Privacy Policy
1. Introduction
Welcome to the privacy policy of Shisha Now, the operator of shishanow.ae. 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 informs 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. Age Restriction
This website is intended for users aged 18 and above, and we do not knowingly collect data relating to children.2.2. Policy Supplements
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. Company Information
The controller and company responsible for the collection and use of your personal data is Alhaj Coal Trading, a Fujairah registered company with trade license number 1017515, (“Shisha Now”, “we”, “us” or “our”).3.2. Contact Details
If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager at Sales@shishanow.ae.3.3. Complaints
You have the right to make a complaint at any time to your local regulator for data protection issues. If you are a resident in the UAE, this is the UAE Data Office established under Federal Decree-Law No. 44 of 2021. However, we would 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. Policy Updates
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 Sales@shishanow.ae.4.2. Accuracy of Data
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. External Links
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. Information Collected
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, to optimize our website, or to display advertising in the browser of your terminal.6.2. Definition of Personal Data
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. Types of Personal Data
- Identity Data includes first name, last name, username (if you choose to set up an account), date of birth, age, and gender.
- Contact Data includes email address and telephone numbers.
- Financial Data includes bank account and payment card details (to the extent the website offers paid-for services/online sales).
- 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.
- Profile Data includes your username and password, your interests, preferences, feedback, and survey responses.
- Usage Data includes information about how you use our website, products, and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
6.4. Aggregated Data
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. Sensitive Personal Data
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. Impact of Not Providing Data
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. Methods of Collection
- 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:
- Request our products or services
- Create an account on our website
- Subscribe to our service or publications
- Request marketing to be sent to you
- Enter a competition, promotion, or survey
- Give us feedback or contact us
- 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. There is more information about cookies set out in section 10 below.
- Third parties or publicly available sources: We will receive personal data about you from various third parties as set out below:
- Technical Data from analytics providers such as Google based outside the UAE.
- Contact, Financial, and Transaction Data from providers of technical, payment, and delivery services.
- Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the UAE.
8. How We Use Your Personal Data
8.1. Legal Grounds for Processing
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:- Performance of a Contract: Where we need to perform the contract we are about to enter into or have entered into with you.
- Legal Obligation: Where we need to comply with a legal or regulatory obligation.
- Legitimate Interests: Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Consent: Where we have your consent to process your data for specific purposes.
8.2. Purposes for Using Your Data
We may use your personal data for the following purposes:- To register you as a new customer: Identity, Contact, and Financial Data.
- To process and deliver your order: Identity, Contact, Financial, and Transaction Data.
- To manage your relationship with us: Identity, Contact, Profile, and Marketing and Communications Data.
- To enable you to participate in a prize draw, competition, or complete a survey: Identity, Contact, and Profile Data.
- To administer and improve our website: Technical Data.
- To deliver relevant website content and advertisements to you: Technical and Usage Data.
- To measure or understand the effectiveness of the advertising we serve to you: Technical and Usage Data.
- To make suggestions and recommendations to you about goods or services that may be of interest to you: Identity, Contact, Technical, Usage, and Profile Data.
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 by following the opt-out links on the footer of any marketing message sent to you or by contacting us at any time at Sales@shishanow.ae. 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
10.1. 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:- 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 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 of 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.
12. International Transfers
12.1. 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. 12.2. 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:- 12.2.1. We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data; or
- 12.2.2. Where we use certain service providers, we may use contractual protections to give personal data the same protection it has in 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 unauthorized 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 fulfill 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 unauthorized 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 Sales@shishanow.ae 14.4. In some circumstances, we will anonymize 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. 14.4. In some circumstances, we will anonymize 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 the processing of your personal data or request restriction of processing your personal data (e.g. for marketing purposes).
- 15.1.5. Request transfer of your personal data to another controller.