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Privacy Policy

Viya App: Global Privacy Notice
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Dubai Golf LLC ("DG", "we", "our" or "us") respects your privacy and is committed to protecting your Personal Information (as defined under Section 1 – Definitions). This privacy notice is designed to help you understand how we collect, use, disclose, transfer, store and otherwise process Personal Information relating to individuals who access, use or interact with the Viya App and related services.

We encourage you to read the whole notice. Alternatively, if you wish to read about specific privacy practices that interest you, please click on the relevant links below.

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1 Definitions

For the purposes of this privacy notice:

Partner means a third-party business, merchant, service provider or organisation participating in the Viya ecosystem.

Personal Information means personal information is any data relating to an identified or identifiable natural person who can be directly or indirectly identified from that data.

Services means all products, services, memberships, rewards, reservations, bookings, events, experiences and benefits made available through Viya, including services offered by DG, Wasl Group entities and Partners.

User means a registered holder of a Viya account.

Wasl Group means Wasl LLC and its affiliates, subsidiaries and associated companies.

 

2 The purpose of this privacy notice

 

2.1 Identity

DG is a company incorporated in Dubai, in the United Arab Emirates and forms part of Wasl Group.

DG owns and operates the Viya mobile-application (“Viya” or “Viya App”), a digital loyalty and rewards platform that enables Users to access products, services, benefits, promotions, memberships, events and experiences offered by DG businesses, other Wasl Group entities and participating third-party partners.

DG processes your Personal Information in our capacity as a controller. This means that DG is responsible for deciding how we hold and use your Personal Information and ensuring that we comply with relevant data protection laws when processing your Personal Information.

Contact Details:

Dubai Golf LLC

P.O. Box 24040

Dubai, United Arab Emirates

Email: customerservice@viya.ae

 

2.2 This privacy notice

This privacy notice applies to the Viya App.

Please note DG may publish additional privacy statements that apply to:

• our operations in specific countries to help ensure our compliance with local data protection requirements; or

• specific products or services that we offer from time to time.

If an additional privacy statement is relevant to you because of the way in which you engage with us and there is a conflict between the information set out in this privacy notice and the additional privacy statement, then the additional privacy statement will take precedence over the information set out in this privacy notice.

For the purposes of this privacy notice, references to DG’s website mean the Viya website (Viya.ae | viya.ae).

 

2.3 Updating this privacy notice

DG will provide this privacy notice through the “YOUR PRIVACY” link which is presented wherever Personal Information is collected. DG may update this privacy notice at any time. DG will take reasonable measures to communicate any substantial changes that we make to this privacy notice to you – for example, by posting an updated version of this privacy notice on our website, or by sending you an updated version of this privacy notice by email. We also encourage you to check this page from time to time for any changes.

This privacy notice is dated 4th September 2026.

 

2.4 Who does this privacy notice apply to?

This privacy notice applies to any individual whose Personal Information is processed by DG through or in connection with Viya, including:

• Users;

• prospective users;

• recipients of marketing communications;

• individuals included in bookings or reservations;

• co-players, guests and dependants;

• individuals contacting customer support;

• individuals whose information is shared with DG by Partners; and visitors to the Viya website.

 

3 How We Use Personal Information

 

We use Personal Information for the following purposes:

• creation and administration of Viya accounts;

• provision and operation of the Services;

• management of memberships, subscriptions and rewards;

• processing bookings, reservations and purchases;

• payment processing;

• customer support and communications;

• administration of loyalty programmes;

• fraud prevention and security;

• service improvement and analytics;

• marketing and promotional activities;

• compliance with legal obligations; and

• establishment, exercise or defence of legal claims.

 

4 Personal Information we collect

 

4.1 Information you provide directly

We may collect Personal Information that you voluntarily provide to us, including:

Identity Information

• full name;

• title;

• gender (where voluntarily provided);

• nationality;

• date of birth.

Contact Information

• email address;

• telephone number;

• residential address;

• mailing address.

Account Information

• username;

• password;

• account preferences;

• communication preferences;

• loyalty programme data.

Booking and Reservation Information

• reservation details;

• attendance details;

• event registrations;

• membership information;

• guest information;

• player information.

Payment Information

• payment card details;

• billing information;

• transaction history.

Payment card processing may be performed by authorised third-party payment service providers. DG does not store full payment card details unless necessary and permitted by applicable law.

Customer Communications

Information contained in:

• emails;

• support requests;

• complaints;

• surveys;

• call recordings;

• social media interactions;

• online chats.

Identification Documents

Where required for a specific Service, legal obligation or verification process, we may collect information contained in identification documents such as:

• passports;

• Emirates ID cards;

• residency permits; or

• other government-issued identification documents.

 

4.2 Information About Other Individuals

Certain Services may require you to provide Personal Information relating to other individuals such as:

• co-players;

• guests;

• dependants;

• family members;

• beneficiaries of a booking;

• or any other beneficiary of the Services.

By providing such information, you confirm that you are authorised to do so and that you have informed those individuals of the contents of this Privacy Notice where required by law.

 

4.3 Information Automatically Collected

When you access or use Viya, we may automatically collect certain information including:

Device Information

• device type;

• operating system;

• browser type;

• application version;

• language settings;

• device identifiers.

Usage Information

• pages viewed;

• features used;

• searches performed;

• clicks and interactions;

• access dates and times.

Log Information

• IP address;

• network information;

• error logs;

• diagnostic information.

Location Information

Where you grant permission through your device settings, we may collect precise or approximate location information to provide location-based Services and recommendations.

Cookies and Similar Technologies

DG and its service providers may use cookies, software development kits (SDKs), pixels, local storage technologies and similar technologies to collect information about how Users interact with Viya and the Viya / DG website(s). These technologies may be used to enable functionality, remember preferences, authenticate Users, measure performance, analyse usage trends, improve Services and support marketing activities.

Where required by applicable law, we will obtain consent before deploying non-essential cookies or similar technologies.

 

4.4 Information Received from Third Parties

We may obtain Personal Information from:

• Partners;

• Wasl Group entities;

• payment service providers;

• strategic partners;

• marketing partners;

• social media providers;

• reservation platforms;

• publicly available sources; and

• fraud prevention and security service providers.

Where Services are provided by a Partner, the Partner may independently collect and process your Personal Information in accordance with its own privacy notice. Depending on the circumstances, DG and the relevant Partner may each act as independent controllers of Personal Information. We encourage you to review the privacy notices of any Partner with whom you interact through Viya.

We may combine information obtained from third parties with information already held by us in order to improve the Services, verify information, investigate complaints, prevent fraud and enhance the User experience.

 

5 Legal Basis for Processing

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DG may process your Personal Information in different ways – including by collecting, recording, organising, storing, analysing, modifying, extracting, sharing, deleting and/or destroying it.

We will only process Personal Information where a valid legal basis exists to do so under applicable data protection laws. The legal basis relied upon may vary depending on your location and the specific processing activity. Accordingly, we may rely on one or more of the following legal bases:

Contractual Necessity

Processing is necessary to perform a contract with you or to take steps at your request before entering into a contract.

Consent

You have provided your consent to the processing of your Personal Information for one or more specific purposes.

Legal Obligation

Processing is necessary to comply with a legal or regulatory obligation.

Legitimate Interests

Processing is necessary for our legitimate interests or those of a third party, provided that such interests are not overridden by your rights and freedoms.

Recognised Legitimate Interests

Processing is necessary for a recognised legitimate interest, including the prevention, detection or investigation of crime, safeguarding vulnerable individuals, responding to emergencies or making certain disclosures to persons carrying out public tasks or official functions.

Public Interest

Where permitted by law, processing may be carried out for reasons of public interest.

Vital Interests

Processing is necessary to protect the vital interests of an individual.

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6 Purposes of Processing

 

6.1 DG may process Personal Information for the following (but not limited to) purposes:

Purpose

Examples

Account Creation and Management

Creating and maintaining your Viya account

Provision of Services

Reservations, bookings, memberships, rewards, purchases and customer support

Payment Processing

Processing and administering payments and refunds

Customer Service

Responding to enquiries, complaints and requests

Communications

Service updates, reservation confirmations and account notifications

Marketing

Promotions, offers, newsletters and loyalty programme communications

Personalisation

Tailoring offers, recommendations and content

Analytics and Improvement

Understanding user behaviour and improving Services

Security and Fraud Prevention

Detecting and preventing fraud and misuse

Legal Compliance

Compliance with laws, regulations and court orders

Corporate Transactions

Mergers, acquisitions and restructuring

 

6.2 Failure to provide Personal Information to DG

If you tell us you do not want DG, DG and Wasl Group entities to use your information, DG, DG and Wasl Group entities will respect your wishes. Where we need to collect your Personal Information by law or in order to process your instructions, provide you with the Services or perform a contract we have with you and you decide not to provide that information when requested, we may not be able to carry out your instructions, provide the Services or perform the contract we have or are trying to enter into with you. In other circumstances where you choose not to provide us with your Personal Information we request, your decision not to provide us with your Personal Information may affect our ability to provide certain of the Services.

 

6.3 Consent

Where DG processes your Personal Information based on your consent, you have the right to withdraw your consent at any time. To withdraw your consent please email us at customerservice@viya.ae or, to stop receiving our marketing emails or updates, please click on the unsubscribe link in the relevant email you receive from us. Once DG has received notification that you have withdrawn your consent, we will no longer process your Personal Information for the purpose(s) to which you originally consented unless there is another legal ground for the processing. Please note that where DG relies on your consent to process your Personal Information and you choose to withdraw your consent, your decision may affect our ability to provide certain of our products and services.

Please note that when DG collects Personal Information in connection with a transaction, DG may extract some information about that transaction in an anonymous format. This anonymous information is used and analysed only at an aggregate level to help DG and all other Wasl group entities understand trends and patterns. None of this information is reviewed at an individual level. If you do not want your transaction details used in this manner, you can opt-out at the order or request page.

 

6.4 Does DG share your information with anyone else?

DG does not sell your information. However, DG may share your information in the following circumstances:

• where it is necessary or appropriate for the purposes for which we hold your information and we have a lawful basis for doing so, we share your relevant information between members of the Wasl Group;

• to operate our business efficiently, we require the assistance of various external service providers, particularly in relation to our IT systems and reservations functionalities. Some of these services (such as email hosting and data backups) involve the service provider holding and using your Personal Information. In each case where we share your information with one of our service providers, the service provider is required to keep it safe and secure and make sure it is properly protected. They are also not permitted to use your information for their own purposes;

• in connection with a sale or business transaction. If we sell our business or undergo another business transaction (such as a reorganisation, merger, joint venture, assignment, transfer, or other disposition of any or all portion of our business, assets, or stock, including in connection with any bankruptcy or similar proceedings), then your information may be shared with, or transferred to, a third party;

• to protect the rights, property and safety of members of the Wasl Group and others. Such information will be disclosed in accordance with applicable laws and regulations. This includes where we share information with other parties in the context of litigation discovery and in response to subpoenas and court orders; and

• we share your Personal Information with other third parties, such as relevant public and government authorities, including regulators and law enforcement bodies, where appropriate, including where we are required to do so to comply with legal or regulatory requirements or to respond to a request from such an authority.

 

7 Other important things you should know

 

7.1 Keeping Personal Information safe

DG intends to protect the quality and the integrity of Personal Information. DG has implemented appropriate steps, such as encryption for transmission of credit card numbers, to help maintain the security of our information systems and processes and prevent the accidental destruction, loss, or unauthorised disclosure of the Personal Information we process.

In addition, DG limits access to your Personal Information to those employees, agents, contractors and other third parties who have a business need to know. They will only process Personal Information on our instructions and they are subject to a duty of confidentiality.

DG has put in place procedures to deal with any suspected Personal Information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

While we strive to protect Personal Information, no transmission method or storage system can be guaranteed as completely secure.

 

7.2 Profiling and automated decision making

DG does not currently use profiling (where an electronic system uses Personal Information to try and predict something about you) or automated decision making (where an electronic system uses Personal Information to make a decision about you without human intervention).

Where automated decision-making or profiling is introduced in the future, DG will implement appropriate safeguards and provide any notices required under applicable data protection laws.

 

7.3 How long does DG keep Personal Information?

DG keeps your Personal Information for no longer than is necessary for the purposes described in this privacy notice and, in any event, no longer than we are permitted to under applicable law.

Our retention periods are based on the requirements of relevant data protection laws and the purpose for which the information is collected and used, taking into account legal and regulatory requirements to retain the information for a minimum period, limitation periods for taking legal action, good practice and our business purposes. In addition, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorised use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve such purposes through other means.

We will destroy or anonymise your Personal Information as soon as the purpose of collecting it, or the legal requirement pursuant to which are required to keep the Personal Information, has expired.

If you would like further details regarding applicable retention periods, please email us at customerservice@viya.ae.

 

7.4 Cross border transfers

The global nature of our business means that your personal information may well be transferred across national boundaries, including, potentially, to countries that do not require organisations by law to look after your personal information in the way in which you have come to expect in your own country. As a result, Personal Information may be transferred to and processed in countries outside your country of residence.

Where DG transfers your Personal Information across national boundaries, we will protect your Personal Information by ensuring that those transfers are made in compliance with all relevant data protection laws. These and all other transmissions will remain secure and under our control.

If you would like further details of how your Personal Information is protected when transferred from one country to another then please email us at customerservice@viya.ae.

 

7.5 Hyperlinks

Our website may provide links to third-party websites for your convenience. If you access those links, you will leave our website. We do not control those websites or their privacy practices, which may differ from ours. We do not endorse or make any representations about third-party websites. This privacy notice does not cover the Personal Information you choose to give to unrelated third parties. We encourage you to review the privacy notice of any company before submitting your Personal Information. Some third-party companies may choose to share their Personal Information with us; that sharing is governed by that third-party company's privacy policy.

 

7.6 Local differences

Whilst this privacy notice describes the data protection practices adopted by us generally local data protection laws may vary and our operations in some countries may mean that we are subject to different, or additional, local data protection requirements.

 

8 Your rights

 

8.1 Contacting DG and your rights

If you have any questions or complaints in relation to DG’s use of your Personal Information, please email us at customerservice@viya.ae

The rights available to you may vary depending on your location and the data protection laws applicable to the processing of your Personal Information. Subject to applicable law, you may have the right to require us to:

• provide you with further details on the use we make of your personal information;

• confirm whether we process Personal Information about you and (where this is the case) provide you with access to the Personal Information we hold about you;

• update any inaccuracies in the Personal Information we hold about you;

• delete any of your Personal Information that we no longer have a lawful ground to use;

• where processing is based on consent, stop that processing by withdrawing your consent (which you may do at any time);

• object to any processing based on our legitimate interests unless our reasons for undertaking that processing outweigh any prejudice to your data protection rights, or object to processing for direct marketing purposes;

• restrict how we use your Personal Information in certain circumstances; and/or

• transfer your Personal Information to you or to a third party in a standardised machine-readable format.

In certain circumstances, DG may need to restrict your rights to safeguard the public interest (for example, the prevention or detection of crime) and our interests (for example, the maintenance of legal privilege).

To exercise any of your rights, please email DG at customerservice@viya.ae. We will assess any request to exercise your rights on a case-by-case basis and we may ask you for proof of identity or other information before doing so. This is a security measure to ensure that Personal Information is not disclosed to any person who has no right to receive it. We will make a sincere effort to respond in a timely manner to your requests.

We also are obliged to keep your Personal Information accurate and up to date. Please help us to do this by advising us of any changes to your Personal Information.

Please note that if you ask us to delete your Personal Information, it may take us more time to delete your information from our back-up systems than it does from our active servers.

Please also note that if you ask us not to process your Personal Information and unsubscribe from our services such as mail alerts, we may need to keep some information in order to fulfil your request, for example, we will retain enough information about you to ensure that your preference not to receive direct marketing is respected in the future.

 

8.2 Your right to complain

If you are not satisfied with our use of your Personal Information or our response to any request by you to exercise your rights, or if you think that we have breached any relevant data protection laws, then you have the right to complain to the authority that supervises our processing of your Personal Information.

If you are unsure of the authority that supervises our processing of your Personal Information then please email us at customerservice@viya.ae.

Under UK data protection law, you also have the right to complain directly to us if you consider that we have infringed UK data protection law in connection with your Personal Information. If you would like to make a complaint, please email us at customerservice@viya.ae.

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