Privacy Policy – 

Tafani LLC and each of our subsidiaries throughout the world (together, Tafani LLC, we or us or our) respect your right to privacy. This Privacy Policy summarises what personal information we may collect in UAE, how we may use this information and other important topics relating to your privacy and data protection.

This Privacy Policy applies to all websites and mobile applications operated by or on behalf of Tafani. It also applies to personal information Tafani may otherwise collect (i) through our products and services, (ii) when you interact with us by means other than Tafani websites or mobile applications, for example, in person, by telephone, or through our social media pages or other digital platforms or devices, and (iii) from our customers, contractors, distributors, suppliers, vendors and other business partners and prospective employees and contractors.

However, different Tafani websites, mobile applications, products and services have different purposes and features. If additional or different disclosures are required for a specific Tafani website, mobile application, product or service, then we will provide specific disclosures separately on, or with, the relevant website, mobile application, product or service. Such specific privacy disclosures, policies, or statements (Specific Privacy Statements) supplement, and from time to time may amend, this Privacy Policy.

By browsing or accessing our websites, mobile applications, social media pages and other digital platforms (together, the Sites), or using our products and services, you agree to this Privacy Policy (as amended from time to time) and consent to the collection, use and disclosure of your personal information as set out below.

Collection of personal information

• What is “personal information”?

When used in this policy, “personal information” has the meaning given to that term in the Privacy Act 1988 (Cth). Generally speaking, personal information refers to any information that can be used to personally identify you, or from which your identity can be reasonably determined.

• What kinds of personal information do we collect, use and hold?

The kinds of personal information that we collect, use and hold include:

• name
• age and date of birth
• gender
• contact details such as home and business address, phone number and email address
• social media account details
• delivery and collection details
• signature
• all other personal information you provide us when you visit, browse or shop on our Sites or at our stores, including through our rewards programs
• other information that is relevant to our functions and activities

If you are a candidate for employment or a prospective contractor, we may collect other personal information provided by you or your referees, such as employment and educational history.

In addition to the information set out above, we may also collect, use and hold other information from you. The kinds of information we collect, use and hold will depend on your interactions with us. This information may not necessarily be personal information because it does not identify you personally. However this information is normally retained with your personal information and may include:

• your shopping preferences and a list of products and services you have purchased from Tafani. This may include your shopping history, product types, specifications, sizes, dimensions, colours or other attributes of products and services we have provided to you or may provide to you in the future.
• information about how you interact with us, including technical data about your usage of our Sites, how you interact with our digital advertisement and promotions (such as content viewed or downloaded, features used, links clicked, Tafani promotional emails opened and dates and times of interactions).
• information we require to deliver, service or fulfil warranty obligations for products or services.
• transaction details such as payment method and where you shopped and information collected via our secure payment processing systems.
• your marketing preferences, including the type of marketing materials you wish to receive and the method of delivery (email, SMS, direct mail, or other).
• if you are a member of the Tafani rewards program, your membership number, and reward redemption history for Tafani special rewards or services;
• information you provide to us via our customer service centre, Sites, application forms, or directly to the Tafani team members in relation to our products and services.
• device and browser information when you use a computer, mobile phone, smart phone, tablet or other device to interact with us through our Sites. This information may include session cookies, your device IMEI number, IP address or MAC
• location information including precise real-time location information from your device and imprecise location information derived from your IP address or postal code. Tafani will not access precise real-time location information from your device unless you grant permission to do so.

• How do we collect personal information?

We usually collect information from you directly, unless it is unreasonable or impracticable to do so. Collection of your personal information can occur when you:

• register with us by creating an online account, or subscribing to our marketing programs.
• join the Tafani rewards program or any other loyalty program operated by us.
• access and use our Sites.
• make a purchase, submit orders, registrations, requests or applications for our products or services (by phone, in person or electronically via our Sites).
• communicate with us directly (by email, telephone, direct mail or any other means).
• interact with us during promotions, competitions, special events or subscribe to our newsletter.
• post a review or leave a rating on our Sites or complete our surveys.
• request an exchange, a return, a repair or a replacement of products.
• make inquiries about us or our products or services or contact us for any other reason so that we can process, deal with and respond to your queries or other issues including any complaints.
• provide information to us relating to an employment or contracting opportunity with us.

We may also collect personal information about you from the following third parties:

• online retailers and suppliers who provide or make available our products and services to you on our behalf.
• third party service providers who provide services or functions on our behalf, such as IT service providers, delivery service providers, mailing houses, our insurers and brokers and marketing agencies.
• third party sources and platforms, such as publicly and commercially available sources, social networking sites, information service providers and third party analytics providers to whom you have provided your personal information.
• if you are a candidate for employment or prospective contractor, your nominated referees (where you have authorised us to do so).

When you provide us with personal information about other individuals, you should make them aware of this Privacy Policy and obtain their consent to you providing their details to us.

• What happens if you do not provide your personal information to us?

You have choices about the personal information you provide to us. If you do not provide personal information that we request in connection with our activities, some or all of the following may occur:

• we may not be able to provide our products or services to you, to the requested standard or at all.
• we may be unable to communicate with you to provide information about products and services that you have purchased from us, or may intend to purchase in the future.
• we may be unable to tailor the content of our marketing communications to suit your preferences.
• your experience when interacting with us may be delayed or not as efficient as you may expect, or you may not be able to use or access certain features of our Sites.
• if you are a candidate for employment, we may not be able to process your application for a position at Tafani. 
• How we hold your personal information

We will hold your personal information in electronic form. If you provide information to us electronically we retain this information, and may combine or link such information with your personal information in our computer systems and databases. Our computer systems and databases include firewall protected computer folders and software programs, internet servers, and hosted internet storage solutions provided by third parties.

Why do we collect, use, hold and disclose your personal information?

We collect, use, hold and disclose your personal information as necessary for purposes directly related to our functions and activities or as otherwise described to you at the time of collection, including to (each a Purpose):

• allow you to create or manage an online account with us.
• create orders, transaction records, accounts, tax invoices or receipts.
• provide you with products and services that you have requested from us.
• provide your personal information to third parties that assist us in providing products and services you have requested, such as delivery service providers and fulfilment managers.
• communicate with you, including about products and services, competition results, special offers and events which might interest you (including any associated Tafani special offers and rewards).
• tailor how we provide and market our products and services to you, based on your purchase history, shopping preferences and personal information you have provided us.
• answer your questions and provide you with information or advice relating to our products and services, or consider and respond to complaints made by you.
• interact with you via social media and digital marketing (subject to you not opting-out of such communications).
• if you are a Tafani rewards program member, or a member of any other loyalty program operated by us, to provide the services relating to such membership, including accumulation and redemption of points and providing discounts and rewards.
• carry out administration, marketing, planning, fraud and loss prevention activities, procurement, product and service development.
• carry out quality control and research, analysis and tracking to improve the functionality of our Sites and the way we and our service providers provide products and services to you.
• comply with any applicable law, rule, regulation or any order, request or direction of any governmental, semi-governmental, judicial, quasi-judicial, regulatory, administrative or supervisory body or agency (Applicable Laws).
• address legal issues such as establishing, exercising or defending legal claims and detecting, preventing, and responding to violation of any agreement between you and Tafani, any Applicable Laws or other misuse of our Sites or services.
• if you are a candidate for employment or prospective contractor, assess your suitability for a position at Tafani.

We may also collect data about you on an aggregate and anonymous basis for any one or more of the above Purposes.

Do we use cookies or other web tracking systems?

A “cookie” is a file of information placed on your device when you visit a website. We use cookies to ensure a more streamlined online shopping experience, to identify and store your personal preferences without the need for you to save them and provide you with appropriate and relevant promotions. We may use temporary (session) cookies or permanent cookies when you access our Sites, which allows us to recognise your region IP address and browser, and track the web pages you have visited. We may collect this information in relation to your website account, as well as on an anonymous basis. You can switch off cookies by adjusting the settings on your web browser.

In addition, we use third party providers to provide us with web analytics services. These providers collect information on how individuals use our Sites and our services. These providers may use cookies and other technology (for example, web beacons) to obtain such information. This allows us to improve our Sites and our services.

Will we disclose personal information to anyone else?

Your personal information may be disclosed in connection with any Purpose to any of the following:

• other Tafani entities, including those in different countries.
• our employees, contractors and service providers who provide products, services and/or functions on our behalf.
• suppliers and other third parties with whom we have commercial relationships, for business, marketing and related purposes.
• professional service firms providing services to us, such as legal, accountancy or marketing services as well as data hosting and technology firms.
• if required by Applicable Laws, any person authorised by such law.
• if you are a candidate for employment or a prospective contractor, any third party engaged by us to assess or process your application.

We may also provide your information to others:

• if required or permitted to do so by Applicable Laws.
• in connection with sale, purchase, merger, reorganisation, liquidation or dissolution of Tafani or its related entities, or under similar circumstances. If such an event occurs, we will take appropriate steps to protect your personal information.

To the extent we disclose your personal information to any third party, such third party will be required to use the personal information we share with them in a manner consistent with this Privacy Policy, any applicable Specific Privacy Statements and all applicable privacy and data protection laws.

Do we disclose personal information overseas?

We may disclose your personal information to third parties and service providers located overseas in connection with a Purpose. These include:

• our headquarters in the Republic of Korea; and
• our service providers that are located overseas or hold and store data overseas including Singapore.

We take reasonable steps to ensure that the overseas recipients of your personal information do not beach the privacy obligations relating to your personal information.

Third party websites

Our Sites may contain links or banners to websites or mobile applications that are not operated by Tafani and plugins from social media platforms and other third parties. When you click on these links, banners or plugins, you will be subject to the relevant third party’s privacy policies. Tafani is not responsible for the privacy or security practices of those third parties.

Such third party websites, mobile applications and plugins may independently solicit and collect information (including personal information) from you and, in some instances, provide us with information about your activities on those websites.

Unsubscribing from our marketing materials

We may send you direct marketing communications and information about products and services offered by us or by our retail partners or suppliers via the channels you have nominated. This may include, but is not limited to, email, SMS, regular mail, social media and other digital channels. If you have indicated a preference for a method of communication, we will endeavour to use that method whenever practical to do so.

You may opt out of receiving marketing communications at any time by responding via the channel in which you received the marketing communication, or by contacting us (see contact information below). For example, you can unsubscribe from emails by clicking the unsubscribe link on the footer of the email communication you have received. You may also opt out of receiving marketing communications by updating your online profile.

Dealing with us anonymously or using a pseudonym

You have the discretion to use a pseudonym or remain anonymous when dealing with us. However, if you do not provide us with the personal information that we request, our ability to handle your query, request, order, complaint or application may be diminished.

Security

We use industry-standard measures to safeguard and protect your information. This includes taking reasonable steps to ensure your personal information is protected from unauthorised access, modification or disclosure and from misuse, interference and loss.

Some of the steps we take to protect your personal information include:

• utilising security restrictions on access to our systems such as passwords, firewalls and anti-virus software.
• restricting the number of employees or contractors internally who can access such data.

Once personal information is no longer required by us for the Purposes for which it was collected or held or otherwise in accordance with the Privacy Act 1988 (Cth), we will take all steps as are reasonable in the circumstances to ensure that it is either destroyed or de-identified. 

Children’s privacy
Our Sites are general audience websites. We do not knowingly solicit or collect personal information from children under the age of 13. 

Access, correction and removal of your personal information

You may access your personal information (where it is held online) by logging into our portal at https://coway.ae/.

You may also review, correct and update your personal information held by Tafani at any time by contacting our Privacy Officer using the contact details set out below.

We may ask you to verify your identity to ensure that personal information we hold is not improperly accessed. Normally we will provide a record of your personal information to you via your preferred contact method (phone, email or mail), and we may charge a fee to cover the reasonable costs incurred by us in providing you with the information (the fee does not apply to the making of the request). If your request is unlawful or may interfere with the privacy of others we may reasonably refuse to provide access to your personal information.

Questions and complaints

If you have any question or complaint about this Privacy Policy, any Specific Privacy Statement or our use of your personal information, please contact our Privacy Officer using the contact details set out below. 

All complaints received by the Privacy Officer will be dealt with fairly and in a timely manner considering all the circumstances of the complaint. In most cases, we expect that complaints will be investigated and a response generally provided within 30 days of receipt of the complaint. If the matter is more complex and our investigation may take longer, we will contact you and advise you of this.

If you believe that your complaint has not been satisfactorily addressed by us, after following the procedure set out above, you can refer your complaint to the Office of the UAE Information Commissioner (OAIC). The OAIC’s contact details are available at the following website: https://www.oaic.gov.au/about-us/contact-us. 

Amendments

We may amend this Privacy Policy and any Specific Privacy Statement from time to time without prior notice. Amendments to this Privacy Policy or any Specific Privacy Statement will be posted on our Sites and will be effective when posted.

This Privacy Policy was last revised in [January 2024].

Current and former employees

This Privacy Policy does not apply to current and former employees of Tafani. If you are a current or former employee and have a query about your personal information, please contact a Tafani Human Resources Representative.

Contact us

If you would like to contact us in relation to this Privacy Policy, any Specific Privacy Statement or our use or your personal information, please contact us at: 

Email: info@coway.ae

Mail: The Privacy Officer, 

Suite 601 | Building 11

Bay Square | Business Bay

PO Box 3151 | Dubai | UAE