EFFECTIVE: 01/01/2024

VIP Sthetic and/or its affiliates and entities (collectively “[COMPANY]”, “we” or “us”) values your security and privacy. VIP Sthetic is required to comply with Personal Data Protection Law, Federal Decree Law No. 45 of 2021 regarding the Protection of Personal Data, (the “UAE DP Law”), and may for certain types of personal data processing, be subject to laws from other jurisdictions.

As such, it is the Privacy Notice of VIP Sthetic to respect the privacy of its app users.  In accordance with UAE DP Law  , VIP Sthetic collects information about you when you use or access our App, as well as through  interactions and communications you have with us, through the VIP Sthetic App (the “App”).

This online data privacy notice (the “Privacy Notice") sets out the basis on which any information, including any personal data, we collect from you, or you provide to us, will be processed by VIP Sthetic. Each time you access or use the App or provide us with information, by doing so you acknowledge the practices described in this Privacy Notice.  

1. Scope and Application

This Privacy Notice applies to persons anywhere in the world who access or use VIP Sthetic’s App (“Users”).

2. Collection of Information

Information you give us

This is personal data you give us by providing information or filling in forms on the App, or by corresponding with us (for example, by telephone, e-mail or any other digital or electronic form). It includes for example information you provide when you contact us, download and register to use the App, search for the App in app stores (including but not limited to Apple App Store and Google Play Store), share data via the App's social media functions, and when you report a problem with the App.

If you contact us, we will keep at least an electronic record of such correspondence, including personal information shared at that time, in order to reply or process it as per your request. The personal information you give us may include your name, address, e-mail address and phone number, certain device information, username, password, residential building, work address, photograph, and other information you choose to provide (“Personal Information” or “Personal Data”).

The App collect and process Personal Data in accordance with the UAE DP Law and applicable laws, including for specific, lawful purposes explained herein or at the time of collection, or for the performance of tasks carried out in your interests or the legitimate interests of VIP Sthetic.

Information we collect about you and your device

Each time you use our App we may and often will automatically collect the following information:

• technical information, including the type of mobile device you use, a unique device identifier (for example, mobile network information, your mobile operating system, the type of mobile browser you use, device token, device type, time zone setting (“Device Information”);
• details of your use of our App including, but not limited to traffic data and other communication data, and the resources that you access (“Log Information”);
• location information if the App uses GPS technology to determine your current location. If you wish to use the particular feature, you may be asked to opt-in to your data being used for this purpose.

If you do not wish to share certain data with us or do not want us to use / share it for certain purposes (to the extent possible, in accordance with applicable laws and information in this notice), you can alter your  preferences at any time.  Where applicable, please check with your device provider's instructions for further information about how to do this.

Other Information We May Collect Through Your Use of the App

When you use the App, we may collect Personal Data including demographic information, for example information that you submit, or that we collect, which may include, but is not limited to, post code, age/birth date, current residence, hometown, gender, username, mobile network information, your mobile operating system, the type of mobile browser you use, time zone setting, device location, IP address, SMS data, transaction information, business activities and services / distribution locations, browsing history information, searching history information, and registration history information (“Demographic Information”).

3. Use of Personal Data

We may use Personal Data which you provide to us or we collect from you to:

• Provide, maintain, and improve our App including, for example, to facilitate payments, send receipts, provide products and services you request (and send related information about them), develop new features that will enhance your user experience and our efficiency, provide customer support to Users, authenticate users, and send administrative messages, whether information-only or required by applicable law;
• Perform internal regulatory, administrative and operational requirements, including, for example, to prevent fraud or abuse of our App Services; to troubleshoot software bugs and operational problems; to conduct permitted data analysis, testing, and research; to ensure you and VIP Sthetic are complying with internal or external legal requirements, including those that necessitate use of digital systems; and to monitor usage and activity trends;
• Send you communications we think will be of interest to you based on your previous interactions with us, including information about products, services, promotions, news, and VIP Sthetic events, where permissible under the UAE DP Law and according to any other applicable laws; and to process contest, sweepstake, or other promotion entries and fulfill any related awards;
• Notify you about changes to this Privacy Notice, or our App;
• Allow you to participate in any interactive features of our App;
• Keep our App Services safe and secure; or
• Personalize and improve the App Services, including to provide or recommend features, content, social connections, referrals, and advertisements, in accordance with your preferences, to the extent permissible by law.

4. Processing, Storage and Transfer of Personal Data

We will take all steps reasonably necessary to ensure your Personal Data is processed fairly and lawfully, in accordance with the UAE DP Law, other applicable laws and this Privacy Notice.  By submitting your Personal Data (including Log, Device and / or Demographic Information), we expect you to understand that such transfer, storing or processing in order for VIP Sthetic to perform its general administrative functions is necessary and will be done in a proportionate, lawful manner, including but not limited to responding to enquiries you raise via the App, and maintaining contacts for future informational or promotional activities. Unless otherwise notified, VIP Sthetic does not ordinarily rely solely on automated decision making when processing your Personal Data. 

In order to conduct our operations or fulfil regulatory obligations, we must transfer the Personal Data described in this Privacy Notice to and from, and process and store it in, the United Arab Emirates and (where applicable or required) with processors in other countries, some of which may have less protective privacy laws than those where you reside. In all such cases, and generally for any processing operations, we take appropriate security measures to protect your Personal Data in accordance with this Privacy Notice. VIP Sthetic ensures all information security measures are strictly enforced. Please see section 7 below for further details.

To preserve the integrity of our databases, we provide the App on behalf of all Users, for research, analytics and statistics purposes and to ensure compliance with applicable laws and regulations, we retain Personal Data submitted by Users for a reasonable length of time unless otherwise prescribed by applicable law.

VIP Sthetic is not responsible for the accuracy of the information you provide, and will modify or update your Personal Data in our databases when you provide updated information or ad hoc upon your request, as further outlined below.  We will erase or put beyond active use your Personal Data upon request, unless we are required to retain it in accordance with UAE DP Law or other applicable laws or to perform agreed services, in which case we align with applicable principles such as purpose specification and data minimization.

If it is not disproportionate or prejudicial, and required beyond this Privacy Notice’s notices, we will contact you to let you know we are processing your personal information.

By accessing or using the App to which this Privacy Notice applies, we can reasonably expect that you understand that all information submitted by you through the App or otherwise to VIP Sthetic may be used by VIP Sthetic to support these processing operations, in accordance with applicable laws and its policies.

5. Sharing of Personal Data

We may share Personal Data which we collect about you as described in this Privacy Notice or as described at the time of collection or sharing, including as follows:

We may share your Personal Data:

• With third parties to provide you a service that you requested through a partnership or promotional offering made by a third party or us; or
• With third parties with whom you choose to let us share your Personal Data, for example other apps or websites that integrate with our API or Website Services, or those with an API or Service with which we integrate

Other Types of Data Sharing

We may share your Personal Data:

• With VIP Sthetic subsidiaries and affiliated entities, to the extent permissible by law;
• With vendors, consultants, marketing and advertising partners, and other service providers who need access to such Personal Data to carry out work on our behalf or to perform a contract we enter into with them;
• If we otherwise notify you and you provide your affirmative opt-in to share your data, where needed;
• In response to a request for information by a competent authority or government entities if we determine that such disclosure is in accordance with, or is otherwise required by any applicable law, regulation, or legal process;
• With law enforcement officials, government entities or authorities, or other third parties as required by applicable law;
• With third parties in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company; or
• With third parties in an aggregated and/or anonymized or pseudonymized form that cannot reasonably be used to identify you

Government Data Sharing

In some circumstances we are legally obliged to share information with public authorities or law enforcement. For example, we may be required to provide information related to a court order or where we must cooperate with supervisory authorities in handling complaints or investigations.  In any scenario, we’ll attempt to satisfy ourselves that we have a lawful basis on which to share the information, document our decision making, and satisfy ourselves we have a legal basis on which to share the information.

We may also share information in the event of the non-payment including of a monetary penalty or court ordered costs. If the debt remains outstanding after the specified timeframe for payment, no payment plan is in place or an agreed payment plan is not being adhered to, we may initiate formal proceedings to recover the full amount of the unpaid penalty. 

As a result, VIP Sthetic will share Personal Data with the litigation and recovery specialists it instructs in order for them to identify assets and undertake recovery action through the courts.

6. Your Rights and Choices 

Marketing and Preferences

VIP Sthetic supports Users’ legal rights to opt-in or subsequently opt-out of receiving communications from us and our partners. You have the option to ask us not to process your Personal Data for marketing purposes and to remove it from our database, to not receive future communications or to no longer receive our App 

You may change your preferences at any time.

Please note that we may continue to send you transactional or service-related e-mails despite your desire to not receive promotional or marketing e-mail messages.  Additionally, please note that if you elect to opt-out of or unsubscribe from receiving promotional or other similar e-mails or messaging from one of our App, you may continue to receive promotional emails from our other websites, providers, or other, non-affiliated marketers whose services you may have accessed via VIP Sthetic App.

Finally, while we may remove your individual contact information from our professional contacts database, please be aware that if such information is in a different, third party's marketing directory through your request or election, you will need to request removal with such third party directly.

Access to and Correction of Your Personal Information

You have the right to access information held about you. Your right of access can be exercised for any reason, at any time, in accordance with UAE DP Law and other applicable laws.

You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.

You may also request that we restrict the processing of, erase, transfer the information you gave us from one organisation to another, or otherwise process your Personal Data in line with the relevant articles providing for such rights set out in the UAE DP Law or other applicable laws.

Any access request generally comes at no cost to you and we must respond within one month unless provided otherwise by the UAE DP Law or other applicable laws.  We may, where permissible, impose a reasonable fee to meet any extraordinary administrative costs in providing you with details of the information we hold about you.

When you contact us about a potential Personal Data error or query, we will endeavor to confirm or verify the information in question, then correct verified inaccuracies and respond to the original inquiry. We will endeavour to send a correction notice to businesses or others whom we know to have received the inaccurate data, where required and / or appropriate. However, some third parties and third-party sites may continue to process inaccurate data about you until their databases and display of data are refreshed in accordance with their update schedules, or until you contact them personally to ensure the correction is made in their own files.

As set out in the UAE DP Law, we may not discriminate against you for exercising your rights by denying services or changing prices or quality of service, unless reasonable to do so in general, as objectively determined, and applicable to all individuals offered or receiving such benefits. 

7.  Security Precautions

VIP Sthetic makes every effort to ensure that your Personal Data is secure on its system. VIP Sthetic has staff dedicated to maintaining our data protection and security measures, periodically reviewing them and making sure that VIP Sthetic employees are aware of our data protection and security practices. Unfortunately, no data transmission over the internet can be guaranteed to be 100% secure. As a result, VIP Sthetic cannot warrant or guarantee the security of any Personal Data you transmit to us, and you do so at your own risk.

VIP Sthetic has established policies and procedures for securely managing information and protecting Personal Data against unauthorized access. We continually assess our data privacy, information management and security practices. We do this in the following ways:

• Establishing policies and procedures for securely managing information;
• Limiting employee access to viewing only necessary information in order to perform his or her duties;
• Protecting against unauthorized access to Personal Data by using data encryption, authentication and virus detection technology, as required;
• Requiring service providers with whom we do business to comply with relevant data privacy legal and regulatory requirements;
• Monitoring our websites through recognized online privacy and security organizations;
• Engaging in regular third-party audits of our policies and practices; and
• Conducting background checks on employees and providing training to our employees.

If you have any further questions about our security and processing activities, please contact the VIP Sthetic team. To the extent permitted by applicable law, VIP Sthetic expressly disclaims any liability that may arise should any other third parties obtain the Personal Data you submit through fraud or otherwise where it is no fault of VIP Sthetic.

8. External Links

The App may contain links to other websites on the Internet that are owned and operated by third parties (the "External Sites"). These links are provided solely as a convenience to you and not as an endorsement by VIP Sthetic of the contents of or reliability on such External Sites. You acknowledge that VIP Sthetic is not responsible for the availability of, or the information and content of any External Site. You should contact the site administrator or webmaster for those External Sites if you have any concerns regarding such links or the content located on such external Sites.

If you decide to access linked third party websites, you do so at your own risk. VIP Sthetic does not accept liability, and shall not be liable to you for any loss or damage arising from or as a result of your acting upon the content of another website to which you may link from the App.

9. Changes to this Privacy Notice

VIP Sthetic may change this Privacy Notice from time to time and without notice. If we make significant changes in the way we treat your Personal Data, or to the Privacy Notice, we will endeavor to provide you notice through the App or by some other means, such as email. Your continued use of the App Services after such notice constitutes your understanding of the changes. We encourage you to periodically review this Privacy Notice for the latest information on our privacy practices. We provide links to it through:

• The App
• Incorporating it into our contracts, agreements, and other documents as necessary or appropriate

Contact Us

If you have any questions, comments and requests related to this Privacy Notice, or if you have any complaints related to how VIP Sthetic processes your personal data, please contact:  web@vipsthetic.com