Privacy Policy
Effective date: [Insert publication date]
1 Who Is Responsible for Your Information
[Full legal entity name], trading as EmiratesX, is responsible for the personal information processed for the purposes described in this Policy.
Registered address: [Full registered address], Dubai, UAE. Privacy contact: contact@emiratesx.net.
2 Information We Process
Depending on your interaction with us, we may process your name, contact details, country of residence and professional or company information; membership application information and relevant profile assessment materials; service preferences, destinations, dates, budgets and request details; correspondence, quotations, agreements and transaction records; and identity or verification documents where necessary for a specific service or legal requirement.
We may also process technical information generated through website use, such as IP address, browser type and security logs, where collected by the website’s configured systems.
Some requests may require sensitive information, such as accessibility or health-related requirements. We will seek this only where necessary and subject to the safeguards and permissions required by applicable law.
Please do not submit unnecessary sensitive information or payment card details through ordinary email.
3 How We Obtain Information
We obtain information directly from you, from a representative acting with your authority, and from providers involved in your request where this is lawful and necessary.
If an assessment requires information from public sources or verification providers, its use must be relevant, proportionate and permitted by law. Additional notices will be provided where required.
4 Why We Use Information
We process information to respond to enquiries and assess membership applications; prepare quotations and coordinate requested services; administer memberships, agreements, payments and records; verify identity or authority where required; protect the website, prevent misuse and resolve disputes; and meet applicable legal and regulatory obligations.
We rely on consent where required, or another basis expressly permitted by applicable law, including processing necessary for contractual steps you request, performance of an agreement or compliance with legal obligations.
Submitting an enquiry or application does not constitute consent to unrelated marketing.
5 Membership Assessments
Membership applications are reviewed by our specialist team using information relevant to the application. Additional information may be requested to complete an assessment.
Information supplied for an application will be used for the purposes described in this Policy and will not be treated as permission for unrestricted profiling or unrelated use.
6 When Information Is Shared
Where necessary for the relevant purpose, information may be shared with authorised personnel handling your application or request; service providers involved in preparing or fulfilling your request; hosting, email, technical and administrative providers supporting our operations; professional advisers and verification providers where relevant; and authorities or other recipients where disclosure is legally required.
Only information reasonably necessary for the relevant purpose should be shared. Recipients must be subject to appropriate confidentiality, contractual or legal safeguards.
7 International Transfers
International services may require information to be processed outside the UAE, including in a destination country or by a supporting provider.
Where this occurs, we will apply the transfer conditions and safeguards required by applicable data protection law and obtain additional consent where required.
8 Retention
Information is retained only for as long as necessary for the purpose for which it was collected, including applicable contractual, accounting, legal and dispute-related requirements.
Retention depends on the information concerned, whether a membership or service proceeds, and any mandatory retention period. Information will then be deleted or anonymised, unless continued retention is legally required.
You may contact us for information about the retention criteria applicable to your records.
9 Security
We apply appropriate technical and organisational measures to protect personal information against unauthorised access, loss, misuse or disclosure.
No electronic system can guarantee absolute security. Any personal data breach will be assessed and handled in accordance with applicable notification and other legal requirements.
10 Your Rights
Subject to applicable law, you may request access to your information, correction of inaccurate information, deletion, restriction of processing, cessation of certain processing or transfer of your information.
Where processing relies on consent, you may withdraw that consent. Withdrawal does not invalidate lawful processing carried out beforehand.
Send requests to contact@emiratesx.net. We may need to verify your identity. Requests will be handled within applicable legal time limits, and any lawful restriction will be explained.
You may also raise a complaint with the competent data protection authority.
11 Information About Other People
If you provide information about guests, family members or colleagues, you must be authorised to do so and ensure they receive appropriate information about its use.
Membership applications are intended for adults with legal capacity to contract. Information about children travelling or participating with an adult will be handled only as necessary and with appropriate parental or guardian authority.
12 Cookies and External Websites
Please see our Cookie Policy for information about website technologies. External websites have their own privacy practices. Review their policies before providing personal information.
13 Policy Updates
We may update this Policy to reflect changes in our activities or applicable requirements. The latest version will show its effective date. Where required, we will provide additional notice or seek consent for a material change.
Privacy enquiries: contact@emiratesx.net.