Emirates Leisure Retail LLC ("ELR", "We", "Us") is a controller of your personal data. We respect your data and your privacy is important to us.

This Privacy Notice explains what personal data we collect and how it is used. This notice also explains what rights you have over your personal data and how you can use those rights.

More information about your rights and how to exercise these is set out in the “Your rights” section of this notice.

An overview of how we use your data is here.

1. Summary of how we use your data and your rights
2. Information we collect from you
3. Information we receive from third parties
4. How we use information and the legal basis
5. Data sharing
6. International transfers
7. Cookies and similar technologies
8. Data retention
9. Your rights Contact details
10. Which Costa entity is the controller?

1. Summary of how we use your data and your rights

We use your data to provide and improve our products and services, including for marketing, research, feedback and enquiries, and for safety and security purposes. We also use your data when you enter competitions or awards that we organise.

We will use your data to comply with laws and regulations. We use your data to prevent and detect crime, such as fraud.

When you give consent, you are able to withdraw that consent at any time, for instance by emailing Support@costacoffeeclubuae.ae

to exercise any other data rights, such as obtaining a copy of your data, correcting, deleting or restricting how we use your data. Please see "Your rights" for more information.

You can unsubscribe from marketing communications at any time. To opt out of direct marketing, including profiling for direct marketing purposes, you can either adjust the preference settings in your Costa Coffee Club UAE account, or select “unsubscribe” in emails, or email Support@costacoffeeclubuae.ae

Our websites and app use cookies and similar technologies to improve functionality, recognise you and to customise your experience. You can reject and block cookies in your browser settings. Please see our Cookie Notice for more information.

If you enable location services on the app, or you access the location finder on our sites and your browser settings allow this, your device will identify and alert you to the nearest Costa Store in UAE to your location.

Please see section 5 and 6 for how ELR can share your data with 3rd parties.

2. Information we collect from you

We collect information when you purchase something or use our services or enter our competitions or awards. This includes store visits, using our websites or app, joining the Costa Coffee Club UAE, or corresponding with us.

In particular:

• We keep information you give us directly such as contact details (including name, email, address and telephone number), comments, date of birth, gender, region, frequency of visits, feedback, marketing opinions and competition entries.
• We record and analyse store, web and app visits, details of your purchases and where you take advantage of our promotions.
• If there is an incident, we log information about it.
• If you engage with us online via our websites or app our cookies and similar technologies will capture your IP address, your location, and record how you use the site or app to help improve it and improve your user experience, where your browser settings or permission allows for this.
• If you post information online about us or provide feedback, we keep a record.
• If you contact us directly and complain or give feedback, receive compensation, or enter a
  competition, we will record details and all related information (including that you provide to us) such as emails, letters, phone calls, date of birth to our product customer information helplines including those operated by third parties as detailed in Section 5 below.
• We use CCTV in our premises for the prevention and detection of crime and for safety and security reasons.

3. Information we receive from third parties

We receive your information from other people in certain circumstances. This can happen when:

• You participate in market research, such as focus groups or surveys.

4. How we use information and the legal basis

We are allowed to use your data only if we have a proper reason to do so such as:

• ·To fulfil a contract we have with you;
• When it is in our legitimate interest;
• When you consent to it; or
• To comply with the law.

A legitimate interest is when we have a business or commercial reason to use your data. This involves us making an assessment of when we can rely on our legitimate interests.

We have set out below how and why we use your personal information and the legal basis we rely on. This is also where we tell you what our legitimate interests are.

When you buy something from us, join the Costa Coffee Club UAE, or enter a competition we run, we use your information to fulfil our contract with you.

We take information to communicate with you, check your identity, take payment, and provide products and services, including awarding loyalty points if you are a Costa Coffee Club UAE member.

To run our business and pursue our legitimate interests, we use your information.

Our legitimate interests include keeping our records up to date, fulfilling our legal, compliance and contractual duties, working out which of our products and services may interest you, improving our site and apps, and services, developing new products and services, and telling you about them and conducting market research.

Further details of our legitimate interests:

To run and promote our business, we use your information:

• To provide and improve our products and services, including in-store Wifi, Costa Coffee Club UAE, and to respond to you if you contact us.
• To record call centre communications, including incoming and outgoing calls and emails, for staff training, quality improvement purposes and establishing facts and to deal with concerns or complaints that you may raise.
• When we monitor Costa websites, social media platforms such as Facebook and Twitter and online services including our mobile app and responses to email marketing. If you post
  comments online or in other media, we capture this information, use it to contact you, and use it to improve our products and services.
• To run competitions and promotions and track which offers seem of interest to you.
• To understand you better as a customer by analysing your transactions and other information you provide to us or which we learn through your interactions with us.
• To send you emails including offers tailored to your perceived preferences where you are a Costa Coffee Club UAE member and your preference settings permit this. We record which emails seem to be of interest to you. Based on your purchase history and membership card usage, some Costa Coffee Club UAE members may be offered additional loyalty points.
• To contact you where you provide us with market research feedback or pass this data to a third-party business partner of ours for panel market research analysis.
• To prevent, investigate and/or report fraud, terrorism, misrepresentation, security incidents or crime, including where we are required to do so by law, we:
• Monitor Costa Coffee Club UAE accounts and review CCTV, record call centre communications and emails.
• Use other organisations to check the validity of the credit or debit card details you use
  to pay (for further details see “Data sharing” below).

To comply with law, assess and uphold legal or contractual rights and claims, and for monitoring, auditing and training on compliance matters:

• We monitor, and record call centre communications, including incoming and outgoing calls and emails.
• We verify your identity in certain circumstances.
• We keep records to comply with health and safety legislation, including accounting for the number of individuals on our premises and logging accidents.

If you give us consent, we:

• Send you electronic marketing, including promotions and offers, in relation to our products and services if you are a member of our Costa Coffee Club UAE and inform you of other outlets that award Costa Coffee Club UAE points. Costa Coffee Club UAE members can subscribe or unsubscribe from our marketing communications at any time. For instance, preferences can be adjusted in account settings online.
• Use cookies or similar technologies on the website, app and in marketing emails, including analytic cookies. For more details on our use of such technologies, click here to see our Cookie Notice.
• Through the settings on your device, send you push notifications through the app.
• If you use the store locator in the app or site and enable location services, it will notify you of the nearest Costa Store in UAE.
• Use data for other purposes where we explain that purpose when we ask for your consent.
• When you give consent, you are able to withdraw that consent at any time by contacting us, for instance by emailing Support@costacoffeeclubuae.ae
• If you do so we can only continue to use your data if another legal basis applies, such as when we’re required to do something by law.

Nevertheless, you have an absolute right to opt-out of direct marketing, including profiling for direct marketing purposes, at any time. You can opt out of marketing by selecting “unsubscribe” in emails or by adjusting the preference settings on your Costa Coffee Club UAE account or by emailing Support@costacoffeeclubuae.ae

When the law requires us to process your data we will do so. This can include:

• Legal, compliance, regulatory and investigative purposes, including for government agencies and law enforcement.
• When you exercise your rights under data protection legislation, including when you ask to unsubscribe from our marketing communications.

5. Data Sharing

For some activities ELR uses third party service providers. When these service providers need customer data from you, we may have to share information with them for verification purposes.

We use third party providers for the following services:

• Wifi
• Sending promotional offers
• Customer feedback surveys
• Online order fulfilment, including the management of queries, concerns or complaints related to your order(s)
• Data analysis to enable us to optimise our services (including locations and products) Gift
  cards (including E-Gifts)
• Loyalty scheme platform and app
• Insurance
• IT development, support, maintenance and hosting, including the provision of applications and website hosting
• Payments’ processing to enable you to pay by credit or debit card
• CCTV system provision and maintenance
• Administration of our competitions

If our business is to be integrated with another business or sold, your details would be shared with our advisers and any prospective purchaser’s advisers. Your information could be passed to the new owners. (You will be notified if this happens).

Personal data may be shared with government authorities and/or law enforcement officials for the prevention or detection of crime, if required by law or if required for a legal or contractual claim.

6. International transfers

Sometimes we send or store your data outside of the UAE. For example, to follow your instructions, comply with a legal duty or to work with or receive services from our service providers who we use to help run your accounts and our services.

If we do transfer information outside of the UAE, we will make sure that it is protected by using one of these safeguards:

• Transfer it to a country inside the European Economic Area (the EU plus Iceland, Lichtenstein and Norway) (‘EEA’) and as such your data is protected by the EU’s General Data
  Protection Regulation (‘GDPR’).
• Transfer it to a non-EEA country with privacy laws that give the same protection as the EEA. Some countries have been deemed adequate by the EU.
• Put in place a contract with the recipient that means they must protect it to the same
  standards as the EEA or use other mechanisms and measures to achieve adequate protection. We also may use the Standard Contractual Clauses published by the EU.

7. Cookies and similar technologies

Our website, apps and marketing emails use cookies and similar technology. Full information is in our Cookie Notice. This includes information on how to adjust your browser settings to accept or reject cookies.

8. Data retention

We keep your data to enable us to fulfil our contract with you or to provide services, whilst you are an active user of our site, app or Costa Coffee Club UAE, where required by law or to protect legal rights. We always look to keep your data for the minimum time in line with data protection principles and our processes. For example, we keep:

• Information on Costa Coffee Club UAE members as follows. After 12 months of inactivity on your account we reserve the right to delete the account and all beans associated with the account. All Information associated with your account that is held by us will also be deleted.
• Records of payment information in line with tax law and audit requirements.
• Customer feedback and correspondence with our customer services teams for up to 4 years afterwards, depending on the nature of the interaction and any applicable law, such as health and safety. This enables us to respond to any questions or complaints.
• Information to maintain records according to rules that apply to us.

If you unsubscribe from marketing communications we keep a record of this request indefinitely to ensure we do not send you direct marketing again.

We may keep your data for longer if we cannot delete it for legal, regulatory or technical reasons.

9. Your rights

You have rights over your personal data.

You can:

• ask for a copy of your information;
• ask for information to be corrected;
• ask for information to be erased or deleted
• ask for us to limit or restrict processing;
• object to us processing your data, in particular, where we do not have to process the data
  to meet a contractual or other legal requirement and in relation to processing for direct marketing purposes, including profiling for direct marketing purposes;
• ask us to send you a copy in a structured digital format or ask for us to send it to another party.

Some rights, however, may be limited. We may be obliged by law or regulation to keep information. We must respect other people’s privacy as well, which means we may need to redact or remove information where it includes personal data about someone else, even if it is connected to your data. On occasion there may be a compelling legitimate interest to keep processing data.

If you want a copy of your data, to object to how we use your data, or ask us to delete it or restrict how we use it or, please see ‘Contact details’ below. To process a request from you, we may need to confirm your identity to ensure we’re accessing the right data.

10. Contact details

To exercise any of your rights or to withdraw consent you can email: Support@costacoffeeclubuae.ae

For any queries related to your Costa Coffee Club UAE membership, including personal date contact us at Support@costacoffeeclubuae.ae

We may change or update this notice from time to time. We will communicate these as appropriate – for example, by updating our website or, where legally required, by actively telling you about the changes.

11. Which Costa entity is the controller?

The controller for your information is Emirates Leisure Retail LLC (ELR), Level 5, Emirates Holiday Building, Sheikh Zayed Road, 122199, Dubai, UAE. ELR runs the Costa Coffee Club UAE within the UAE.

Please remember that when you click a link to go from our website to another website, our Privacy Policy no longer applies. Any browsing and interaction on another website, is subject to that website's or third party notices and policies which we recommend you read. This policy applies solely to data collected and processed by Costa Coffee.

Some stores using the Costa brand are franchisees. Franchisees are all committed to protecting your privacy but, just to be clear, each Costa franchisee is an independent business and is responsible for the operation of its own stores and compliance with data protection law.