Privacy Policy
This Privacy Policy (“Privacy Policy”) forms a part of the terms of use/terms and conditions of use agreed between you and AP2GP Trading Middle East FZ LLC (“Company” or “us” or “we”) and applies to all products and services available on the Website (“Services”) and sets out how the Company collects, uses, stores, discloses, transfers and protects the information including Sensitive Personal Data (as defined below) and information of the user(s) of the Website (referred to as “you”, “your” or “User”). This Privacy Policy is an electronic record and is generated by a computer system and does not require any physical or digital signatures.
This Privacy Policy sets out the type of information collected from the User, the purpose, means and modes of usage of such information and how and to whom we may disclose or transfer such information. You may at any time withdraw your consent for the collection and use of your information, including Personal Data (as defined below) and Sensitive Personal Data. However, please note that if you withdraw your consent, we may no longer be able to provide you with the corresponding Service(s) for which you have withdrawn your consent. It is hereby clarified that your decision to withdraw your consent will not affect the processing of Personal Data and/or Sensitive Personal Data based on your previous consent prior to the withdrawal.
We recognize the importance of privacy as well as the importance of maintaining the confidentiality of personal information.
Capitalized terms not defined in this Privacy Policy shall have the meaning provided in the Company’s Terms of Use (the latest updated version of which can be found on our Website).
This Privacy Policy applies to the use of the Website, viz., www.rarabarefoot.com (“Website”). The Privacy Policy seeks to comply with the provisions of the Federal Decree Law No. 45 of 2021 on the Protection of Personal Data (“PDPL”) and any other applicable UAE laws that require publishing of the Privacy Policy for the collection, use, storage, disclosure and transfer of Sensitive Personal Data or information.
For the purpose of this Privacy Policy, “Sensitive Personal Data” means any data revealing a natural person’s racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs, criminal record, biometric data, genetic data, health data, or any data relating to the sexual life of a person, as defined under the PDPL.
“Processor” shall have the meanings ascribed under the PDPL.
You shall not access our Website without accepting this Privacy Policy. Your access and use of the Website signify your acceptance of this Privacy Policy. The Company may amend this Privacy Policy from time to time without prior notice to you, and such updated Privacy Policy shall be effective immediately upon becoming available on the Website. Your continued access or use of the Website after such posting constitutes your consent to be bound by such amended Privacy Policy. By accessing the Website, you agree and consent to the collection, transfer, use, storage, handling, disclosure and sharing of your information in the manner described hereunder.
The purpose of this Privacy Policy is to ensure that: (i) you are aware of and have complete control over what data and information including Sensitive Personal Data and information you provide to the Company, and how the same is and will be used by the Company; (ii) you are at all times aware of the rights available to you with respect to your data and information including Sensitive Personal Data and information; and (iii) how the information provided by you is processed, stored, and used in accordance with the applicable laws.
1. How We Collect and Use Your Personal Data
a. All your information is collected and retained by the Company having its registered office at VUNE0538, Compass building - Al Hulaila, AL Hulaila Industrial Zone-FZ, Ras Al Khaimah, United Arab Emirates.
b. Information which you provide when you register on the Website may include some or all of the following:
(i) information about your personal identity such as gender, name, address, age, preferences, etc.;
(ii) your financial information, such as your banking details;
(iii) any information relating to your lifestyle;
(iv) any information relating to your contact details, such as your postal addresses, telephone, mobile number, email addresses and social media handles ("Profiling Information");
(v) your account history, which you share with us, includes, without limitation, all billing information and communications, payment history, etc. We maintain all such information in encrypted form on secure servers;
(vi) information regarding browsing activities on the Website, including but not limited to IP addresses, date, and time of your use of the Website, browsing patterns, IMEI number and User behavioural patterns. In addition, we gather statistical information about the Website and visitors to the Website, including, but not limited to, browser software, operating system, software and hardware attributes, pages viewed, number of sessions and unique visitors;
(vii) transactional history (other than banking details) about your e-commerce activities on the Website;
(viii) Your usernames, passwords, email addresses and other security-related information used by you in relation to the Website;
(ix) your phone number which may be used to send you occasional marketing messages via WhatsApp. By providing your phone number, you opt in to receive such communications. Each WhatsApp message we send will include a link to unsubscribe or opt out of further WhatsApp communications.
(x) Data either created by you or by a third party, and which you wish to store on our servers, such as image files, documents, etc. We only collect your personal information to conduct our business and to enable us to deliver and improve our Services. (Article 1(b)(i) to Article 1(b)(x) are collectively referred to as "Personal Data")
c. Any information freely available or accessible in the public domain shall not form part of your Personal Data. The Company is not responsible for the authenticity and completeness of your information.
d. We will process any information provided to us in connection with disputes or to support complaints in connection with the Website or Services purchased via the Website. Please note that Users may submit complaints regarding the Services on the Website and under such circumstances, we will process data provided to us by the Users that is relevant for the expeditious resolution of complaints submitted.
e. Once you give us your Personal Data, you are not anonymous to us. Where possible, we indicate which fields are required and which fields are optional. You always have the option to not provide information by choosing not to use a Service or feature on the Website. We may automatically track certain information about you based on your behaviour on the Website if the same is necessary for providing you the Services you have opted for and your use of the Website. We use this information to do internal research on our Users' demographics, interests, and behaviour to better understand, protect and serve our Users. This information is compiled and analysed on an aggregated basis. This information may include the URL that you just came from (whether this URL is on our Website or not), which URL you next go to (whether this URL is on our Website or not), your computer browser information, data from your GPS (if activated) and your IP address.
f. We do not and shall never, for any reason whatsoever, sell your personal information to any third party or otherwise trade on it. We will only disclose your personal information in accordance with this Privacy Policy and as per the applicable laws. If we want to use your personal information/ data for any other purpose, we will obtain your prior written consent. In the event the Users do not provide any or sufficient Personal Data marked as mandatory, the Company may not be able to complete the registration process or provide such Users with the Company's products or Services. Information, which is disclosed publicly, may also be shared with our affiliates, third-party service providers, sponsors of competitions, etc., unless expressly stated otherwise for the purpose of providing the Services. We are not liable to you or any third party for any damages that you or any third party may suffer, howsoever arising from your disclosure of your Personal Information in any public environment. You accordingly disclose information in a public environment at your own risk.
2. Right to Collect Personal Data
a. By accepting the Terms of Use (an updated copy of which can be accessed on the Website), you expressly agree that we may collect and store your personal information as long as you use our Services and/ or Website, subject to the limitations set out in this Privacy Policy. We process Personal Data and Sensitive Personal Data on the following lawful bases under the PDPL: (i) where you have given consent; (ii) where processing is necessary for performance of a contract to which you are party; (iii) where processing is necessary for compliance with a legal obligation under UAE law; (iv) where processing is necessary to protect your vital interests or those of another person; and (v) where processing is necessary for the legitimate interests pursued by the Company, provided such interests do not override your rights and freedoms.
b. If you provide any Personal Data to the Company, you are deemed to have authorized the Company to collect, retain, handle, and use that Personal Data for the following purposes:
i. verification of the User's identity and eligibility to register on the Website, conducting security and KYC (know-your-customer) of the Users in accordance with the applicable UAE laws;
ii. processing the User's registration on the Website and maintaining and managing the User's registration;
iii. providing Users with customer service, including information about administrative service, announcements, security alerts and responding to Users’ queries, feedback, claims or disputes;
iv. for rendering the Services;
v. to verify and ascertain the charges and/ or consideration paid by you;
vi. for business, marketing and promotional activities;
vii. to facilitate communication between Users on the Website and/ or processing Users' transactions on the Website;
viii. performing research or statistical analysis in order to improve the content and layout of the Website, to improve the Company's product offerings and Services;
ix. subject to applicable law, the Company (including our affiliated companies) may use User's name, phone number, email address and other data to provide notices, surveys, product alerts, communications and other marketing materials to User(s) relating to Services offered by the Company or its affiliated companies and you explicitly consent to sharing your information that is essential to provide you with a better experience of using the Website;
x. if User voluntarily submits Personal Data or other information to the Website for publication through the publishing tools, then Users are deemed to have given their consent to the publication of such information on the Website; and
xi. making such disclosures as may be required for any of the above purposes or as required by law, regulations, and guidelines or in respect of any investigations, claims or potential claims brought on or against us or against third parties.
b. Any personal information which we collect and which we may use in an aggregated format, ensuring you are not individually identified, may be used by us for any legitimate and legal purposes.
c. Sometimes we use "cookies" so that we can provide you with more customised information when you return to our Website. "Cookies" are used to store User preferences and to track User trends, so as to enhance your interactive experience and generally improve our Services to you. You can set your browser to notify you when you are sent a "cookie", giving you the chance to decide whether or not to accept it. If you do accept a "cookie", you thereby agree to our use of any personal information collected by us using such Cookie. You may update your Profiling Information at any time on the Website. You acknowledge and agree that in the interests of improving personalisation and service efficiency, we may, under controlled and secure circumstances, share your personal information with our affiliates (an entity which is our subsidiary or holding company or a subsidiary of our holding company or an entity which controls, is controlled by or is under common control with us). The management of the “cookies” and the information collected through “cookies” is at the sole discretion of the Company, which is used for the operational purposes of the Website and the Services provided by us.
d. You understand that you may set or amend your web browsers to delete or disable cookies. If you choose to disable cookies on your computer or mobile telecommunication device, it may impair, degrade or restrict access to certain areas of the Website.
3. General exceptions
If we are required to intercept, disclose, monitor and/or store your personal information: (a) by law; (b) to conduct our business; (c) to secure our systems; or (d) to enforce our own rights, we will do so in the manner as prescribed by law. Such interception, disclosure, monitoring and storage may take place without your knowledge. In that case, we will not be liable to you or any third party for any damages howsoever arising from such interception, disclosure, monitoring and storage. In order to ensure that all our Users comply with the Terms of Use, we may monitor your personal information to the extent that this may be required to determine compliance and/or to identify instances of non-compliance. To ensure that the security and integrity of our Services are safeguarded, we may monitor your Personal Data. This monitoring may include (without limitation) the filtering of incoming and outgoing electronic data messages to identify, limit and/or prevent the transmission of spam, viruses and/or unlawful, defamatory, obscene or otherwise undesirable material or content. We may, under certain circumstances, procure an element of the Services from a third-party service provider. To the extent that it may be necessary, and solely for the purposes of providing the Service to you, you agree that we may disclose to such third party any of your personal information that may be necessary for the procurement of services from the third party.
Where we transfer Personal Data outside the UAE, we will only do so in compliance with the PDPL. Transfers may occur to jurisdictions deemed to have an adequate level of protection by the UAE Data Office, or subject to appropriate safeguards such as contractual clauses, or your explicit consent.
4. Collection of automation information, use of cookies and other tracking devices
We and our third-party service providers (such as analytics and advertising partners) use cookies, web beacons, and similar tracking technologies to collect certain information when you use our Website and Services. This information may include your browser type, operating system, IP address, device type, access times, and referring URLs. We use this information to understand User behaviour, improve our Website and Services, and deliver relevant advertisements. By using our Website, you consent to our use of cookies and tracking technologies, as detailed in this Privacy Policy. Where legally required, we will obtain your consent before using tracking technologies. You may disable cookies through your browser settings; however, some features of our Website may not function properly as a result. Currently, we do not respond to browser “Do Not Track” signals, but you may opt out of interest-based advertising by following the instructions provided in our Privacy Policy.
5. Third-party ad network
We may work with third-party ad networks that may display advertisements on other websites based on your visits to our Website and elsewhere. This enables us and these third parties to target advertisements by displaying ads for products and services in which you might be interested. Third-party ad network providers, advertisers, sponsors and/or traffic measurement services may use cookies, JavaScript, web beacons (including clear GIFs) and other technologies to measure the effectiveness of their ads and to personalize advertising content and to show you ads that may be of interest to you. We only engage in such tracking with your prior consent, which we obtain through our cookie management tool. Where we engage such third-party service providers to process Personal Data on our behalf, such Processors are bound by contractual obligations to handle the data in compliance with the PDPL, ensuring adequate technical and organisational safeguards. You can manage or withdraw your consent at any time through your browser settings or our Cookie Policy page. These third-party cookies and other technologies are governed by each third party's specific privacy policy. While we may provide these third-party advertisers with limited and anonymised information about your usage of our Website and our Services, as well as aggregate or non-personally identifiable information about visitors to our Website and Users of our Services, we do not share personally identifiable information without your explicit consent.
6. What choices do I have regarding the use of my personal information?
We may send periodic promotional or informational emails or WhatsApp messages to you about our services, offers, or updates that may be of interest to you. You may opt out of such communications by following the opt-out instructions contained in the email. Please note that it may take up to 7 (seven) business days for us to process opt-out requests. If you opt out of receiving emails/SMS about recommendations or other information we think may interest you, we may still send you emails or WhatsApp messages about your account or any Services you have requested or received from us.
7. Refer a friend
Our Website Users can voluntarily choose to electronically forward a link, page, or invite someone else by clicking on a feature referring to "Refer a friend". To do so, the User can send the link by email, WhatsApp, Telegram, or any other electronic means. If the referral is sent using our platform (e.g., where you enter the recipient’s email address or phone number), we will use that information solely for the purpose of delivering the message. We do not store or use the recipient's information for any other purpose, and the recipient will be informed that their contact details were provided by you. If the referral is sent through your own messaging application (such as WhatsApp), we do not access or collect any third-party Personal Data in that process.
8. Collection of personal information from social networking sites
You may log on to our Website through your social media account. If you do so, you must enter the authentication details that you use for that account. We will ask that you grant us permission to access and collect your basic information (this includes your name, profile picture, gender, networks, User IDs, list of friends, date of birth, email address, and any other information you have set to public on your social media account). We will access and use only the information that is necessary for authentication and to provide our Services, and only after you have granted us explicit permission to do so. We do not access or store information that you have marked as private on your social media account unless you expressly allow us to. You may revoke our access to your social media account at any time by changing the settings on your social media platform. We do not share this information with third parties except as necessary to provide the requested Services, and in accordance with this Privacy Policy.
9. Security
We endeavour to comply with applicable UAE laws, including the PDPL and the relevant rules thereunder. We undertake reasonable security practices and procedures, as required under UAE law, to protect your Personal Data and other information on our systems and Website. However, we do not control and are not liable for the practices of any third parties who are not subject to our control, for example, advertisers and websites that have links to our Website. While we take appropriate steps to safeguard your information, we are not responsible for any unauthorized disclosure of your information if such disclosure occurs due to factors beyond our control, including third-party actions not governed by us or any force majeure events. Kindly note that the information and privacy practices of our business partners, advertisers, sponsors or other sites to which we provide hyperlinks may be different from ours. We at our sole discretion may change any or all of the terms of this Privacy Policy by updating this document from time to time to reflect changes in law or our data practices. In case of material changes, we will provide appropriate notice or obtain your consent, if required by law. To make sure you are aware of any changes, please review this Privacy Policy periodically. If you have any questions regarding this Privacy Policy, please feel free to drop us a line at care@rarabarefoot.com.
10. Data retention and disclosure
In accordance with our Privacy Policy and as required under applicable UAE laws, you provide your consent to collect, use, store and share your Personal Data with our authorized employees, affiliates, or other third-party service providers strictly for the purpose of providing the Services, improving our offerings through analytics, trend identification, and enhancing User experience. We may use your Personal Data for the provision of relevant beneficial schemes, new offers, as well as for User experience enhancement that we believe may be of interest to you, subject to applicable laws. In the event of a corporate restructuring, such as a sale, merger, reorganization, dissolution or similar event, the Company may be required to transfer your Personal Data as part of the transferred assets, or we may be required to disclose certain Personal Data as part of the due diligence process. Any such transfer will be handled in accordance with applicable data protection laws. Please note that any information you voluntarily provide in public areas of the Service may be visible to others. We advise you to exercise discretion before sharing personal or sensitive information in such areas. Subject to applicable laws, we may also be directed by law enforcement agencies or the government and related bodies to disclose your Personal Data in connection with criminal or civil proceedings. We retain your Personal Data only for as long as necessary to fulfil the purposes stated herein or as required by law. Even if you discontinue accessing the Services or terminate your account, we may use the data to comply with our legal obligations or for the establishment, exercise, or defence of legal claims. The Company reserves the right to share the data with relevant agencies or bodies when needed. It will not be considered an infringement of the right to privacy. Under the applicable laws, Users have the right of access to personal information held by the Company and to request updating/ correcting/ deleting the information. We retain your Personal Data only for as long as necessary to fulfil the purposes set out in this Privacy Policy or as required by applicable UAE law. Thereafter, data will either be securely deleted or anonymised.
11. Modification
We reserve the right to amend this Privacy Policy from time to time and as required under the applicable UAE laws. The Privacy Policy, as and when modified, shall be updated on the Website. We encourage you to review this Privacy Policy whenever you visit our Website to understand how your Personal Data is used.
12. Governing law
The terms of this Privacy Policy shall be governed and construed in accordance with the laws of the UAE.
13. Severability
Whenever possible, each section of this Privacy Policy shall be interpreted in a manner so as to be valid under applicable law. However, in the event any provision is held to be prohibited or invalid, such provision shall be ineffective only to the extent of such prohibition or invalidity, without invalidating the remainder of such provision or other remaining provisions of this Privacy Policy.
14. Grievance redressal
In accordance with the provisions of applicable laws, including but not limited to the PDPL, UAE Consumer Protection Law (Federal Law No. 15 of 2020), UAE Civil Transactions Law (Federal Law No. 5 of 1985, as amended) and the UAE Commercial Transactions Law (Federal Law No. 18 of 1993, as amended) and rules enacted under those laws, the contact details of the grievance redressal officer are provided below. In compliance with the PDPL, the below-mentioned Grievance Officer acts as our Data Protection Officer (“DPO”) and is responsible for overseeing compliance with data protection obligations, handling complaints, and acting as the point of contact with the UAE Data Office, if required. You may contact our designated grievance redressal officer with any complaints or queries relating to the Services or the Terms of Use.
Attn: Grievance Officer
Email: care@rarabarefoot.com
Phone: +971 52 764 5001
Address: VUNE0538, Compass building - Al Hulaila, AL Hulaila Industrial Zone-FZ, Ras Al Khaimah, United Arab Emirates