Habibi-Souq App privacy notice

Introduction and scope

This privacy notice explains how Burj Trade LLC uses your personal information in the context of your use of the DragonMart mobile app (“App”) and the DragonMart website (“Website”) (together “Our Sites”).

Burj Trade LLC is the controller of personal information processed by Our App. When we mention "Habibi-Souq", “our” or “we” in this notice, we are referring to Burj Trade LLC. 

The personal information we collect about you

We use, store and transfer the following types of personal information about you in the context of your use of Our App:

• “Personal identifiers/details” – your first name and surname, delivery address and email address.
• “Usage data” - product clicks, scrolling information, purchase details, cart information, screen navigations, crash logs, diagnostic data.
• “Payment data” - your bank account number, IBAN, BIC, billing address, as well as your purchase history. 
• “Marketing data” - preferences regarding communications methods and areas of interest relating to: our products or services and receiving electronic marketing communications from us. 

We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage data to calculate the percentage of users accessing a specific feature. However, if we combine or connect Aggregated Data with your personal information so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

How and on what basis we use your personal information

We use your personal identifiers in line with our legitimate interests in order to enable you to log in to Our Sites and as is necessary in order to perform the contract of purchase to deliver the products to you.

We use your usage data in line with our legitimate interests in:

• seeking to promote, develop and grow our businesses through the sale of products and services and to provide excellent customer services or to otherwise exercise our fundamental rights to property and to operate a business under articles 16 and 17 of the EU’s Charter of Fundamental Rights;
• improving or services monitoring the performance and relevance of Our Sites; and
• to prevent fraud or criminal activity, misuse of our products or services as well as the security of our IT systems, architecture and networks and security of our premises. 

We use your payment data as this is necessary to perform the contract of purchase to provide you with the products and, where relevant to refund you for purchases made.

We use your marketing data either with your consent or in line with our legitimate interests in order to develop and grow our businesses.

How we obtain your personal information

The information we collect about you comes from the information you give us when you use Our Sites and purchase our products including your interactions with us and others.  

We also receive usage data from Google as a third-party analytics provider.

Disclosing, sharing and transferring your personal information

Where we collect, transfer and store your personal information with any direct or indirect subsidiary of Burj Trade LLC (a member of the “Burj Group” or our “Group”) located outside the EEA (including in the United Arab Emirates), we have in place standard contractual clauses to protect your personal information and share such information on the basis of our Group’s legitimate interests in promoting our products and services and undertaking direct marketing, because we think you may have an interest in their products and services, and in order to provide our services to you. 

We share certain information with third parties outside of our Group including:

• Service providers (including contractors and designated agents) who provide:
• marketing services – based in the UK
• call centre services - based in Egypt;
• third party payment processors – based in the UAE; and
• cloud hosting services – based in the UAE. 

• A potential buyer, transferee, merger partner or seller and their advisers in connection with an actual or potential transfer or merger of part or all of DP World’s business or assets.
• Any national and/or international regulatory or enforcement body or court or other form of tribunal where we are required to do so by applicable law or regulation or at their request.

We will only share your personal information with third parties for marketing purposes if you provide us with your consent to do so including by email or by ticking a box on a form, or any other method that we use to collect your personal information. 

International transfers

Your information in Our Sites will be accessible from the United Arab Emirates. We have put measures in place to protect your personal information when it is transferred outside of the UK or the EEA (or other locations that protect international transfers of personal data) to a country that has different data protection rules and is not subject to an adequacy decision, making use of a form of contract approved by the European Commission known as “standard contractual clauses” under Article 46(2) GDPR / UK GDPR. For more information about those measures, please contact us at the details below.

Data retention

We will retain and process information about you for as long as you continue to use or express an interest in our services, log into Our Sites or use our interactive services and, if you have not used or expressed an interest in our services, logged into Our Sites or used our interactive services for more than 6 years, we will delete your information shortly thereafter. 

Your rights

Data protection law grants you certain rights ('information rights') which we summarise in the table below. Please note that these rights are not absolute and they may not always apply in your particular circumstances.  

Right of access and data portability

You have the right of access to information we hold about or concerning you and/or to have it transferred to another data controller in some circumstances. 

Right of rectification or erasure.

If you feel that any data that we hold about you is inaccurate you have the right to ask us to correct or rectify it. You also have a right to ask us to erase information about you where you can demonstrate that the data we hold is no longer needed by us, or if you feel that we are unlawfully processing your data. Your right of rectification and erasure extends to anyone we have disclosed your personal information to and we will take all reasonable steps to inform those with whom we have shared your data about your request for erasure.

Right to restriction of processing

You have a right to request that we refrain from processing your data where you contest its accuracy, the processing is unlawful and you have opposed its erasure, where we do not need to hold your data anymore but you need us to in order to establish, exercise or defend any legal claims, or we are in dispute about the legality of our processing your personal information.

Right to object

You have a right to object to our processing of your personal information. This includes the right to object to the use of your information for direct marketing and profiling purposes.

Right to withdraw consent.

You have the right to withdraw your consent for the processing of your personal information where the processing is based on consent. At such point we will stop processing your personal information. 

Right of complaint.

If you are unhappy with the way we have used or are handling your personal information you have the right to lodge a complaint with the supervisory authority for data protection issues in your country in the UK or EEA where you usually live, work or where the data protection issue arose. We would, however, appreciate the chance to deal with your concerns before you approach the supervisory authority, so please contact us in the first instance at the email set out above.

You can exercise any of these rights at any time by contacting us at the details below.

Contact us

If you have any questions about this notice, you can also contact us at JAFZA 17 or email us support@dragonmart.ae. If you would like to speak to us please call 04-5563988. 

Changes to this privacy notice

We keep this notice under regular review, and it may change. If it does, these changes will be posted on the Website and, where material, you’ll be notified about them when you next start the App. 

This notice was last updated on: [10 Feb 2024]