Seven Tides is a Dubai-based, privately owned property development and holding company established in 2004. Currently focusing on luxury hospitality and residential real estate sectors, Seven Tides thinks progressively, works creatively, partners strategically and acts quickly. The result is a current portfolio of offerings in the gateway cities of Dubai and London.
Data That We Hold
We may hold data about the following individuals:
- Customers and clients
- Suppliers and service providers
- Advisors, consultants and other professional experts
- Complainants and enquiries
- Information of individuals gathered through marketing and advertising campaigns
- Information of brokers / agents who have signed agreements with us
- Information of individuals who visits our websites and submits their data either via the Contact Us forms or subscribing to our Newsletters
Data We Collect – Real Estate
- We will only collect information that is relevant to the contract signed with you or information you have provided us with pursuant to an enquiry. In particular we may collect the following information from you which is defined as ‘personal data’:
- Personal details, including identity data and contact details
- Financial details
- Business activities of the person whose details we are processing
- We never collect any personal data from you when you view one of our websites unless you expressly register through our Contact Us forms, subscribe to our newsletter or send us an enquiry via email.
- We never collect information that is referred to as being in a ‘special category’ under the General Protection Regulation 2016/679 (GDPR).
- We also operate a client relationship management email mailing list programme, which we use to inform clients and other contacts about our services, properties and special promotions. Such marketing activities may contain tracking technologies in order for us to track subscriber activity relating to engagement, demographics and other data.
- If you would like to stop receiving marketing materials from us at any time, please contact email@example.com. You can also change your preferences for receiving our marketing emails and updates from us at any time, simply unsubscribe by following the instructions specified in our marketing emails or via the websites.
Data We Collect – Hotels
- The personal information we collect when you interact with us through any of our hotel websites includes:
- When you make a booking, we need to know your name, address, username, password, telephone number, email address and card details. This allows us to process and fulfill your booking. You have the option to withhold personal information that is not required for the booking process.
- We do not sell, rent or exchange personal information with any third party for commercial reasons, beyond the essential requirement for credit/debit card validation during purchase. We may be required to give information to third parties such as expert witnesses, law enforcement agencies, courts and other professional advisers.
- We never send emails asking you to provide personal or credit card information nor do we disclose buyer’s information to third parties.
Web Browser Cookies
Our websites use Google Analytics, a web analytics service provided by Google Inc. Google Analytics uses “cookies”, which are text files placed on your computer, to help the website analyse how users use our sites. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers outside of the EEA.
Data Collection – Real Estate
- When your organization seek our services
- When you or your organization make an enquiry (including, without limitation, in person, through email, via our website and/or social media platforms or over the phone)
- When you attend any events (including, without limitation, project launches, exhibitions, seminars and conferences) or sign up to receive communication from us
- When you or your organization provide services to us, or otherwise offer to do so
- When you register on any of our websites through completing our Contact Us forms or subscribing to our newsletters
Data Collection – Hotels
- Take and fulfill customer bookings
- Administer and enhance the sites and services
- Only disclose information to third parties for goods delivery purposes
- Any information stored by Seven Tides is encrypted for your protection
Your personal information is used in a variety of ways, including but not limited to, when you visit our websites, place bookings, subscribe to our newsletter and in connection with other activities, services, features or resources we make available on our sites. You may be asked for, as appropriate, name, email address, mailing address, phone number etc. You may, however visit any of our sites anonymously. We will collect personal identification information from you only if you voluntarily submit such information to us.
Credit Card Information
Our payment processes are PCI DSS compliant. In booking to process credit and debit card transactions, the bank or card processing agency may require to verify your personal details for authorization. We do not store credit card information which is passed directly to our payment service provider.
We follow strict security procedures in the storage and disclosure of information which you have given to us to prevent unauthorized access in accordance with the GDPR regulations.
We will send emails to you, for the purpose of informing you of new products, offers and services. You may have consented to us sending you newsletters from time to time as part of the registration process.
You may opt out of this notification service by clicking on the unsubscribe button on the newsletter and/or email communication received from us alternatively you can send an email with the word ‘unsubscribe’ in the subject line to firstname.lastname@example.org
Basis For Processing
The basis on which we process your personal data is one or more of the following:
- It’s necessary for the performance of our contract with you
- It’s necessary for us to comply with a legal obligation
- It’s in our legitimate interests to do so
- You have given us consent (this can be withdrawn at any time upon request by sending an email to email@example.com)
How We Use Your Data – Real Estate
We may use your information for the following purposes:
- Provision of real estate services including advising and acting on behalf of clients (including where we are acting on your behalf on a sales/leasing transaction in the land department or any government or semi-government department responsible for real estate transactions in the relevant emirate of the United Arab Emirates)
- Promotion of our products and services
- Maintaining accounts and records
- Supporting and managing employees
- Managing and administering your or your organization’s business relationship with us, including processing payments, accounting, auditing, billing and collection or support of services
- Complying with our legal and regulatory obligations (such as record keeping obligations) and for insurance purposes
- Communicating with you through appropriate channels to keep you up to date on the latest developments, announcements, and other information about our services, properties as well as events and exhibitions we may organize
- For any purpose related and/or ancillary to any of the above or any other purpose for which your personal data was provided to us
How We Use Your Data – Hotels
We will use your personal information to manage bookings, provision of services, offers, surveys and newsletters you have requested. Specifically:
- To keep you informed of any special offers, company news, updated, product information or events that we believe might be or particular interest to you
- To administer and operate your account and to fulfill bookings placed through our websites
- For payment processing associated with the fulfillment of bookings
- To respond to your customer service requests
- To track activity on our websites
- For record-keeping purposes
- For market research
- To confirm your identification when you contact us
Automated Decision Making
We do not undertake any automated decision, excluding Google Analytics, making using your data, nor do we use your data for profiling or any other investigative purposes
We may share your personal information outside our company and this may include:
- Third party agents/suppliers or contractors, bound by obligations of confidentiality, in connection with the processing of your personal information for the purposes described in this Policy. This may include, but is not limited to, IT service providers
- Third parties relevant to the real estate services that we provide. This may include, but is not limited to, professional service providers, regulators and government authorities (land departments of relevant emirates)
- To the extent required by law, regulation or court order, for example, if we under duty to disclose your personal information in order to comply with any legal obligation
Where you authorize us, we may also disclose your information to your family, associates or representatives and we may also disclose your information to debt collection agencies if you do not pay our invoices
How Long We Keep Your Information For
We will normally keep your information throughout the period of time that we do work for you and afterwards for such period as we are required to do so by law and also by the regulations and insurance requirements that apply to us
Usually this will be for a period of six years after we conclude the work we have carried out for you, but may be for a longer period in specific cases (including and in particular with regards to real estate transactions)
Transfers To Third Countries
We may from time to time transfer your personal data to a country outside of the European Union (EU). Normally this will be necessary for the performance of your contract with us. Sometimes we may transfer for other reasons and we will ensure that appropriate safeguards are in place at all times. These safeguards may include:
- The country to which we send your personal data is approved by the European Commission as providing an adequate level of protection of personal data
- The recipient has entered into European Commission standard contractual clauses with us
- You have explicitly consented to the transfer of your personal data
- We take appropriate technical and organizational measures to keep your personal data confidential and secure, in accordance with our internal policies and procedures regarding storage of, access to and disclosure of personal data
- We may keep your personal data in our electronic systems, in the systems of our contractors, or in paper files
- We have security measures in place to ensure that we can effectively identify report, manage and resolve personal data breaches
- We have procedures to deal with key data subject rights, like subject access requests and the right to request erasure
- We are reviewing our key third party vendor arrangements to ensure that we have the appropriate contractual protection in place to satisfy GDPR requirements
- We regularly review our data security procedure to ensure they are kept up-to-date
You have the following rights under the GDPR:
Subject To Access Request
Under GDPR, individuals are entitled, subject to certain exceptions, to request access to information held about them. This is called a Subject Access Request.
The information that you are entitled to is:
- What information the company holds about you and why
- How you can gain access to it
- How to keep it up to date
- How the company is meeting its data protection obligations
We will usually process your request free of charge and within 30 days however we reserve the right to charge a reasonable administration fee and to extend the period of time a further 60 days if the request is manifestly unfound or vexatious and/or is very complex
Right to Erasure
- You have the right to ask us to erase your personal data in certain cases
- We will deal with your request free of charge and within 30 days but reserve the right to refuse to erase information that we are required to retain by law or regulation, or that is required to excise or defend legal claims
- To exercise your right to erasure, please contact us by email on firstname.lastname@example.org together with proof of identity
If you are dissatisfied with our handling of your requests about the protection of your data, you have the right to complain to us by emailing email@example.com