Privacy Notice

Last updated: 15 July 2024

We are committed to protecting and respecting your privacy. This Privacy Notice (the “Notice”) governs the collection and use of personal data by Emirates Academy of Hospitality Management LLC and its affiliates or any company it controls. It explains how and why we use your personal data and applies to the personal data that you provide us directly, or which we may obtain from other sources.

We may use your personal data for any of the purposes described in this Notice, or as otherwise stated at the point of collection. For more information about Emirates Academy of Hospitality Management LLC please see www.dubaiholding.com.

References to "our", "us" or "we" within this Notice are to Emirates Academy of Hospitality Management LLC, a company incorporated under the laws of Dubai with commercial licence number 848304, and whose registered office address is at Building 69, Al Saqool Street - Umm Suqeim 3, Dubai, United Arab Emirates; tel: +971 4 315 5555, Email: privacyoffice@jumeirah.com.

The Emirates Academy of Hospitality Management LLC is the data controller of your personal data. We decide how and why your personal data is processed, either alone or jointly with others.

If you visit our venue or use our facilities and services, the entity which manages the relevant venue, facility or service will also be a data controller in respect of your personal information. You can access a ‘Data Controller List’ here, [SR(1] which sets out all affiliates/related entities of Emirates Academy of Hospitality Management LLC and their contact details. This will enable you to identify the relevant Emirates Academy of Hospitality Management LLC entity that holds, processes, and secures your personal data and is the data controller in relation to your personal data.

If you have any questions about this Notice, the use of your data, or would like to be directed to our Data Protection Officer, please contact privacyoffice@jumeirah.com.

[SR(1]Separate data controller list to be linked here.

In this Notice we refer to “processing” your “personal data”.

Processing is taken to mean anything that is done to or with personal data (including simply collecting, storing or deleting that data).

Personal data is any information relating to an identified or identifiable living person.  When “you” or “your” are used in this statement, we are referring to the relevant individual who is the subject of the personal data.

We process different categories of personal data to enable us to provide services to you, and as further described below.

Contact Details: Includes but is not limited to address, email address and telephone number.

Identification data: Includes but is not limited to name, title, company and individual physical description.

Personal Information: Includes but is not limited to date of birth, age, gender, nationality, passport, marital status, signature, country of residence, photograph, family, voice recording, religion, languages spoken, place of birth, emergency contact details, insurance details and driving licence number.

Web Data: Includes but is not limited to cookies, user activity logs, IP address, social media profile and website visitor interaction data.

Health Data: Includes but is not limited to health, allergies, dietary requirements, medical information forms and notes and disability records.

Financial Data: Includes but is not limited to card details and bank details.

Student Data: Includes but is not limited to course registrations, transcripts, academic and test responses, and Student ID.

The reason these categories of personal data are processed, along with our legal basis for doing so, are set out in the table below.

Description of Processing Purpose for Processing Category of Personal Data Legal Basis
We process your personal data for academic and learning purposes. Operations Contact Details, Identification Data and Student Data Legitimate Interest
We process personal data to assess your suitability for academic programs. Operations Contact Details, Identification Data, Personal Information and Student Data Legitimate Interest
We process your personal data for career development and alumni engagement purposes. Operations Contact Details and Identification Data Legitimate Interest
We process personal data for counselling purposes. Operations Contact Details, Identification Data, Student Data, and Health Data Legitimate Interest and when processing special category personal data - Explicit Consent
We process personal data for general student administration purposes. Operations Contact Details, Identification Data, Student Data, and Financial Data Legitimate Interest
Reviewing and confirming your legal right to study in a particular country or geographic region. Operations Contact Details, Identification Data, Student Data, and Financial Data Legitimate Interest and Legal Obligation
We process your personal data when facilitating the check-in and check-out process. Customer Service Contact Details, Identification Data, Personal Information, Accommodation information Health Data, and Financial Data Contract and when processing special category personal data – Explicit Consent
We process your personal data in order to conduct surveys, obtain feedback and manage and progress complaints as necessary. Customer Service Contact Details, Identification Data, Personal Information, Web Data, Health Data, and Financial Data Legitimate Interest and when processing special category personal data - Explicit Consent
We process your personal data for marketing purposes, such as personalising offers for you, as well as for analytics purposes. Advertising / Marketing Services, Analytics Services Contact Details, Identification Data, Personal Information, Web Data, and Financial Data Consent and Legitimate Interest
We process your personal data for service and quality monitoring purposes. Customer service Contact Details, Identification Data, Personal Information and Financial Data Legitimate Interest
We process your personal data in relation to incidents and accidents. Health and Safety Contact Details, Identification Data, Personal Information, Web Data, Health Data and Legal obligation, Vital Interest, Legitimate Interest and when processing special category personal data - Health Exemption
We process your personal data for invoicing purposes. Account Management Contact Details, Identification Data, Personal Information, Student data and Financial Data Contract
We process your personal data in order to comply with legal requirements and exercise or defend legal claims. Litigation & Disputes Contact Details, Identification Data, Personal Information and Health Data Legal obligation, Legitimate Interest and when processing special category personal data - Legal Claims Exemption
We process your personal data in order to provide medical care where required. This includes COVID-19 processes and procedures Health and Safety Contact Details, Identification Data, Personal Information and Health Data Consent, Vital Interest and Legal obligation and when processing special category personal data - Health or Social Care Exemption
We process your personal data in order to improve the services we provide. Customer Service Contact Details, Identification Data, Personal Information, Web Data, Health Data, and Financial Data Legitimate Interest and when processing special category personal data - Explicit Consent
We process your personal data for management and audit of our business operations including accounting Audit Purposes and Financial Management Contact Details, Financial Details, Personal Information, Identification Data, Health Data Legitimate Interest and when processing special category personal data - Health Exemption
We process your personal data for security purposes and to ensure secure backup and archival of IT Systems. Security Purposes Contact Details, Identification Data, Personal Information, Web Data, Health Data and Financial Data Legitimate Interest and when processing special category personal data – Legal Claims Exemption
We process your personal data for identifying, investigating and mitigating incidents, such as if a personal data breach occurred Security Purposes Contact Details, Identification Data, Personal Information, Web Data, Health Data, and Financial Data Legitimate Interest and when processing special category personal data – Legal Claims Exemption
We process your personal data for tenant management purposes including issuing of access tags, managing complaints, issuing vehicle / parking permits, gym memberships (if applicable) and coordinating tenant move-in or move-out with the security team after permits are issued, as required. Tenant Management Contact Details, Personal Information, Government Related data, Financial data and Health data Legitimate Interest, Contract and when processing special category personal data – Health Exemption
We process your personal data to liaise with applicable government authorities Supporting Service Contact details, Identification Data, Personal Information and Student Data Legal obligation
We process your personal data for procurement purposes, such as vendor management and contract management. Supporting Service Contact Details, Personal Information and Financial Data Legitimate Interest and Contract

Your personal data will not be kept longer than necessary to meet the purposes detailed above. The criteria that we use to determine how long we will keep your personal data includes the period of time during which we have an ongoing relationship with you, and whether we have a legal obligation to store it (for example, for accounting purposes or for litigation, or regulatory investigations purposes).

Should retention of your personal data no longer be required we will remove it from our systems and records and/or take steps to properly anonymise it so that you can no longer be identified from it.

Where necessary to fulfil the purposes described in this Notice, we shall disclose your personal data to certain third-parties, vendors and service providers or affiliated employees, contractors and entities as described below.

To the extent necessary, and where we have a legal basis to do so, we will also share your personal data with other entities related to Emirates Academy of Hospitality Management LLC, including any affiliates.

Where we share personal data, we do so with the following parties for the following purposes:

Category of Third-Party Purpose for Disclosure
Legal and professional advisers Accident and Incidents, Comply with legal requirements and exercise or defend legal claims, Competition and events and IT security
Health Providers Accident and Incidents, Comply with legal requirements and exercise or defend legal claims and Medical care
Finance Providers Accident and Incidents, Comply with legal requirements and exercise or defend legal claims and IT security
Government Bodies Accident and Incidents, Bookings / reservations / providing services, IT security and Medical care
IT, digital, technology and telecoms Analytics, Bookings / reservations / providing services, Marketing and Memberships
Marketing and Research Services Bookings / reservations / providing services and Marketing
Education and Childcare Providers Bookings / reservations / providing services and IT security

Where we have a lawful basis to do so, we will use your personal data to evaluate certain personal aspects about you, such as to analyse or predict aspects concerning your economic situation, personal preferences, interests, reliability, behaviour, location or movements. This is known as “Profiling”. We only conduct profiling where it will not have a legal or other significant effect on you. We undertake profiling to help tailor our marketing to you.

When processing your personal data, we may transfer this to third parties based in other countries, to the extent necessary to fulfil the purposes described in this Notice. Emirates Academy of Hospitality Management LLC forms part of Dubai Holding LLC and its subsidiaries. Your personal data may be transferred within this group of companies, as well as to Emirates Academy of Hospitality Management LLC affiliates and related entities. Such transfers shall always be done in compliance with relevant data protection laws.

For transfers of personal data from the UK and European Economic Area (“EEA”) we transfer personal data to entities outside the EEA, under the EU Standard Data Protection Clauses. Further information about transfers can be obtained by contacting us using the following email address privacyoffice@jumeirah.com.

To the extent required, we will also transfer your personal data to third parties in connection with a reorganization, restructuring, merger, acquisition or transfer of assets, provided that the receiving party agrees to treat your personal data in a manner consistent with applicable laws and requirements.

The Emirates Academy of Hospitality Management LLC has implemented technology and operational security measures in order to protect personal data from loss, misuse, alteration or destruction. Only authorised persons are provided access to personal data; such individuals have agreed to maintain the confidentiality of this personal data.

You have certain rights relating to your personal data. However, these rights can differ depending upon the country in which you are located. That country’s law will determine which rights apply and in what instances.

Right to withdraw consent

Where you have provided your consent to us, you will always have the right to withdraw this at any time. You can do this by either following the information provided at the time you provided your consent, or by contacting us using the following email address privacyoffice@jumeirah.com.The withdrawal of consent will not affect any processing that was based on consent before its withdrawal.

Right to request correction of your personal data

You will always have the right to request that we correct any personal data that we process about you that is inaccurate or incomplete. You can do this by contacting us privacyoffice@jumeirah.com..

Right to request access to information

You have the right to be informed about what data is being processed and how it is being processed. You can do this by contacting us privacyoffice@jumeirah.com.

Right to restrict the processing of your personal data

You have the right to ask us to restrict, suspend or stop the processing of your data. You can do this by contacting us privacyoffice@jumeirah.com.

Right to request deletion of your personal data

You have the right to request for your personal data to be deleted. You can do this by contacting us privacyoffice@jumeirah.com.

 

It is important to understand that these rights are not absolute (e.g., their application may depend upon the Lawful basis we rely upon to process your personal data) and that we may require further information from you (e.g., to confirm your identity) to action your request.

European data protection rights

Where the General Data Protection Regulation applies, you are also provided with additional rights. This allows you, subject to certain conditions, to:

●      Upon request, be provided access to, or copies of, your personal data that we process;

●      Object to our processing of your personal data; or

 

You also have the right to lodge a complaint with the supervisory authority in your country of residence, place of work or the country in which an alleged infringement of data protection law has occurred within the EU.

Where we use cookies, you can also control the data stored by cookies and withdraw consent to cookies by using the browser-based cookie controls described on our websites.

If you want to exercise any of the rights set out above or have any questions or concerns about how we treat your personal data, please contact us at privacyoffice@jumeirah.com or by writing to us at: Emirates Academy of Hospitality Management LLC: Building 69, Al Saqool Street - Umm Suqeim 3, Dubai, United Arab Emirates. Please include your reply address when you write to us.

We keep this Notice under regular review. We reserve the right, at our discretion, to change, modify, add or remove sections of this Notice at any time. You are also encouraged to review this Notice from time to time for updates. We will notify you of any changes (including when they will take effect) if we are required to do so by data protection laws.