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The First Group Hospitality is committed to protecting your privacy and developing technology that gives you a powerful and safe online experience. This Statement of Privacy applies to The First Group Hospitality’s family of websites and those of its affiliates and governs data collection and usage. By using The First Group Hospitality website, you consent to the data practices described in this statement.

COLLECTION OF YOUR PERSONAL INFORMATION
The First Group Hospitality collects personally identifiable information, such as your e-mail address, name, home or work address or telephone number. The First Group Hospitality also collects anonymous demographic information, which is not unique to you, such as your postcode, age, gender, preferences, interests and favourites.

There is also information about your computer hardware and software that is automatically collected by The First Group Hospitality. This information can include: your IP address, browser type, domain names, access times and referring website addresses. This information is used by The First Group Hospitality for the operation of the service, to maintain quality of the service, and to provide general statistics regarding the use of The First Group Hospitality website.

The First Group Hospitality encourages you to review the privacy statements of websites you choose to link to from The First Group Hospitality so that you can understand how those websites collect, use and share your information. The First Group Hospitality is not responsible for the privacy statements or other content on websites outside of The First Group Hospitality and The First Group Hospitality family of websites.

GENERAL USE OF YOUR PERSONAL INFORMATION
The First Group Hospitality collects and uses your personal information to operate The First Group Hospitality website and deliver the services you have requested. The First Group Hospitality also uses your personally identifiable information to inform you of other products or services available from The First Group Hospitality and its affiliates. By completing and sending an enquiry form through this website or other The First Group Hospitality websites, you are providing explicit permission to be contacted by email, SMS or telephone about The First Group Hospitality’s offerings and promotions and agreeing to our having possession of and retaining any information that you provide to us. Upon initial contact, you will always be given an opportunity to opt out of future communications. You may also opt out using the unsubscribe function in the email you receive from us. The First Group Hospitality may also contact you via surveys to conduct research about your opinion of current services or of potential new services that may be offered.

The First Group Hospitality does not sell, rent or lease its customer lists to third parties. The First Group Hospitality may, from time to time, contact you on behalf of external business partners about a particular offering that may be of interest to you. In those cases, your unique personally identifiable information (e-mail, name, address, telephone number) is not transferred to the third party. In addition, The First Group Hospitality may share data with trusted partners to help us perform statistical analysis, send you email or postal mail, provide customer support, or arrange for deliveries. All such third parties are prohibited from using your personal information except to provide these services to The First Group Hospitality, and they are required to maintain the confidentiality of your information.

The First Group Hospitality does not use or disclose sensitive personal information, such as race, religion, or political affiliations, without your explicit consent.

The First Group Hospitality keeps track of the websites and pages our customers visit within The First Group Hospitality family’s websites, in order to determine which The First Group Hospitality products and services are the most popular. This data is used to deliver customised content and advertising to customers and potential customers of The First Group Hospitality whose behaviour indicates that they are interested in a particular subject area.

The First Group Hospitality websites will disclose your personal information, without notice, only if required to do so by law or in the good faith belief that such action is necessary to: (a) conform to the edicts of the law or comply with the legal process served on The First Group Hospitality or the site; (b) protect and defend the rights or property of The First Group Hospitality; and, (c) act under exigent circumstances to protect the personal safety of users of The First Group Hospitality website, or the public.

EUROPEAN UNION USERS
Legal basis under EU General Data Protection Regulation for processing personal information of EU residents (“Personal Information”).

Where you have consented to data processing, your consent provides the legal basis to process your Personal Information. You have the right to withdraw consent at any time.

We may also process your Personal Information on the basis of contractual necessity to perform a contract we have with you. For example, when we process your credit card details when you provide them to make a payment.

We may also process your Personal Information on the basis of our legitimate interests, such as providing and improving our services. For example, The First Group Hospitality has a legitimate interest in understanding your website visit history so we can assess your interests and provide a better experience. We also have a legitimate interest in providing and developing features to provide to our users.

Where we rely on legitimate interests to process your Personal Information, you have the right to object to such processing. You can contact us at inquiries@tfghospitality.com to object to additional forms of processing.

GCC USERS
We process your Personal Information in accordance with the applicable laws, including the UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data and other relevant regulations. The processing of your Personal Information is carried out on one or more of the following legal bases:

• Consent: Where you have explicitly consented to the processing of your Personal Information, such consent shall constitute the legal basis for processing. You retain the right to withdraw your consent at any time by notifying us via the contact details provided below. Please note that the withdrawal of consent shall not affect the lawfulness of processing carried out prior to the withdrawal.
• Contractual Necessity: In cases where processing is necessary for the performance of a contract to which you are a party, or in order to take steps at your request prior to entering into a contract, we process your Personal Information based on the necessity of such processing. For example, when you provide us with payment information to facilitate a transaction, the processing of your data is required to fulfill the contractual obligations between you and us.
• Legitimate Interests: We may also process your Personal Information based on our legitimate interests, provided that such interests are not overridden by your fundamental rights and freedoms. Our legitimate interests include, but are not limited to, improving and enhancing our services, understanding user preferences and behavior, and developing new features for our users. For example, we may analyze your website usage patterns to improve user experience and optimize service offerings.

We are committed to ensuring that your Personal Information is processed in a transparent, secure, and lawful manner in line with the UAE’s Federal Decree-Law No. 45 of 2021 and other applicable regulations. For further information regarding your rights or to exercise any of them, please contact us at inquiries@tfghospitality.com.

USE OF COOKIES
The First Group Hospitality websites use cookies (small files stored on your browser), web beacons, pixels and device identifiers (collectively also known as “cookies”) to help us personalise your online experience. A cookie is a text file that is placed on your hard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you.

One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to tell the web server that you have returned to a specific page. For example, if you personalize The First Group Hospitality pages, or register with The First Group Hospitality or its family of websites or services, a cookie helps The First Group Hospitality to recall your specific information on subsequent visits. This simplifies the process of recording your personal information, such as billing addresses, shipping addresses, and so on. When you return to the same The First Group Hospitality website, the information you previously provided can be retrieved, so you can easily use The First Group Hospitality features that you customised. You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can modify your browser settings to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of The First Group Hospitality services or its websites that you visit. (a) third parties may use cookies, web beacons, and similar technologies to collect or receive information from our website and elsewhere on the internet and use that information to provide measurement services and target ads, (b) Users can opt-out of the collection and use of information for ad targeting anytime by going to www.aboutads.info/choice and exercise their choice.

SECURITY OF YOUR PERSONAL INFORMATION
The First Group Hospitality secures your personal information from unauthorised access, use or disclosure. The First Group Hospitality secures the personally identifiable information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure. When personal information (such as a credit card number) is transmitted to other websites, it is protected through the use of encryption, such as the Secure Socket Layer (SSL) protocol.

DATA PROTECTION
At The First Group Hospitality, we take your privacy seriously and are committed to protecting your personal information. In the unlikely event of a data breach, we will promptly investigate and work to contain it. If the breach affects your data, we will notify you with details about what happened, how it might impact you, and what steps we are taking to resolve it. We will also advise you on actions you can take to protect yourself, such as changing passwords or monitoring accounts. As part of our commitment to safeguarding your information, we follow strict processes to verify your identity and secure access to your data. For example, we use One-Time Passwords (OTPs) to authenticate sensitive transactions and changes to your account. Additionally, we may require two-factor authentication (2FA) for added security, ensuring that a second layer of verification such as a confirmation through your registered phone or email is completed before granting access. We also employ additional safeguards, such as session timeouts to automatically log you out of your account after a period of inactivity, encryption of sensitive data during transmission, and monitoring tools to detect suspicious login attempts. For instance, if unusual activity is detected—such as a login from a new device or location—you may be required to confirm your identity before proceeding. If necessary, we will notify the relevant authorities and work with any third-party partners involved to address the issue. Going forward, we will review and strengthen our security measures to help prevent similar incidents. We encourage you to remain vigilant and contact us if you notice any suspicious activity on your account.

RETENTION
We will retain your personal information for the period necessary to fulfil the purposes outlined in this Privacy Notice unless a longer retention period is required or permitted by law.

REFERRAL PROGRAMS
Should you engage in our referral program to tell an individual about The First Group Hospitality, we will ask you for their name, email address and phone number. You must ensure you have the person’s permission to do so for the purposes detailed in this Privacy Notice. We will contact them by email and/or phone number to discuss The First Group Hospitality’s product offering. The First Group Hospitality stores this information for the sole purpose of following up on the contact request and tracking the success of our referral program. Referred individuals may contact us at inquiries@tfghospitality.com to request that their information be deleted from our database.

USER RESPONSIBILITY FOR ACCOUNT SECURITY
Users are solely responsible for maintaining the confidentiality of their account credentials and ensuring the security of the devices they use to access our services. This includes the use of strong passwords, enabling two-factor authentication, and being vigilant against potential security threats. While we implement robust security measures, we cannot be held liable for any unauthorized access or loss of data arising from user actions, such as sharing credentials, using unsecured devices, or neglecting to secure their accounts. Users are encouraged to report any suspicious activity promptly to mitigate potential risks.

MINORS
The First Group Hospitality does not knowingly solicit or collect personal information from anyone under the age of 18. If you are under 18, do not enter information on this website or engage our services. You can enter your information only under the supervision of a parent or guardian. If you believe a child of yours under the age of 18 has entered personal information, please contact us to have the data removed.

CHANGES TO THIS STATEMENT
The First Group Hospitality will occasionally update this Statement of Privacy to reflect company and customer feedback. Additionally, The First Group Hospitality reserves the right to update the statement at any time without prior notice. The First Group Hospitality encourages you to periodically review this Statement to remain informed as to how The First Group Hospitality is protecting and using your information.

INQUIRIES RESPONSE
The First Group Hospitality strives to respond to all inquiries within 48 hours during regular business hours, from 9:00 AM to 5:30 PM, Monday to Friday, excluding public holidays such as New Year’s Day, National Day, etc. Inquiries received outside of these hours or on public holidays will be addressed on the next business day. In cases of force majeure (such as natural disasters, strikes), response times may be affected. If significant delays occur, we will make reasonable efforts to notify users.

CONTACT INFORMATION
The First Group Hospitality welcomes your comments regarding this Statement of Privacy. If you believe that The First Group Hospitality has not adhered to this Statement, please contact The First Group Hospitality at inquiries@tfghospitality.com. We will use commercially reasonable efforts to promptly determine and remedy the problem.