Privacy Policy

CUSTOMER PRIVACY POLICY

Effective Date: March 2023

1. WHAT IS COVERED BY THIS PRIVACY POLICY AND DO OTHER POLICIES APPLY TO YOU?

This Privacy Policy (“Policy”) describes how we collect, use, store, share, and protect your personal information when you interact with our services, platforms, websites, mobile applications, and any other products or services we offer (collectively, the “Services”). This Policy applies to all customers, users, and visitors who access or use our Services, regardless of the channel or medium through which they are accessed.

Please note that our Services may contain links to third-party websites or platforms that operate under their own privacy policies. We are not responsible for the privacy practices of such third parties, and we encourage you to review their respective policies before providing any personal information. In addition, certain specific services or promotional activities may be governed by supplemental privacy notices, which should be read in conjunction with this Policy. In the event of a conflict between this Policy and any supplemental notice, the supplemental notice shall prevail with respect to that particular service or activity.

2. WHAT SPECIFIC TERMS APPLY TO YOU DEPENDING ON YOUR COUNTRY OF RESIDENCE?

Depending on your country or region of residence, additional or different terms may apply to the processing of your personal information in accordance with applicable local laws and regulations. We are committed to complying with the data protection legislation of each jurisdiction in which we operate.

For residents of specific countries or regions — including, but not limited to, Australia, the European Union, the United Kingdom, the United States (including California), Qatar, Vietnam, China, Kuwait, Saudi Arabia, Mexico, Chile, South Korea, and Azerbaijan — country-specific terms and rights are set out in the Appendices at the end of this Policy. We encourage you to review the Appendix relevant to your jurisdiction for detailed information on your rights and our obligations under applicable law.

3. WHO COLLECTS & USES YOUR PERSONAL INFORMATION?

Your personal information is collected and used by us — the entity operating the Services you are accessing. Depending on the nature of your interaction with our Services, personal information may be collected and processed by one or more of our affiliated group companies acting as a data controller or data processor, as the case may be.

In certain circumstances, we may act as a data processor on behalf of a business partner or third-party data controller. In such cases, the relevant business partner’s privacy policy will govern the processing of your personal information, and we encourage you to consult that policy for further details. Our registered business details and contact information are available in Section 18 of this Policy.

4. WHY DO WE COLLECT YOUR PERSONAL INFORMATION?

We collect and process your personal information for a variety of lawful purposes, including but not limited to: (a) providing, operating, and maintaining our Services; (b) processing and fulfilling your orders, bookings, or requests; (c) managing your account and providing customer support; (d) personalising and improving your experience with our Services; (e) communicating with you regarding updates, promotions, and relevant information about our products and services; (f) complying with our legal and regulatory obligations; (g) detecting, preventing, and investigating fraud, security breaches, and other unlawful activities; and (h) conducting research and analytics to enhance our Services.

We will only process your personal information where we have a valid legal basis to do so, which may include your consent, the performance of a contract with you, compliance with a legal obligation, or our legitimate business interests, provided such interests are not overridden by your rights and freedoms.

5. WHAT PERSONAL INFORMATION DO WE COLLECT?

The categories of personal information we may collect about you include, but are not limited to:

Identity and Contact Information: such as your full name, date of birth, gender, nationality, passport or government-issued identification details, email address, phone number, and postal address.
Account and Profile Information: including your username, password, preferences, and any other information you provide when creating or updating your account.
Transaction and Financial Information: such as details of purchases or bookings made, payment method details (excluding full card numbers), billing address, and transaction history.
Device and Technical Information: including IP address, browser type and version, operating system, device identifiers, and browsing behaviour on our platforms.
Communications Data: any information you provide when you contact us, respond to our surveys, or participate in our promotional activities.
Location Data: approximate or precise geolocation information, where you have granted us permission to collect it.

6. WHEN DO WE COLLECT YOUR PERSONAL INFORMATION?

We collect your personal information at various points throughout your interaction with us, including:

When you register for an account or sign up for our Services;
When you make a purchase, booking, or reservation through our platforms;
When you contact our customer service or support teams;
When you browse or use our websites, mobile applications, or other digital platforms;
When you participate in competitions, surveys, promotions, or events we organise;
When you provide feedback, post reviews, or interact with our social media channels;
When information about you is provided to us by third parties, such as business partners, loyalty programme operators, or analytics providers.

7. HOW DO WE COLLECT YOUR PERSONAL INFORMATION?

We collect your personal information through various methods, which may include:

Direct Collection: Information you provide directly to us when completing forms, registering an account, making a purchase, or communicating with us via telephone, email, live chat, or other channels.
Automated Collection: Information collected automatically through cookies, web beacons, pixel tags, and similar tracking technologies when you access and interact with our digital platforms. Please refer to Section 17 for further details on our use of cookies.
Third-Party Sources: Information received from third parties such as business partners, data analytics providers, social media platforms, and publicly available sources, in accordance with their respective privacy policies and applicable law.

8. WHO ARE OUR THIRD-PARTY SOURCES?

We may receive personal information about you from a range of third-party sources, including:

Business Partners and Affiliates: Companies with whom we have commercial arrangements for the provision of joint products, services, or loyalty programmes.
Social Media Platforms: If you choose to connect your social media accounts with our Services, we may receive information from those platforms in accordance with their privacy settings and policies.
Analytics and Advertising Providers: Third-party analytics companies and advertising networks that collect and share aggregated or pseudonymised data with us to help improve our Services.
Data Brokers and Public Sources: Publicly available databases, directories, and legally permissible commercial data sources used to verify, supplement, or update your information.
Payment Processors: Payment service providers who facilitate transactions on our behalf and share relevant transaction data with us.

9. SHOULD YOU ALWAYS SHARE YOUR PERSONAL INFORMATION WITH US?

The provision of certain personal information is necessary for us to provide you with our Services. Where information is required, we will indicate this clearly at the point of collection. If you choose not to provide information that is mandatory, we may be unable to provide you with the relevant Service, fulfil your request, or comply with our legal obligations.

For information that is optional, you retain full discretion over whether to share it with us. We will always endeavour to inform you of the consequences of not providing optional information so that you may make an informed decision. You may also update or withdraw information previously provided by contacting us as described in Section 18 of this Policy.

10. FOR HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?

We retain your personal information only for as long as is necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements. The appropriate retention period for personal information is determined by considering the amount, nature, and sensitivity of the information, the potential risk of harm from its unauthorised use or disclosure, the purposes for which we process it, and whether we can achieve those purposes through other means.

In some circumstances, we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information indefinitely without further notice to you. When we no longer require your personal information, we will securely delete or destroy it in accordance with our data retention policies and applicable law.

11. HOW DO WE PROTECT YOUR PERSONAL INFORMATION?

We take the security of your personal information very seriously and have implemented appropriate technical and organisational measures to protect it against unauthorised access, accidental loss, destruction, alteration, or disclosure. These measures include, but are not limited to, encryption of data in transit and at rest, access controls and authentication mechanisms, regular security assessments and audits, and staff training on data protection and security best practices.

While we make every effort to protect your personal information, no method of transmission over the internet or electronic storage is entirely secure. We therefore cannot guarantee absolute security. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify you and the relevant regulatory authorities in accordance with applicable law.

12. WHERE DO WE TRANSFER & STORE YOUR PERSONAL INFORMATION?

Your personal information may be transferred to, stored in, and processed in countries other than the country in which you reside. These countries may have data protection laws that differ from those of your home country. By using our Services, you acknowledge and consent to such transfers as described in this Policy.

Where we transfer personal information to countries that have not been deemed to provide an adequate level of data protection by the relevant regulatory authorities, we will ensure that appropriate safeguards are in place, such as standard contractual clauses approved by the applicable supervisory authority, binding corporate rules, or other legally recognised transfer mechanisms. Further details regarding our international data transfers are available upon request by contacting us as set out in Section 18.

13. WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

We may share your personal information with the following categories of recipients:

Group Companies and Affiliates: Other entities within our corporate group that assist in delivering our Services or that have a legitimate business need to access your information.
Service Providers: Trusted third-party vendors and service providers who perform functions on our behalf, such as payment processing, IT services, marketing, analytics, customer support, and logistics.
Business Partners: Partners with whom we offer co-branded products, services, or promotions, where you have agreed to the sharing of your information.
Regulatory and Legal Authorities: Government authorities, law enforcement agencies, courts, or other public bodies where we are required or permitted to do so by applicable law.
Prospective Buyers or Investors: In connection with any proposed merger, acquisition, restructuring, or sale of assets, where personal information may be transferred as part of the transaction.

We do not sell your personal information to third parties for their own marketing purposes without your explicit consent.

14. HOW DO WE ADDRESS THE PRIVACY OF CHILDREN?

Our Services are not directed at, and we do not knowingly collect personal information from, children under the age of 18 (or such other age as may be stipulated by applicable law in your jurisdiction). If you are under the applicable age of majority, you must not use our Services or provide any personal information to us without the consent and supervision of a parent or legal guardian.

If we become aware that we have inadvertently collected personal information from a child without appropriate parental or guardian consent, we will take immediate steps to delete such information from our records. If you believe we may have collected information from or about a child, please contact us immediately using the details provided in Section 18.

15. WHAT ARE YOUR RIGHTS REGARDING YOUR PERSONAL INFORMATION?

Subject to applicable law, you may have the following rights in relation to your personal information:

Right of Access: The right to obtain confirmation of whether we process your personal information and, if so, to receive a copy of that information.
Right to Rectification: The right to request the correction of inaccurate or incomplete personal information we hold about you.
Right to Erasure: The right to request the deletion of your personal information, subject to certain exceptions under applicable law.
Right to Restriction: The right to request that we restrict the processing of your personal information in certain circumstances.
Right to Data Portability: The right to receive your personal information in a structured, commonly used, and machine-readable format, and to transmit it to another data controller.
Right to Object: The right to object to the processing of your personal information based on our legitimate interests or for direct marketing purposes.
Right to Withdraw Consent: Where processing is based on your consent, the right to withdraw that consent at any time, without affecting the lawfulness of processing carried out prior to withdrawal.

To exercise any of the above rights, please contact us using the details set out in Section 18. We will respond to your request within the timeframes prescribed by applicable law. Please note that certain rights may be subject to limitations or exceptions under applicable legislation.

16. CAN THE PRIVACY POLICY CHANGE?

We reserve the right to update or amend this Privacy Policy from time to time to reflect changes in our business practices, applicable laws, or industry standards. Any material changes to this Policy will be communicated to you through appropriate means, which may include posting the updated Policy on our website, sending you an email notification, or presenting a notice when you next use our Services.

The date of the most recent revision will always be indicated at the top of this Policy under the “Effective Date” heading. We encourage you to review this Policy periodically to stay informed of how we are protecting your personal information. Your continued use of our Services following the posting of changes constitutes your acceptance of those changes, to the extent permitted by applicable law.

17. DO WE USE COOKIES OR OTHER ONLINE ADVERTISING TECHNOLOGIES?

Yes. We use cookies, web beacons, pixel tags, and other similar tracking technologies on our digital platforms to enhance your experience, analyse usage patterns, deliver personalised content, and serve targeted advertising. Cookies are small text files placed on your device when you visit our website, which enable us to recognise your device and store certain information about your preferences and actions.

We use the following types of cookies: (a) Strictly Necessary Cookies, which are essential for the operation of our Services; (b) Performance and Analytics Cookies, which help us understand how visitors interact with our platforms; (c) Functionality Cookies, which remember your preferences and settings; and (d) Targeting and Advertising Cookies, which are used to deliver advertisements relevant to your interests across different platforms and websites.

You may manage or withdraw your consent to the use of non-essential cookies through our cookie consent tool or through your browser settings. Please note that disabling certain cookies may affect the functionality and performance of our Services. For further information on how we use cookies and similar technologies, please refer to our Cookie Policy, which is available on our website.

18. HOW CAN YOU CONTACT US?

If you have any questions, concerns, or complaints regarding this Privacy Policy or the manner in which we handle your personal information, or if you wish to exercise any of your data subject rights as described in Section 15, please contact our Data Protection Officer or privacy team using the following details:

Data Protection Officer / Privacy Team
Email: privacy@sueita.com
Postal Address: [Company Legal Name], [Street Address], [City, Country, Postcode]

We are committed to addressing your enquiries promptly and in accordance with the timelines prescribed by applicable law. If you are not satisfied with our response, you may have the right to lodge a complaint with the relevant data protection authority in your jurisdiction.

APPENDIX 1 – Specific Information for Australian Residents About the Use of Your Personal Information

This Appendix applies to individuals located in Australia and supplements the information contained in the main body of this Privacy Policy. We are committed to complying with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs) contained therein.

As an Australian resident, you have the right to access your personal information held by us and to request its correction if it is inaccurate, out-of-date, incomplete, irrelevant, or misleading. You also have the right to lodge a complaint with the Office of the Australian Information Commissioner (OAIC) if you believe we have mishandled your personal information. Requests for access or correction, and privacy complaints, may be directed to our privacy team using the contact details in Section 18. We will endeavour to resolve all complaints within a reasonable timeframe.

APPENDIX 2 – Specific Information for Residents of Qatar, Vietnam, China, Kuwait, Saudi Arabia, Mexico, Chile, South Korea, or Azerbaijan About the Use of Your Personal Information

This Appendix provides additional information relevant to residents of Qatar, Vietnam, China, Kuwait, Saudi Arabia, Mexico, Chile, South Korea, and Azerbaijan, in accordance with the data protection and privacy laws applicable in each of these jurisdictions.

We are committed to processing your personal information in a manner that is consistent with your local legal rights and entitlements. Where applicable local law grants you rights that are broader than or different from those described in the main body of this Policy, those local rights shall prevail. Residents of these jurisdictions may contact our privacy team at the address provided in Section 18 to enquire about their specific rights under local law and to make any related requests.

APPENDIX 3 – Specific Information on Text and Instant Messages for Residents of the United States or Guam

This Appendix applies to residents of the United States (including the territory of Guam) and addresses our practices regarding the use of text messages (SMS) and instant messaging services for commercial communications.

By providing your mobile telephone number and opting in to receive SMS or instant messages from us, you consent to receive promotional and transactional text messages sent using automated dialling technology. Message and data rates may apply. You may opt out of receiving text messages at any time by replying “STOP” to any message we send, or by contacting us using the details in Section 18. We comply with the requirements of the Telephone Consumer Protection Act (TCPA) and all other applicable federal and state laws governing electronic communications.

APPENDIX 4 – Specific Information for Californian Residents

This Appendix is provided pursuant to the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively, “CCPA/CPRA”), and applies to personal information of residents of the State of California.

As a California resident, you have the following rights under the CCPA/CPRA: (a) the right to know what personal information we collect, use, disclose, and sell; (b) the right to delete personal information we hold about you, subject to certain exceptions; (c) the right to correct inaccurate personal information; (d) the right to opt out of the sale or sharing of your personal information for cross-context behavioural advertising; (e) the right to limit the use and disclosure of your sensitive personal information; and (f) the right to non-discrimination for exercising your privacy rights.

To exercise your rights under the CCPA/CPRA, you may submit a verifiable consumer request to us using the contact information in Section 18, or through any designated submission mechanism available on our website. We will not discriminate against you for exercising any of your rights under California law. For further information regarding our California-specific data practices, including the categories of personal information collected and the purposes for which they are used, please contact our privacy team.