PAIR User Agreement & Privacy Policy

1. Who We Are (Data Controller)

• Legal Entity: PAIR RESTAURANTS MANAGEMENT L.L.C.
• Trade License No.: 1164342 (issued by the Dubai Department of Economic Development)
• Registered Address: Dubai, Jumeirah Emirates Towers Hotel, G floor, Dubai, United Arab Emirates
• Contact Email for Privacy Matters: info@pairstores.com (please mention "Attn: DPO" in the subject line)
• Phone: +(971) 58 694 42 82

We are a mainland company operating in Dubai and are subject to the UAE DP Law.

2. What Personal Data We Collect and Why

We only collect data that is necessary to provide you with high-quality service. Depending on how you interact with us, we may process the following categories of personal data:

3. How We Use Your Data (Detailed)

3.1. Guest Data (Reservations & CRM)

We use your name and contact details to confirm bookings and send updates. Your preferences (e.g., favorite table or dietary restrictions) help us tailor your dining experience. For marketing communications (promotions, events), we will only contact you if you have explicitly opted in.

3.2. CCTV Monitoring

For your safety and the security of our property, CCTV is in operation at all our locations, including entrances, dining areas, and exits. Signage is displayed at all entry points. Recordings are typically retained for 30 days unless required for an investigation.

3.3. Loyalty Program (Loona)

If you join our loyalty program, we track your visits and spending to offer you relevant rewards. You can withdraw your consent at any time by contacting us.

3.4. Marketing Automation & Customer Data Platform (Mindbox)

We use Mindbox as our marketing automation and customer data platform to:

• Unify your data from various sources (website, reservations, loyalty program, order history) into a single customer profile.
• Segment audiences for targeted marketing campaigns.
• Send personalized emails, SMS, and push notifications (based on your consent).
• Analyze customer behavior to improve our services and offerings.
• Predict preferences and recommend dishes or events you might enjoy.

Mindbox processes your data on our behalf under a strict Data Processing Agreement (DPA) and in compliance with UAE DP Law.

4. Tracking Technologies (Cookies, Pixels & SDKs)

We use various tracking technologies to understand how you interact with our website and marketing materials. This helps us improve your experience and measure the effectiveness of our campaigns.

4.1. Types of Tracking Technologies We Use

4.2. Cross-Device Tracking

We may use tracking technologies to recognize you across different devices (e.g., smartphone, tablet, laptop) to provide a seamless experience and ensure you receive relevant communications. This is done through hashed identifiers and is always subject to your consent where required.

4.3. How to Control Tracking

• Browser Settings: You can block or delete cookies through your browser settings.
• Opt-Out Links: Our marketing emails contain an "unsubscribe" link. You can also opt-out of targeted advertising via your account settings.
• Platform Controls: You can adjust your ad preferences directly on platforms like Facebook and Google.

5. Sharing Your Data (Third Parties & Processors)

To operate effectively, we work with trusted service providers who process data on our behalf. They are contractually bound to protect your data and comply with UAE law.

We do not sell your personal data to third parties.

6. Data Retention Periods

We keep your data only as long as necessary for the purposes described above, or as required by UAE law.

After the retention period, your data is securely deleted or anonymized.

7. Your Rights (Data Subject Rights)

Under the UAE DP Law, you have the following rights regarding your personal data:

• Right to Access: You can request a copy of the personal data we hold about you.
• Right to Rectification: You can ask us to correct inaccurate or incomplete data.
• Right to Erasure (Deletion): You can request the deletion of your data where it is no longer needed.
• Right to Withdraw Consent: If you previously agreed to marketing or tracking, you can opt-out at any time.
• Right to Object: You can object to processing based on legitimate interest (e.g., CCTV, analytics).
• Right to Restrict Processing: You can ask us to temporarily stop processing your data.
• Right to Data Portability: You can request your data in a structured, machine-readable format.

How to Exercise Your Rights:
Please send your request to info@pairstores.com with the subject line "Data Subject Request". We will respond within 14 business days as mandated by law. We may need to verify your identity before processing your request.

For Tracking-Specific Requests:

• To opt-out of cookies: Adjust your browser settings.
• To opt-out of targeted ads: Use platform controls (e.g., Facebook Ad Preferences).
• To clear your Mindbox profile data: Contact us directly.

8. Security Measures

We take data security seriously and implement robust measures to protect your information, including:

• Encryption: TLS 1.3 for data in transit (website), AES-256 for data at rest (servers).
• Access Control: Role-based access, two-factor authentication (2FA) for critical systems (including Mindbox dashboard), and biometric security for server rooms.
• Monitoring: 24/7 security monitoring, regular penetration testing, and vulnerability assessments.
• Data Minimization: We only collect what we need and pseudonymize data where possible.

9. Cookies and Tracking (Detailed)

When you visit our website, you will see a cookie consent banner that allows you to:

• Accept all cookies.
• Reject non-essential cookies.
• Customize your preferences (analytics, marketing, functional).

Categories of Cookies We Use:

1. Strictly Necessary Cookies: These are essential for the website to function and cannot be switched off.
2. Performance/Analytics Cookies: These allow us to count visits and traffic sources (e.g., Google Analytics, Mindbox analytics).
3. Functional Cookies: These enable enhanced functionality and personalization (e.g., remembering your language preferences).
4. Targeting/Marketing Cookies: These are set by our advertising partners (Meta, Google) to build a profile of your interests and show you relevant ads on other sites.

You can change your cookie preferences at any time by clicking the "Cookie Settings" link in the website footer.

10. International Data Transfers

Some of our service providers (like AmoCRM, Mindbox, and Meta) may process data outside the UAE. We ensure such transfers are protected by appropriate safeguards, such as:

• Standard Contractual Clauses (SCCs) approved by relevant authorities.
• Binding Corporate Rules (where applicable).
• Data Processing Agreements (DPAs) that include specific data transfer provisions.
• Adequacy Decisions (if the destination country is recognized as having adequate data protection laws).

11. Contact Us

If you have any questions about this Privacy Policy or how we handle your data, please contact us:

• Email: info@pairstores.com
• Phone: +(971) 58 694 42 82
• Address: Dubai, Jumeirah Emirates Towers Hotel, G floor, Dubai, UAE
• Working Hours: 11 AM to 1 AM (Monday to Sunday)

Data Protection Officer (DPO):
In accordance with Article 14 of the UAE DP Law, you may direct any privacy-related inquiries to our designated representative via the email above.

12. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. The updated version will be posted on this page with the "Effective Date" revised. We encourage you to review this page periodically.

For significant changes, we may notify you via email or a prominent notice on our website.