Privacy Policy

Policy Description and Objectives

This Data Privacy policy (“Privacy Policy”) sets out details for external users relating to the collection and use of Personal Data by Small Worlds Kids Amusement LLC Expo City Branch (“Small Worlds”) through its digital platforms. The Privacy Policy is intended for external use and the text below will be published across Small Worlds websites, mobile application and digital platforms.

1. DEFINITION

Abbreviation

  • Affiliate: An organization or entity which directly or indirectly controls, is controlled by, or is under direct or indirect common control with Small Worlds or its subsidiaries.
  • Data Subject: shall mean the natural person who is the subject of the Personal Data.
  • EU: shall mean the European Union.
  • GDPR: shall mean the ‘General Data Protection Regulation’, Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data.
  • Personal Data: Has the meaning assigned to it in section 6.1.1 of this Policy.
  • Sensitive Personal Data: means Sensitive Personal Data as defined in the UAE Data Privacy Law and special categories of personal data in the GDPR as further described in section 6.1.2 of this Policy.
  • UAE: shall mean the United Arab Emirates.
  • UAE DP Law: shall mean Federal Decree-Law No. 45/2021 on the Protection of Personal Data (as amended)

2. DATA PRIVACY AND COOKIE POLICY

2.1 Personal Data

The entity responsible for your Personal Data is Small Worlds Unless defined herein, capitalized terms have the meaning given to them in the UAE Data Privacy Law and/or GDPR as applicable.

2.2  Place of Business

Small Worlds is incorporated in the Emirate of Dubai, United Arab Emirates whose principal place of business. This Privacy Policy is applicable to all the subsidiaries and Affiliates of Small Worlds.

2.3 Affiliates

Small Worlds, and our Affiliates (also referred to as “we” and “us”), take our data protection and privacy responsibilities seriously. This Privacy Policy describes how we collect, process, use, disclose and transfer your Personal Data. As the “data controller” of your Personal Data, we determine why and how we process your Personal Data. This Privacy Policy covers instances when you contact us, use our services and products or interact with our websites, such as www.smallworldsme.com, and visit our branch Small Worlds in Expo City Dubai.

3. TERMS OF USE

3.1 Use of Small Worlds Websites
The Small Worlds website is subject to this Privacy Policy. Please ensure you read it carefully and understand it. In jurisdictions where your consent to this Privacy Policy is required you hereby consent to it and agree to be bound by it and its terms.

3.2 Policy Applicability
The Privacy Policy applies to virtual and website visitors, ticket buyers, merchandise buyers, tenants, customers, visitors, suppliers, brokers, licensees and media professionals, and any other third-party users of Small Worlds Websites or other Small Worlds applications. Please refer to section 6 of this policy to understand what Personal Data is and how and why Small Worlds uses it.

3.3 Data Accuracy
The accuracy of your data is important to us. You are required to provide us with correct and accurate information. Whenever necessary we enable you to correct the data that you have provided to us either through self-service or through contacting our customer service desk, or the data privacy office mentioned in clause 16.3.

4. UPDATES

4.1 Privat Policy Changes

Small Worlds may make necessary changes to this Privacy Policy at its sole discretion wherever or whenever required without any notice. Consequently, we would recommend that you review this policy from time to time to check for such updates.

5. THIRD PARTY WEBSITES

5.1 Website Responsibility

Small Worlds Websites may link you to other websites, including those of our service providers, advertisers and Affiliates. We are not responsible for the way in which third party websites operate or the way in which they may process any Personal Data, which you provide to them. It is important that you understand this and check their respective privacy policies and terms of use.

6. WHAT PERSONAL DATA WE COLLECT AND WHEN AND WHY WE USE IT

6.1 What is Personal Data?

6.1.1 Sensitive Personal Data in this Privacy Policy means any data that directly or indirectly reveals a natural person’s family, racial origin, political or philosophical opinions, religious beliefs, criminal records, biometric data, or any data related to the health of such person, such as his/her physical, psychological, mental, genetic or sexual condition, including information related to health care services that reveals his/her health status.

6.1.3 The Personal Data we collect is based on the Small Worlds services you chose to use, as described in the subsequent sections.

6.2 When and why is Personal Data collected?

6.2.1 Purchase of tickets or other Small Worlds Products

a) If you use the Small Worlds Websites to purchase tickets, Small Worlds merchandise etc., we may collect and use Personal Data about you as necessary to manage the purchase. This may include Personal Data such as your name, date of birth, address, contact information (such as phone number and e-mail address), as well as information collected about your navigation patterns on our websites. We may also seek to collect Sensitive Personal Data from you in order to enhance your purchase and visitor experience. The Sensitive Personal Data we collect may include details such as health-related information provided by you.
b) If you purchase a ticket from us, we may collect and use Personal Data about you to help to create personalized pathways for you through the Small Worlds site on the basis of your preferences which we will have ascertained from your navigation of Small Worlds Websites and, once you are on the Small Worlds site, through location tracking using our mobile application.

6.2.2 Supplier Data

a) We process personal data of supplier’s employees and contractors that we receive from or in connection with the delivery of products, the provision of services and from or in connection with the initiation, conclusion and performance of contracts. This includes, in particular, title, name, business contact data (e.g. address, telephone number, mobile number, e-mail address) and further data which are transmitted to us by the supplier.

b) We may supplement existing information from publicly available sources, in particular from the supplier’s website, trade registers, address databases and company directories. We also use services to provide economic information on the creditworthiness and performance of companies.

6.2.3 Customer Support and online services

a) If you contact us by way of email, live chat, message boards or any other facility made available by Small Worlds with a query or comment about any of our services or products, or would like us to keep you informed about latest news and developments at Small Worlds through our newsletter or other means (for example, direct marketing), we will need to collect information about you (including your contact details) to help us respond to your query or request or provide our services to you. We may do this when you call our customer support center or interact with us through our online support tools. This information may include identification data (such as your name, date of birth, gender, nationality etc.), contact details (such as email address and telephone number) and other information (such as your interests, personal preferences and transaction history).
b) We may also keep a record of any communications we have with you (including a recording of any calls you make). We do this to help monitor and improve the quality of our customer support services, to make and defend legal claims, and to comply with legal obligations to which we are subject.

6.2.4 Creating a registered account on Small Worlds website

a) There are several sections of the Small Worlds Websites where we may require you to register in order to be able to make full use of the services we offer.
b) If you register with us to create an Small Worlds Websites account, we may process your Personal Data to:

i) Manage your access to certain parts of Small Worlds Websites and, if applicable, allow you to make certain purchases (such as tickets and merchandise) or receive certain services.
ii) Send you newsletters and marketing and promotional materials (including via social media, based on the contact details you provide us), subject to your marketing preferences; and
iii) Offer you the opportunity to download digital souvenirs following your visit to Small Worlds (if applicable).

c) If you register with us to create an Small Worlds Websites account, the Personal Data we will collect from you may include identification data (such as your name, age, gender and country of residence), contact details (such as your email address, phone number and address), your preferences (which we can ascertain from the way in which you have navigated the Small Worlds Websites), and may also include professional information about you and your photo. If you choose to register an account with us by using a third-party app (such as Facebook or Twitter), you will be presented with a dialogue box which will ask your permission to allow Small Worlds to access your Personal Data from that third-party app (e.g., your full name, date of birth, email address and any other information you have made publicly accessible). Please note that any information that is not required will not be retained by Small Worlds.
d) If you create an account with us, we may use your Personal Data to verify your identity when using the Small Worlds Websites. We may also use your contact details to send you transactional and other non-marketing email messages pertaining to your account and provide certain other account maintenance services to facilitate your transactions with Small Worlds and/or your use of the services we offer on Small Worlds Websites.

6.2.4 Events and Promotions
From time to time, we hold events and special promotions to introduce Small Worlds and its Affiliates to interested parties. If you come to one of these events, or take part in a promotion, we may ask for your Personal Data to help us run the promotion and keep in touch with you about our services and any special offers or competitions that we think may be of interest. Any information which you provide will be used in accordance with the terms of this Privacy Policy and you can unsubscribe from further communications from us at any time.

6.2.5 Partnering with Small Worlds
If you contact us with a view to becoming a business partner of Small Worlds or to meet with Small Worlds in a business capacity, we will need to collect information about your business, which may include Personal Data (for example, your contact details) to help us respond to your query or request. We may do this when you call us, or interact with us through our online support tools. The information we collect may include for example your name, date of birth, address, email, telephone number, your photograph, passport details (if applicable), bank account details. This information may also be used to issue permits.

6.2.6 Application Users
If you use Small Worlds Websites to browse our services, we may collect your Personal Data as necessary to enhance your user experiences as part of fulfilling our service obligations towards you. This information may include your name, date of birth, country of residence, gender, age range, language, nationality, contact details (such as e-mail address), geolocation data, unique identifier (such as device or person) and third-party data about you, for example, your Twitter, Facebook or other social media profiles.

6.2.7 Media Professionals
We may collect your Personal Data as necessary to issue permits and manage your access to the Small Worlds site. This Personal Data may include for example your name, date of birth, email address, mobile number, nationality, organization, photo ID (Emirates ID or Passport number).

6.2.8 Additional Information
Sometimes we will require you to provide additional Personal Data. When we do this, we will provide further information about why we are collecting it and how we will use it. Where we provide personalized content, we may ask your permission to review third-party data about you to get to know you better and to personalize the services we provide to you, for example, your Twitter, Facebook, LinkedIn, Google+, Weibo, or WeChat accounts.

6.2.9 Information posted by You
You should be aware that the information you post on public areas of Small Worlds Websites or elsewhere on the internet may be used by anyone including Small Worlds.

6.2.10 Careers
We may need to collect your Personal Data should you choose to apply to Small Worlds for potential job openings or send us your CV with a view to exploring career opportunities with Small Worlds.

6.2.11 Participation in Small Worlds as volunteer
We may collect and use information about you as necessary to manage the application process and, if successful, your participation in the volunteering program. This may include communicating information with you which we deem to be of relevance to your participation in Small Worlds. The Personal Data we collect from you may include your name, date of birth, address, nationality, next of kin details, identification information (such as your Emirates ID number), contact details (such as phone number and e-mail address), information about your health (such as whether or not you have a disability or specific dietary requirements), biometric information (such as your height and weight), employment and education history and third party data about you, for example, your Twitter, Facebook or other social media profiles.

6.2.12 Tracking and Automatic collection

a) Small Worlds and third parties that provide content, advertising, or other functionality on our services, may use Cookies, pixel tags, local storage, and other technologies to automatically collect Personal Data through the services. This Personal Data is collected for the purposes of:

  • developing the design and style of our products and services to make improvements;
  • carrying out statistical, technical and logistical analysis and strategic development;
  • carrying out market research;
  • understanding more about you such as your location and demographic information; and
  • providing you with personalized services, such as recommendations on our websites, apps and in direct marketing and tailored advertising.

b) Small Worlds Websites may collect Personal Data about how you use our content online, and the device(s) you use to access the site. This includes collecting unique online identifiers such as IP addresses, which are numbers that can uniquely identify a specific computer or other network devices on the internet.

7. LAWFUL BASES FOR USING YOUR DATA

We will only collect, use and share your Personal Data where we have an appropriate lawful basis to do so under applicable law. Depending on where you are when you provide your Personal Data, appropriate legal bases may include:

  • a) Circumstances where we need to use your Personal Data to conclude, perform and/or terminate a contract or take steps to enter into a contract with you;
  • b) our legitimate interests as an organization (where this ground is available under applicable law), for example we may use customer contact information to keep our customers informed about changes to the Small Worlds and other important service messages;
  • c) where the Personal Data is needed by Small Worlds to initiate or defend itself or claim its rights in legal proceedings, or to comply with judicial or security procedures;
  • d) where we need to use your Personal Data to comply with a relevant legal or regulatory obligation that we have including in the employment context; and
  • e) where we have your consent to use your Personal Data for a particular activity.

8. HOW WE SHARE INFORMATION WITH OTHERS

8.1 We work closely with a number of trusted partners with whom we may need to share your Personal Data to help us provide our services, such as:

  • a) banks and payment providers, to authorize and complete payments;
  • b) third party service providers who help manage our business and deliver services. For example, these may include IT service providers who help manage our IT and back-office systems, or third-party booking agents.

8.2 From time to time we may share information about you with government organizations and agencies, including international organizations, to comply with applicable laws, regulations and rules, and legitimate requests from law enforcement, regulatory and other government or international agencies, or when to do so is in our legitimate interests, even if we are not compelled to share that information by applicable law.

8.3 If, in the future, we sell or transfer some or all of our business or assets to a third party, we may disclose or transfer Personal Data to a potential or actual third-party purchaser of our business or assets.

9. MORE ABOUT DIRECT MARKETING, PROFILING AND AUTOMATED DECISION MAKING

9.1 Direct Marketing

9.1.1 We are committed to keeping you informed about Small Worlds and our products and services in line with your personal preferences.

9.1.2 We will usually send such information by email, but we may choose to contact you in other ways for example by phone, post, SMS and/or other electronic means if that is more appropriate.

9.2 Managing your marketing preference

9.2.1 To protect your privacy rights and to ensure you have control over how we manage our marketing with you:

  • a) we will take steps to limit direct marketing to a reasonable and proportionate level and only send you communications which we believe may be of interest or relevance to you;
    b) to stop receiving marketing material from us, you can click the “unsubscribe” link that you will find on any electronic communications which you receive from us, or, for other types of communications, by contacting us; and.
  • c) you can change the way your browser or device manages Cookies, which may be used to deliver online advertising, by following the settings on your browser as explained in the “Cookies” section (section 12) below.

9.2.2 We recommend you routinely review the privacy policies and preference settings that are available to you on any social media platforms.

9.3 More about profiling and analytics

9.3.1 We may use some of the information you provide to us in order to perform profiling and data analytics.

9.3.2 One of the methods by which we do this is by installing and using Cookies on your browser or device. You can learn more about how to adjust settings relating to Cookies on your browser and device, and about our Cookie Policy in the “Cookies” (section 12) below.

9.3.3 Some of the legitimate purposes according to which we profile and analyse data include:

  • a) to allow us to enhance our provision of services to you;
  • b) to provide you with online content tailored to your preferences and needs and to optimize your experience of Small Worlds Websites;
  • c) to offer personalized products when you use our services;
  • d) to obtain a better understanding of our customers, what you would like to see from us, and how we can improve our services to you;
  • e) to share advertising material, we believe may be of interest to you, including from our third-party partners; and
  • f) to help us operate our services more efficiently.

10. HOW WE PROTECT AND STORE YOUR INFORMATION


10.1 How we protect your information

10.1.1 Small Worlds invests in an appropriate and reasonable level of cyber security protection and practices to keep your Personal Data secure and confidential, including but not limited to:

  • a) Access to the personal data will be restricted, and the personal data will be used only on a strictly need to know basis; and
  • b) implementation of physical, electronic, administrative, technical, and procedural safeguards to protect your Personal Data from unauthorized or inappropriate access, alteration, disclosure and/or destruction.

10.1.2 Where you disclose information to us using our mobile app, please ensure that your mobile device remains safe. We cannot be held responsible for any data misuse arising from unauthorized access to your mobile device.

10.2 Storing your Personal Data

10.2.1 We will store your Personal Data for as long as reasonably necessary for the purposes for which it was collected, as explained in this Privacy Policy.

10.2.2 In some circumstances we may need to store your Personal Data for longer periods of time, for instance where we are required to do so to comply with legal, reporting, regulatory, tax, accounting requirements. Should you require information about how we retain information you can contact us as indicated in section 16.

11. YOUR RIGHTS – LEGAL RIGHTS AVAILABLE TO HELP MANAGE YOUR PRIVACY

11.1 You may have certain rights relating to your Personal Data depending on the country in which you access Small Worlds Websites. In some cases, depending on applicable legislation, such as the UAE DP Law or the GDPR, these rights may include:

11.1.1 The right to obtain information about such matters as (a) the categories of Personal Data being processed; (b) the purposes of processing; (c) targeted sectors or establishments with which your Personal Data will be shared, whether inside or outside the UAE; (d) controls and standard periods for storing your Personal Data; e) procedures for correcting, erasing or limiting the processing of your Personal Data (f) procedures for objecting to processing of your Personal Data and (g) information about the safeguards we have put in place to ensure the adequate protection of your Personal Data when it is transferred.

11.1.2 The right to request a Personal Data transfer to a third party. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format where technically feasible. Note that this right only applies to digital Personal Data which you initially provided consent for us to use or where we used the Personal Data to perform a contract with you.

11.1.3 The right to erase or correct your Personal Data. This enables you to ask us to correct or delete Personal Data where there is no good reason for us to continue processing it. You also have the right to ask us to delete or remove your Personal Data where you have successfully exercised your right to object to processing (see below) or where we are required to erase your Personal Data to comply with applicable laws. Please note that for certain purposes we may be legally obligated to retain your Personal Data (see section 11.2).

11.1.4 The right to restrict the processing of your Personal Data. This enables you to ask us to suspend the processing of your Personal Data under the following circumstances:

  • a) if you want us to confirm the accuracy of your Personal Data;
  • b) where you need us to hold the Personal Data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
  • c) you have objected to our use of your Personal Data but we need to verify whether we have overriding other grounds to use it.

11.1.5 The right to stop the processing of your Personal Data. This enables you to object to and stop the Processing of your Personal Data in any of the following cases:

  • a) if the processing is for direct marketing purposes, including profiling related to direct marketing;
  • b) if the processing is for the purposes of conducting statistical surveys, unless the Processing is necessary to achieve the public interest; or
  • c) if the processing is in violation of the provisions of the UAE DP Law.

11.1.6 The right to object to decisions made by the Data Controller with respect to automated processing of your Personal Data that may have legal consequences or seriously affect you, including personal profiling.

11.2 You should note that the rights referred to in paragraph 13.1 are not absolute but are subject to the Data Controller’s rights with respect to the Personal Data under applicable laws.

11.3 You may raise your concerns with the UAE Data Office. However, we would encourage you to contact us in the first instance as we aim to promptly resolve any concerns or complaints you may have in relation to our processing of your Personal Data.

11.4 You can exercise your rights by contacting us as set out in Section 16. Subject to legal and permissible considerations, we will make every reasonable effort to honour your request promptly or inform you if we require further information in order to fulfill it. This may include asking you to confirm your identity or provide other information for security purposes before disclosing Personal Data to you. We may not always be able to address your request fully, for example if it would affect our duty of confidentiality to others, or if we are legally entitled to treat your request in a different way. We reserve the right to refuse your request if it is manifestly unfounded, excessive or unlawful.

12. INFORMATION ABOUT YOUR DEPENDANTS AND RELATED PERSONS

12.1 If you provide Small Worlds with Personal Data about your next of kin and/or related persons for emergency contact or any other purposes, it is your responsibility to inform such individuals about such activities and to obtain their consent, where necessary, to the processing (including transfer) of their Personal Data by Small Worlds as set out in this Privacy Policy.

13. COLLECTION OF DATA FROM THE MINORS

13.1 If you are resident in the UAE and under 18 or, alternatively, are resident elsewhere and have not yet reached the relevant age of majority in the jurisdiction in which you reside, we are not permitted to contract with you directly. If we seek your consent to process your Personal Data for a specific purpose in accordance with this Privacy Policy, such consent must be granted on your behalf by your guardian. In such cases and in accordance with applicable legislation, your guardian, by agreeing to this Privacy Policy, acknowledges and consents to the terms of this Privacy Policy on your behalf.

14. COOKIES

14.1 INFORMATION ABOUT OUR USE OF COOKIES

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.

14.2 A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

14.3 We use the following cookies:

  • Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, 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 our website when they are using it. This helps us to improve the way our website 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 our website. This enables us to personalise 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 our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

14.4 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

15.  WANT TO GET RID OF COOKIES OR CHANGE YOUR COOKIE SETTINGS?

15.1 You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.

15.2 Except for essential cookies, all cookies will expire after 45 days.

16 CONTACT US

16.1 If you have any questions, concerns or complaints regarding this Privacy Policy and the applicable data protection regulations, or if you wish to exercise your rights, please contact us. We will investigate and will make every reasonable effort to resolve such enquiries and to honor your wish to exercise your rights as quickly as possible, in any event, within the timescales provided by applicable data protection laws.

16.2 In some countries, you may have a right to lodge a complaint with your local data protection supervisory authority. We ask that you attempt to resolve any issues with us first before referring to the UAE Data Office or your local supervisory authority.

16.3 If you have any questions or comments regarding the processing of your Personal Data or Small Worlds data privacy practices or if you would like to update your Personal Data or preferences or exercise your rights under this Privacy Policy or applicable data protection laws, you can contact our data privacy office via email on admin@smallworldsme.com

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