Privacy Policy

WELCOME TO OUR PRIVACY POLICY

This privacy policy (“Privacy Policy”) applies to the personal information we collect about you through the websites operated and made available by Sanctuary Corporate Services FZ LLC (trading as Sanctuary Corporate Services), (“Sanctuary”, “we”, “us” and “our”) located at sanctuary.ae (the “Website”). This Privacy Policy applies regardless of media platform (e.g., computer, smartphone, tablet, etc.) used to access our Website, or information you submit to us offline which we submit to our online database. Your privacy is important to us, and this Privacy Policy is designed to make clear our intentions and approach to the collection and use of personal information in connection with our Website and the choices you have. If you have any questions regarding this Privacy Policy, please contact us at ask@sanctuary.ae

YOUR CONSENT

By using the Website, you agree to the terms of this Privacy Policy. If you do not agree with the terms of this Privacy Policy, please refrain from using the Website.

This privacy policy is divided into the following sections:

1. Third party websites 2. The information we collect about you. 3. How we collect information. 4. Our legal basis for processing your personal information 5. Governing law 6. Disclosure and Purpose of Personal Information 7. Security 8. How long do we keep your information? 9. Your rights 10. Your Responsibilities 11. Cookies 12. Changing Our Privacy Policy 13. Contact us

1. Third Party Websites

Our website links to third party sites which we do not operate or endorse. These websites may use cookies and collect your personal information in accordance with their own privacy policies. This privacy policy does not apply to third party websites and we are not responsible for third party websites.

2. The Data We Collect About You

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender. • Contact Data includes billing address, delivery address, email address and telephone numbers. • Financial Data includes bank account and payment card details. • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us. • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website. • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses. • Usage Data includes information about how you use our website, products and services. • Marketing and Communications Data includes your preferences in receiving marketing information, newsletters, or other information from us and our third parties and your communication preferences. • When you interact with any Sanctuary page or account on a social media platform, such as Facebook, Twitter, Google+, LinkedIn, Tumblr, YouTube, Instagram, TikTok, or Pinterest, or when you use your social media account or credentials to log into the Website, we may also collect the Personal Information that you make available to us on that page or through that account. We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. How We Collect Information We use different methods to collect data from and about you including through: • Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you: • apply for our products or services; • create an account on our website; • subscribe to our services or publications; • request marketing to be sent to you; • enter a competition, promotion or survey; or • give us feedback or contact us. • Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see further details, section 12 of this Privacy Policy. • Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below: • Technical Data from analytics providers, advertising networks and search information providers. • Contact, Financial and Transaction Data from providers of technical, payment and delivery services. • Identity and Contact Data from data brokers or aggregators. • Identity and Contact Data from publicly available sources.

4. Our Legal Basis for Processing your Personal Information

When we use your personal information we may be required to have a legal basis for doing so. There are various legal basis upon which we may rely, depending on what personal information we process and why. The legal basis we may rely on include: • consent: where you have given us clear consent for us to process your personal information for a specific purpose. • contract: where our use of your personal information is necessary for a contract we have with you, or because you have asked us to take specific steps before entering into a contract. • legal obligation: where our use of your personal information is necessary for us to comply with the law (not including contractual obligations). • legitimate interests: where our use of your personal information is necessary for our legitimate interests or the legitimate interests of a third party (unless there is a good reason to protect your personal information which overrides our legitimate interests). Governing Law

5. This Privacy Policy shall be governed by the laws of United Arab Emirates (UAE), excluding any laws that might direct the application of the laws of another jurisdiction.

6. Disclosure and Purpose of Personal Information Except as set forth in this Privacy Policy or as specifically agreed to by you, we will not disclose any Personal Information we gather from you through the Websites.

Third Party Service Providers/Program Partners. We might share Personal Information with trusted third party vendors to help us in operating our Websites and services. For example, if we hire or collaborate with a third party to process our email or handle our help desk function, we might share our email list with them. Under all circumstances, however, these organizations will be required to maintain the confidentiality of your Personal Information either by contract with us or under the terms of their Privacy Policies.

Legal and Governmental Authorities/Protection. To comply with legal requirements that may arise, we may share your Personal Information if requested to do so by legal or government authorities. We also may share your Personal Information when necessary to investigate, prevent, or take action regarding illegal or suspected illegal activities and to protect and defend the rights, property, or safety of Sanctuary and its staff, users of our Websites, or others.

• We may send your personal information to other group companies, affiliates and third parties to help us process your personal information for the purposes set out in this policy. • We may disclose your personal information if we or any of our assets are the subject of a sale or similar corporate transaction. We will ensure that the third parties who receive your personal information are required to keep it confidential.

7. Security

We are committed to protecting the security of our users’ Personal Information. To that end, we use industry standard security practices to keep your Personal Information private. Please note, however, that we do not and cannot guarantee the security of Personal Information, and there is some risk that an unauthorized third party may find a way to circumvent our security systems, or that transmission of your information over the Internet will be intercepted. We disclaim all liability involving Personal Information submitted through our Websites.

8. How long do we keep your information?

We will keep your information for a period of 12 months, or as per the laws and regulation of this Privacy Policy.

9. Your Rights

You may review, edit and delete the Personal Information you have provided to us by contacting us at ask@sanctuary.ae Please note, however, that even if you delete your information, there may still be residual information about you in our systems, for example in our log files.

10. Your Responsibilities

You are responsible for ensuring the accuracy of the Personal Information you submit to us in order to receive communications or services from us. You can update your Personal Information at any time by contacting us at ask@sanctuary.ae

11. Cookies

We may use information obtained from cookies or similar technology. Cookies are text files containing small amounts of information which we download onto your computer or device when you visit our website. Therefore, when we refer to “you” in this section we mean your computer. We can recognise these cookies on subsequent visits and they allow us to remember you.

Cookies come in many forms.

First and third-party cookies – whether a cookie is first-party or third-party refers to the domain placing the cookie. First-party cookies are those set by a website that is being visited by the user, the website displayed in the URL window e.g. sanctuary.ae Third-Party cookies are cookies that are set by a domain other than that of the website being visited by the user. If a user visits a website and another entity sets a cookie through that website this would be a third-party cookie. Persistent cookies – these cookies remain on a user’s device for the period of time specified in the cookie. They are activated each time that the user visits the website that created that particular cookie. Session cookie – these cookies allow website operators to link the actions of a user during a browser session. A browser session starts when a user opens the browser window and finishes when they close the browser window. Session cookies are created temporarily. Once you close the browser, all session cookies are deleted. This website uses cookies that fall into all the categories. Also we use data from targeting cookies placed on your computer by third parties when you have visited other websites.

12. Changing our Privacy Policy

We review our privacy practices from time to time, and these practices are subject to changes and updates, which will be effective immediately. We will notify you of any material change to this Privacy Policy at minimum by posting the new Privacy Policy and by updating the Effective Date located at the bottom of this page. To ensure familiarity with the current version of our Privacy Policy, return to this page periodically. We will not apply any changes retroactively.

13. Contact Us

If you wish to exercise any of your rights in relation to your personal information or if you have any queries about how we use your personal information, please let us know by contacting us at ask@sanctuary.ae.

Effective as of July 05, 2021.