PRIVACY POLICY
Amiri Gate Marketplace - Premium Airport Services Bookings
1. Overview
Amiri Gate General Trading L.L.C. (“Amiri Gate”, “we”, “us” or “our”) operates a marketplace platform connecting customers with third-party Service Providers for premium airport services, including Meet & Greet, Fast Track, Airport Lounge Access, and Luxury Transportation (the “Services”). We are committed to protecting and respecting your privacy. In this Privacy Policy, we inform you of how we collect, process, and use your personal data. Personal data means any information relating to an identified or identifiable natural person (“Personal Data”).
1.1 Consent
By providing your Personal Data to us, you consent to the processing of your Personal Data in accordance with this Privacy Policy. You are free to decide whether or not to supply us with your Personal Data. However, in some cases we need your Personal Data to provide our Services to you - if you do not provide it, we may not be able to complete your booking. If you are booking on behalf of other individuals (e.g. family members, colleagues, or other travellers included in your booking, including minors), you warrant that you have obtained their consent (or, in the case of a minor, the consent of their parent or guardian) and have brought this Privacy Policy to their attention.
1.2 Definitions
In this Privacy Policy:
“Business Partner” refers to any bank, corporate client, membership programme, or other party (e.g. a partner bank offering Amiri Gate services to its cardholders) through whose platform, app, or programme you may access or book our Services;
“Data Controller” means the party who determines the purposes and means of the processing of Personal Data;
“Data Processor” means the party who processes Personal Data on behalf of the Data Controller. There may be circumstances where we process your Personal Data as a Data Processor on behalf of a Business Partner who is the Data Controller, such as when you access our Services through a Business Partner's platform or app;
“Data Protection Laws” means the UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (“PDPL”), as amended, replaced or superseded from time to time, and any other applicable data protection laws and regulations in force in relation to Personal Data (which may include the EU General Data Protection Regulation (“GDPR”) where applicable to you);
“Location” means a service desk, lounge, or other physical location where the Services are provided;
“My Benefits” means Amiri Gate's membership/benefits programme, where applicable, which members may use to access discounts on the Services;
“Service Provider” refers to the third-party operator (e.g. Meet & Greet operators, Fast Track operators, and airport lounges) engaged by Amiri Gate to fulfil the Services booked through the Website;
“Website” or “Websites” refers to the online platforms adopted by Amiri Gate to provide the Services, including but not limited to www.amirigate.com, booking.amirigate.com, and any related booking subdomains, which are subject to change from time to time.
1.3 Where does this Privacy Policy apply?
This Privacy Policy applies to our Locations, Websites, and any booking made for our Services (including bookings made through a Business Partner's platform or app) only, and not to the locations or websites of other companies, individuals, or organisations to which we provide links or from which there are links to us.
2. Data Controller
When we are the Data Controller, we can be contacted at the details in Section 3 — “Contacting Us” below. Where you access our Services through a Business Partner, that Business Partner may be the Data Controller of your Personal Data for certain purposes, and their own privacy policy will also apply — please refer to it for further information.
3. Contacting Us
Data Protection queries - Amiri Gate General Trading L.L.C.
Address: Aldar HQ Building, Level 3, Office 301/32, Abu Dhabi, United Arab Emirates
For general booking enquiries, please use reservations@amirigate.com.
4. Information Required by Local Data Protection Laws
We may be required by certain local Data Protection Laws to provide you with additional information relating to data privacy, which shall be updated from time to time as such notices are issued.
5. How and When Do We Collect Your Personal Data?
5.1 Sources of collection
We may obtain your Personal Data from you and/or other sources, including but not limited to when:
you book our Services directly through the Website;
you access our Services through a Business Partner (e.g. a partner bank's mobile app or a partner concierge team), and we receive your Personal Data from them, or from their concierge team booking on your behalf;
you access any of our Locations, including any service desk or lounge where Closed Circuit Television (CCTV) may be installed and may capture your Personal Data;
you use any of our Services and we are required to collect your Personal Data to deliver them (e.g. verifying your booking or membership card at the Location);
you make any enquiries with us, including orally, virtually, or in writing;
you communicate with us by email, telephone, or through our social media platforms;
you sign up for or use a My Benefits membership, where applicable; and/or
other sources provide us your Personal Data for which you have given consent to disclose information relating to you and/or where not otherwise restricted.
5.2 From representatives or third parties
We may also collect Personal Data from your authorised representative(s) or third parties validly acting on your behalf (e.g. a travel agent, a Business Partner's concierge team, or another traveller in your booking party).
5.3 Automated processing
We may use automated processes, including basic profiling, under the applicable Data Protection Laws to support certain functions of the Services (for example, matching your booking to the correct Service Provider and rate). This means certain decisions may be supported by systems based on your Personal Data.
6. Why Do We Process Your Personal Data?
6.1 To perform our contract with you
A contract is entered into between you and us when you book our Services. We process your Personal Data to facilitate and process your booking, to provide the Services pursuant to your booking (including verifying your booking or membership at the Location), and to perform any requests made by you. We also use your Personal Data to handle your interactions with us relating to your booking, including enquiries, amendments, or cancellations.
Legal basis: performance of our contract with you.
6.2 To verify your eligibility for our Services
Where you access our Services through a Business Partner (for example, using a partner bank's VIP card or membership benefit), we may need to verify your eligibility for the relevant discount or Service. To do so, we process your Personal Data, including any membership or card details provided at the time of booking.
Legal basis: our legitimate commercial interest.
6.3 To respond to enquiries
If you submit an enquiry to us in any manner, we may process your Personal Data to manage, respond to, or administer your enquiry or request.
Legal basis: our legitimate commercial interest.
6.4 To comply with our legal obligations
We operate in the United Arab Emirates and may be required by local law to obtain certain Personal Data from you in the course of our operations.
Legal basis: compliance with a legal obligation.
6.5 To manage a My Benefits membership, where applicable
If you hold or sign up for a My Benefits membership with us, we will process your Personal Data to administer your membership, send related communications, and maintain your account on our backend systems.
Legal basis: your consent, and our legitimate commercial interest.
6.6 For marketing purposes
If you subscribe to our mailing list, we will send you marketing communications about our Services, offers, and news. Please refer to Section 13 - “Marketing Communications” for more information.
Legal basis: your specific consent for direct marketing.
6.7 For other operational purposes
to improve the provision of Services to you;
to manage your account or membership with us, including addressing queries and notifying you of changes to the Website or Services;
to compile and provide anonymous statistics about users of the Website;
to manage our relationship with you and with our Business Partners;
to facilitate our business operations, including reconciliation of bookings with Service Providers and Business Partners;
to improve and develop new products and/or Services;
to respond to your feedback and complaints;
for audit, compliance and risk management purposes; and
for such other purpose that is incidental, ancillary or in furtherance to the above purposes.
Legal basis: our legitimate commercial interest.
7. What Personal Data Do We Collect?
We collect specific Personal Data depending on the circumstances of the collection and the Services requested. This includes, but is not limited to:
Personally identifiable information, such as your name, passport number, identity card number, date of birth, or membership/card numbers (e.g. a Business Partner VIP card number);
Contact details, such as your mailing address, phone number, and email address;
Travel information, such as your flight number, travel date and time, journey type (arrival/departure/transfer), and number of passengers;
Payment information, such as your payment card details, where a booking requires payment; and
Other information attributable to you, such as your service requests or special requests provided at the time of booking.
7.2 Minors
Our Website is intended for use by adults, and bookings must be made by an individual aged 18 or over. However, our Services may be booked for, and used by, minors travelling as part of a family or group booking (for example, Child and Infant fare categories for Meet & Greet Services). Where a booking includes a minor, the adult making the booking is responsible for providing that minor's Personal Data and warrants that they have the necessary parental or guardian authority to do so. If a minor's Personal Data has been provided to us without appropriate parental or guardian consent, the parent or guardian should contact us using the details in Section 3 to request its removal.
7.3 Special categories of Personal Data (Sensitive Data)
Where required or permitted by Data Protection Laws, or where you have given us your explicit consent, we may ask for special categories of Personal Data (for example, relating to accessibility or medical requirements needed to deliver a Service safely).
8. Disclosure of Personal Data
We may have to disclose your Personal Data to other parties in order to provide you with our Services. By providing your Personal Data to us, you acknowledge and consent to our disclosure of your Personal Data as set out below.
8.1 To Service Providers
We share your Personal Data with the relevant Service Provider (e.g. the Meet & Greet operator, Fast Track operator, or lounge) so that they can fulfil the Service you have booked.
8.2 To Business Partners
Where you access our Services through a Business Partner, we may share your booking and Personal Data with that Business Partner for the purposes of verifying eligibility, processing your booking, and reconciliation.
8.3 To other parties
We may share your Personal Data with other companies or parties, such as airport authorities, our Suppliers, or professional advisers, to assist in fulfilling the purposes for which your Personal Data was processed. We may also share your Personal Data with service providers that provide analytics or IT hosting services to us, solely for those purposes.
8.4 Your responsibilities
If you hold a My Benefits membership account with us, you are solely responsible for safeguarding your own login and password information, and should not disclose it to any third party. We will not ask you for your password under any circumstances. You acknowledge that the transmission of information via the Internet is not completely secure, and while we take practical steps to safeguard your Personal Data, we do not guarantee its security when transmitted via the Internet, and any such transmission is at your own risk.
9. Transfer of Your Personal Data
We may transfer your Personal Data across national or regional borders when disclosing it in the manner set out in Section 8 above (for example, where a Service Provider or Business Partner is located outside the UAE). Where such a transfer is performed, it will be done in compliance with the applicable Data Protection Laws. We will take reasonable care and exercise due diligence to ensure your Personal Data, after being transferred to recipients located in other countries, is not stored, processed, or used in a manner that would contravene the Data Protection Laws, including, where applicable, by entering into data processing agreements or standard contractual clauses with our Service Providers and Business Partners.
10. Retention of Your Personal Data
We retain your Personal Data for as long as necessary to fulfil the purposes for which it was collected, or for as long as required by applicable law, or for our legitimate business needs in line with our data retention practices. Data collected to carry out the purposes stated in this Privacy Policy will be stored in our databases, which may include your name, contact details, booking, and travel information. If we destroy any Personal Data in our possession, it will be done in accordance with the applicable Data Protection Laws.
11. Your Rights
You may have certain rights under applicable Data Protection Laws in respect of your Personal Data being processed by us, including the right to:
know whether or not we process your Personal Data, and if so, to access it;
request corrections to your Personal Data if you find it to be inaccurate or incomplete;
obtain information on how we process your Personal Data, including the purposes, categories of data, and recipients;
request a copy of your Personal Data being processed by us (we may charge an administrative fee for repeated requests, or decline where providing a copy would adversely affect the rights of others);
request erasure of your Personal Data, or object to or restrict its processing, subject to applicable Data Protection Laws;
withdraw your consent at any time, where processing is based on consent, without affecting the lawfulness of processing carried out before withdrawal; and
where required or permitted by Data Protection Laws, request your Personal Data be transmitted to another Data Controller in a structured, commonly used, machine-readable format, subject to technical feasibility.
A request to exercise any of these rights, or to obtain a copy of this Privacy Policy, must be made in writing to the email address in Section 3 — “Contacting Us”. We may require you to verify your identity before actioning a request. You may also lodge a complaint about how your Personal Data is handled with the UAE Data Office or other competent data protection authority.
12. Cookies
Cookies are used on the Website to distinguish you from other users, to analyse how visitors navigate the Website with a view to improving its design, and to maintain your logged-in session if you have an account with us. Cookies in general do not tell us your email address or other Personal Data; however, if you voluntarily provide such information (for example, by making a booking), it may be linked to data in the cookies. Most web browsers are set up to accept cookies by default; you may edit your browser settings to block cookies, though certain features of the Website may not work properly if you do so. Cookies from third parties unaffiliated with Amiri Gate may also be set while browsing our Website; we do not control these and recommend checking the relevant third party's own policy.
13. Marketing Communications
We use your Personal Data to conduct direct marketing via email or other communication channels, to provide you with information about Services offered by Amiri Gate. You will only receive marketing communications if you have subscribed to our mailing list or explicitly agreed to receive marketing materials when providing your Personal Data to us. You may withdraw consent at any time, free of charge, by following the “opt-out” or “unsubscribe” instructions in the communication, or by emailing us with the subject “Unsubscribe” at the address listed in Section 3.
14. Changes to this Privacy Policy
We may amend this Privacy Policy at any time at our sole discretion. Please check back for updates, which will be dated as of the most recent revision. If you continue to provide us with your Personal Data or use our Services after a change takes effect, you will be deemed to have accepted that change.
15. Conflict
In the event of any conflict between the English version of this Privacy Policy and any corresponding translation, the English version shall prevail.