Introduction

ADNEC Group take your right to privacy seriously and want you to feel comfortable using our digital services. This Privacy Policy deals with personally identifiable information (referred to as "Data" below) that may be collected by us via this website or an associated mailing list or social media account.

This Policy does not apply to other entities that we do not own or control or persons that are not our employees, agents or within our control.

Collection of Data via ADNEC Group Website

Your name, e-mail address, or other submissions that you make on our website may contain your real name or other personally identifiable information and, as a result, may be processed on our website. Like many website, we may also automatically receive general information that is contained in our server log files such as your IP address and cookie information. Information about how advertising may be served on our website (if at all) is set forth below.

Use of Data collected via ADNEC Group Website

We may use Data to customize and improve your user experience on our websites. We will make efforts so that your Data will not be provided to third parties unless;

• provided for otherwise in this Privacy Policy;
• we obtain your consent, such as when you choose to opt-in or opt-out to the sharing of Data;
• a service provided on our site requires the interaction with or is provided by a third party, by way of example an Application Service Provider;
• pursuant to legal process or law enforcement;
• we find that your use of our websites violates our this Policy, Terms of Service, other usage guidelines or as deemed reasonably necessary by us to protect our legal rights and/or property; or,
• a site is purchased by a third party whereby that third party will be able to use the Data in the same manner as we can as set forth in this Policy.

In the event you choose to use links that appear on our site to visit other websites, you are advised to read the privacy policies that appear on those sites.

ADNEC Group Mailing List

By submitting your name onto ADNEC’s mailing list, you are consenting to the processing of Data to send you marketing communications regarding ADNEC venues, relevant events and offers.

Third parties who might collect your personal data

Google

On our website we use Google Analytics, Google Web Fonts, Google Maps and Recaptcha all of which are services provided by Google Inc Ireland Limited, Gordon House, Barrow Street, Dubin 4, Ireland. These services provided by Google allow us to provide you with a better experience when using our website and in some cases provide us with data about your visit. See our Cookies Policy for more information about the information captured and why.

Google’s privacy policy appears here: https://policies.google.com/privacy?hl=en

Social Media

We have Facebook, Instagram and LinkedIn social media pages. Each of these social media networks have elements that are integrated into our website which in basic terms will allow these pages to recognise that you have visited our website.

Facebook and Instagram are operated by Meta Platforms Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland.

LinkedIn is operated by LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland.

Where you view or interact with our Facebook and Instagram social media pages Meta will process your personal data in line with their own privacy policy which appears here

https://privacycenter.instagram.com/policy/

Where you view or interact with us via LinkedIn, they will process your personal data in line with their own privacy policy which appears here:

https://www.linkedin.com/legal/privacy-policy

Mailchimp

We use Intuit (Mailchimp) from Intuit Inc., 2700 Coast Ave, Mountain View, CA 94043, USA to send our newsletter. This enables us to contact subscribers directly. In addition, we analyse your usage behaviour in order to optimise our offering. We only pass on your name and email address to Intuit. Intuit will process your personal data in line with their own privacy policy which appears here: https://www.intuit.com/privacy/statement

Data-sharing

ADNEC NEVER share or sell your e-mails address with any third-parties for any commercial purposes. We may, on occasion, send you communications on behalf of third-parties that we work with.

Unsubscribing and other data privacy enquiries / requests

You have the right to unsubscribe / deregister from the ADNEC mailing list at any time. This can be achieved by unsubscribing via the link provided at the bottom of any ADNEC e-mail communication.

Alternatively, you can send an e-mail to dataprotectionofficer@adnec.ae to make this request. You can also use this same e-mail address to find out what information we are holding about you, request correction or deletions.

What is the purpose of this privacy policy?

This privacy policy is to tell you what personal data we collect from you and why and what we will do with this data. It also tells you about some of the key rights which you have under data protection laws.

We will only process your personal data as set out in our privacy policy or otherwise notified to or agreed by you or as we are otherwise permitted to do in accordance with data protection laws.

When we refer to “you” in this privacy policy, we mean the lead passenger, anyone else we communicate with in respect of an enquiry, quote or booking (for example, the person by or through whom payment is made if not the lead passenger), all persons who travel or are intended to travel on holiday and the parent/guardians of any minors who travel or who are intended to travel. What is our role in relation to your personal data?

For the purposes of data protection laws, we, Capital Holidays Sole Proprietorship L.L.C a company registered in Abu Dhabi with commercial license number CN- 3897160 trading as Etihad Holidays, are a data controller in respect of the personal data you provide us with.

What is my personal data and what do you mean by process?

When we refer to personal data, we mean any information which relates to an identified or identifiable individual. Where we refer to process or processing, we mean anything which we may do with your personal data including collecting, storing, using, disclosing to third parties and erasing it.

What personal data will we collect from you and why?

In order to respond to an enquiry, provide a quote, administer and fulfil your booking or send you any promotional material including our newsletter, we need to process personal data we obtain from you.

Where you wish to make a booking, the personal data we need to collect and process at various stages is likely to include;

• Name of the lead passenger
• Contact details for the lead passenger including their e-mail and postal addresses and telephone number(s)
• If different to the lead passenger, the point of contact for financial arrangements / payments including their e-mail and postal addresses and telephone number(s)
• Names and dates of birth of all persons travelling
• Passport details and other ID document details.
• Information in respect of any medical condition, disability or reduced mobility which may affect anyone travelling – this comes within special categories of personal data (see below)

General enquiries

For an enquiry, the personal data we will need to process is likely to include the name and contact details of the person making the enquiry.

Booking enquiries, quotes and bookings

For a booking or booking enquiry, we will process your personal data (other than any data which comes within special categories of personal data - see below) on the basis that this is necessary for the performance of your contract with us or to enable us to take steps at your request prior to your entering into a contract with us. We may also need to do so to comply with a legal obligation to which we are subject or in order to protect your vital interests (for example, in an emergency situation).

Marketing and promotions

If you wish to receive any promotional material from us such as our newsletter, enter a competition or take part in a survey, we will need your name and the contact details applicable to the form of communication you have consented to. For example, if you wish to receive information by e-mail, we will need your e-mail address. We do not use any personal information for marketing purposes other than the names and applicable contact details of the person who has consented to receive such material.

Special categories of personal data

Personal data which concerns your health, or which reveals your racial or ethnic origin, or your health are special categories of personal data. Other information also comes within special categories, but this is unlikely to be relevant to the booking and provision of travel arrangements.

Generally speaking, the processing of special categories of personal data requires the explicit consent of the person concerned. Accordingly, information concerning any disability, medical condition, restricted mobility or other health related issue (and related requirements) as well as dietary restrictions which disclose your religious beliefs or any health issue are special categories of personal data. We will ask for your consent to our processing this information at the time you make your booking or your booking enquiry or whenever you otherwise provide or indicate that you intend to provide such information.

This consent should be provided to us by the party leader on behalf of the person concerned who must authorise the party leader to do so.

In the case of special categories of personal data which relates to children and young people under the age of 18 when the consent is required, consent will need to be provided by the party leader on behalf of the individual’s parent or legal guardian who must authorise the party leader to do so.

Who may we provide your personal data to?

Where you make a booking, appropriate personal data will be passed on to the relevant suppliers of your chosen travel arrangements. If you ask us to book any additional services, we will have to pass on your details to the supplier of those services. Suppliers and other third parties are likely to include the following depending on the travel arrangements booked:-

• Hotels and other accommodation providers
• Airlines and other transport providers
• Cruise lines
• Event organisers

When you make a booking, you will be prompted to give credit/ debit card or other payment details to a third party payment processor. Whilst it may feel like we are collecting this information, it is actually being collected by the payment processor directly in order to take authorised payments. The information may also be provided to government / public authorities such as customs or immigration if required by them, or as required by law.

We may also make personal data available to other companies who provide services on our behalf, such as direct marketing, administration, customer care, website hosting and the reorganisation/structuring/sale of our business. We only provide third parties with the personal data they require in order to deliver their services.

Other than in relation to government / public authorities (over whom we have no control), we will take reasonable steps which are intended to ensure that anyone to whom we pass your personal data for any reason agrees to keep it secure, only uses it for the purposes of providing their services and does not collect any personal data from you in the course performing their services.

Third parties who might collect your personal data

Google

On our website we use Google Analytics, Google Web Fonts, Google Maps and Recaptcha all of which are services provided by Google Inc Ireland Limited, Gordon House, Barrow Street, Dubin 4, Ireland. These services provided by Google allow us to provide you with a better experience when using our website and in some cases provide us with data about your visit. See our Cookies Policy for more information about the information captured and why. Google’s privacy policy appears here: https://policies.google.com/privacy?hl=en

Social Media

We have Facebook, Instagram and LinkedIn social media pages. Each of these social media networks have elements that are integrated into our website which in basic terms will allow these pages to recognise that you have visited our website.

Facebook and Instagram are operated by Meta Platforms Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland.

LinkedIn is operated by LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland.

Where you view or interact with our Facebook and Instagram social media pages Meta will process your personal data in line with their own privacy policy which appears here

https://privacycenter.instagram.com/policy/

Where you view or interact with us via LinkedIn, they will process your personal data in line with their own privacy policy which appears here:

https://www.linkedin.com/legal/privacy-policy

Mailchimp

We use Intuit (Mailchimp) from Intuit Inc., 2700 Coast Ave, Mountain View, CA 94043, USA to send our newsletter. This enables us to contact subscribers directly. In addition, we analyse your usage behaviour in order to optimise our offering. We only pass on your name and email address to Intuit. Intuit will process your personal data in line with their own privacy policy which appears here: https://www.intuit.com/privacy/statement

Where will we process your personal data?

We use a suite of interconnected travel management systems in order to provide you with our services. We work with systems providers to ensure that we process as much of your data within the EU as much as possible. Where, we are required to process your data outside of the EU, we do this when an adequate level of protection is guaranteed in compliance with the GDPR.

How do we protect your personal data?

We take appropriate technical and organisational measures to protect against unauthorised or unlawful processing of personal data and against accidental loss or destruction of, or damage to, personal data, which is appropriate to the harm that might result from the unauthorised or unlawful processing or accidental loss, destruction or damage and the nature of the data to be protected, having regard to the state of technological development and the cost of implementing any measures.

Can we use your personal data to send you information about other travel services in the future?

We will only retain and use your personal data for marketing purposes where you have specifically consented to our doing so where you have previously provided us with your e-mail address in the course of entering into a contract with us for travel arrangements or negotiations for such arrangements and we wish to email you marketing material about our similar services or products.

You will be given the opportunity to opt out of receiving such e-mail marketing communications when you first provide us with your e-mail address and whenever we send you any e-mail marketing.

You may provide your consent to receiving marketing material from us either on-line or by telephone. You may also choose in what ways you are happy to receive communications from us. You may, for example, be happy to receive information and offers by post and e-mail but not by telephone.

Can you withdraw your consent to our processing your personal data?

Yes, you can withdraw your consent to receiving marketing material or other communications from us at any time, either generally or in any particular way, by e-mailing us at info@etihadholidays.com Alternatively you can telephone us.

How can you find out what information we are holding about you?

You are entitled to ask us (by letter or e-mail) what personal data of yours is being held or processed, for what purpose and to whom it may be or has been disclosed. No fee will be charged for responding to this request unless it is obviously unfounded or excessive or we have previously provided the same information.

We promise to respond to your request without delay and in any event within 1 month unless the request is complex, or you have made numerous requests in which case we may be able to extend our response time by a further 2 months.

What should you do if the personal data we are holding is inaccurate, out of date or incomplete?

If you believe this is the case, please tell us by e-mail as soon as possible. We will rectify the problem within 1 month or within 3 months if the rectification request is complex.

How long can we retain and process your personal data?

We will not process your personal data in a form which enables you to be personally identified for any longer than is necessary in order to fulfil the purpose for which it was originally collected or for any other legitimate business purpose.

Where your personal data has been provided for the purpose of the booked travel arrangements or other services you have contracted, we are entitled to retain this data for a reasonable period after those arrangements have been completed. In certain limited circumstances, we may be able to retain it for a longer period.

If you have consented to receiving marketing communications from us, we may continue to use your personal data for this purpose until you withdraw your consent or otherwise for as long as we reasonably consider your consent remains valid and effective.

Can you ask us to delete your personal data?

Yes, you can ask us to erase your personal data in certain circumstances, for example where you have withdrawn your consent to further marketing material where the data in question has only been processed for this purpose. However, this is not always the case. Please see the previous paragraph for further information on the period of time we may retain personal data.

Can this privacy policy be changed?

Yes, from time to time we may need to make changes to this privacy policy. The latest version of this privacy policy can be found on our website.

Does our website use cookies?

Yes, as is the common practice, our website uses cookies.

A ‘cookie’ is a small data file which our website server stores on your computer in order to collect information about your visit and to remember you when you visit again at a later date. The main purpose of a cookie is to identify users and to personalise their visit by customising web pages for their use.

We may also use third parties who will collect data which is not personally identifiable to analyse site visits and carry out other similar activities. In the course of doing so, they may place their own cookies on your computer so that they can collect information about your visit.

You may if you wish to disable or delete such cookies through your internet browser. However, doing so may mean you will be unable to access our website or parts of it, your experience of our website may be adversely affected and/or you may not receive information which is relevant to your personal interests.

We offer our services via several different websites, and the use of cookies varies by the website. Therefore, please consult the Cookie Policy on the specific website that you have engaged us through.

What should I do if I have a complaint about the processing of my personal data?

If you have any complaint about the way in which your personal data has been dealt with, please let us know by e-mail to info@etihadholidays.com. We will investigate and respond to you as soon as we reasonably can.

What are our contact details??

You can contact us here:
Capital Holidays Sole Proprietorship L.L.C
ADNEC Centre Abu Dhabi, Khaleej Al Arabi Street,
P.O. Box 5546, Abu Dhabi

Telephone: +971 2 599 0700

e-mail: info@etihadholidays.com