Privacy Policy

Welcome to The Arts Club Limited’s Privacy Policy, which has been written in accordance with the Data Protection Law, DIFC Law No.5.

What Does This Privacy Policy Cover?

The Arts Club Limited respects your privacy and is committed to protecting your Personal Data. We want to be transparent with you about how we collect and use your Personal Data in your dealings with us and your use of our Services (“Services”) and tell you about your privacy rights and how the law protects you.

With that in mind, this Privacy Policy is designed to describe:

  • Who we are and how to contact us
  • Your rights relating to your Personal Data
  • Complaints
  • Marketing communications preferences
  • What Personal Data we collect
  • How we use your Personal Data and why
  • What is our ‘Legal Basis’
  • What happens when you do not provide necessary Personal Data
  • Personal Data and Third-Party Sources
  • How we use cookies and other tracking or profiling technologies
  • Who we share your Personal Data with
  • Data Transfers
  • How we keep your Personal Data secure
  • How long we store your Personal Data
  • Our policy on children
  • Third Party links

This Privacy Policy aims to give you information on how The Arts Club Limited collects and processes your Personal Data through your use of our Services, and any data you may provide to us.

The Privacy Policy is intended to meet our Duties of Transparency under the “DIFC Law No.5 of 2020” Data Protection Law and the “General Data Protection Regulation 2016/679”, “EU Law” or “GDPR”.

We will post any modifications or changes to this Privacy Policy on this page.

1. Who We Are & How to Contact Us

Who we are:
We are The Arts Club Limited with registered address Unit P/FR-01 Level POD, Gate Village Building 8, DIFC, Dubai, Dubai, United Arab Emirates

How to contact us:
You can contact us by emailing: membership@theartsclub.ae

2. Your Rights Relating to Your Personal Data

Under certain circumstances, by law you have the right to:

  • Request access to your Personal Data.
  • Request correction of your Personal Data.
  • Request erasure of your Personal Data.
  • Object to processing of your Personal Data.
  • Request the restriction of processing of your Personal Data.
  • Request the transfer of your Personal Data.
  • Withdraw consent.

How to exercise your rights:
If you want to exercise any of the rights described above, please contact us using the contact details shown under “Who We Are and How to Contact Us”.

Typically, you will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, except in relation to Consent Withdrawal, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive, or, we may refuse to comply with your request in these circumstances.

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.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

3. Complaints

If you would like to make a complaint regarding this Privacy Policy or our practices in relation to your Personal Data, please contact us at: membership@theartsclub.ae.

We will reply to your complaint as soon as we can.

If you feel that your complaint has not been adequately resolved, please note that the “DIFC Law No.5 of 2020” Data Protection Law gives you the right to contact the Commissioner of Data Protection, for which details can be found at https://www.difc.ae/about/difc-management-team/.

4. Marketing Communications Preferences

You can ask us to stop sending you marketing messages at any time by opting out on the Membership Application Form, following the opt-out links on any marketing message sent to you and/or by contacting us at any time using the contact details shown under “Who We Are and How to Contact Us”.

Where you opt out of receiving these marketing messages, this will not apply to Personal Data provided to us as a result of membership applications, restaurant reservations and other purchases or Services where we require your Personal Data to complete your order.

5. What Personal Data We Collect

All the Personal Data we collect, both from you and from third parties about you, is outlined in the table below.

Before you read that table, it might be useful to explain what “Personal Data” is. UAE Federal Law does not define ‘personal data’. However, the FTZ laws define it as any data that refers to an identifiable natural, living person. This includes, among other things, passport details, Emirates ID number, employment contracts, individual health records, biometric data and individual bank details.

It does not include ‘anonymous data’ (i.e. information where the identity of individual has been permanently removed).

However, it does include ‘indirect identifiers’ or ‘pseudonymous data’ (i.e. information which alone does not identify an individual but, when combined with certain additional and reasonably accessible information, could be attributed to a particular person).

Category of Personal Data Collected What This Means
Identity Data First name, surname, marital status, title, date of birth and gender.
Contact Data Your home address, work address, billing address, email address and telephone numbers.
Financial Data Your payment card details. Note that we pass any Financial Data we receive from you immediately to our third-party payment processors. We do not store any of your Financial Data.
Transaction Data Details about payments to and from you in respect of food, beverage and other services you have purchased from us.
Marketing & Communications Data Your preferences in receiving marketing from us and your communication preferences.
Behavioural Data Inferred or assumed information relating to your behaviour and interests based on your online activity and use of our services.
Technical Data Internet protocol (IP) address, 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 or use our services.
Allergy Data Information about food allergies, intolerances and/or preferences you have.
Aggregated Data We also collect, use and share “Aggregated Data” such as statistical or demographic data for any purpose. Aggregated Data may be derived from your Personal Data, but once in aggregated form it will not constitute considered Personal Data as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Behavioural Data to calculate the percentage of users accessing a specific Service 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. How We Use Your Personal Data and Why

We will only use your Personal Data for the purposes for which we collected it as listed below, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

If we need to use your Personal Data for an unrelated purpose, we will update this Privacy Policy and we will explain the legal basis which allows us to do so.

7. What Is Our “Legal Basis” for Processing Your Personal Data?

In respect of each of the purposes for which we use your Personal Data, most commonly, we will rely on one of the following legal bases:

  • Where we need to perform a contract, we are about to enter into or have entered into with you (“Contractual Necessity”).
  • Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests (“Legitimate Interests”). More detail about the specific legitimate interests pursued in respect of each Purpose we use your Personal Data for is set out in the table below.
  • Where we need to comply with a legal or regulatory obligation (“Compliance with Law”).
  • Where we have your specific consent to carry out the processing for the Purpose in question (“Consent”).

Generally, we do not rely on your consent as a legal basis for using your Personal Data other than in the context of direct marketing communications.

We have set out below, in a table format, the legal bases we rely on in respect of the relevant Purposes for which we use your Personal Data.

Purpose Category(ies) of Personal Data Involved Why Do We Do This Our Legal Basis for This Use of Data
Membership applications/elections Identity Data, Contact Data, Marketing & Communications Data To process membership applications and elect members. Contractual Necessity
Reservations/Bookings Identity Data, Contact Data, Transaction Data To secure and manage customer reservations, and to settle bills upon consumption. Contractual Necessity
Marketing Identity Data, Contact Data, Marketing & Communications Data To send you newsletters and event information which we think may be of interest to you. Consent. We obtain opt-in consent to send marketing communications to you.
To process payments for gift cards Identity Data, Contact Data, Financial Data, Transaction Data To process and deliver your order. Contractual Necessity
To process advance payments for bookings Identity Data, Contact Data, Financial Data, Transaction Data To process your order to secure a reservation or to pay, or part pay, for a reservation in advance and allocate such payments correctly. Contractual Necessity
To improve our services Behavioural Data, Technical Data To monitor use of our Services to improve our Services and to help operate our Services more efficiently, and to improve your experience. Legitimate Interests. We have a legitimate commercial interest in ensuring that our Sites operate as efficiently as possible and that we improve our Sites based on information we learn from our users’ use of our Sites.
To provide your order to you, taking your food allergies, intolerances and preferences into account Allergy Data To ensure that we take into account information about your food allergies, intolerances and/or preferences when preparing and delivering your order to you. Explicit Consent. We obtain your explicit consent to use data relating to your food allergies and intolerances.
Legitimate Interests. We have a legitimate interest in taking your food preferences into account when preparing and delivering your order to you, to ensure that you are satisfied with the services you receive from us.

8. What Happens When You Do Not Provide Necessary Personal Data?

Where we need to process your Personal Data either to comply with law, or to perform the terms of a contract we have with you, and you fail to provide that data when requested, 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 the functionalities of the Services).

In this case, we may have to stop you using our Services, but we will notify you if this is the case at the time.

9. Personal Data from Third Party Sources

In addition to the Personal Data that we collect directly from you (as described in the section immediately above this one), we also collect certain aspects of your Personal Data from third party sources. These sources are broken down in the table below, together with a description of whether they are publicly available or not.

Third Party Data Source Publicly Available? Category(ies) or Other Types of Personal Data Received
Online booking platforms when in effect No Identity Data, Contact Data, Transaction Data
Analytics providers No Behavioural Data, Technical Data

10. How We Use Cookies and Other Tracking or Profiling Technologies

Cookies: We may collect information using “cookies”.

What are cookies?
Cookies are small data files stored on the hard drive of your computer or mobile device by a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience on our Sites.

We use two broad categories of cookies:

  • First Party Cookies: served directly by us to your computer or mobile device
  • Third Party Cookies: served by our partners or service providers on our Sites

Cookies we use:

Type of Cookie Purpose
Essential Cookies These cookies are essential to provide you with Services available through our Sites and to enable you to use some of its features.
Functionality Cookies These cookies allow our Sites to remember choices you make when you use our Sites, such as remembering your language preferences. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit our Sites.
Analytics and Performance Cookies These cookies are used to collect information about traffic to our Sites and how users use our Sites. The information gathered via these cookies does not “directly” identify any individual visitor. However, it may render such visitors “indirectly identifiable”. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access our Sites. The information collected is aggregated and anonymous. It includes the number of visitors to our Sites, the websites that referred them to our Sites, the pages they visited on our Sites, what time of day they visited our Sites, whether they have visited our Sites before, and other similar information.
Social Media Cookies These cookies are used when you share information using a social media sharing button or “like” button on our Sites or you link your account or engage with our content on or through a social networking website such as Facebook, Twitter or Google+. The social network will record that you have done this.

Disabling cookies:
You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings”, “help”, “tools” or “edit” facility). Many browsers are set to accept cookies until you change your settings.

If you do not accept our cookies, you may experience some inconvenience in your use of our Sites. For example, our Sites not remembering your language setting.

Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.com.

You can also prevent the use of Google Analytics relating to your use of our Sites by downloading and installing the browser plugin available via this link: Google Analytics Opt-Out

11. Who We Share Your Personal Data With

Recipients Category(ies) of Personal Data We Share Why We Share It
Membership Platform Identity Data, Contact Data, Transaction Data To process membership applications, and elections and store member data including payment history.
Payment Systems Financial Data To process payments via Third Party platforms in a PCI compliant manner.
Reservations Platforms Identity Data, Contact Data To manage our bookings and reservations process.
Marketing Digital Platforms Identity Data, Contact Data To administer our marketing communications with customers who have opted-in to receive such communications from us.
The Arts Club Limited (London) Identity Data, Contact Data, Transaction Data To facilitate International Memberships and allow Members from all Clubs to support each others’ applications.
Lanserhof at The Arts Club Identity Data, Contact Data, Transaction Data To facilitate International Memberships and allow Members from all Clubs to support each others’ applications.
Courier Companies Identity Data, Contact Data To deliver physical content to you from time to time.
Printing Companies Identity Data, Contact Data To print physical content that requires your name and address (letters/envelopes).

12. Data Transfers

We share your Personal Data with our affiliated companies and certain external third parties. We endeavour to ensure that people to whom we provide Personal Data hold it subject to appropriate safeguards and controls. Whenever we transfer your Personal Data out of DIFC, Dubai, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented.

13. How We Keep Your Personal Data Secure

We have put in place appropriate technical and organisational security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. We store all the personal information you provide on secure password and firewall protected servers.

We limit access to your Personal Data to those employees and other staff who have a business need to have such access. All such people are subject to a contractual duty of confidentiality.

We have put in place procedures to deal with any actual or suspected Personal Data breach. In the event of any such breach, we have systems in place to work with applicable regulators. In addition, in certain circumstances (e.g., where we are legally required to do so) we may notify you of breaches affecting your Personal Data.

14. How Long We Store Your Personal Data

We will only retain your Personal Data for so long as we reasonably need to use it for the purposes set out above “How We Use Your Personal Data and Why”, unless a longer retention period is required by law (for example for regulatory purposes).

Category of Personal Data Retention Period
Identity Data Deleted after 2 years from membership termination unless opted-in to marketing.
Contact Data Deleted after 2 years from membership termination unless opted-in to marketing.
Financial Data Not stored. Passed immediately to third-party payment processors.
Transaction Data Stored for 2 years from membership termination.
Marketing and Communications Data Stored until you unsubscribe from our communications.
Behavioural Data Anonymised almost immediately, retained in anonymised form for 38 months.
Technical Data Anonymised almost immediately, retained in anonymised form for 38 months.
Allergy Data Stored for 2 years from membership termination.

15. Our Policy on Children

You may provide us with Identity Data relating to children where, for example, you make a booking for a child’s birthday party, and we may store this information on your account. In providing us with this Identity Data, you are agreeing that you hold parental responsibility for that child or that you have been properly authorised by the holder of parental responsibility for the child to give us this Identity Data to use for these purposes.

16. Third Party Links

Our Sites 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 your Personal Data. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Site, we encourage you to read the privacy policy of every site you visit.

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