Privacy Notice (applicable to the Dubai Fitness Challenge platforms only)

Your privacy is important to us. This privacy statement explains the personal data we process, how we process it, and for what reasons.

Last modified: 18^th October, 2020. View Earlier Versions.

Background

Department of Tourism and Commerce Marketing (“DTCM”) is an entity established pursuant to Law No. 1 of 1997 and having its principal address at P.O. Box 594, Dubai, United Arab Emirates.

DTCM is the principal authority for the planning, supervision, development and marketing of tourism in Dubai. We also market and promote Dubai’s commerce sector and are responsible for the licensing and classification of all tourism services, including hotels establishments, tour operators, travel agents and all other tourism services. You can find out more about us at: https://www.visitdubai.com/en/department-of-tourism/about-dtcm.

DTCM and its affiliates, including,  but  not  limited  to,  Dubai  Festivals  and  Retail  Establishment,  Dubai Corporation for Tourism and Commerce Marketing, Dubai Business Events and Dubai Calendar (collectively, “Dubai Tourism”, “We”, “we”, “our” or “us”) are committed to providing excellent service to all customers, including respecting their concerns about privacy and taking the relevant measures to safeguard their personal data in accordance with applicable data protection legislation.

In this Privacy Notice:

“Dubai Fitness Challenge” or “DFC” means a 30 day fitness challenge taking place in Dubai for participants located in the United Arab Emirates including all events and activities that form part of the Dubai Fitness Challenge (which includes without limitation ‘Dubai Run’ and ‘Dubai Ride’); and

“Dubai Run” means the run event that takes place in Dubai for participants located in the United Arab Emirates annually as part of the Dubai Fitness Challenge.

“Dubai Ride” means the cycling event that in Dubai for participants located in the United Arab Emirates annually as part of the Dubai Fitness Challenge.

“Platforms” means

• any of our websites operated for the Dubai Fitness Challenge (including without limitation, dubaifitnesschallenge.com; www.dubairun.com and www.dubairide.com), including any microsites or tools contained therein which has been created and is supported by our technology solutions providers;
• any of our mobile applications and any tools contained therein;
• any of our social media pages for the Dubai Fitness Challenge; and
• any of our other technological platforms in whatever form for the Dubai Fitness Challenge.

As well as providing an events calendar and information on events/activities that form part of the Dubai Fitness Challenge, our Platforms may be synced with sports devices/applications and organises personalised exercise sessions or sports competitions and provides multimedia content. Our Platforms will allow us to store, organise and process data, including, for example, identifying data such as photographs, first and last name, birthdate, email address, weight and height, within a database.

We have provided this Privacy Notice to help you, the user, understand how we collect, use and protect your information when you visit and use our Platforms, and how that information will be treated.

Please read the following carefully to understand our views and practices regarding your information and how that information will be treated.

This Privacy Notice should be read together with our terms of use and any other documents referred to in it.

Please note that we will ask for your consent before using information for a purpose other than those that are set out in this Privacy Notice.

This Privacy Notice uses the following key terms:

• Browser web storage: enables websites to store data in a browser on a device. When used in “local storage” mode, it enables data to be stored across sessions (for example, so that the data are retrievable even after the browser has been closed and reopened). One technology that facilitates web storage is HTML 5.
• Non-personally identifiable information: information that is recorded about users so that it no longer reflects or references an individually identifiable user.
• Personal data: any information which you provide to us which directly or indirectly personally identifies you, such as your name, email address, billing information, credit card information, or other data which can be reasonably linked to such information by Dubai Tourism, such as information we associate with any accounts you may hold with Dubai Tourism.
• Sensitive personal data: special categories of personal data, specifically, information about your race, ethnic origin, political opinions, religious beliefs, any health and genetics, biometrics (where used for ID purposes) and criminal convictions.

What information do we collect?

We collect and use a range of information you provide us when you participate in the Dubai Fitness Challenge or any events, promotions, surveys, competitions or activities associated with the Dubai Fitness Challenge using our Platforms or via third party platforms in order to deliver and improve our services, including:

• Personal data you provide –
  • when you to sign-up and create an account or edit your profile or otherwise sign-up as a guest to receive our services, such as your name, username, password, email address, nationality, age, country of residence, phone number or credit card to store with your account.
  • when you register, participate or volunteer for events, initiatives or fitness activities, such as your name, email address, shipping address, phone number, place of residence, age, nationality, identity details (such as passport number or Emirates ID number), emergency contacts (who must be 21 years of age or above), gender, company affiliation, occupation, weight, height and body measurements (such as t-shirt or apparel size), self-reported disability status or other health-related information that you provide us as necessary for participation in an event or fitness activity as well as contact tracing as part of Covid-19 detection in compliance with our legal obligations under applicable law, for instance Dubai Run and Dubai Ride. Information we collect as part of our Covid-19 contact tracing procedures mandated by the authorities may include information related to, your health, prior travels and such other related information. Our third-party service providers may also collect your credit card information when you submit your registration.
  • fitness activity data provided by you or generated through our Platforms (for example time, duration, distance, location, calorie count, pace/stride).
  • when you participate or enter into competitions, draws, incentive and reward programmes in relation to the Dubai Fitness Challenge such as name, email and phone number.
  • when you communicate with us regarding our services, such as when you send questions, complaints, comments or suggestions, respond to surveys, rate our services or communicate with us.
• Consents we receive when you consent to us processing your data where consent is required.

• Technological data that we or our third-party service providers may automatically receive and record including:
  • Internet protocol (IP) address
  • device-specific information (such as your hardware model, operating system version, unique device identifiers, and mobile network information including phone number)
  • device event information such as crashes, system activity, hardware settings, browser type, browser language, the date and time of your request and referral URL,
  • cookies or similar technologies that may uniquely identify your browser or any of your accounts on our Platforms,
  • information (including personal data) locally on your device using mechanisms such as browser web storage (including HTML 5) and application data caches
  • location information when you use our Platforms through various technologies such as Wi-Fi access points and cell towers.

For more information on technological data, please see our section on ‘Direct Marketing, IP addresses and Cookies’

How we collect personal data

We collect your personal data directly from you unless it is unreasonable or impractical to do so. We do this in a number of ways including:

• through your access and use of our Platforms or sending SMS/MMS to us or our representatives;
• when you to sign-up and create an account or edit your profile to receive our services;
• when you register to sign-up and attend online or offline fitness classes or sessions organised in relation to the Dubai Fitness Challenge;
• when you register, participate or volunteer for events, initiatives or fitness activities, such as Dubai Run and Dubai Ride;
• when you participate or enter into competitions, draws, promotions, incentives and reward programmes in relation to the Dubai Fitness Challenge;
• through someone else who has provided us with your information (e.g. a gift subscription) in relation to the Dubai Fitness Challenge;
• during conversations between you and our representatives in relation to the Dubai Fitness Challenge;
• when you communicate with us or our representatives regarding our services such as feedback surveys and ratings; and/or
• when you complete an application or subscription for a service in relation to the Dubai Fitness Challenge.

We may also collect personal data from third parties including:

• organisers or co-organisers of events, schemes or initiatives as well as service providers assisting with organising such events, schemes and initiatives in relation to the Dubai Fitness Challenge, such as Dubai Run and Dubai Ride;
• advertisers;
• mailing lists;
• contractors and business partners;
• third party companies such as credit reporting agencies, law enforcement agencies and other government entities;
• Where you engage on one of our social media platforms, for example our Facebook page, we receive information from third parties, including Sprinklr, which provides us with a view of your publicly available information across social media platforms. To understand more about how Sprinklr use your personal data, please refer to their Sprinklr Social Media Management System (SMMS) Privacy Notice.

Any personal data we collect about you will only be retained for as long as it takes for the purposes for which such information is required to be completed. If we no longer need to use or disclose your personal data for the purposes set out in this Privacy Notice and we are not legally required to retain that information, then we will take reasonable steps to destroy your personal data or ensure it is rendered anonymous (i.e. turned into non-personally identifiable information).

How we use personal data

We may receive your personal data from you or from third parties which we use:

• to operate and administer our Platforms and for internal operations, including troubleshooting, data analysis, testing, market research, statistical and survey purposes;
• to display information about participating individuals and companies on publicly available leader boards, including posting name details provided to us, and you consent to such use of your information by creating an account and signing up to the Dubai Fitness Challenge through our Platforms;
• to provide  you  with  the  information,  products  and  services  that  you  request from us;
• to provide you with details about future events in relation to the Dubai Fitness Challenge that are same or similar to those you have registered for, or have otherwise participated (for example Dubai Run and Dubai Ride);
• to respond to your questions, comments and requests regarding your account, events for which you have registered, updates regarding our services and other administrative matters;
• to provide you with services related to the Dubai Fitness Challenge;
• to allow you to participate in interactive features of our service, when you choose to do so;
• where you have indicated your consent, to provide you, or permit selected third parties to provide you, with additional services and/or information about additional services that may interest you (see “Marketing” section below for more information);
• to notify you about changes to our Platforms;
• to improve our Platforms to ensure that content from our Platforms is presented in the most effective manner for you and for your device;
• to organise and administer events, competitions, activities, schemes and initiatives, fulfil the terms of any agreement you have with us, respond to your requests and or any other purpose related to managing our organisation in relation to the Dubai Fitness Challenge such as Dubai Run and Dubai Ride;
• to measure or understand the effectiveness of advertising we serve you and others, and to deliver relevant advertising to you;
• to conduct post-event surveys for events, activities etc. organised for Dubai Fitness Challenge to measure customer satisfaction and improve our products and services;
• to provide us insights into the trends of participation in the Dubai Fitness Challenge and usage of our services so that we may better deliver our services; and/or
• to comply with any applicable law (for example to fulfil national security obligations we may share personal data with national security agencies such as Dubai Police and other departments of the Government of Dubai), or in good faith believe such action is necessary or desirable to comply with the applicable laws (for example information we collect as part of our contact tracing procedures for the Covid-19 pandemic), or to protect or defend the rights or property of Dubai Tourism, our Platforms, or their users, including as described in the section below titled “How We Share Personal Data”.

Direct Marketing, IP Addresses and Cookies

Marketing

Where you have indicated your consent or we have a legitimate interest, we (and permitted third parties) may contact you for direct marketing purposes via post, telephone, email, SMS/MMS, push notifications, and social media channels such as Facebook, Instagram, Twitter and WhatsApp. 

This marketing may relate to:

• additional products and services we (or permitted third parties) feel may interest you;
• information about other goods and services we offer that are similar to those that you have already used or enquired about; and
• upcoming events, promotions and new products/services or other opportunities as well as those of selected third parties.

If you are an existing customer, we will only contact you by electronic means without seeking your consent in advance (including but not limited to telephone, e-mail, SMS/MMS, push notifications, and social medial channels such as Facebook, Instagram, Twitter and WhatsApp) with information about services similar to those which were the subject of a previous dealing with you. If you are signing-up to register and participate in the Dubai Fitness Challenge, we will contact you by electronic means (including but not limited to telephone, e-mail, SMS/MMS, push notifications, and social medial channels such as Facebook, Instagram, Twitter and WhatsApp) to provide you information or notify you on upcoming events, activities, promotions, new products / services or other opportunities as well as those of third parties partners/sponsors in relation to the Dubai Fitness Challenge.

If you no longer wish to receive marketing communications from us you may unsubscribe by following the unsubscribe link in the bottom of our email communications or by requesting us to remove you and your personal data collected electronically from our database(s) by emailing [email protected].

Marketing Emails and Newsletters

We use MailChimp for our marketing emails and newsletters. So when you register or subscribe to our email marketing or newsletter services, the email address and name you submit will be held securely by them and the information also made accessible to us. You can read their full privacy policy here: https://mailchimp.com/legal/privacy/.

We may also combine the information you provide us at sign-up on our Platforms with data from other sources to help us improve the relevance of the emails we send you. For example if you sign-up to a Dubai Fitness Challenge event, we will record that information in your MailChimp subscriber profile to ensure that the content of our emails reflects that.

Opt-Outs of marketing email communication

You may unsubscribe from marketing email communication sent by our Platforms at any time by following the unsubscribe link found at the bottom of every email communication we send via MailChimp or by requesting us to remove you and your personal data collected electronically from our database(s) by emailing [email protected]. If you unsubscribe MailChimp will retain your email address for the purposes of a suppression list to ensure that no further marketing messages can be sent unless you actively choose to opt-in again.

You can request our third party partners to stop sending you marketing messages at any time by clicking the “unsubscribe” button at the bottom of emails or by directly contacting such third parties at any time.

Internet Protocol (IP) Address

An IP address is a number that is automatically assigned to your device every time you browse the internet. When you visit our Platforms, the server used by our web host will make a record of your IP address, together with the date and time of your visit, the type of internet browser you use and the URL of any other websites that referred you to our Platforms.

We may also log IP addresses to analyse trends, administer our Platforms, track user movements, and gather broad demographic information.

Cookies

In some cases we may also collect your personal data through the use of cookies. When you access our Website, we may send a “cookie” (which is a small summary file containing a unique ID number) to your device. This enables us to recognize your device and customise the online experience. It also helps us keep track of services you view, so that we can send you news about those services. We also use cookies to measure traffic patterns, to determine which areas of our Website have been visited, and to measure transaction patterns in the aggregate. We use this to research our users’ habits so that we can improve our services. If you do not wish to receive cookies, you can set your browser so that your device does not accept them. You can find out how to do this, and find more information about cookies, at www.allaboutcookies.org.

We may also collect anonymous data (which is not personal data) relating to your activity on our Website (including IP addresses) via cookies, or we may collect information from you in response to a survey. We generally use this information to report statistics, analyse trends, administer our services, diagnose problems and target and improve the quality of our services. To the extent this information does not constitute personal data because it does not identify you or anyone else, we may use this information for any purpose and by any means whatsoever.

For further information on the cookies we use, please refer to our Cookie Policy.

Google ReCaptcha

We use the ReCAPTCHA service provided by Google Inc. (Google) to protect your submissions via internet submission forms on this Website. Your use of ReCAPTCHA is subject to the Google Privacy Policy and Terms of Use.

Links to Other Websites

We are not responsible for the practices employed by websites or services linked to or from our Platforms, including the information or content contained therein or the data collection practices or privacy policies therein. Please remember that when you use a link to go from our Platforms to another website, our Privacy Notice does not apply to third-party websites or services. Your browsing and interaction on any third-party websites or service, including those that have a link or advertisement on our Platforms, are subject to that third party’s own rules and policies. For example, when you sign-up to register and attend any online or offline fitness classes, activities or events in relation to the Dubai Fitness Challenge via a third party link on our Platforms, our Privacy Notice does not apply to your use of such third party site or any personal data you may share with such third party websites. We are not responsible for the privacy practices of such third party websites and encourage you to read the privacy statements of any such third party sites. In addition, you agree that we are not responsible and we do not have control over any third-parties that you authorize to access your user content. If you are using a third-party website or service (like Facebook, Instagram, Twitter, Instagram, or Google groups etc.) and you allow such a third-party access to your user content you do so at your own risk. This Privacy Notice does not apply to information we collect by other means (including offline) or from other sources other than through our Platforms.

How we share information

We do not share personal data with companies, organizations and individuals outside of Dubai Tourism unless one of the following circumstances applies:

• With your consent

We will share personal data with companies, organisations or individuals outside of Dubai Tourism (and the parties and bodies referenced in this section of the Privacy Notice) when we have your consent to do so.

• For external processing

We provide personal data to our service providers, affiliates or other trusted businesses or persons to process it for us, based on our instructions and in compliance with our Privacy Notice and any other appropriate confidentiality and security measures. This includes our technology solutions providers. For example, if you register as a corporate participant in the Dubai Fitness Challenge on our Platforms, your data will be shared with our third party technology solutions provider Steppi App for the 30x30 Corporate Challenge. To understand more about how Steppi App uses your data, please refer to their privacy policy at https://www.steppi.com/terms.html. Similarly, if you register to participate in Dubai Run on our Platforms, your data will be shared with our technology solutions provider and DFC partner Sun & Sands Sports to process your payment for purchase of Dubai Run apparel. To understand more about how Sun & Sands Sports uses your data, please refer to their privacy policy at https://en-ae.sssports.com/policies/privacy-policy. We also use EventsCase as our events management solution. So when you register to attend any online or offline fitness classes, activities or events for DFC directly on our Platforms, your information will be transferred to EventsCase for processing. You can read their full privacy policy here: https://eventscase.com/pages/privacy. Other examples of organisations we share your data with for external processing include third party event organisers, sponsors, ticket sellers, organisations running competitions, events and initiatives on our behalf or we collaborate with in order to arrange and deliver programmes, competitions, and other initiatives in relation to the Dubai Fitness Challenge or in order for such third parties to provide you with a service.

• Sharing with our partners

We may share non-personally identifiable information publicly and with our partners – like publishers, advertisers or connected websites. For example, we may share information publicly to show trends about the general use of our services.

• Where required by applicable law

We will disclose personal data when required by any applicable law (for example to fulfil national security obligations we may share personal data with national security agencies such as Dubai Police and other departments of the Government of Dubai), or in good faith believe such action is necessary or desirable to comply with the applicable laws (for example to fulfil our reporting obligations for the Covid-19 Pandemic we may share information we collect as part of our contact tracing procedures with the concerned health and regulatory authorities such as Dubai Health Authority), or to protect or defend the rights or property of Dubai Tourism, our Platforms, or their users.

• With selected third parties

We may disclose your personal data to third parties in the following circumstances:

• in the event that Dubai Tourism sells or buys any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
• if Dubai Tourism or substantially all of its assets are acquired by a third party, in which case personal data held by it will be one of the transferred assets;
• agents, service providers and third parties who provide services relating to the purpose for which the personal data is collected including data processing services, whether or not such agents, service providers and third parties are based in the UAE; and
• any person who is under a duty of confidentiality and has undertaken to keep such data confidential.

Where we store your personal data

The data that we collect from you may be transferred to, stored and otherwise processed on servers located outside the country in which you reside and which may be located in secure data centres worldwide, and personal data may be stored in any one of them.

How long we keep your data for

We will retain your personal information for the period necessary to full the purposes outlined in this Privacy Notice. When assessing these periods we carefully examine our need to collect personal data at all and if we establish a relevant need we only retain it for the shortest possible period to realise the purpose of collection unless a longer retention period is required by contractual obligation or law.

Contacting us

If you select to contact us with any questions, comments or requests using one of the online forms that form part of our Platforms, you will need to provide your full name, telephone number and email address so that we can be sure to be able to contact you. Depending on which online form you complete, you will be given the opportunity to provide additional information that will allow us to serve you better, although the additional information might not be required in order for you to complete and submit the online form.

If you have any general enquiries, complaints or suggestions, please contact us at [email protected].

Security of your personal data

We will take all reasonable steps to protect the personal data that we hold from misuse, loss, or unauthorized access, including by means of firewalls, password access and secure servers. In particular, we review our information collection, storage and processing practices, including physical security measures, to guard against unauthorized access to systems, and restrict access to personal data to our employees, contractors and agents who need to know that information in order to process it for us, and who are subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations. Unfortunately, there is always risk involved in sending information through any channel over the internet. You send information over the internet entirely at your own risk. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted over the internet and we do not warrant the security of any information, including personal data, which you transmit to us over the internet. If you suspect any misuse or loss of, or unauthorized access to, your personal data, please let us know immediately.

Compliance and cooperation with regulatory authorities

We regularly review our compliance with our Privacy Notice. When we receive formal written complaints, we will contact the person who made the complaint to follow up. We work with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of personal data that we cannot resolve with our users directly.

Privacy Notice Changes

In the future, we may revise or amend this Privacy Notice at any time by amending this page to publish a new version. All changes will be made here so you will always know what information we gather, how we might use that information and whether we will disclose it to anyone. We recommend that you revisit this page from time to time to keep informed of our current privacy practices.

Conclusion

Your privacy concerns are important to us. We hope this Privacy Notice has been helpful to you.

Questions Concerning this Privacy Notice

If you have questions regarding this Privacy Notice, please feel free to email us at [email protected].

General Enquiries, Complaints or Suggestions

If you have any general enquiries, complaints or suggestions, please contact us at [email protected].