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PRIVACY POLICY OUR PRIVACY POLICY AT A GLANCE

 * WHO WE ARE. We are VStar Multimedia LLC (Virgin Megastore) we process your
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   customised communications. See more.
 * WHY WE USE YOUR DATA. We have legal standing to process your data for various
   reasons. The main reason is that we need to process your data to perform the
   contract that you accept with us when you register and when you make a
   purchase or enjoy any of our services or functionalities. We also use your
   data for other reasons, for example, to respond to your queries or to send
   you newsletters that you have asked to receive from us. See more.
 * WHO WE SHARE YOUR DATA WITH. We share your data with service providers who
   provide us with assistance or support, these being companies in the Azadea
   Group or third party providers, both inside and outside the European Union.
   See more.
 * YOUR RIGHTS. You have the right to access, rectify or delete your personal
   data. In certain cases, you are also entitled to other rights, such as, for
   example, to object to us using your data, or to transferring your data, as
   explained in depth below. See more.

We encourage you to read our full Privacy and Cookies Policy below to understand
in depth the manner in which we will use your personal data and your rights over
your data.


BEFORE YOU START…

 * In this Privacy and Cookies Policy, you will find all relevant information
   applicable to our use of our users' and clients' personal data, regardless of
   the channel or means of Virgin Megastore in Kuwait that you use to interact
   with us.
 * We are transparent about what we do with your personal data, to help you to
   understand the implications of the way in which we use your data, and the
   rights you are entitled to in relation to your data: us.
   * We permanently make available for you all the information included in this
     Privacy and Cookies Policy, that you can check when you consider
     appropriate, and in addition,
   * you will also find further information on how we use your data as you
     interact with us.
 * These are some terms we regularly use in this Privacy and Cookies Policy:
   * When we speak about our Platform, we refer, in general, to any of the
     channels or means you may have used to interact with us. The main ones are:
     * Our Website, www.virginmegastore.ae
     * Our Virgin Megastore App, this is, including both the mobile application
       you installed on your mobile device and others we may use in our stores.


1. WHO IS THE CONTROLLER OF YOUR DATA?

 * [VSTAR MULTIMEDIA LLC (Virgin Megastore)] ("the SELLER"):
   * Postal address: O-14 Tower, P1, Abraj Street, Business Bay, Dubai, UAE


2. WHY WE PROCESS YOUR PERSONAL DATA

Depending on the purpose for which we process your data from time to time, as
explained above, we need to process one or other data, which will in general be,
depending on each case, as follows:

 * your identity data (for example, your name, surname, language and country
   from which you interact with us, contact data, etc.);
 * economic and transactions information (for example, your payment or card
   data, information on your purchases, orders, returns, etc.);
 * connection, geolocation and/or browsing data (if you interact with us from
   your mobile phone, for example);
 * commercial information (for example, if you have subscribed to our
   newsletter),
 * information about your tastes and preferences.

Remember that, when we ask you to fill in your personal data to give you access
to any functionality or service of the Platform, we will mark certain fields as
compulsory, since this is information that we need to be able to provide the
service or give you access to the functionality in question. Please take into
account that, if you decide not to make such data available to us, you may be
unable to complete your user registration or may not be able to enjoy those
services or functionalities.

Depending on how you interact with our Platform, i.e., depending on the
services, products or functionalities that you wish to enjoy, we will process
your personal data for the following purposes:

PURPOSE + info To manage your registration as user of the Platform If you decide
to become a registered user of our Platform, Virgin Megastore needs to process
your data to identify you as a user of the Platform and grant you access to its
various functionalities, products and services available to you as a registered
user. You may cancel your registered user account by contacting us through
Customer Support. For the development, performance and execution of the purchase
or services contract that you executed with Us on the Platform This purpose
includes We will process your data, mainly:

To contact you for updates or informative notices related to the contracted
functionalities, products or services, including quality surveys and to be able
to establish the degree of customer satisfaction with the provided service;

To manage payment of the products that you purchase, regardless of the payment
procedure used. For example:

If on purchasing any of our products through the Website or the App, you opt to
activate the functionality of save your card data for future purchases, we need
to process the indicated data for activation and development of that
functionality. Consent to the activation of this functionality enables your
autocompleted payment data to appear in subsequent purchases so that you do not
need to introduce them in each new process, and these data will be deemed valid
and effective for subsequent purchases. You may change or cancel your cards at
any time through the section on payment information of your Website registered
user account.

Activate the necessary arrangements in order to control and prevent potential
fraud against you and against us during the purchase process. If we consider
that the transaction can be fraudulent, this processing may cause the blocking
of the transaction.

To manage potential returns after you have purchased and manage requests of
availability information for articles, reservations of products through the
Platform, depending on the availability of such options from time to time.

For invoicing purposes and to make available to you the tickets and invoices of
the purchases you have made through the Platform.

To ensure that you are able to use other available functionalities or services,
such as the purchase, management and use of the Gift Card or of the Gift
Voucher. To meet requests or applications that you make through the Customer
Services channels We only process the personal data that are strictly necessary
to manage or resolve your request or application. For marketing purposes. Virgin
Megastore will process your data, mainly, for:

If and when you subscribe to our Newsletter, Virgin Megastore will process your
personal data to manage your subscription, including to send customised
information on our products or services through various means (such as e-mail or
SMS). Virgin Megastore may also make available to you this information through
push notifications in case you have activated them in your mobile device.

Accordingly, please take into account that this data processing implies analysis
of your user or customer profile to establish your preferences and therefore
which products and services are most fit to your style when sending you
information. For example, based on your purchases and browsing history (i.e.,
depending on the articles that you clicked), Virgin Megastore will make you
suggestions on products that Virgin Megastore believes may interest you and, if
you are a registered user, we will provide you with the "recover cart "
functionality.

Remember that you may unsubscribe from the Newsletter at any time without cost
through the "Newsletter" section of the Platform, in addition to through the
instructions that we provide you with in each notice. If you do not want to
receive push notifications, you can deactivate this option in your mobile
device.

To perform promotional actions (for example, for the organization of
competitions or to send the list of items stored to the e-mail you designate).

To disseminate in the Platform or through our channels in the social networks
photographs or pictures that you shared publicly, provided that you expressly
give Virgin Megastore your consent for the purpose. Analysis of usability and
quality to improve our services If you access our Platform, Virgin Megastore
informs you that it will treat your browsing data for analytic and statistic
purposes, i.e., to understand the manner in which users interact with the
Platform and thus be capable of introducing improvements in the Platform.

In addition, Virgin Megastore occasionally performs quality surveys and actions
to know the degree of satisfaction of our customers and users and detect those
areas in which we may improve.


3. HOW WE ARE LEGALLY PERMITTED TO PROCESS YOUR DATA?

The legal terms on which we are permitted to process your personal data also
depends on the purpose for which we process them, as explained in the following
table:

PURPOSE Legal standing To manage your Platform user registration Virgin
Megastore processes your data because this is necessary on the terms regulating
the use of the Platform. In other words, for you to be able to register as a
user on the Platform, Virgin Megastore needs to process your personal data,
since it would otherwise be unable to manage your registration. Development,
performance and making of the purchase or services contract We process your data
because their processing is necessary for us to make the purchase or services
contract with you.

Certain processing of data related to the purchase process is activated only
because you request or authorise it, as is the case of the storage of payment
(card) data for future purchases. In this case, our processing of your data is
supported by your own consent.

We consider that we have a legitimate interest to carry out the necessary
verifications to detect and prevent potential fraud when you make a purchase. We
understand that the processing of these data is positive for all the
participating parties when a purchase is paid and in particular for you, since
this allows us to establish measures to protect you from fraud attempts by third
parties. Customer Service We consider that we have legitimate interest in
answering the requests or queries raised by you through the existing different
contact channels. We understand that the processing of these data is also
beneficial to you to the extent that it enables us to assist you adequately and
answer to the consultations raised.

When you get in touch with us, in particular, for the management of incidents
related to your order or the product/service acquired through the Platform, the
processing of your data is necessary to perform the purchase contract.

When your query is related to the exercise of your rights on which we inform you
below, or to claims on our products or services, we are legally permitted to
process your data for compliance with our legal obligations. Marketing Virgin
Megastore is legally permitted to process your data for marketing purposes due
to the consent that you give it, for example when you accept receiving
customized information through multiple channels, when authorizing the sending
of push notifications in your mobile device or to publish your pictures on the
Platform or on the social networks' channels. In order to show you customised
information. Virgin Megastore considers that has a legitimate interest to
conduct a profiling with the information that it has about you (such as your
browsing, preferences or purchase history) and the personal data that you have
provided it, such as the age range or language, since Virgin Megastore
understands that the data processing of these data is also beneficial to you
because it allows you to improve your user experience and access the information
in accordance with your preferences. Analysis of usability and quality We
consider that Virgin Megastore has a legitimate interest in analysing the
Platform usability and the user's satisfaction degree, since we understand that
that the processing of these data is also beneficial for your because the
purpose is to improve the user experience and provide a higher quality service.


4. HOW LONG WILL WE KEEP YOUR DATA?

The time for which we will keep your data will depend on the purposes for which
we process them, as explained below:

PURPOSE Time for which the data are kept To manage your Platform user
registration Virgin Megastore will process your data for the time during which
you remain a registered user (meaning, until you decide to unsubscribe).
Development, performance and execution of the purchase or services contract We
will process your data for the time necessary to manage the purchase of the
products or services that you buy, including potential returns, complaints or
claims related to the purchase of the product or service in question.

Sometimes, we will only process the data until the time when you decide, as is
the case of payment (card) data that you requested us to store for future
purchases. Customer Support We will process your data for the time necessary to
meet your request or application. Marketing Virgin Megastore will process your
data until you unsubscribe or cancel your subscription to the newsletter.
Analysis of usability and quality Virgin Megastore will process your data
occasionally for the time during which we proceed to carry out a specific
quality action or survey or until it anonymise your browsing data.

Notwithstanding the fact that we will process your data for the time strictly
necessary to achieve the purpose in question, we will subsequently keep them
duly stored and protected for the time during which liability may arise for
their processing, in compliance with legislation in force from time to time.
Once each of the potential actions is time-barred we will proceed to delete the
personal data.


5. DO WE SHARE YOUR DATA WITH THIRD PARTIES?

To achieve the purposes mentioned in this Privacy and Cookies Policy, We must
give access to your personal data to entities of Azadea Group and to third
parties that provide us with support in the services that we offer your, i.e.:

 * financial institutions,
 * anti-fraud detection and prevention entities,
 * technological service providers,
 * logistic, transport and delivery partners and service providers,
 * providers of customer support related services,
 * advertising and marketing related partners and service providers.

For service efficiency purposes, some of these providers are located in
territories outside the European Economic Area that do not offer a level of data
protection comparable to that of the European Union, in other words, the United
States of America. In such cases, we inform you that we will transfer your data
with adequate safeguards and always keeping your data safe

 * Some providers are certified Privacy Shield, which certification you may
   consult through the following link: https://www.privacyshield.gov/welcome
 * With other providers, we have agreed Standard Contractual Clauses approved by
   the EU Commission, the content of which you may consult through the following
   link: https://ec.europa.eu

In addition, We inform you that we need to share your data with Azadea Group
Holding SAL, located in Lebanon, for compliance with the obligations of the
parent companies.


6. WHAT YOUR RIGHTS ARE WHEN MAKING YOUR DATA AVAILABLE TO US

We undertake to keep your personal data confidential and to ensure that you may
exercise your rights. Bearing that in mind, we have agreed that you may exercise
your rights free of charge by writing us an e-mail to
(hello@virginmegastore.ae), simply informing us of the reason for your request
and the right that you wish to exercise. If we consider this necessary to be
able to identify you, we may request you to provide a copy of a document
evidencing your identity.

In particular, notwithstanding the purpose or legal basis we use to process your
data, you have the following rights:

 * To request access to your personal data that we hold. We remind you that
   where you are a Platform registered user you may also consult this
   information in the relevant section of your online account.
 * To request that we rectify the personal data that we hold. Please bear in
   mind that if you are a registered user on the Platform, you may also access
   the relevant personal data section of your online account to change or update
   your personal data. In any case, please take into account that, on actively
   making your personal data available to us through any procedure, you
   guarantee that they are true and accurate and you undertake to notify to us
   any change or modification of your data. You will be liable for any loss or
   damage caused to the Platform or to the person responsible for the Platform
   or to any third party by reporting erroneous, inaccurate or incomplete
   information in the registration forms. Please remember that, as a general
   rule, you must provide us only with your own data, not with those of third
   parties, other than to the extent otherwise permitted in this Privacy and
   Cookies Policy.
 * To request that we erase your personal data to the extent that they are no
   longer necessary for the purpose for which we need to keep processing them,
   as we have explained above, or when we are no longer legally permitted to
   process them.
 * To request that we cancel or limit the processing of your personal data,
   which entails that in certain cases you can request us to temporally suspend
   the processing of the data or that we keep them longer that necessary.

If you have given us your consent to process your data for any purpose, you also
have the right to withdraw such consent at any time. Some of the circumstances
in which you may withdraw your consent are detailed in section 2 where we
explain for which purposes we process your data.

When we are legally permitted to process your data due to your consent or to for
the purposes of a contract, as explained in section 3, you will also have the
right to request the portability of your personal data. This means that you will
have the right to receive the personal data that you made available to us in a
structured, commonly used and machine-legible format, to be able to transmit
them to another entity directly without impediments on our part.

In addition, where the processing of your data is based on our legitimate
interest, you will also have the right to object to the processing of your data.


7. CHANGES TO THE PRIVACY AND COOKIES POLICY

We may amend the information contained in this Privacy and Cookies Policy when
we consider this appropriate. Should we do so, we will notify you by various
procedures through the Platform (for example, through a banner, a pop-up or a
push notification), or we may even send you a notice to your e-mail address when
the change in question is relevant to your privacy, for you to be able to review
the changes, assess them and, as the case may be, object or unsubscribe from any
service or functionality. In any case, we suggest you to review this Privacy and
Cookies Policy from time to time in case minor changes are made or we make any
interactive improvement, taking the opportunity that you will always find it as
a permanent point of information on our Website and our App.


8. INFORMATION ON COOKIES

We use cookies and similar devices to facilitate your browsing in the Platform,
understand how you interact with us and, in certain cases, to be able to show
you advertisements in accordance with your browsing habits. Please read our
Information about Cookies to understand with greater detail the cookies and
similar devices that we use, their purpose and other information of interest.

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