Privacy Policy

Overview

We take your privacy seriously and are committed to protecting your personal information. This Skywards Miles Mall Privacy Notice explains how your personal information is collected, used and shared in the course of operating Skywards Miles Mall. In order to help you find what you are looking for, we have divided the information into several sections.

About Skywards Miles Mall

The Skywards Miles Mall Platform is a third party website developed and powered by Collinson Middle East (Collinson), a company incorporated and registered in Dubai, United Arab Emirates with company Licence number 16710 whose registered office address is Business Central Towers, Tower A 32nd Floor 3204A Dubai.

The earning of Skywards Miles via the Skywards Miles Mall Platform and the benefits associated with the Emirates Skywards Programme is managed by Emirates (“Emirates”), a Dubai corporation established by Decree No. (2) of 1985 (as amended) and having its principal place of business at Emirates Group Headquarters, P.O. Box 686, Dubai, United Arab Emirates.

(in terms of the operation of Skywards Miles Mall, Collinson and Emirates together as “we / us / our”).

Some functions of the Skywards Miles Mall Platform, and therefore the processing of personal information with respect to those functions, are managed by Collinson individually, while others are managed by Emirates. The Skywards Miles Mall Platform also has some functions, which are managed by Collinson on behalf of Emirates.

In order for you to use the Skywards Miles Mall Platform, you must be an Emirates Skywards Member, so for your interactions on the Skywards Miles Mall Platform, which are related to your Emirates Skywards membership, such as using your Emirates Skywards credentials to log in to the Skywards Miles Mall Platform, the Emirates Privacy Policy applies.

For any of your interactions on the Skywards Miles Mall Platform, which are strictly related to the use of the Skywards Miles Mall Platform and not covered by the Emirates Privacy Policy, the below terms will apply.

To ensure that you are fully aware and appropriately informed about how your personal information is collected and used, we provide you with all the relevant details, together with examples below.

Providing your personal information on the Skywards Miles Mall Platform

You do not have to provide your personal information to us, but if you do not provide certain information we will not or will only be able to provide limited services to you on the Skywards Miles Mall Platform.

Updates

We may amend this Privacy Notice from time to time to keep it up to date with legal requirements and the way we manage the Skywards Miles Mall. If we decide to change our Privacy Notice we will place any updates on this webpage. Please regularly check this webpage as well as the Emirates Privacy Policy referred to above.

This Privacy Notice was last updated on 23 July 2020.

Your duty to inform us of changes

It is important that the personal information we hold about you is accurate and current. We use appropriate technical and organisational measures to keep your data accurate on our end, but please keep us informed if your personal information changes during your relationship with us.

Third Party Websites and Links

The Skywards Miles Mall Platform includes external 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 personal information about you. We are not responsible for the privacy practices of those websites, so when you leave the Skywards Miles Mall Platform, we encourage you to read the privacy statement of any such third party website.

Personal information we collect and use when you log in to and shop on the Skywards Miles Mall Platform

When you log in to and use the Skywards Miles Mall Platform we will collect, process and use personal information so that we can deal with all aspects of your use of the Skywards Miles Mall Platform.

Types of personal information we collect and process with respect to the Skywards Miles Mall Platform:

• Name;
• Title;
• Email address;
• Emirates Skywards membership number and tier;
• Payment card (credit or debit card) data, if you link you payment card to the Skywards Miles Mall Platform;
• Transaction details (such as points or miles accrual, redemption, purchase);
• Information collected and processed via Cookies, such as IP address or device type (for more details see our Cookie Policy)

We use the above personal information as follows:

Personal information collected, used and transferred by Emirates to Collinson

• Emirates will collect, use and transfer to Collinson your name, email address, Emirates Skywards membership number and membership tier. Such disclosure shall be made in accordance with the Emirates Privacy Policy and for the purposes of enabling you to conduct the transactions on the Skywards Miles Mall Platform;
• In relation to the login to the Skywards Miles Mall, Emirates will use your login credentials provided to your Skywards account (single sign-on). Emirates has implemented its second-level authentication process (one-time passcode service) to the Skywards Miles Mall Platform too (see more details about Emirates’ one-time passcode service in the Emirates Skywards Programme Rules;
• Emirates will transfer to and receive from Collinson transaction details (see below), which are necessary for you to avail of the partnership benefits, including the earning of Skyward Miles;
• Emirates may also share name and email address with Collinson to enable Skywards Miles Mall special offers from time to time where you have consented to receive such offers via the Skywards Miles Mall Platform;
• Emirates will not share your personal information with Participating Brands.

Personal information collected, used and transferred by Collinson to Emirates

• Collinson will collect, use and transfer to Emirates certain personal information about you, including personal data which you provide to Collinson when purchasing via Skywards Miles Mall, such as: name, email address, membership number and membership tier, transaction details, limited to the date, time and the value of the transaction, the number of Skywards Miles earned, and whether a special offer was availed. Such disclosure shall be made in accordance with the Collinson Privacy Policy and for the purposes of enabling you to conduct the transaction;
• Collinson will collect and use credit and debit card data (together as “payment card data”). All data provided by you when linking your payment card(s) to the Skywards Miles Mall Platform are processed by Collinson and are subject to the Skywards Miles Mall Terms and Conditions and Privacy Policy;
• The Skywards Miles Mall Platform uses cookies in facilitating transactions via the Skywards Miles Mall Platform. A “cookie” is a small computer file which is downloaded to the your device. It collects information as to how you navigate the Skywards Miles Mall Platform and tracks your path from the Skywards Miles Mall Platform to Participating Brands' website to enable Skywards Miles earn from the relevant purchase to be credited to your Emirates Skywards Membership Account. Some cookies may collect personal information about you. The use of Cookies on the Skywards Miles Mall Platform is managed by Collinson and is subject to the Cookie Policy;

Tracking

• Transactions are electronically tracked and reported back by the participating partner brand. We cannot be held responsible if for any reason partner brands are not correctly reporting sales to us or reporting back at all. We will, however, use reasonable efforts to ensure correct reporting by participating partner brands. However we do not accept liability if retailers fail to do so.
• All participating partner brands’ transactions are tracked through the use of cookies. It is your responsibility to ensure that cookies are enabled with your browser and ensure that any security software on your computer does not block cookies.

Tracking – Instore Purchases

Where you have agreed to receive card-linked offers, notwithstanding anything to the contrary in the Terms and Conditions or Privacy Policy, Collinson, Inc. and its third-party service providers will use transaction information solely as follows:

• to confirm a qualifying purchase and to confirm whether you qualify for an offer;
• to share with the participating partner brand where a transaction occurred as needed for the partner brand to confirm a specific transaction occurred or Skywards Miles should be awarded; for example, the date and amount of your purchase and the last 4 digits of your card number so the partner brand can verify your purchase with its records if there is a missing or disputed transaction;
• to provide participating partner brands or third-party service providers aggregated and anonymized information relating specifically to registered card activity solely to allow participating partner brands and third party service providers to assess the results of their campaign;
• to create a record of the transaction data and thereafter maintain and use data in connection with operating the program;
• to conduct analysis for the improvement and optimization of the program; and
• to provide information in order to respond to a request from government authority or a payment organization involved in a transaction with you or a partner brand.

Please note that this Privacy Notice is complementary to the Emirates Privacy Policy, which is applicable to Emirates’ services, so we recommend that you check it regularly, in particular those sections where we describe the personal information we collect and use in connection with Emirates’ loyalty schemes.

Personal information we collect and use for legal, compliance, regulatory and crime detection and prevention purposes

We process your personal information so that we can meet our (either Emirates or Collinson) legal, compliance and regulatory obligations, for legal purposes, such as to respond to a valid legal subpoena, claim, summons or regulatory order, and to protect our property, rights and interests as well as the property, rights and interest of other persons.

We also process your personal information for crime prevention and detection purposes, including the prevention of fraud for online payments and use of loyalty schemes, for identity verification, for credit checking and credit scoring purposes and accounting or audit purposes.

Legal basis for using your personal information

We only collect, process, use, share and store your personal information where we are satisfied that we have an appropriate legal basis to do this. This may be because:

• we need to use your personal information to perform a contract or take steps to enter into a contract with you;
• we need to use your personal information for our legitimate interest as a commercial organisation. In all such cases, we will look after your information at all times in a way that is proportionate, that respects your privacy rights and is in accordance with our Privacy Notice, and you have a right to object to processing as explained in Legal rights available to help manage your privacy;
• we need to use your personal information to comply with a relevant legal or regulatory obligation that we have;
• we have your consent to using your personal information for a particular activity. For example, where you consent to us sharing with you special offers about the Skywards Miles Mall Platform; and
• we need to use your personal information to protect your vital interests. For example, we may need to report your medical condition to a hospital or clinic in the event of an emergency on board our flights.

Storage of your personal information

We keep your personal information for as long as is reasonably necessary for the purposes for which it was collected. For example, to manage your earning of Skywards Miles with your in-store purchases when you linked your payment card to the Skywards Miles Mall. We will ensure that it is disposed of in a secure manner.

In some circumstances we may store your personal information for longer periods of time, for example, where we are required to do so in accordance with legal, regulatory, tax, or accounting requirements, so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your personal information or dealings.

Security of your personal information

We have implemented and maintain appropriate technical and organisational security measures, policies and procedures designed to protect the personal information that you share with us and safeguard the privacy of such information. For example, the measures we take include:

• placing confidentiality requirements on our staff members and service providers;
• destroying or permanently anonymising personal information if it is no longer needed for the purposes for which it was collected;
• following security procedures in the storage and disclosure of your personal information to prevent unauthorised access to it; and
• introducing second-level authentication through use of one time passcode for certain Emirates Skywards account activities.

As the security of information depends in part on the security of the computer or other device you use to communicate with us and the security you use to protect user IDs and passwords, please take appropriate measures to protect this information.

Cookies

The Skywards Miles Mall Platform uses cookies. A “cookie” is a small computer file which is downloaded to your device. It collects information as to how you navigate the Skywards Miles Mall Platform and the internet, and helps to provide better services to you and tailor certain content. For more information on how the Skywards Miles Mall Platform uses cookies and how to manage cookie settings, see the Skywards Miles Mall Cookie Policy. The acceptance and the further operation of cookies on the Skywards Miles Mall is managed by Collinson.

Legal rights available to help manage your privacy

If you are subject to laws that provide you with such rights, depending on certain exceptions, and in some cases dependent upon the processing activity we are undertaking, you may have certain rights in relation to your personal information. Click on the links below to learn more about each right you may have:

• To access personal information
• To rectify / erase (‘right to be forgotten’) personal information
• To restrict the processing of your personal information
• To object to the processing (including direct marketing) of personal information
• To transfer your personal information
• To obtain a copy of personal information safeguards used for transfers outside your jurisdiction
• To lodge a complaint with your local supervisory authority

If you wish to access any of the rights set out above, we may ask you for additional information to confirm your identity and for security purposes, in particular before disclosing personal information to you. We reserve the right to charge a fee where permitted by law, for example, if your request is manifestly unfounded or excessive.

As we operate the Skywards Miles Mall Platform in partnership, we have set up processes to ensure that you can exercise your above rights if you contact either Emirates or Collinson.

If you would like to first contact Emirates, you can exercise your rights by completing a form on our website which you can find here, by emailing Emirates at privacy@emirates.com or by sending Emirates a communication at Data Privacy Office, Emirates, P.O. Box 686, Dubai, United Arab Emirates.

If you would like to first contact Collinson, you can exercise your right by contacting Data.Protection@CollinsonGroup.com

Subject to legal and other permissible considerations, we will make every reasonable effort to honour your request promptly or inform you if we require further information in order to fulfil your request.

We may not always be able to fully address your request, for example, if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.

Who is responsible for my/your personal information

Who is responsible for my/your personal information, when…

I log in to the Skywards Miles Mall Platform with my Emirates Skywards credentials?	Emirates. When you log in to the Skywards Miles Mall Platform, you log in through Emirates’ single sign-on gateway with your Emirates Skywards account credentials.
I sign up newsletters?	Emirates, but the processing of your requests to subscribe to or unsubscribe from newsletters as well as the deployment of such newsletters are managed by Collinson on behalf of Emirates Skywards.
I link my credit or debit card to the Skywards Miles Mall Platform?	Mainly Collinson. Emirates will not have access to your payment card details, and Collinson will ensure that your payment card details are only used for the purposes of your in-store purchases and to facilitate earning Skywards Miles.
I accept the cookies when arriving to the Skywards Miles Mall Platform?	Collinson. The cookies on the Skywards Miles Mall Platform are managed by Collinson.
A Participating Brand may request personal information from me when shopping?	Neither Collinson, not Emirates is responsible for the privacy practices of the Participating Brands, so we encourage you to read the privacy notices or statements of any such Participating Brands.
I have personal data related issue with respect to my earning of Skywards Miles or other benefits associated with the Emirates Skywards Programme?	Mainly Emirates, but if your issue is strictly related to the use of the Skywards Miles Mall Platform, Emirates may direct you to Collinson.
I have a personal data related issue strictly related to the Skywards Miles Mall Platform?	Mainly Collinson, but if Collinson requires, Emirates will support Collinson in identifying and resolving your issue.