PRIVACY POLICY
Last updated: 20th February 2023
1. INTRODUCTION
Welcome to the privacy policy of Ooka Heating Devices LLC, the operator of ooka.com.
We respect your privacy and are committed to protecting your personal data. This privacy policy tells you about how we collect, process and look after your personal data when you visit and use our website (regardless of where you visit it from) and tells you about your privacy rights and how the law protects you.
By using this website, you accept the terms of this privacy policy.
2. IMPORTANT INFORMATION
2.1. This website is intended for users aged 18 and above and we do not knowingly collect data relating to minors.
2.2. It is important that you read this privacy policy together with any other privacy or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.
3. WHO WE ARE AND HOW TO CONTACT US
3.1. The controller and company responsible for the collection and use of your personal data is Ooka Heating Devices LLC, a Dubai mainland company with trade license number 1055048, (“Ooka”, "we", "us" or "our").
3.2. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please email us at data.privacy@ooka.com.
3.3. You have the right to make a complaint at any time to your local regulator for data protection issues. If you are resident in the UAE this is the UAE Data Office established under Federal Decree-Law No. 44 of 2021, the UAE regulator for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the data regulator so, please contact us in the first instance.
4. CHANGES TO THIS PRIVACY POLICY AND YOUR INFORMATION
4.1. We may update this privacy policy from time to time by posting a new policy on this website. Changes will not have retroactive effect so you will only be bound by them from the date on which the new terms are posted on our website. Please refer to the date at the top of this privacy policy so you are aware if the terms have changed.
4.2. Historic versions can be obtained by emailing us at data.privacy@ooka.com.
4.3. It is important that the personal data we hold about you is up-to-date and accurate. Please keep us informed if your personal data changes during your relationship with us.
5. THIRD-PARTY LINKS
5.1. This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
6. THE DATA WE COLLECT ABOUT YOU
6.1. When you access or are directed to our website, various information is exchanged between your device and our server. This may include personal data. The information collected in this way is used, among other things, to implement a contract we or our local distributor may have with you, or to optimise our website or to display advertising in the browser on your device.
6.2. 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).
6.3. We may collect, use, store and transfer different kinds of personal data about you which we have categorised as follows:
Identity Data: includes first name, last name, username (if you choose to set up an account) date of birth, age and gender.
Contact Data: includes email address and telephone numbers.
Financial Data: includes bank account and payment card details (to the extent the website offers paid for services/ online sales).
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, your interests, preferences, feedback and survey responses.
Usage Data: includes information about how you use our website, products and services
Marketing and Comms Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences.
6.4. We also collect, use and share Aggregated Data such as statistical or demographic data for various reasons. 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 website feature. However, if we combine or connect Aggregated Data with your personal data 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 policy.
6.5. We do not collect any Sensitive Personal Data about you - this includes details about your race or ethnicity, religious or philosophical beliefs, political opinions, criminal record, biometric data or information about your health.
6.6. Please be aware that if you fail to provide personal data that we need to collect by law, or under the terms of a contract we or our local distributor has with you we may not be able to perform this contract (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us or our local distributor but we will notify you if this is the case at the time.
7. HOW IS YOUR PERSONAL DATA COLLECTED?
7.1. 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 (both offline and online) or by corresponding with us by email. This includes personal data you provide when you:
a. request our products or services;
b. create an account on our website;
c. register your device/ warranty with us;
d. subscribe to our service or publications;
e. request marketing to be sent to you;
f. participate in product testing or market research;
g. enter a competition, promotion or survey; or
h. give us feedback or contact us.
Automated technologies or interactions:
We may also automatically collect Technical Data about your equipment, browsing actions and patterns. If we collect this personal data we will do so by using cookies, server logs and other similar technologies and will provide information about the specific cookies used in a cookie policy. There is some more information about cookies set out in section 10 below.
Third parties or publicly available sources:
We will receive personal data about you from various third parties as set out below:
a. Technical Data from analytics providers such as Google; and
b. Contact and Transaction Data from providers of technical, payment and delivery services.
8. HOW WE USE YOUR PERSONAL DATA
8.1. We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
8.1.1. Where we (or our local distributor) needs to perform a contract we (or our local distributor) are about to enter into or have entered into with you; and
8.1.2. Where we need to comply with a legal obligation.
8.2. Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time for the future free of charge by emailing us at data.privacy@ooka.com.
8.3. We set out below a description of the ways we plan to use your personal data, and which of the legal bases we rely on to do so. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.
8.4. Please contact us at data.privacy@ooka.com if you need details about the specific legal ground we are relying on
8.5.
Purpose/Activity:
To register you as a new customer and to register your device for warranty purposes
Type of data:
(a) Identity
(b) Contact
Lawful basis for processing:
(a) Performance of a contract with you
Purpose/Activity:
To process and deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
Type of data:
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Comms
Lawful basis for processing:
(a) Performance of a contract with you
Purpose/Activity:
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey
Type of data:
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Comms
Lawful basis for processing:
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
Purpose/Activity:
To enable you to take part in a prize draw, competition or complete a survey
Type of data:
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Comms
Lawful basis for processing:
(a) Performance of a contract with you
Purpose/Activity:
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
Type of data:
(a) Identity
(b) Contact
(c) Technical
Lawful basis for processing:
(a) Necessary to comply with a legal obligation
Purpose/Activity:
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
Type of data:
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Comms
(f) Technical
Lawful basis for processing:
(a) Your consent
Purpose/Activity:
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
Type of data:
(a) Technical
(b) Usage
Lawful basis for processing:
(a) Your consent
Purpose/Activity:
To make suggestions and recommendations to you about goods or services that may be of interest to you
Type of data:
(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
(f) Marketing and Comms
Lawful basis for processing:
(a) Your consent
Purpose/Activity:
To enable you to use the Live Chat function on the website
Type of data:
(a) Identity
(b) Contact
Lawful basis for processing:
(a) Necessary to comply with a legal obligation
9. MARKETING COMMUNICATIONS
9.1. Marketing communications from us
You will only receive marketing communications (via email or SMS) from us if you have:
- given your consent,
- requested information from us, or
- purchased goods or services from us and you have not opted out of receiving that marketing.
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.
9.2. Third-party marketing
We will get your express opt-in consent before we share your personal data with any third-party for marketing purposes.
9.3. Opting out. You can ask us or third parties to stop sending you marketing messages at any time for the future free of charge by following the opt-out links on the footer of any marketing message sent to you or by contacting us at any time at data.privacy@ooka.com.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase or other transactions.
10. COOKIES
10.1. Cookies are small files automatically created by your browser and stored on your end device when you visit or are redirected to a website. The use of cookies serves to enhance the user-experience and make the website content more relevant for you. Most browsers accept cookies automatically. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of a website may become inaccessible or not function properly.
11. SHARING YOUR PERSONAL DATA
11.1. We may share your personal data with the parties set out below for the purposes set out in the table above and any other reasons set out:
Our Other Group Companies
Ooka is part of the AIR group which has affiliate companies based both in and outside of the UAE.
We may share your personal data with them for:
- the provision of IT and system administration services
- the provision of delivery and customer services
- audit and reporting purposes, and
- so that our group companies can share with you information about new initiatives and/or product launches that they are involved in.
External Third Parties
Service providers acting as processors based in and outside of the UAE who provide:
o IT and system administration services
o a secure payment gateway
o delivery and courier services, and
o marketing communications automation.
- Professional advisers acting as processors including lawyers, bankers, auditors and insurers based in both in and outside of the UAE who provide consultancy, banking, legal, insurance and accounting services.
- Regulators and other authorities based both in and outside the UAE who require reporting of processing activities in certain circumstances.
- Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
11.2 We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. Our current service partners and their tasks can be made available to you on request at the e-mail address data.privacy@ooka.com.
12. INTERNATIONAL TRANSFERS
12.1. We may share your personal data within the global AIR Global group. This may involve transferring your data outside the UAE.
12.2. In addition, some of our external third parties are based outside the UAE so their processing of your personal data will involve a transfer of data outside the UAE. For example, our UAE customer’s data will be stored in secure data centres in the EEA.
12.3. Whenever we transfer your personal data out of the UAE, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
12.3.1. We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data; or
12.3.2. Where we use certain service providers, we may use contractual protections to give personal data the same protection it has in the UAE.
12.4. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UAE.
13. DATA SECURITY
13.1. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
13.2. We will notify you and any applicable regulator of a breach where we are legally required to do so.
14. DATA RETENTION – HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
14.1. We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for. Unless we are required to keep it longer to comply with any legal, regulatory, tax, accounting or reporting requirements, we will review the personal data we hold every 2 years. If users have been completely inactive during the previous 2-year period, we will delete your data.
14.2. To determine the appropriate retention period, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
14.3. In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
15. YOUR LEGAL RIGHTS
15.1. You have the right to:
15.1.1. Access your personal data and information on the personal data stored, the purpose of processing, the category of personal data and recipients to whom the data have been or will be disclosed, the planned storage period and eventually the origin of your data if not collected directly from you;
15.1.2. Request correction of inaccurate personal data or completion of accurate personal data;
15.1.3. Request deletion of your personal data, insofar as no legal or contractual retention periods are to be observed;
15.1.4. Object to processing of your personal data or request restriction of processing your personal data (e.g. for marketing purposes); and/or
15.1.5. Request transfer of your personal data to another controller.
15.2. If you wish to exercise any of the rights set out above, please email us at data.privacy@ooka.com. You also have the option of contacting the supervisory authority responsible – see section 3.3 above.
15.3. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
15.4. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.