Privacy Policy
With the following Privacy Policy, we would like to give you as a “data subject” an overview of the processing of your Personal Data by us and your rights under Federal Decree-Law No. 45 of 2021 (“Law No. 45”) and the General Data Protection Regulation (“GDPR”).
In principle, it is possible to use our website without entering Personal Data. However, if you want to use our services, processing of Personal Data could become necessary. If the processing of Personal Data is necessary and there is no legal basis for such processing, we will generally obtain your consent.
What is Personal Data?
Personal data is any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Person responsible and Data Controller
The person responsible for the processing of Personal Data is
Coolspa
204, indigo central 6,
Umm al sheif,
Dubai, UAE
If you have any questions, you can reach us at info@coolspa.ae or 050-884-1816.
Legal basis for processing
Our legal basis for collecting and using your Personal Data as described in this Privacy Policy depends on the Personal Data involved and the specific context in which we collect it. Generally, your Personal Data will be collected and processed by us on one or more of the following legal bases:
- Your consent,
- Compliance with contractual obligations,
- Compliance with legal obligations, and
- On the basis of our legitimate interests.
If you have any questions or need more information about the legal basis for the collection of your Personal Data, please contact us.
General Principles
- Security
This site uses SSL or TLS encryption to ensure the security of data processing and to protect the transmission of confidential content, such as orders, login data or contact requests that you send to us as the operator. You can recognise an encrypted connection by the fact that the address line of the browser contains a “https://” instead of a “http://” and by the lock symbol in your browser. If SSL or TLS encryption is activated, the data you transmit to us cannot be read by third parties.
We have implemented numerous technical and organizational measures to ensure the most complete protection of Personal Data processed through this website. Nevertheless, internet-based data transmissions can always have security gaps, so that absolute protection cannot be guaranteed.
Further, databases or data sets that include Personal Data may be breached inadvertently or through wrongful intrusion. Upon becoming aware of a data breach, we will notify all affected individuals whose Personal Data may have been compromised, and the notice will be accompanied by a description of the action being taken to reconcile any damage as a result of the data breach. Notices will be provided as expeditiously as possible after which the breach was discovered.
- Retention and Storage
We will retain your Personal Data as necessary in connection with the purposes described in this Privacy Policy, for as long as you are actively working with us, and in accordance with the UAE`s` Statutory Retention Periods and other applicable laws for up to 6 years.
- Minors
Persons under the age of 16 should not transmit any Personal Data to us without the consent of their parents or legal guardians. We do not request Personal Data from minors and children and do not knowingly collect such data or pass it on to third parties.
- Automated decision-making
Automated decision-making including profiling does not take place.
- Do Not Sell
We do not sell your Personal Data.
- Special Category Data
Unless specifically required and consent is obtained, for a particular service, we do not process Special Category Data.
- Social Media
We are present on social media on the basis of our legitimate interest. If you contact us via social media platforms, we and the relevant social media platform and we are jointly responsible for the processing of your data and enter into a so-called joint controller agreement. The legal basis for the use of the relevant social media platform is our legitimate interest, your consent or, in the case of a (pre) contractual relationship with us, the initiation of a contractual service, if any.
- International Transfer
In the course of our business, we process data. This also includes disclosure by transmission to third parties and, where applicable, to so-called third countries outside the UAE. Where we transfer data outside the UAE, we ensure that processing of your Personal Data is governed by Processing Agreements that include Standard Contractual Clauses to ensure a high level of data protection.
- Marketing
Insofar as you have also given us your consent to process your Personal Data for marketing and advertising purposes, we are entitled to contact you for these purposes via the communication channels you have given your consent to.
- Disclosure
We will not disclose or otherwise distribute your Personal Data to third parties unless this is a) necessary for the performance of our services, b) you have consented to the disclosure, c) or the disclosure of data is permitted by relevant legal provisions.
We are however entitled to outsource the processing of your Personal Data in whole or in part to external service providers acting as processors within the framework of Law No. 45 and GDPR. The service providers commissioned by us will process your data exclusively in accordance with our instructions and Law No. 45 and the GDPR. Doing so we always make sure that service providers commissioned by us are carefully selected, follow strict contractual regulations, technical and organizational measures, and additional controls by us.
We may also disclose Personal Data to third parties if we are legally obliged to do so e.g., by court order or if this is necessary to support criminal or legal investigations or other legal investigations or proceedings at home or abroad or to fulfil our legitimate interests.
Processing of Personal Data by us
- Log files
Each time a user accesses our website and each time a file is retrieved, data about this process is temporarily processed in a log file. In detail, the following data is stored for each access/retrieval: a) Date and time of the retrieval (time stamp), as well as the IP address of the accessing device or server, b) request details and destination address (protocol version, HTTP method, referrer, User Agent string), c) name of the retrieved file and transferred data volume (requested URL incl. query string, size in bytes) and d) Message as to whether the retrieval was successful (HTTP status code).
On the basis of our legitimate interest in a secure website, we are store the data to protect against attacks for up to 7 days beyond the time of your visit. This data is analyzed and required for legal and criminal prosecution in the event of attacks on communications technology. The data is deleted as soon as it is no longer required for the performance of tasks.
- Cookies
We use so-called cookies on our web site. Cookies are small text files that are stored on your respective device (PC, smartphone, tablet, etc.) and saved by your browser. The legal basis for the use of cookies is your consent as well as our legitimate interest.
- Hosting
To provide our website, we use the services of [Insert Hosting Provider] which processes the data listed below and all data to be processed in connection with the operation of this website (log file when visiting the website) on our behalf. The legal basis is our legitimate interest.
- Contacting us
Personal Data is processed depending on the contact method. In addition to your name and e-mail address, IP address or telephone number, we usually collect the context of you message which may also include certain Personal Data. The Personal Data collected when contacting us is processed for the purpose of dealing with your request and the legal basis is your consent. The use of your IP address takes place exclusively in the context of law enforcement and security measures in compliance with our legal requirements.
- Booking a treatment and provision of services
If you have contracted us to provide a service, we process your data (if provided: Name, contact details (email address and telephone number), address, and all information required in the context of the performance of the services including payment data, exclusively for the purpose of processing and handling the contractual relationship. This includes in particular our support, correspondence with you, invoicing, fulfilment of our accounting and tax obligations. Your data will not be used by us for automated decision making or profiling, nor will it be shared with third parties. Accordingly, the data is processed on the basis of fulfilling our contractual obligations as well as to fulfil our legal obligations.
- Administration
We process the same data that we process in the course of providing our contractual services in context of administrative tasks as well as organization of our business, and compliance with legal obligations, such as archiving. The processing bases are our legal obligations and our legitimate interest.
Third-party services and content
We use content or service offers of third-party providers on the basis of our legitimate interests in order to integrate their content and services (“content”).
This always requires that the third-party providers of this content are aware of the IP address of the user, as without the IP address they would not be able to send the content to their browser. The IP address is therefore necessary for the display of this content.
The following provides an overview of third-party providers and their content, together with links to their privacy policies, which contain further information on the processing of data and so-called opt-out measures, if any:
- Analytics and Tracking: Google Analytics by
- Video: YouTube by Google LLC
- Maps: Google Maps by Google LLC
- Content Management System: WordPress by Automatic Inc
- Online Advertising and Marketing: Google Ads from Google LLC
If you do not wish to participate in our advertising personalization or retargeting/tracking you can object to behavioral advertising at the Following websites: Your Online Choices, Digital Advertising Alliance of Canada, Network Advertising Initiative or AdChoices.
Your Rights and Privileges
- Privacy rights
Under Law No. 45 and the GDPR, you can exercise the following rights:
- Right to information
- Right to rectification
- Right to object to processing
- Right to deletion
- Right to information
- Right to data portability
- Right of objection
- Right to withdraw consent
- Right to complain to a supervisory authority
- Right not to be subject to a decision based solely on automated processing.
If you have any questions about the nature of the Personal Data we hold about you, or if you wish to request the erasure or rectification of Personal Data we hold about you, or to exercise any of your other rights as a data subject, please contact us.
- Updating your information
If you believe that the information, we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion, or object to its processing, please do so by contacting us.
- Withdrawing your consent
You can revoke consents you have given at any time by contacting us. The legality of the data processing carried out until the revocation remains unaffected by the revocation.
- Access Request
In the event that you wish to make a Data Subject Access Request, you may inform us in writing of the same. We will respond to requests regarding access and correction as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any Personal Data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the respective legal regulations mentioned above).
- Complaint to a supervisory authority
You have the right to complain about our processing of Personal Data to a supervisory authority responsible for data protection.
Changes and Questions
We may update this Privacy Policy from time to time. If we make changes to this Privacy Policy or materially change our use of your Personal Data, we will revise the Privacy Policy accordingly and also change the effective date at the end of this section. We encourage you to periodically review this Privacy Policy to be informed of how we use and protect your Personal Data. If you would like to contact us regarding our privacy practices for any reason, please contact us.
Effective Date
Saturday, 28 January 2023