Privacy Policy

ABOUT US

Seeniun Media (“Seeniun Media ”, “we”, “us”, “our”) is committed to respecting your privacy.

Please read the following privacy policy (“Privacy Policy”) carefully to understand our views and practices regarding your personal data and how we will collect, store, use, transfer, disclose, and process it in our capacity as a data controller and/or data processor.

This data includes but is not limited to personal data collected via our Seeniun Media  official website (www.seeniunmedia.com) and related network, ecosystem, pages, content, features, products, and tools offered by us via any kind of digital platform (“Platform”).

If you have any questions about how we interact with your personal information, please contact info@dubairen.com. Where any reference in this Privacy Policy is made to contacting us, please use this method unless otherwise stated.

As an entity registered in the United Arab Emirates, the below (including terminology) should be interpreted in the context of UAE Federal Decree – Law No. 45/2021 on the Protection of Personal Data (the “UAE Data Protection Law”).

 

Glamour’us AS A DATA CONTROLLER AND PROCESSOR

Seeniun Media may act as a data controller, meaning that we determine the purposes for which, and the way in which, personal data is collected and processed.

Seeniun Media may also be a data processor when we deal with personal data provided by, and as instructed by, a data controller (such as a payment gateway) for specific purposes. In such cases, data is provided to us in strict confidence and subject to restrictive undertakings regarding use and disclosure.

 

CHANGES TO THIS PRIVACY POLICY

We may change this Privacy Policy from time to time, at our sole discretion in accordance with applicable laws.

We encourage you to frequently check the Platform for any changes to our Privacy Policy. We will not substantially reduce or diminish your rights under this Privacy Policy without your explicit consent, but we may not notify you of all changes to this Privacy Policy.

 

CONSENT

This Privacy Policy applies to the Platform. By making a purchase or signing up to our newsletters on our website, you agree irrevocably and without condition to your personal information and other data being collected (including via cookies), used, stored, disclosed as set out in this Privacy Policy.

If you do not consent to the terms of this Privacy Policy, please do not access the Platform, or provide Seeniun Media with your personal data. If you wish to withdraw consent previously granted, please contact us.

Once consent has been granted as above, your continued use of the Platform constitutes your understanding of, and your agreement to, the practices described in this Privacy Policy including subsequent updates.

In limited circumstances, and solely to the extent permitted by the UAE Data Protection Law (such as to protect the public interest and public health), we may process data without your explicit consent.

You must not provide us with personal data about another person unless you have first obtained that person’s prior consent to do so, and you have their consent for their personal information to be handled in accordance with this Privacy Policy (including where to find it).

 

FOR WHAT PURPOSES DO WE COLLECT DATA?

We collect your personal information to enable you to receive the benefit of the Platform and services and/or products. Subject to this Privacy Policy, we may use your personal information for the following purposes:

  •   To provide you with services and/or products
  •   To open, maintain and administer your account and other forms of Platform access
  •   To provide customer services, including to notify you about changes and updates to our services and/or products, alerting you to data breaches, and troubleshooting
  •   To send you service communications and marketing material to promote our services and/or products and the Platform (including any social media pages maintained or operated by us such as Facebook, Instagram, TikTok, Twitter, YouTube)
  •   To send you service communications and marketing material to promote the services and/or products of third parties
  •   To provide quality assurance and training for our staff
  •   To develop our products and services, including optimizing Platform security, performance measurement, and customisation
  •   To verify your identity or location
  •   To process payments
  •   To make reasonably necessary security and credit checks
  •   To manage in-person visits to properties and events
  •   To access third-party development platforms or add-on keys
  •   To conduct market research and analysis
  •   To provide you with recommendations and personalized products and services
  •   To comply with legal, regulatory, and tax reporting obligations
  •   Any other purpose closely related to or facilitating the above and/or to which you expressly consent

Any other uses identified to you at the time of collecting your personal information or as reasonably contemplated by this Privacy Policy

 

WHAT INFORMATION DO WE COLLECT?

(a)User Provided Information

When you register, use the Platform, or otherwise communicate with us, you may provide us with data (including personally identifiable information) such as: 

  • Name (including title and pronouns)
  • Contact details (including home/office address, email address, telephone number)
  • Bank/credit card details
  • Date of birth/birthday

For example, you may provide us with an email address to receive marketing material or updates about our services, a phone number so that we provide you with a one-time passcode, or your name and payment information when you purchase a product or service.

Registration with the Platform is optional. However, you may not be able to use some of the features offered by the Platform unless you have an operational account with us.

(b)Automatically Collected Information

While you use the Platform, we collect general information of the sort that web browsers, servers and network operators typically make available, such as:

  • Details of how you interact with the Platform (such as the links that you click, content that you view, terms, products, and services that you search for, products that you buy, people you communicate or share information with, and how you interact with advertisements)
  • Internet protocol address
  • Location, using locator technologies, such as sensor data from devices that may, for example, provide information on nearby Wi-Fi access points and cell towers
  • Device-specific information (including hardware model, operating system version, unique device identifiers (e.g., persistent cookies, MAC addresses, device IDs, IMEI numbers), and mobile network information)
  • Device event information such as crashes, system activity, hardware settings, browser type, browser settings, browser language, the date and time of request and referral URL
  • Cookies that may uniquely identify the browser
  • GPS signals sent by a mobile device

 

FROM WHICH SOURCES DO WE COLLECT DATA?

We collect information from various sources, such as when you:

  • Interact with the Platform (including when you sign up for an account, enter competitions, and use the Platform on an ongoing basis)
  • Contact us via phone, email, chat, or other channel
  • Interact with our social media channels
  • Sign up for email newsletters
  • From third-party service providers, agencies, or other publicly available sources where applicable, including credit reference and fraud prevention agencies

Cookies

To make certain aspects of the Platform work properly, we sometimes place small data files called cookies on your device.

A cookie is a small text file that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns. It enables the website to remember your actions and preferences (such as login, language, font size and other display preferences), so you don’t have to keep re-entering them whenever you come back to the Platform or browse from one page to another.

The Platform uses cookies to help us identify you from other users, track your usage of the Platform, and your website access preferences. We do or may use the following cookies:

  •   Strictly necessary cookies. These are cookies that are required for the operation of the Platform. They include, for example, cookies that enable you to log into secure areas of the Platform, use a shopping cart or make use of e-billing services.
  •   Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around the Platform when they are using them. This helps us to improve the way the Platform works, for example, by ensuring that users are finding what they are looking for easily.
  •   Functionality cookies. These are used to recognise you when you return to the Platform. This enables us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
  •   Targeting cookies. These cookies record your visit to the Platform, the pages you have visited and the links you have followed. We will use this information to make the Platform and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

You can control and/or delete cookies as you wish—for details, see www.aboutcookies.org. You can delete all cookies that are already on your computer and you can set most browsers to prevent them from being placed. If you do this, however, you may have to manually adjust some preferences every time you visit the Platform and some services and functionalities may not work.

If you wish to deny the use of and saving of cookies from the Website onto your computer, you should take the necessary steps in your browser settings. You always have the choice of accepting, rejecting, or deleting cookies. If you choose to change your settings, you may find that certain functions and features will not work as intended.

 

FOR HOW LONG DO WE RETAIN AND PROCESS DATA?

Seeniun Media retains your personal information for such period of time as may be required for the purposes for which it was collected and to comply with legal, regulatory and Seeniun Media policy requirements.

Where the use of personal data is not necessary for any of the agreed purposes, we will either (i) cease to process the applicable data, or (ii) process the data using an automated process to render it non-personally identifiable before use (via pseudonymisation or anonymisation).

 

DISCLOSURE OF YOUR PERSONAL DATA

Your data stays within the exclusive control of Seeniun Media and its affiliates, other than when:

  •   You give us explicit consent to share your data
  •   We share it with trusted external service providers and data processors with appropriate data protection protocols in place such as banks, payment services providers, data centers, web hosts, cloud storage and cloud software providers, customer support providers, payment processors, debt collectors, accountants, and insurers
  •   We share it with regulators and other relevant public authorities for the purpose of legal or contractual compliance, or reporting purposes
  •   As otherwise permitted by UAE Data Protection law, including with regard to matters of public security and public health

Recipients of your personal data may be located outside of the United Arab Emirates. You agree that we may transfer your personal data outside of the United Arab Emirates if the data is processed in accordance with this Privacy Policy and applicable laws.

Business transfer

If we, or substantially all of our assets, are the subject of a potential acquisition, or in the event that we go out of business or enter bankruptcy, user information may be comprised within the assets inspected, transferred, or acquired by a third party.

You acknowledge and agree that if such events occur, that any subsequent processor of our business may continue to use your personal information as set forth in this Privacy Policy.

Cross-Border Transfer

We will not transfer your data to parties outside the UAE unless adequate data protection protocols in place or other valid reasons as prescribed by Art. 23 of the UAE Data Protection Law are applicable.

Use of personal information for direct marketing

From time to time we may use the personal information we collect from you to identify specific products and services that we believe may be of interest to you. We may then contact you to let you know about these products and services, new features and how they may benefit you, solicit your feedback, or just keep you up to date with what’s going on with us and our products and services.

Direct marketing from us generally takes the form of an email. Where we use your personal information to send you marketing information by email, SMS, MMS or other electronic means we may do so with your express or deemed consent. Every directly addressed marketing contact sent or made by us will include a means by which you may unsubscribe (or opt out) of receiving further marketing information.

Additionally, you may instruct us at any time to remove any previous consent you provided to receive marketing communications from us.

 

Personal information by category

Do we collect this?

Do we disclose this for business purposes?

Do we sell this?

Personally Identifiable Information (PII): such as real name, alias, unique personal identifier, online identifier, gender, date of birth, Internet Protocol (IP) address, email address, or other similar identifiers.

YES

YES

NO

Customer records: such as paper and electronic customer records containing personal information, such as name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

YES

YES

NO

Protected classifications: such as race, color, sex, age, religion, national origin, disability, citizenship status, and genetic information.

NO

NO

NO

Purchase history & tendencies: such as commercial information, including transaction records of products or services purchased in participating merchant outlets, or other purchasing or consuming histories or tendencies, excluding any PII data.

YES

NO

NO

Biometric information: such as physiological, biological or behavioral characteristics that can be used alone or in combination with each other to establish individual identity, including DNA, imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information.

NO

NO

NO

Usage data: such as internet or other electronic network activity information, including, but not limited to, your precise geographical location (based on your device), browsing history, search history, and information regarding your interaction with an internet website, application, or advertisement, excluding any PII data.

YES

YES

NO

Audio visual: such as audio, electronic, visual, thermal, olfactory, or similar information.

NO

NO

NO

Employment history: such as professional or employment-related information.

YES

NO

NO

Profiles & inferences: such as inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes, excluding any PII data.

YES

NO

NO

 

 YOUR PERSONAL DATA RIGHTS

The following outlines a non-exhaustive summary of your rights with respect to personal data.

Accessing Your Personal Data Records

On request we will, as soon as reasonably possible, provide you with personal data about you that is in our possession or under our control and information about the ways in which the personal data has been or may have been processed or disclosed by us during the year preceding the date of the request.

We reserve the right to withhold such services in the limited circumstances prescribed by Art. 13(3) of the UAE Data Protection Law. We will aim to (but shall not be obliged to) provide reasons for doing so.

If you wish to access the data we hold about you or to find out more about how we process it, please contact us on info@dubairen.com.

Accuracy, Rectification, and Deletion

To the extent required by law, you may review, edit, correct, or delete any personal information you submit to us. We take reasonable steps to ensure that the personal information we hold about you is accurate, complete, and up to date.

However, we rely on you to advise us of any changes to your personal information. By accepting this Privacy Policy, you hereby undertake to use all reasonable endeavors to provide corrections and updates of your personal data in a timely manner.

Please contact us at info@dubairen.com as soon as possible if there are any changes to your personal information or if you believe the personal information we hold about you is not accurate, complete, up-to-date, no longer necessary for the purpose for which it was collected or processed, or lacks a valid legal ground for processing so that we can update your file accordingly.

Depending on the circumstance, we may change, erase, or block from use any inaccurate, incomplete, or outdated information. We may require documentary proof or evidence for certain requests and in the limited circumstances prescribed by Art. 15(3), we may decline to act on such requests.

We will process any legitimate requests to correct inaccurate or incomplete data as soon as practicable, and take steps to inform (on a reasonable endeavors basis) other organizations to which the data was disclosed during the year preceding the date of the correction, unless it is impossible, involves disproportionate effort, the other organizations no longer require the corrected personal data for any legal or business purpose, or you otherwise agree that we do not need to resend the corrected information to any other organization.

You can stop all collection of information by the Platform easily by uninstalling the Platform.

You may use the standard uninstall processes as may be available as part of your mobile device or via the mobile app marketplace or network. You can also request to opt-out or delete your account via email, at info@dubairen.com.

Right to object to or restrict data collection

Please contact us at info@dubairen.com if you wish to request a restriction or cessation of your data processing, along with your reasons for objection. We will respond to all requests within a reasonable time frame. If we disallow your objection, we will inform you of our reasons for doing so.

 

DATA SECURITY

We value the confidentiality and security of your personal data.

We provide a suitable level of physical, electronic, and procedural safeguards to protect the data that we process and maintain, and we will aim to take all steps that may be necessary to ensure that your personal information is treated securely and to prevent unauthorized access, collection, use, disclosure, copying, modification, disposal, or similar risks.

For example, we limit access to this information to authorized employees and contractors to the extent needed to operate, develop, or improve the Platform.

Although we endeavor to provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches. To the extent permitted by applicable law, Seeniun Media does not warrant or guarantee in any way that your personal data will always remain private or safe and Seeniun Media disclaims any responsibility or liability arising out of or in connection with loss or unauthorized use, access, or disclosure of any personal data held by us.

We will inform you without undue delay unless the risk to your individual rights and freedoms is low—such as if the compromised data was well encrypted.

Please contact us immediately if you become aware of any unauthorized use of your account by anyone else or any other breach of security.

 

LINKS TO THIRD PARTY WEBSITES

The Platform may contain links to and from third party websites.

If you click on such links, you do so at your own risk and subject to whatever privacy policy and/or website terms may govern the use of such websites. We have no control over, and are not responsible, nor liable for, the content, privacy practices or website terms of such websites or any information you provide to them.

You should read the privacy policy of these third parties to find out how they handle your personal information when you visit their websites.

 

GOVERNING LAW

This Privacy Policy is governed by and construed in accordance with laws of the United Arab Emirates as applicable in the Emirate of Dubai.