Privacy Notice
1. Who We Are
This Privacy Notice explains how High End Timeless Lounge and Cafe LLC (Trade Licence No. 796935, TRN 100545709600003, G13, Meera Tower, Al Habtoor City, Business Bay, Dubai, UAE) (“Business”, “we”, “us”) collects, uses, shares and protects your personal data. We are the Data Controller under Federal Decree-Law No. 45/2021 (the “PDPL”).
2. Personal Data We Collect
We may collect the following categories of personal data:
- Identification & Contact: name, mobile phone number, email address, Loyalty Card ID, transaction history.
- Programme Data: spend amounts, tier status, discounts applied, points accrued and redeemed.
- Technical Data: device identifiers, app or wallet usage, login records, verification codes.
- Communications: your opt-in/opt-out preferences for marketing messages, service communications.
3. Purposes of Processing
We process your personal data for the following purposes:
1. Contract performance: to operate the Loyalty Programme (enrolment, accrual and redemption of benefits, account management).
2. Legal compliance: to comply with UAE laws, VAT accounting, consumer protection.
3. Legitimate interests: to prevent fraud, manage our business, analyse anonymised usage patterns.
4. Consent-based activities: sending marketing messages, cross-border transfers to specific countries (see Section 6).
4. Legal Basis
We rely on the following legal bases under PDPL:
- Contractual necessity — processing needed to deliver the Programme.
- Legal obligation — compliance with UAE tax and consumer laws.
- Legitimate interests — fraud prevention, IT security, internal analytics.
- Consent — for marketing communications and certain international transfers (see Section 6).
You may withdraw consent at any time without affecting prior lawful processing.
5. Retention
We retain your personal data for as long as you are a Member of the Loyalty Programme and for up to 5 years thereafter to comply with accounting, tax, and consumer protection laws. After this period, data will be securely deleted or anonymised.
6. International Data Transfers
Your personal data may be transferred and stored outside the UAE, including:
- Transatlantic transfers (to the United States and the European Economic Area) for hosting, analytics, or communication services.
- Transfers to the Russian Federation, where some Partner systems or backup servers may be located.
By enrolling in the Programme, you explicitly consent to:
- the transatlantic transfer of your personal data to service providers located in the US and EEA; and
- the storage and processing of certain data in the Russian Federation.
Such transfers are necessary for Programme operation and are protected by appropriate contractual and technical safeguards.
7. Sharing of Data
We may share your personal data with:
- Authorised Partners (Points of Sale) for benefit accrual/redemption.
- Payment processors and banks for transaction settlement.
- Service providers (IT hosting, CRM, SMS/email delivery).
- Regulators and government authorities where legally required.
We do not sell your personal data.
8. Your Rights under PDPL
You have the following rights under UAE law:
- Right of access to your personal data.
- Right to rectification of inaccurate data.
- Right to erasure (deletion) in certain cases.
- Right to withdraw consent.
- Right to data portability (where technically feasible).
- Right to object to certain types of processing.
You may exercise your rights by contacting us (see Section 10). We will respond within the timeframes required by PDPL.
9. Security
We apply strict security measures, including encryption, access controls, continuous monitoring, and regular audits, to protect your personal data against unauthorised access, disclosure, or misuse.
10. Contact and Complaints
Data Protection Contact: welcome_dubai@timeless.club
Postal Address: High End Timeless Lounge and Cafe LLC, G13, Meera Tower, Al Habtoor City, Business Bay, Dubai, UAE.
(Effective 01.05.2025; Version 1.0)
