Introduction

360 Brand Management (“we,” “us,” or “our”) is committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy explains how we collect, use, store, and protect your data when you use our website, services, or interact with our brand management solutions.

This policy complies with:

• United Kingdom: UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018
• United Arab Emirates: UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data, and applicable emirate-level data protection regulations

Where we operate across both jurisdictions, we apply the highest standard of data protection to ensure compliance with both legal frameworks.

 

1. Information We Collect

We collect and process the following types of personal information:

 

1.1 Information You Provide Directly

• Contact Information: Name, email address, phone number, business name, and postal address
• Identification Information: Passport details, Emirates ID, or other identification (when required for property access or compliance)
• Business Information: Business type, services required, property details, trade license information, and operational data
• Communication Records: Messages, enquiries, booking requests, consultation notes, and customer service interactions
• Payment Information: Billing details, bank account information, and transaction records (processed securely through third-party payment processors)
• Marketing Preferences: Your consent for marketing communications and communication preferences

1.2 Information Collected Automatically

• Technical Data: IP address, browser type, device information, operating system, and device identifiers
• Usage Data: Pages visited, time spent on site, referring URLs, navigation patterns, and feature usage
• Location Data: General geographic location based on IP address
• Cookies and Tracking Technologies: Information collected through cookies and similar technologies (see Section 8)

1.3 Information from Third Parties

• Booking Platforms: Guest information and booking data from platforms like Airbnb, Booking.com, Expedia, and VRBO
• Business Partners: Information from vendors, suppliers, and service providers working with your property
• Government Authorities: Information required for regulatory compliance in both UK and UAE jurisdictions

2. How We Use Your Information

We use your personal information for the following purposes:

 

2.1 Service Delivery

• Providing brand management, marketing, booking, and operational services
• Managing bookings and guest communications
• Coordinating operations, housekeeping, and maintenance
• Processing payments and maintaining financial records
• Delivering 24/7 guest support services
• Facilitating property access and security

2.2 Business Operations

• Responding to enquiries and consultation requests
• Managing client relationships and accounts
• Improving our services and operational efficiency
• Conducting market research and performance analysis
• Training and quality assurance purposes

2.3 Marketing and Communications

• Sending service updates, newsletters, and promotional materials (with your consent)
• Providing personalized marketing content and recommendations
• Conducting surveys and gathering feedback
• Running marketing campaigns across UK and UAE markets

2.4 Legal and Compliance

• Complying with legal obligations in UK and UAE jurisdictions
• Meeting regulatory requirements (including tourism, property, and business licensing)
• Protecting our rights and preventing fraud
• Resolving disputes and enforcing our terms of service
• Cooperating with law enforcement and government authorities

2.5 Website Functionality

• Ensuring website security and functionality
• Analyzing website performance and user experience
• Personalizing your browsing experience
• Preventing unauthorized access and cyber threats

3. Legal Basis for Processing

3.1 Under UK GDPR

We process your personal data based on the following lawful grounds:

• Consent: When you have given explicit permission for specific data processing activities
• Contract Performance: To fulfill our contractual obligations and deliver services you’ve requested
• Legitimate Interests: For business operations, fraud prevention, and service improvement (where not overridden by your rights)
• Legal Obligation: To comply with UK legal and regulatory requirements

3.2 Under UAE Data Protection Law

We process your personal data based on:

• Consent: Your explicit, freely given consent for processing activities
• Contractual Necessity: Performance of a contract to which you are a party
• Legal Obligation: Compliance with UAE federal and emirate-level legal requirements
• Legitimate Interest: Our legitimate business interests, provided they do not override your fundamental rights
• Public Interest: Where processing is necessary for public interest purposes

4. Data Sharing and Disclosure

We may share your information with:

4.1 Service Providers

• Technology platforms and software providers
• Payment processors and financial institutions
• Hosting and cloud storage providers (with data residency compliance)
• Marketing and analytics platforms
• Professional service providers (accountants, legal advisors)
• IT security and technical support providers

4.2 Booking Platforms

• Airbnb, Booking.com, Expedia, VRBO, and other online travel agencies
• Direct booking website platforms
• Channel management systems

4.3 Business Partners

• Housekeeping and maintenance vendors
• Property suppliers and contractors
• Guest service providers
• Property management companies

4.4 Legal and Regulatory Authorities

• UK: Information Commissioner’s Office (ICO), HMRC, law enforcement agencies
• UAE: Telecommunications and Digital Government Regulatory Authority (TDRA), Dubai Economy, Department of Tourism and Commerce Marketing (DTCM), police authorities, and other government entities
• Courts and regulatory bodies when legally required
• Protection of our legal rights and prevention of fraud

4.5 Corporate Transactions

In the event of a merger, acquisition, or sale of assets, your data may be transferred (with appropriate safeguards and notifications)

We ensure all third parties comply with applicable data protection standards through contractual agreements and data processing agreements.

 

5. International Data Transfers

Your data may be transferred to and processed in countries outside the UK and UAE. When we transfer data internationally, we ensure adequate protection through:

 

5.1 From the UK

• Adequacy Decisions: Transferring data to countries recognized by the UK as providing adequate protection
• Standard Contractual Clauses: Using UK-approved standard contractual clauses
• Binding Corporate Rules: Where applicable for intra-group transfers

5.2 From the UAE

• Adequate Protection Countries: Transferring to jurisdictions recognized under UAE law
• Contractual Safeguards: Implementing appropriate contractual protections
• Regulatory Approval: Obtaining necessary approvals from TDRA or relevant authorities when required

5.3 Cross-Border Transfers (UK-UAE)

Data shared between our UK and UAE operations is protected through appropriate transfer mechanisms and security measures compliant with both jurisdictions.

 

6. Data Retention

We retain your personal information only for as long as necessary to fulfill the purposes outlined in this policy:

 

6.1 UK Requirements

• Client Data: Duration of business relationship plus 7 years (for legal and tax purposes)
• Marketing Data: Until you withdraw consent or request deletion
• Website Analytics: Typically 26 months
• Financial Records: 7 years from the end of the financial year

6.2 UAE Requirements

• Commercial Records: As required by UAE Commercial Companies Law and tax regulations
• Tourism Records: As required by local tourism authorities
• Property Management Records: Duration required by Dubai Land Department or relevant emirate authority
• Marketing Data: Until consent is withdrawn

We apply the longer retention period where requirements differ between jurisdictions, unless you exercise your right to erasure.

 

7. Your Data Protection Rights

7.1 Rights Under UK GDPR

Right of Access: Request copies of your personal data we hold

Right to Rectification: Request correction of inaccurate or incomplete data

Right to Erasure (“Right to be Forgotten”): Request deletion of your personal data in certain circumstances

Right to Restrict Processing: Request limitation of how we process your data

Right to Data Portability: Receive your data in a structured, commonly used format

Right to Object: Object to processing based on legitimate interests or direct marketing

Rights Related to Automated Decision-Making: Not be subject to decisions based solely on automated processing

Right to Withdraw Consent: Withdraw consent for data processing at any time

 

7.2 Rights Under UAE Data Protection Law

Right to Access: Obtain confirmation of whether we process your data and access such data

Right to Rectification: Request correction of inaccurate personal data

Right to Erasure: Request deletion of your data in accordance with UAE law

Right to Restrict Processing: Request restriction of processing in certain circumstances

Right to Data Portability: Receive your data in a commonly used electronic format

Right to Object: Object to processing for direct marketing or based on legitimate interests

Right to Withdraw Consent: Withdraw consent at any time without affecting prior processing

Right to Lodge a Complaint: File a complaint with TDRA or relevant data protection authority

 

7.3 Exercising Your Rights

To exercise any of these rights, please contact us using the details in Section 12. We will respond:

• UK Requests: Within one month (extendable by two months for complex requests)
• UAE Requests: Within timeframes specified by applicable regulations

We may require proof of identity before processing your request.

 

8. Cookies and Tracking Technologies

Our website uses cookies and similar technologies to enhance your browsing experience and analyze website performance.

 

8.1 Types of Cookies We Use

• Essential Cookies: Required for website functionality and security
• Performance Cookies: Help us understand how visitors use our site
• Functional Cookies: Remember your preferences and settings
• Marketing Cookies: Track your browsing to deliver relevant advertisements

8.2 Cookie Consent

In compliance with UK and UAE laws:

• We obtain your consent before placing non-essential cookies
• You can withdraw consent at any time through cookie settings
• Essential cookies are placed based on legitimate interest

8.3 Managing Cookies

You can control and manage cookies through your browser settings. Disabling certain cookies may affect website functionality.

For detailed information, please refer to our Cookie Policy.

 

9. Third-Party Links

Our website may contain links to third-party websites, booking platforms, and services. We are not responsible for the privacy practices of these external sites. We encourage you to review their privacy policies before providing personal information.

 

10. Data Security

We implement appropriate technical and organizational measures to protect your personal data, including:

 

10.1 Technical Measures

• Encryption of data in transit (TLS/SSL) and at rest
• Secure access controls and multi-factor authentication
• Regular security assessments, penetration testing, and audits
• Firewalls and intrusion detection systems
• Secure data backup and disaster recovery procedures

10.2 Organizational Measures

• Staff training on data protection and privacy
• Confidentiality agreements with employees and contractors
• Access controls based on role and necessity
• Incident response and breach notification procedures
• Regular privacy impact assessments

10.3 Data Breach Notification

In the event of a data breach affecting your rights, we will:

• UK: Notify the ICO within 72 hours and inform affected individuals without undue delay
• UAE: Notify TDRA and affected individuals in accordance with applicable regulations

While we strive to protect your data, no method of transmission or storage is 100% secure. We cannot guarantee absolute security.

 

11. Children’s Privacy

Our services are not directed to individuals under 18 years of age. We do not knowingly collect personal information from children without parental consent. If you believe we have collected data from a child, please contact us immediately, and we will take appropriate steps to delete such information.

 

12. Contact Information

For questions about this Privacy Policy or to exercise your data protection rights, please contact:

360 Brand Management

Office:
 Data Protection Officer
 Email: info@360brandmanagement.com
 Address: Office 207, A5, Dubai South Business Park, Dubai, 282228, UAE

General Inquiries:
 Email: info@360brandmanagement.com

 

13. Complaints and Regulatory Authorities

If you believe we have not handled your personal data properly, you have the right to lodge a complaint with the relevant supervisory authority:

 

13.1 United Kingdom

Information Commissioner’s Office (ICO)
 Website: www.ico.org.uk
 Telephone: 0303 123 1113
 Email: casework@ico.org.uk

 

13.2 United Arab Emirates

Telecommunications and Digital Government Regulatory Authority (TDRA)
 Website: www.tdra.gov.ae
 Email: info@tdra.gov.ae
 Toll-Free: 800-8372 (UAE)

Dubai: Dubai Electronic Security Center (DESC)
 Abu Dhabi: Relevant emirate-level data protection authorities

You may lodge a complaint with the authority in your jurisdiction or where the alleged infringement occurred.

 

14. Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes in our practices, technology, legal requirements, or business operations. We will notify you of significant changes by:

• Posting the updated policy on our website with a new “Last Updated” date
• Sending email notifications for material changes (where appropriate)
• Displaying prominent notices on our website
• Obtaining fresh consent where required by law

We encourage you to review this policy regularly to stay informed about how we protect your information.

 

15. Google Ads and Digital Marketing Compliance

In accordance with Google Ads policies and applicable UK and UAE advertising regulations, we commit to:

 

15.1 Transparency

• Clear disclosure of data collection practices
• Transparent advertising disclosures
• Honest representation of services

15.2 Consent and Control

• Obtaining proper consent for data collection and advertising
• Providing clear opt-out mechanisms for marketing communications
• Respecting user privacy preferences
• Honoring do-not-track signals where required

15.3 Compliance

• Complying with UK and UAE advertising standards
• Not collecting sensitive personal information through advertising campaigns
• Following platform-specific policies (Google, Meta, LinkedIn, etc.)
• Adhering to data protection regulations in marketing activities

15.4 Cookie Compliance

• Providing clear cookie notices
• Obtaining consent before placing marketing cookies
• Allowing users to manage cookie preferences

16. Jurisdiction-Specific Provisions

16.1 UK-Specific Provisions

• We maintain records of processing activities as required by UK GDPR
• We conduct Data Protection Impact Assessments for high-risk processing
• We cooperate with the ICO in accordance with UK data protection law
• Brexit-related transfers are managed through approved mechanisms

16.2 UAE-Specific Provisions

• We comply with data localization requirements where applicable
• We maintain necessary registrations with TDRA and relevant authorities
• We adhere to emirate-specific regulations (Dubai, Abu Dhabi, other emirates)
• We process data in accordance with UAE cybercrime laws
• We comply with UAE spam and electronic marketing regulations

16.3 Cross-Border Operations

Where we operate across both jurisdictions, we:

• Apply the highest standard of protection
• Maintain appropriate transfer mechanisms
• Ensure compliance with both legal frameworks
• Provide transparency about data flows

By using our website and services, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, use, and processing of your personal data as described herein.

360 Brand Management is committed to transparency, data protection, and your privacy rights across all jurisdictions where we operate. If you have any concerns or questions, please don’t hesitate to contact us.