Privacy Policy

All Things Nice Distribution FZ-LLC t/a holster® UAE Privacy Policy
(Hereinafter ‘holster® UAE’)

Overview.

Your privacy and the protection thereof is of paramount importance to us.

holster® UAE is strongly committed to respecting the privacy of all persons using our websites and/or mobile applications ("Site/App") and the protection of any personally identifiable information which we may collect uses, maintains, stores, transfers and discloses data collected through on our Site/App and/or use as part of our data collection process and/or which you may choose to share with us through any means of communication, including, but not limited to via telephone, email, chat messaging platforms or otherwise (“the Other Channels”). Such personal information will be collected, processed, used, maintained, stored, transferred and disclosed in accordance with the terms and conditions of this Privacy Policy, which is part of and specifically incorporated into the Terms of Use of the Web Site, www.holsterfashion.ae.

Important information.

holster® UAE is bound by the United Arab Emirates Personal Data Protection Laws and which include (but are not limited to) the Federal Decree Law No. 45 of 2021 (as amended from time to time), the Constitution of the UAE, the UAE Civil Code, the UAE Penal Code, Internet of Things Regulatory Policy and Procedures of the UAE Telecommunications Regulatory Authority; the UAE Federal Law No. (1) of 2006 on Electronic Commerce and Transactions; the UAE Federal Law 5 of 2012 on Combatting Cybercrimes and other applicable data protection and privacy laws, regulations and practices for the purposes mentioned in this Policy. regarding the Protection of Personal Data, which sets out a number of principles concerning the privacy of individuals. When you interact with, access the Site/App, purchase from, subscribe, sign-up or register, or in any way communicate with holster® UAE , you give us your consent to treat your personal information in accordance with this privacy policy.

Lawful basis. Pursuant to the governing Data Protection laws of the United Arab Emirates, we process your personal information under the following lawful bases:

Your consent;
The performance of the contract between you and the Site/App;
Compliance with our legal obligations;
To protect your vital interests;
To perform a task carried out in the public interest;
For our legitimate interests, which do not override your fundamental rights and freedoms.

Please further be advised that, all personal information collected and processed in the United Arab Emirates, is done fairly, lawfully, securely, accurately, transparently, with the information being retained for no longer than is necessary (or as required by law) and being processed only in accordance with your rights.

Definitions.

Terms which are not defined in this Privacy Policy shall have the meanings ascribed to them in the Terms of Use of the website/Site.

Data processor: means any person who processes your personal information on behalf of the data controller. holster® UAE is a data processor of your personal information and shall process your personal information directly, or may do so through our third parties, such as project partners who may be chosen by us for the purposes of furthering the individual and entities’ business interests of holster® UAE.

Data controller: means a person who determines the purposes for and the manner in which any personal information are to be processed. holster® UAE is the data controller of your personal information. Data protection is important to us and we adhere to all applicable data protection laws and regulations.

Your Express Consent to Collection and Use of Information.

We use your personal Information to provide our services to you, which includes, but is not limited to: offering products for sale, processing payments, shipping and fulfilment of your order, and keeping you up to date on new products, services, and offers.

When you visit the Site/App, we collect certain information about your device, your interaction with the Site/App, and information necessary to process your purchases. This is further supported, but not dependent on your application for and/or the creation of a User account. We may also collect additional information if you contact us for customer support. In this Privacy Policy, we refer to any information that can uniquely identify an individual (including the information below) as “Personal Information”. See the list below for more information about what Personal Information we collect and why.

holster® UAE reserves the right to collect such personally identifiable information as, name, address, telephone number, e-mail address, etc., as well as demographic, transactional and profile data, including IP address, internet domain or browser, referrer or user agent information, or other relevant information that we use as part of our data collection process on the Site/App, or via the Other Channels, such as the use of cookies or certain other information you may provide to us, etc. (“Personal Information”) as set forth in this Privacy Policy. We hold all such Personal Information on secure servers and treat it as fully confidential.

BY CHOOSING TO ACCESS OUR WEB SITES/APPS AND/OR COMMUNICATING WITH US THROUGH THE OTHER CHANNELS, YOU ARE INDICATING YOUR EXPRESS CONSENT AND AGREEMENT TO THE COLLECTION, TRANSFER, PROCESSING, USE AND STORAGE IN ACCORDANCE WITH THIS PRIVACY POLICY OF ANY PERSONAL INFORMATION WHICH MAY BE OBTAINED FROM YOU AS A RESULT. If you do not agree with any of the terms and conditions set forth in the Privacy Policy, or have any questions, please contact us directly via email at contact@holsterfashion.ae or by postal mail with address at Office 404, Building B, Al Saaha Offices, Souk Al Bahar, Old Town Island, Burj Khalifa District, Downtown Dubai, United Arab Emirates, for the attention and receipt of All Things Nice Distribution FZ-LLC t/a holster® UAE ; and we will be pleased to assist you with your concerns. By accessing or using the Site/App and/or communicating with us through the Other Channels, you grant holster® UAE a non-exclusive, worldwide, royalty-free perpetual license to use your Personal Information for the purposes set forth herein.

Additionally, see the list below for more information about what Personal Information we may collect and why:

Device information.

Examples of Personal Information collected: version of web browser, IP address, time zone, cookie information, what sites or products you view, search terms, and how you interact with the Site.
Purpose of collection: to load the Site/App accurately for you, and to perform analytics on Site usage to optimize our Site/App.
Source of collection: Collected automatically when you access our Site using cookies, log files, web beacons, tags or pixels.
Disclosure for a business purpose: shared with our e-commerce processor Shopify® or advertising partners, or other authorised third party affiliates, service providers / vendors.

Order information.

Examples of Personal Information collected: name, billing address, shipping address, payment information (including credit card numbers), email address, and phone number.
Purpose of collection: to provide products or services to you to fulfil our contract, to process your payment information, arrange for shipping, and provide you with invoices and/or order confirmations, communicate with you, screen our orders for potential risk or fraud, and when in line with the preferences you have shared with us, provide you with information or advertising relating to our products or services.
Source of collection: collected from you.
Disclosure for a business purpose: shared with our processor Shopify®, fulfilment partners including but not limited to authorised and contracted logistics services providers, including DHL.

Customer support information.

Examples of Personal Information collected: name, billing address, shipping address, payment information (including credit card numbers), email address, and phone number.
Purpose of collection: to provide customer support.
Source of collection: collected from you.

When you contact us or we contact you or you take part in promotions, competitions, surveys or questionnaires about our Services, we may collect:

Personal information you provide about yourself;
Details of emails and other digital communications we send to you including information about the emails you open and links in them that you click on;
Your feedback and contributions to customer surveys and questionnaires.

Other sources of personal information.

We may also use personal information from other sources, such as: specialist companies that supply information, online media channels our partners and public registers. We may collect the following types of personal information about you from other sources: contact details, credit history, purchases, interests, preferences, together with other types of publicly/non-publicly available information. This other personal information helps us to review and improve the accuracy of the personal information we hold.

We may be required by law to collect personal information about you, or as a consequence of any contractual relationship which we have with you and with any partner, but we do ensure to you that we will only use your personal information when and how the applicable laws allow us to, as well as in accordance with this privacy policy. If you choose not to provide your personal information to be collected and used in accordance with this Policy, you will still be able to visit our Facilities, but you may not be able to access certain options, products or services; and in some cases we may not be able to fulfill a service which you may request. In such a scenario, Holster® UAE shall have the right to discontinue the provision of any options, products, or services; however, we shall notify you if this is the case at the time. Please be advised that, personal information collected and processed in United Arab Emirates, is done so in accordance with the best data protection practices and principles from the applicable laws and regulations. As such Holster® UAE will:

only collect data for specified and lawful purposes; and not use that information for any reason that would be incompatible with those purposes (purpose limitation)
only collect as much data from users as is actually needed in order to achieve the above purposes and no more (data minimisation)
retain this data only for so long as it is actually needed in order to achieve the above purposes and no longer, unless the law requires otherwise (storage limitation)
use data encryption standards that fulfil the requirements of the competent UAE authorities.
when developing software and hardware, that ‘attempts to make systems free of vulnerabilities and robust to attacks to the best possible extent through continuous testing, authentication safeguards and adherence to best practices’ are made (privacy by design)
classify data collected on the basis of the anticipated harm that could result should such information be disclosed without consent (data classification) and further comply with the applicable data localisation requirements.

Protecting the Data Privacy of Minors.

In observance of Wadeema's, United Arab Emirates Federal Law No. 3 of 2006, holster® UAE is committed to protecting the privacy of children and minors under the age of 13. The Site and/ App is not intended for individuals under the age of 13. We do not intentionally collect Personal Information from children. If you are under the age of 13, please immediately exit our Site/App, if you are not accompanied and expressly permissioned by your Parent / Guardian. Special Instructions for a Parent/Guardian:

We protect the personal information and privacy of children in accordance with this Statement, provided that it is received by us with your consent and knowledge and if this is known to us. You are expected to help us protect the personal information and privacy of children under your custody, to require them to read and accept this Statement together with you, and to ensure that they use our products and services with your consent and guidance. Please note that if you choose to agree to this Statement, or your children begin, or continue, to use our products or services, or submit their personal information, you acknowledge that you agree to our collection, use, storage, sharing, transfer, and disclosure of your children's personal information in accordance with this Statement. If you are the parent or guardian and believe your child has provided us with Personal Information and without your express consent to do so, please contact us at the address below to request deletion.

Sharing and Selling Personal Information.

We will not sell your Personal Information to third parties. We may, however, share selected customer information with the following third parties:

our affiliated companies;
our franchisor;
service provider companies such as e-commerce service providers (including Shopify® and you can read more about how Shopify® uses your Personal Information here: https://www.Shopify.com/legal/privacy), payment service providers (including Stripe and associated banking / payment providers), warehousing service providers and delivery companies (DHL Express), Google Analytics, Social Media i.e. Facebook and Instagram (Meta Platforms, Inc.),to enable you to access, use and shop on our Site. Please check these Cookies Policies regularly, as they are subject to change., for the purposes of processing your payment and managing your order, including delivery and returns;
For example, we use third party technologies such as Shopify®, Stripe,
concessions partners who are responsible for delivering their products directly to you or providing services;
purchasers and their advisors following a sale of all or part of our business, so that they can continue to provide services to you;
third party databases to which holster® UAE and/or one of our affiliates of the franchisor holster® subscribes;
government bodies or other authorities if necessary to comply with regulations or law or to assist with law enforcement, or to protect our property and other rights;
agencies who help us collate statistics about Site/App traffic, sales, demographics and other commercial information to enable us to tailor the services we provide to you and other customers.

We will retain your Personal Information for as long as it is legally required, and to support the business purposes for which it was obtained, whereinafter we will then dispose of it promptly and securely, in accordance with the law.

Data Security.

holster® UAE stores your data in electronic form in a secure IT system protected by up-to-date security including firewall, secure access and anti-virus protection. The data is stored on our own, Shopify® data servers and/or on servers operated by highly reputable Cloud / IT system providers with database centres located in centers are held in the United Arab Emirates, Ashburn, Virginia (USA) Frankfurt, Germany. Dublin, Ireland. The computer hardware used, including desktop and laptops, is whole disc encrypted and, in the event of loss, data on devices is capable of being deleted remotely. When replaced, the hard disc of computer equipment is securely destroyed. When email data is to be permanently deleted this is done by instruction to an email archive facility. Please view the Shopify Privacy and Security Compliance Reports and check for updates regularly.

Transfers of data.

This Privacy Policy is of general application and as such it is not possible to state whether it will be necessary to transfer your information out of the United Arab Emirates in any particular instance or for any particular purpose. Such transfers include transfers for cloud data storage providers situated outside the United Arab Emirates, however applicable. If you are in a country outside the United Arab Emirates, or your order and services [to you] outside of the United Arab Emirates, then it may be necessary to transfer some of your information to that country outside of the United Arab Emirates and for that purpose. If any of these circumstances apply to you and you wish additional precautions to be taken in respect of your information please indicate this to us or when providing instructions in relation to any order.

Generally, however, depending on your country of residence and where you may be geographically situated (as per the provisions of law), we may transfer your Personal Information both inside and outside of the United Arab Emirates. When we transfer your Personal Information, we ensure a similar degree of protection is afforded to it by ensuring we only transfer it to countries that are deemed to provide an adequate level of protection for personal data and under contractual terms that provide appropriate data protection.

Media Data Collection.

When using the media login on our Site/App, we capture the following details:

First name and last name we receive from you and however is captured as a display or registered name under your profile section on our Site/App.
An optional profile picture or any image used as a profile picture.
Any email address used and which may be captured as part of your online profile. We also use it to send through our optional promotional campaigns and/or assisting the customer in case of any queries they might have with the Site/App.
Any social media ID (i.e. Facebook/Instagram/Google ID) which is used and/or captured to only identify that the user has logged into the Site/App using their respective login(s).
If a customer wishes to delete these details that we’ve captured, they can reach out and please contact us directly via email at contact@holsterfashion.ae or by postal mail with address at Office 404, Building B, Al Saaha Offices, Souk Al Bahar, Old Town Island, Burj Khalifa District, Downtown Dubai, United Arab Emirates, for the attention and receipt of All Things Nice Distribution FZ-LLC t/a holster® UAE ; and we will be pleased to assist you with your concerns and which request will be processed within reasonable time u[on receipt of such request and as required by law.
For any marketing materials, additional ‘un-subscription’ and opt-out options shall additionally apply.

Aggregate Data, Data Analytics and Behavioural Advertising.

As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you.

We may aggregate personal information and remove any identifying elements in order to analyse patterns and improve our marketing and promotional efforts, to analyse the use of our Site/App and affiliated tools to improve our content and service offerings, and to customise our Site/App or advertising content, layout, services, and we may appoint third parties to do this on our behalf, as set out in this Policy. We gather certain usage information like the number and frequency of visitors to our Site/App or advertisement communications. We only use such data in the aggregate. This collective data helps us to determine how much our customers use parts of our facilities and means, and do research on our users’ demographics, interests, and behaviour to better understand and serve you.

For example:

We use Google Analytics to help us understand how our customers use the Site. You can read more about how Google uses your Personal Information here: https://policies.google.com/privacy?hl=en.You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.
We share information about your use of the Site/App, your purchases, and your interaction with our ads on other websites with our advertising partners. We collect and share some of this information directly with our advertising partners, and in some cases through the use of cookies or other similar technologies (which you may consent to, depending on your location).

For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.

You can opt out of targeted advertising by:

FACEBOOK - https://www.facebook.com/settings/?tab=ads
GOOGLE - https://www.google.com/settings/ads/anonymous

Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/.

Within the United Arab Emirates: If you want to opt out of unsolicited telemarketing, spam, or malicious calls, you can do so by registering your number in the 'Do Not Call Registry’ (DNCR), in effect since September 2022.

Should you wish to have your telephone number registered on the 'Do Not Call Registry’, you can do so by sending a text to the following cellular network providers’ dedicated DNCR contact numbers. As per the telecommunication providers’ own information, please be advised as follows:

For Etisalat

To block calls, send an SMS to 1012 with the message 'DNCR'.
Next, you will receive a confirmation SMS from Etisalat.
Once you have registered your number, it will immediately be updated in the DNCR registry.
If you want to check if your number is registered in the DNCR, send an SMS to 1012 with 'Check IDNCR' to inquire about your cellular number's status.
According to Etisalat, DNCR ensures customers do not receive any promotional calls unless requested outside of business hours, which are from 9am to 6pm.

For Du

Send an SMS to 1012 with the message - 'Block'.
You will then receive an SMS confirming your number's registration in DNCR.
To check if your number is registered, send an SMS with the message 'Check' to 1012.

For Virgin Mobile

You can register your number in DNCR through the ‘Virgin Mobile’ app, available for Apple and Android devices.
According to Virgin Mobile, this is how customers can block unwanted calls:
1. If you are using an iOS device, tap on 'More' in the menu at the bottom of the home screen. For Android users, open your side menu by tapping on the icon on the top left.
2. Tap on 'Settings'.
3. Next, you will see 'Manage third party voice calls'. Enable the service by tapping on the toggle button and then tap on confirm to add your number to the Do Not Call Registry.

Be advised that: According to telecom providers, if you have given your consent to a company (including holster® UAE) to contact you, they can still call you to inform you about offers, promotions, and updates. Should you specifically wish to unsubscribe and opt out of any marketing communications from holster® UAE , please contact us directly via email at contact@holsterfashion.ae or by postal mail with address at Office 404, Building B, Al Saaha Offices, Souk Al Bahar, Old Town Island, Burj Khalifa District, Downtown Dubai, United Arab Emirates, for the attention and receipt of All Things Nice Distribution FZ-LLC t/a holster® UAE ; and we will be pleased to assist you with your request. If you are not satisfied with our response to your complaint, you have the right to lodge your complaint with the relevant data protection authority.

Automatic decision-making.

You have the right to object to processing based solely on automated decision-making (which includes profiling), when that decision-making has a legal effect on you or otherwise significantly affects you. We DO NOT engage in fully automated decision-making that has a legal or otherwise significant effect using user/customer data.

Our e-commerce services provider and processor, Shopify®, uses limited automated decision-making to prevent fraud that does not have a legal or otherwise significant effect on you. The same may apply to other third-party services providers, including payment gateway or banking services providers.

Services that include elements of automated decision-making include:

Temporary denylist of IP addresses associated with repeated failed transactions. This denylist persists for a small number of hours.
Temporary denylist of credit cards associated with denylisted IP addresses. This denylist persists for a small number of days.

Do Not Track. Please note that because there is no consistent industry understanding of how to respond to “Do Not Track” signals, we do not alter our data collection and usage practices when we detect such a signal from your browser.

Your rights.

You have the following rights which you may exercise in relation to the Personal Information we process about you:

to access a copy of your Personal Information;
to require us to correct inaccurate Personal Information;
to require us to delete your Personal Information;
to restrict our use of your Personal Information;
to object to our use of your Personal Information.

In respect of your right to see or access the personal information we hold about you: To receive a copy, please contact us directly via email at contact@holsterfashion.ae or by postal mail with address at Office 404, Building B, Al Saaha Offices, Souk Al Bahar, Old Town Island, Burj Khalifa District, Downtown Dubai, United Arab Emirates, for the attention and receipt of All Things Nice Distribution FZ-LLC t/a holster® UAE ; and we will be pleased to assist you with your concerns. In addition, you have certain rights regarding your personal information, subject to local laws and regulations. These include the following rights to:

rectify the information we hold about you;
erase your personal information;
restrict our use of your personal information;
object to our use of your personal information;
withdraw any consents you have provided for our use of your personal information;
receive your personal information in a usable electronic format and transmit it to a third party (right to data portability); and
lodge a complaint with your local data protection authority.

If you would like to discuss or exercise such rights with respect to your personal information (in so far as they are applicable), please contact us.

If you are concerned that any of the information we hold about you is incorrect, or out of date, please write to the address above to report your concerns and we will take appropriate steps to amend our records. Please note that where you wish to exercise any of these rights, you must first verify your identity to our satisfaction. We will likely require additional information from you in order to honour your requests.

Updating your Information.

Whenever possible, you can update your personal data directly within your Site User account settings section, subject to verification by holster® UAE. If you are unable to change your Personal Information, please contact us to make the required changes. If you wish for holster® UAE to update your information, please contact us in making such a request. We will retain your information for as long as may be needed to provide you access to your User account and or services of holster® UAE, as outlined above.

If you wish to close your Site User account, you can do so from your User account setting session or you can contact us. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our Terms of Service.

Links.

Our Site/Apps may contain links to other websites operated by other organisations that have their own privacy policies. Please make sure you read the terms and conditions and privacy policy carefully before providing any personal information on a website as we do not accept any responsibility or liability for websites of other organisations.

Notification of Changes to this Privacy Policy.

We may revise, amend, update or supplement this Privacy Policy when needed, to reflect necessary changes, i.e. changes in law, our personal data collection and usage practices, the features of or Site/App, or certain advances in technology. If we are going to use your personal information in a manner different from that stated at the time of collection, we will notify you. All changes will become effective when posted unless indicated otherwise. We encourage you to review this Privacy Policy periodically.