
· Profile Data including your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
· Guest Preferences and Personalized Data such as special health accommodations (e.g., food allergies, dietary requirements, mobility requirements) or information related to your general health and physical characteristics, and your skincare and wellness concerns (e.g., skin type, hair type, skin sensitivity, contraindications, beauty concerns, preference for nourishing or purifying skincare products).
· Marketing Data including your preferences in receiving marketing from us and our third parties and your communication preferences.
· Children’s Data including Identity Data, Profile Data, Accessibility Data and Wellness Data relating to individuals under 18 years of age.
2. How We Collect Personal Data
We may collet Personal Data:
· Within the ENVI Group. We disclose Personal Data to other companies within the ENVI Group for the purposes described in this Privacy Notice and to accomplish our business purposes.
· Through the Services. For example, when you place an order, make, cancel or modify a booking with us, create an account on an Online Service, join an ENVI Group loyalty program, provide us with comments, opinions and/or feedback about the ENVI Group, contact us or correspond with us (for example, by phone, email, social media platforms or otherwise), sign up to receive email updates from us, fill in forms when visiting us or using a Service and, in general, when you use a Service;
· When you Visit Us. For example, when you stay at or visit one of our lodges, use any ENVI Group wellness services, visit any of our restaurants or properties; when we provide you with babysitting, childcare and other activities and services for individuals under 18 years of age.
Where Children’s Data is submitted by you, you confirm that you have authority to provide such data to us on behalf of that minor to enable us to process their Personal Data as described in this Privacy Policy.
3. Cookies
A cookie is a small text file which is placed onto your device (e.g. computer, smartphone or another electronic device) when you use our Services. We use cookies on our Services. These help us, recognize you and your device and store some information about your preferences or past actions.
For example, we may monitor how many times you visit our website, which pages you go to, traffic data, location data and the originating domain name of your internet service provider. This information helps us to build a profile of our users. Some of this data will be aggregated or statistical, which means that we will not be able to identify you individually.
4. Consent to Use Cookies and Changing Settings
We will ask for your permission to place cookies or other similar technologies on your device, except where they are essential for us to provide you with a service that you have requested e.g. your IP address, operating system, browser, domain, other user information (e.g. your username).
You can withdraw any consent to the use of cookies or manage any other cookie preferences by turning them off in your browser and/or deleting them from your hard drive. You do not need to have cookies turned on to use a Service but you will need them to log on to a Service and to access personalized or secure content on it and some web pages may not function properly if the cookies are turned off. It may be necessary to refresh the page for the updated settings to take effect.
5. How and Why We Use Your Personal Data
This Privacy Policy fulfils our duty to process Personal Data fairly, lawfully and in a transparent manner.
We and our service providers may use Personal Data for the following purposes:
· To perform a contract with you and/or to comply with a legal obligation such as:
- To process and facilitate bookings and payments.
- To respond to your requests and queries during your stay at our lodges.
- To send you a copy of our bill.
- To process and deliver your order of our products.
- To manage your membership with us.
- To respond to your inquiries and fulfil your requests.
- To complete your transactions, process returns and exchanges and provide you with related benefits, special promotions, or customer service.
- To send administrative information to you, such as changes to our terms, conditions, and policies.
· To carry out marketing activities with your consent or when we have legitimate interest to do so. These activities include:
- Providing you with our newsletter and/or other marketing materials.
- Sending you marketing related emails, with information about our services, new products and other news about us.
- Conducting surveys about your experience during lodge visits.
Typically, we would collect your consent by you performing an action such as ticking the appropriate consent box or otherwise communicating your consent to us (for example, by email or by you providing us with non-mandatory information). You may withdraw that consent at any time by contacting us at the Contacting Us section below.
· For our legitimate interests and to accomplish our business purposes. The activities falling within this category include:
- Analyze data to improve the efficiency of our Services, better understand your interests, usage trends and preferences and develop new products and services.
- Audits to verify that our internal processes function properly and to address legal, regulatory, or contractual requirements.
- Fraud prevention and fraud security monitoring activities.
· To protect your vital interests or the vital interests of another natural person for example, to disclose your Personal Data to emergency services where we believe it is necessary to protect your vital interests or the vital interest of another person or where you (or someone acting on your behalf) provides us with dietary or other personal health data such as allergies.
6. Who Do We Share Your Personal Data With
We may share or disclose your Personal Data in connection with the purposes described in this Privacy Policy. This may include sharing your Personal Data with the following:
· All companies within the ENVI Group for marketing, business, administrative and legal purposes (for example, payment, verification or membership awards and points);
· Facebook, Twitter, Instagram or any other social media platforms that the ENVI Group may use from time to time (if you use your account with them to sign up/in with us), if applicable;
· Service providers, business partners, suppliers, subcontractors or agents (for example, fitness, medical and healthcare professionals providing assessments for treatments, IT services, travel planning, reservation, booking, rewards management, customer relationship management, business development and marketing support services) who perform functions such as marketing, payment, fulfilment and delivery of orders, administration and processing of payments, as well as bookings and reservations;
· Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services;
· Vendors who provide services to us, such as fulfilling orders, providing data processing and other information technology services, managing promotions, carrying out research and analysis, and personalizing individual ENVI Group customer experiences. We do not allow these vendors to use this information or to share it for any purpose other than to provide services on our behalf;
· Government or other law enforcement agencies, in connection with the investigation of unlawful activities or for other legal reasons (this may include your location information;
· Third parties, who acquire us or substantially all of our assets, in which case your Personal Data (including any sensitive Personal Data) will be one of the transferred assets (however, we will let you know before this happens); and
· Analytics and search engine providers that assist us in the improvement and optimization of the ENVI Group Websites.
7. Your Choices Regarding Our Use and Disclosure of Your Personal Data
We give you choices regarding our use and disclosure of your Personal Data for marketing purposes. You may opt out from:
· Receiving marketing-related emails from us. If you no longer want to receive marketing related emails from us on a going-forward basis, you may opt out by sending an email to hello@envilodges.com or by using the unsubscribed link at the bottom of each marketing email.
· Our sharing of your Personal Data with other members of the ENVI Group for their direct marketing purposes. If you would prefer that we discontinue sharing your Personal Data on a going-forward basis with our members for their direct marketing purposes, you may opt out of this sharing by sending an email to hello@envilodges.com or by using the unsubscribed link at the bottom of each marketing email.
We will try to comply with your request(s) as soon as reasonably practicable.
8. Retention of Personal Data
Your Personal Data will not be kept longer than necessary to meet the purposes detailed above.
The criteria that we use to determine how long we will keep your Personal Data includes the period of time during which we have an ongoing relationship with you, and whether we have a legal obligation to store it (for example, for accounting purposes or for litigation, or regulatory investigations purposes).
Should retention of your Personal Data no longer be required we will remove it from our systems and records and/or take steps to properly anonymise it so that you can no longer be identified from it.
9. Where We Store/Transfer Your Personal Data
We share the Personal Data that we collect from you within the ENVI Group. This will involve transferring, processing and storing your data outside of the country in which you are located depending on the circumstances. This includes any country where the ENVI Group companies are located or operate in but also countries where our external service providers are based or are hosting your Personal Data on our behalf. We take steps to ensure that appropriate transfer safeguards, required by law, are taken with the aim of ensuring that your privacy rights continue to be protected as outlined in this Privacy Policy. You can obtain further details about the transfer safeguards we use by contacting us at the Contacting Us section below.
10. Links to Third Party Website
The Online Services may contain links to other third-party websites, whose privacy practices may differ from those of the ENVI Group. If you submit Personal Data to any of those sites, your Personal Data is not subject to this Privacy Policy.
In addition, we are not responsible for the information collection, use, disclosure, or security policies or practices of other organizations, such as Facebook, Instagram, Google Ads, Yahoo, Tripadvisor, Trivago, Apple, Microsoft, The Hotels Network or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider, or device manufacturer.
11. Security
Your privacy is important to us and we have implemented standard technology and operational security measures in order to protect Personal Data from loss, misuse, alteration or destruction. However, we cannot secure that our level of security meets or exceeds any specific standards. No internet transmission is 100% secure or error-free, nor is stored data free from vulnerabilities. We cannot guarantee the security of our websites, databases or services, nor can we guarantee that the information you supply will not be intercepted while being transmitted to us over the internet. We are not responsible for actions of third parties.
12. Sensitive Data
Unless we request it, we ask that you not send us, and you not disclose, any sensitive Personal Data (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background, or trade union membership) on or through the Services or otherwise to us. We will comply with all applicable laws granting particular protection for this category of Personal Data.
13. Your Rights
You have certain rights relating to your Personal Data. However, these rights can differ depending upon the country in which you are located. That country's law will determine which rights apply and in what instances.
Right to withdraw consent
Where you have provided your consent to us, you will always have the right to withdraw this at any time. You can do this by either following the information provided at the time you provided your consent, or by contacting us using the following email address hello@envilodges.com. The withdrawal of consent will not affect any processing that was based on consent before its withdrawal.
Right to request correction of your Personal Data
You will always have the right to request that we correct any Personal Data that we process about you that is inaccurate or incomplete. You can do this by contacting us at hello@envilodges.com.
Additional Rights
You are also provided with additional rights which allow you, subject to certain conditions, to:
· upon request, be provided access to, or copies of, your Personal Data that we process;
· upon request, restrict the processing of your Personal Data;
· upon request, delete your Personal Data which we process;
· object to our processing of your Personal Data; or
· upon request, obtain a copy of your Personal Data which we process in a commonly used and machine-readable format.
It is important to understand that these rights are not absolute (e.g. their application may depend upon the lawful basis we rely upon to process your Personal Data) and that we may require further information from you (e.g. to confirm your identity) in order to action your request.
You will also have the right to lodge a complaint with the relevant supervisory authority in your country of residence, place of work or the country in which an alleged infringement of data protection law has occurred.
14. Contacting Us
If you want to exercise any of the rights set out above or have any questions or concerns about how we treat your Personal Data, please contact us at hello@envilodges.com or by writing to us at: ENVI Lodges, Dubai Design District, Building 3, L3, Dubai, United Arab Emirates. Please include your reply address when you write to us.
15. Amendments
We reserve the right, in our sole discretion, to amend or update this Privacy Policy at any time.
You are also encouraged to review this Privacy Policy from time to time for updates. We will notify you of any changes (including when they will take effect) if we are required to do so by data protection laws.
LAST UPDATED: November 2023