1- Definitions
Personal Data means any information that relates to an identified or identifiable natural person, whether directly or indirectly.
This includes, for example, your name, date of birth, contact details, nationality, loyalty programme ID, purchase history, device identifiers, location data, or any other information that can identify you.
Sensitive Personal Data (also referred to as Special Category Personal Data) means personal information revealing or relating to a person’s racial or ethnic origin, religious or philosophical beliefs, political opinions, trade-union membership, genetic or biometric data used for identification, health information, sexual orientation or behavior, or financial and government-issued identifiers (such as Emirates ID, passport, or tax number).
We do not intentionally collect or process Sensitive Personal Data unless required for a lawful purpose and with your explicit consent.
Processing means any operation performed on Personal Data, such as collection, recording, organization, storage, use, disclosure, transfer, or deletion, whether automated or otherwise.
Controller means Club Apparel LLC and its relevant Apparel Group entities that determine the purposes and means of Processing Personal Data.
Processor means any third party that Processes Personal Data on behalf of the Controller.
Disclosure means making Personal Data available to any third party other than the Controller or Processor.
Transfer means moving Personal Data from one jurisdiction to another for Processing purposes.
Legitimate Interest means an operational or business purpose pursued by Apparel Group that does not override your rights and freedoms.
Vital Interest means Processing required to protect an individual’s life or health.
2- What Information We Collect
We collect the following information from you when you register on our site, mobile application, loyalty programme, feedback forms, or when you fill out a form on physical/digital devices or kiosks:
• Mobile Number
• Email Address
We do not collect or retain your credit card or other financial details.
You can manage your cookie preferences via your browser settings or by clicking the “Cookie Settings” link on our website. Please note that disabling certain cookies may affect website functionality.
3- Use, Purpose and Means of Collection
Purpose of Collection
We collect Personal Data to operate and enhance our loyalty programme, fulfil your requests, improve services and customer experience, provide relevant offers and communications, and comply with applicable laws and regulatory requirements.
Means of Collection
We collect Personal Data directly from you (for example, during sign-up, purchases, surveys, customer support), automatically through our digital channels (as described above), and indirectly from Apparel Group affiliates, service providers, business partners, or publicly available sources to support programme operations, fraud prevention, and service improvements.
How We Use Your Information
Your information may be used to:
• Personalize your experience and respond better to your needs;
• Improve our website and customer service;
• Process transactions and loyalty benefits;
• Send you transactional, promotional, or informational communications (email/SMS/in-app notifications);
• Administer contests, promotions, or surveys;
• Share aggregate (non-personal) insights for analytics or service improvement;
• Provide and manage your loyalty membership and account;
• Fulfil legal or regulatory obligations.
• Other purposes including, providing you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information.
We do not use your credit card or other financial details.
Your personal information may be transferred to, stored, and processed in countries outside your country of residence (including UAE, GCC, and India). Where such transfers take place, we ensure that appropriate safeguards are in place (for example, standard contractual clauses, data-centre security, encryption) and that the data remains protected in accordance with applicable data protection laws.
We may use your Personal Data for profiling, segmentation, and automated decision-making to personalize offers, loyalty benefits, communications, and service enhancements.
4- How We Protect Your Information
We deploy reasonable technical and organizational security measures to protect your personal data, including encryption in transit and at rest, role-based access controls, regular security audits, vulnerability assessments, and independent reviews. However, no system can guarantee absolute security, and we cannot guarantee the security of your data beyond our reasonable efforts.
5- Your Rights
You consent and ensure that the personal data you share with us is accurate and, where necessary, kept up to date. You may access, rectify, and update your personal data directly through the functionalities provided on the Platform. You have an option to withdraw your consent by writing to us at
[email protected]. We may verify such requests before addressing them. Your withdrawal of consent may hamper your access to the Platform. You understand that we may take 30 days to address or notify you the reason for delay in addressing your request. We shall take all reasonable steps to address your requests for any amendments to your personal data.
You may, however, visit our site anonymously.
6- Third-Party Links
Our website or communications may contain links to third-party sites, which have their own privacy policies. We are not responsible for their content or activities, but we welcome feedback regarding such sites.
7- Retention Period
Your personal information will be retained by Apparel Group and its affiliates unless you request deletion in writing. Upon such request, we will delete or anonymize your information within 90 working days, unless legal or regulatory obligations require longer retention.
8- Marketing Communications and Opt-Out Option
You may opt out of receiving promotional or marketing communications from us at any time by clicking the “unsubscribe” link in such emails or by contacting us at
[email protected], specifying that you wish to opt out of marketing communications.
Please note that you may still receive transactional or service-related messages (such as account notifications) which are necessary for delivering the loyalty programme.
9– Children and Minors
Our services are not targeted to persons under the age of 16 (or such higher age as required in your country). We do not knowingly collect personal data from children below that age. If you believe we have collected such data without parental or guardian consent, please contact us so we may delete the information.
10- Withdrawal of Consent and Account Deletion
You may withdraw your consent or opt out of the loyalty programme, or opt to delete your account at any time by emailing us at
[email protected]. We will delete or anonymize your data within up to 90 working days, unless we are legally required to retain it (for example, for tax, audit, or regulatory reasons). After deletion, you will no longer be able to access the benefits of the loyalty programme.
11- Policy Updates
We may update this Privacy Policy and the Loyalty Programme Terms from time to time.
We will post the revised policy on our website, and the latest version will take effect when published.
12- Disclosure of Your Personal Data
We may disclose your Personal Data under the following limited circumstances, and only to the extent permitted or required by applicable law:
• When required by law, regulation, court order, or other lawful requests by public authorities (including government agencies, regulators, or law enforcement).
• In the good-faith belief that such disclosure is necessary to:
• Comply with a legal obligation;
• Performance of a contract with you.
• Protect and defend the rights, property, or safety of Apparel Group, its customers, or the public;
• Prevent, investigate, or take action regarding possible wrongdoing, fraud, or misuse related to our products or services;
• Protect against legal liability or our legitimate interests;
• Safeguard national security, public interest, or the sovereignty of the country in which the data is processed (for example, the sovereignty of the Kingdom of Saudi Arabia when processing within its territory).
• To competent authorities, regulators, auditors, or external advisors when required to fulfil our legal or contractual obligations.
13- Sharing of Your Personal Data / Information
We may share your Personal Data or Personal Information in the following situations, strictly in accordance with applicable data-protection laws:
• With Service Providers: We may share your Personal Data with trusted service providers who support us in operating our loyalty programme, analyzing usage, providing marketing or technical support, or communicating with you. These service providers are bound by contractual confidentiality and data-protection obligations.
• For Business Transfers: We may share or transfer your Personal Data in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or part of our business to another entity.
• With Business Partners and Group Companies: We may share your Personal Data with our business partners, affiliates, holding companies, subsidiaries, and other group entities of Apparel Group to offer you products, services, or promotions that may be of interest to you.
• With Other Users (Public Areas): When you voluntarily share information (such as reviews, feedback, or posts) in public or interactive areas of our platforms, such information may be viewed and used by others. Please exercise caution before disclosing personal information in such areas.
• With Your Consent: We may disclose your Personal Data for any additional purpose where you have provided your explicit consent.
We do not sell Personal Data to unauthorised third parties.
14- Your Consent
By selecting (Tick) the box below, you acknowledge that you have read and understood the Privacy Policy and Terms, including any amendments made from time to time, and you consent to the collection, processing, and use of your personal information in accordance with them.
I agree to the Privacy Policy and Terms of the Loyalty Programme.
Please note that your continued use of our website, mobile application, or loyalty programme will also be deemed as your consent to the updated terms.
15- Contact Us
If you have questions or requests regarding this policy, please contact us at:
CLUB APPAREL LLC
C/O Apparel FZCO
Jebel Ali Free Zone, Dubai, United Arab Emirates
Thank you for being a valued member of CLUB APPAREL and part of the Apparel Group family. We appreciate your trust and remain committed to safeguarding your privacy.
Warm regards,
Club Apparel Team
Apparel Group