Privacy Policy

Emirates Telecommunication Group Company PJSC (“We”, “Us”, “Our”, “e&”) takes your (“You”, “User”, “Subscriber”, “Customer”) privacy very seriously and is committed to protecting and respecting your privacy.

This Notice provides details on the following sections:

• Applicability of this Notice
• What Personal Data do We collect about You
• What Personal data is indirectly collected from other legitimate sources
• How We use your Personal Data and on which Lawful Basis
• Automated Decision Making & Profiling
• Your Personal Data and your Legal Rights
• Sharing and Disclosing Your Personal Data
• Data Transfers
• Direct marketing
• How long We retain your Personal Data for
• Privacy Notice updates

This Privacy Notice applies to all individuals who have downloaded, installed, and logged into the Smiles application (“Application”) and whose Personal Data is collected, processed, and stored for the purpose of this application. If You provide Us with Personal Data including your contact details and any other information that will allow Us to identify You and provide You with Our services, We will process it according to this Notice (“Notice”).

Your “Personal Data” means any information, which allows Us to identify You directly or indirectly (together with information from other sources), that You have provided to Us or Our Third parties, in connection with a service or product offered whether through the use of the Application, in person or any other mode of communication.

We may collect your Personal Data such as:

• General Personal Data such as names, addresses, contact numbers, date of birth, nationality, gender, geo-location, etc.
• Financial data such as payment transaction details, points accrual, and reward transactions.
• Behavioural data such as User activities on the Application.
• Identifiers such as login details.

We do not collect your Personal from other legitimate sources for this Application. The Notice shall be updated in case of any changes.

We will only use your Personal Data for the purposes for which We collected it.

Based on the necessity to enter into or perform a contract, We may process your Personal Data for the following purposes:

• For User authorisation and login via mobile number;
• For User registration;
• For authorisation of payment;
• For displaying user details in My Account section;
• To share the customer details along with the order details to the food delivery, grocery service provider;
• To facilitate add-on purchases;
• for redemption of Smiles points on LoyLogic Platform, YallaCompare Platform, ClearTrip Platform, Grocery & HomeServices platform;
• To run raffle draws and choose winners for different contests/promotion;.
• To show personalized recommendations to Users based on their activities on the Smiles application;

Based on your consent, We process your Personal Data for the following purposes:

• to show offers and deal to be tailored for you based on the background location;
• to track user location and show nearby offers.

We may process your Personal Data for evaluation or scoring including profiling for the below purpose:

• to show personalized recommendations to Users based on their activities (for e.g., time spent on the Application, Your clicks to the various reward programs etc.);
• to show offers and deal to be tailored for You based on the background location.

You have the right to be informed of any processing of your data in clear, transparent, and easily understandable means. The present Notice aims at fulfilling this right.

You have the right to request information and make a request for a copy of the Personal Data that We hold about you. To make this request, please contact Our Contact Centre team or Data Protection Office (see contact details below).

You have the right to have Personal Data held about You corrected if it is not accurate. If what We hold on to You needs updating, or You think it may be inaccurate, You can contact Our Contact Centre team or Data Protection Office (see contact details below).

You have the right to request the suspension of the processing your Personal Data, when:

• The accuracy of your Personal Data is contested, for a period enabling Us to verify the accuracy of the Personal Data.
• The processing of your Personal Data is unlawful, but You do not want it erased and request the restriction of its use instead.
• Your Personal Data is no longer needed for the purposes for which it was collected, but it is required by You for the establishment, exercise or defence of legal claims.

Notwithstanding the above, under UAE Data Protection Law, we may process your Personal Data in the following cases:

• If the processing is limited to storing Personal Data.
• If the processing is necessary to establish any legal claims or defence of rights or is in connection with any judicial proceedings.
• If the processing is necessary to protect the rights of third parties in accordance with applicable legislation.
• If the processing is necessary to protect the public interest.

You have the right to ask Us to provide You with your Personal Data in a structured, commonly used, machine-readable format and to transmit it to another data controller, providing the following cumulative criteria:

• the Processing is based on your Consent or the performance of a contract with you;
• the processing is carried out by automated means. Where the transfer is technically doable, You have the right to have your Personal Data transmitted directly from Us to another controller. e& shall endeavour to provide this information by allowing You to raise a request for the same to the e& Contact Centre team or Data Protection Office (see contact details below).

You have the right to object, at any given time and without any justification, in the following cases:

• Processing of your Personal Data is for direct marketing purposes, including profiling related to direct marketing
• Processing is carried out to conduct statistical surveys unless it is necessary to achieve public interest (under UAE Data Protection Law)
• Processing is in violation of the data protection standards under article 5 of UAE Data Protection law (under UAE Data Protection Law)

You have the right of your Personal Data not being subject to a decision based on automated processing, including profiling resulting in legal effects or seriously affecting you, however, exercising this right may not enable Us to design and promote products and services tailored to your needs.

We shall strive to only process and retain your Personal Data for as long as We need to. Where there is no good reason for Us continuing to process your Personal Data, You have the right to request that We erase Personal Data of yours that We hold, in particular where

• it is no longer necessary for the purposes for which it was collected or processed,
• You have withdrawn your consent (where the data processing was based on consent) and/or there is no other ground for the processing,
• following a successful request on the ground of your right to object to processing, or
• it has been processed unlawfully.

However, in compliance with potential legal or regulatory requirements, your Personal Data might be retained for a certain period even after your request for erasure. You will be notified, along with a valid justification, if this occurs against your request. For more information on retention periods, refer to section in this Privacy Notice called ‘Information Retention’.

You have the right to withdraw your prior consent to processing based on it, at any time. Once We have received notification that You have withdrawn your consent, We will no longer process your Personal Data for the purpose(s) You originally agreed to.

To invoke your data subject rights, please send an email or letter to e& data protection officer (see contact details below).

Please note that You are entitled to lodge a complaint with a competent Data Protection Authority, concerning e& compliance with the applicable data protection laws and regulations.

Your Personal Data will be accessed internally by e& employees in accordance with their scope of work and competence, only on a need-to-know basis.

We shall not share or use your Personal Data with our affiliates or any third party unless it is necessary for the provision of the services, without putting in place the adequate safeguards.

We may disclose your Personal Data, with predefined processes, if such disclosure is:

• permitted by UAE applicable laws;
• expressly permitted by the UAE telecommunications regulations or any other aspect of the UAE regulatory framework;
• in response to legal process (e.g., police, emergency services, etc.) in order to comply with a court order or applicable law or in connection with judicial proceedings or other legal process.
• necessary for the execution of the agreement between Us and the provision of Our services to you;
• made in order to protect Us or Our Customers’ legitimate interests (e.g., with credit reporting agencies for purposes of fraud protection and credit risk reduction);
• expressly permitted by You (express opt-in consent).

We may share your Personal Data with third parties outside the countries of Our jurisdiction in the following cases:

• To Third parties: Your Personal Data may be transferred to Our Contact Centre vendors in India and Egypt on the basis of Data transfer agreements between e& and the vendors.

Direct Marketing is conducted to contact You to offer promotions and carry marketing of e& services. Below channels are used for this purpose:

• Calls;
• SMS;
• E-mails;

At any time if You would prefer to stop receiving marketing information from e&, You may use the “unsubscribe” option included in the message or contact the e& Contact Centre or Data Protection Office (see contact details below).

e& and Telecommunications and Digital Government Regulatory Authority (TDRA) understand that some of You may not wish to receive promotional SMSs or calls anymore. Therefore, You can opt-out from these communications at any time. In that case, please consider the below options:

• If You do not wish to receive SMSs from e& about offers and promotions w.r.t. Smiles application, please text "b Smiles" to 7726 and We will immediately make sure that You will not receive any promotional SMS.
• If You do not wish to receive any SMSs at all about offers and promotions, please text "ball" to 7726 and We will immediately make sure that You will not receive any promotional SMS. By doing so, all promotional SMSs will cease even if you are no more connected to the Smiles application.
• If You do not wish to receive SMSs from a specific sender about offers and promotions, please text "b sender ID" to 7726 and We will immediately make sure that You will not receive any promotional SMS from that specific sender.
• To stop receiving promotional calls from e& w.r.t. Smiles application, You may send your request by typing DNC and sending it to 1451; these requests to stop receiving promotional calls will be processed within 30 days.
• You can at all times, subscribe again to e& promotions w.r.t. Smiles application by texting "u Smiles" to 7726.

We respect your privacy. Informational messages from e& such as bill invoices and balance recharge notification, service, and information related communication, etc. are not subject to blocking.

The periods for which We keep your Personal Data depends on the purpose for which your Personal Data was collected. We will only keep your Personal Data for as long as it is necessary or needed for Our business purposes, post which We would delete it from Our systems.

We retain transactional data for a period of six months from the date of its generation or collection, which is necessary for our business purposes.

Some of the Personal Data, which You give to e& for a service or product, would be retained even after fulfilment of the purpose of processing, as per the applicable regulatory requirements mentioned below:

• Telecommunications and Digital Government Regulatory Authority (TDRA)

e& reserves the right to change the Privacy Notice or Terms and Conditions when necessary. We keep this Privacy Notice under regular review to reflect any changes and in accordance with applicable laws and regulations.

For queries regarding this Privacy Notice or e&’s services, please contact the e& Contact Centre on 101.

If You have any questions or concerns about Our use of your Personal Data, You should write to the address below:

e&
Data Protection & Privacy
Head Office Marketing Department
Intersection of Sheikh Zayed II Street and Sheikh Rashid bin Saeed Al Maktoum Road
PO Box 3838,
Abu Dhabi, United Arab Emirates

Email: data-privacy-officer@eand.com

Last updated: May 2024