Privacy and Cookie Policy

Who we are
The information we collect
How we use that information
How we gather your information
How you can decide how we can contact you
How to access and update your personal information
What are cookies and how and why we use them?
How to manage your cookies
Ad blockers
How we protect your information
When do we disclose your information?
Where is your information stored?
Changes to this Privacy policy
If you believe we are not properly applying this Privacy Policy
Our brands

 

About us

Al Bahar Perfumes is also responsible for our website www.telegraph.co.uk, and whether you browse as a guest or
register with us we will collect different types of information about you: for example, for website functionality;
to provide improved or personalised services to you; to help decide what kind of advertising you will see on the
site; and, in accordance with your chosen preferences, to market goods or services to you. Please also see our
website terms and conditions.

We are not responsible for the content or privacy practices of external sites, third party Apps or your chosen
internet browser. However, we do seek to explain how we work with third parties, including search engines and ad
servers such as Google. You can see Google’s Privacy Policy here.

We also offer a number of services to our readers and other customers, trading under different brands. You can see
Our Brands and their respective Service Providers at the end of this Privacy Policy.

When we collect your information we may share it across our Al Bahar Perfumes companies. This Privacy and Cookie
Policy explains how we use any of your personal information we might collect and how you can limit our use of it.

1. What information do we gather?
The information that we gather falls broadly into two types (please see further below for how we collect it and what
we use it for):

1.1 Information that relates directly to you (e.g. your name and contact details, communication preferences and
customer history).

1.2 Information that does not directly identify you (e.g. how you might browse our website), specifically:

(1) Your IP address through the placement of cookies; and

(2) Location data, which might be gained through your IP address or GPS data (see Section 3 (4), below).

Please note that not all cookies are either personally identifiable information or even unique identifiers; but some
can be, while others can influence what you see on our website and others (see Sections 6 and 7 on cookies and their
management, below).

2. How we use your information

2.1 When we seek your permission. Often we will be using your information in accordance with your specific consent
or instructions: for example, because you have requested or consented to receiving certain information, or entered
into a contract with us (or one of Our Brands) for goods and services: see Section 2.2 below.

At other times we will use your information on one of the other lawful bases described below in this section.

2.2 Contract.

(1) When you enter into a contract for goods or services with us (including competitions, offers, subscriptions or
your online account), or where you wish to register an interest in doing so, we will use your personal data to enter
into and fulfil our contractual relationship with you.

(2) Fulfilling our contract with you means being able to manage and administer our services, and maintain our
standards of tailored service levels, customer care and consumer compliance. This might include fulfilling orders or
returns, processing payments or refunds, and providing aftercare, as well as improving your customer experience
online and otherwise, including by monitoring service levels and responding to feedback.

2.3 Legitimate interests.

Other uses of your information are made for ordinary and transparent purposes which we think are necessary for our
legitimate interests as a provider of news, content, and other services (including when working with Our Brands). We
use your information on this basis to do the following:

(1) Recognise and remember you when you visit our website and better understand how you use our website and others
by using cookies to follow your use. We explain what cookies are in Section 6 and how you can manage them in Section
7, below;

(2) Recognise and remember you when you use a application , to analyse how you use it and to serve you with
advertisements based on your interests. Section 3.1 (4) explains how we gather this information;

(3) Serve you advertisements on selected, third-party websites that make their advertising space available to us.
We call this “Audience Extension” and we do this either by means of using retargeting cookies and similar
technologies (we explain what cookies are in Section 6 and how you can manage them in Section 7, below) or by
matching other unique identifiers, subject to appropriate safeguards and preferences for the purposes of serving you
targeted advertisements and for running website analytics.

One such example is when we use Facebook’s Custom Audience feature (although other sites may offer similar
services). Custom Audiences enable us to display personalised advertising to our customers whilst they are on
Facebook, or your information may be used to create lookalikes of similar audiences for targeting. This information
is matched on a pseudonymised basis without leaving our servers. Facebook does not receive any new information from
us about you except as necessary to fulfil our instructions to serve relevant advertising as our data processor, and
if you are not an existing Facebook customer then Facebook will not see any of your personally identifiable data
(please see this link for further information). You can opt out of your data being used in this way by contacting
admin@albaharperfumes.com. You can manage your Facebook advertising preferences by visiting
facebook.com/adpreferences/data;

(4) Identify your interests. We might then put your information in aggregated form into groupings (known as
“segments”) by a particular audience, which means we can serve you advertisements and offers that will interest you
within the website, including by reference to data we receive from third parties. Please see Sections 6 and 7 for
more information about cookies and how we serve you more targeted messaging;

(5) Keep you updated on any services you have subscribed to, or any products you have purchased, and/or about
similar services unless you have told us otherwise (including where we are working alongside other Service Providers
to provide these services, such as travel or insurance, as detailed in the Our Brands section);

(6) Contact you to let you know about any of our products, services or promotions (which may in some cases be
provided by third parties), including by email, mail, telephone, or SMS text message, always having regard to your
preferences. Please see Section 4 to understand more about how you provide and can manage your preferences.

(7) Contact you directly via social media in relation to any competitions and/or prize draws you have entered.

(8) Make sure materials on the website or in apps are presented in the most effective way for you and your computer
or mobile device;

(9) Collect and log numeric internet addresses to improve the website and to monitor website usage; and

(10) Assess and understand our readers’, customers, site users’ and account holders’ feedback and identify usage
hotspots;

2.4 Some limited uses of your data are required to comply with legal obligations, for example fraud detection and
taxation;

2.5 Our core activities as a media and publishing organisation, on paper or online, are classed as special purposes
(which includes journalism and the arts). Please be aware that we are subject to a series of exemptions from data
protection law when processing personal data for these purposes, and such purposes are not relevant to this Privacy
Policy unless expressly stated.

3. How do we gather information?

3.1 Information (as set out in Section 1) is gathered in the following ways:

(1) indirectly (e.g. from third party data providers or by using website technology that tracks and administers your
visits through your browser, or similar technology when you use a application (“App”) on a mobile device, or when
you log on and/or share stories through social media;

(2) directly (e.g. when you buy a subscription, sign up to create a albaharperfumes.com profile, download a mobile
device application or you otherwise provide your information when you interact with us);

(3) through your device (e.g. mobile, PC or tablet) where you have enabled location services for the applicable App
or browser. This may be used for location targeted services or advertising in accordance with your preferences,
which may be adjusted either on your device or via server, App or website preferences;

(4) through location technology for mobile web services. The service we use is based on machine learning algorithms
which analyse data from different connection types. These include fixed http and https connections, location consent
requests on https sites and from mobiles Apps using https connections. More information is available here. You can
opt-out of this service here;

(5) through social media sign-on. We offer a quick registration option using your existing social media accounts via
an App or the website. If you log in to our sites using a social media account, you are granting permission to that
social media company to share your user details with us, and to collect information about you and how you use our
site (which process we do not control and will be subject to the terms and conditions of your social media account).
This will include that social media company tracking or identifying when you share one of our stories through their
site. When you use social sign-on, we will gather the information you have already used in the process of
registering for that social media site (in accordance with your preferences provided to that site and/or to us at
the point that you use our social sign-on) and your social media account will be linked to your account, including
in our providing social media messaging to you (See Section 5.2, below on de-linking accounts);

(6) when you subscribe to Al Bahar Perfumes, we may also use a card updater service to automatically update your
credit or debit card details. This service is facilitated by your credit or debit card issuer, whom you should
contact for further information;

(7) in the past we may have obtained certain additional details through a telephone number appending service where
we have had contact details for you but did not have your phone number or needed to update your phone number . We no longer append data in this way;

(8) through cross-device graphing algorithms to associate devices that might be related to each other, such as
devices used by the same person or in the same household. We may collect and use this analytics data together with
your personal information, to stitch session data from unauthenticated (anonymous) user visits with authenticated
(logged in) user visits in order to build a broader profile of our individual users so that we can serve you better.

4. How do you decide how you want to hear from us?

4.1 We will contact you in accordance with your preferences, including by email, phone, post and SMS text. We
always seek to explain why and how we might contact you at the point you give your information to us.

4.2 We also provide the means for you to grant or withhold your permission for us to contact you. We do this by
using opt-in boxes or unsubscribe options, which determine your permission for us to contact you about our wider
range of goods and services, including those provided by Our Brands (the range of Telegraph-branded offers, products
and services listed below this policy).

4.3 Sometimes, we need your information to be able to contact you to provide the service you wish to use. In those
cases, by signing up to the service you are agreeing that we will have to send you service communications to run the
service itself, and we will not offer you the chance to opt-out from receiving those messages until you decide you
no longer wish to use the services.

4.4 As well as the communications we send you, we also offer you the opportunity to choose whether to hear from
specific companies and organisations that we work in association with, including (but not limited to) the Service
Providers for Our Brands. We will always name those companies and organisations, and you will have to opt in to
hearing from them via a tick box (or because you choose to engage with them directly).

4.5 If you have signed up to receive marketing from us by SMS, to stop this, please reply STOP to the last message
you received.

5. Accessing and updating your personal information

5.1 You can update your details and marketing preferences by accessing your account pages on the website, by
emailing admin@albaharperfumes.com or by writing to us at Data Department, AL Qurain, Block 3, Street 34, Kuwait.

5.2 You can de-link your social media account from your Telegraph account by emailing admin@albaharperfumes.com.
De-linking your account will not change your marketing preferences unless you specifically request it and we are not
responsible for how third party social media sites use information they collect about you, including via your own
social media account or through your having linked it to your account.

5.3 You have the right to access the personal information held about you from us, or from any other organisation
that controls your personal information. To understand how to obtain a copy of the personal information that we
hold, please see Section 13 below.

6. Cookies and similar technologies

6.1 A cookie is a small piece of information that is placed on your computer when you visit certain websites. When
we refer to “cookies” we include other technologies with similar purposes, such as tags and identifiers. Find out
more about the use of cookies on cookiecentral.com.

6.2 When you first visit our sites using a new browser, or if you visit in private browsing mode, we will provide
you with a cookies permission banner seeking your consent to use of cookies as required by law. From this banner you
will be able to access our cookies management tool. By clicking OK or clicking through to any part of the site, we
will start to manage your visit using cookies.

6.3 We use the following types of cookie, as will your browser:

(1) Analytics cookies that remember your computer or mobile device when you visit our website and recognise visits
to our website across different devices. They keep track of browsing patterns and help us to build up a profile of
how our readers use the website. We use that information for customer analytics and to serve advertisements that we
think might be of particular interest to you on our and other websites (see Section 7.5). Your browser may use
similar cookies for similar purposes and to serve advertisements for others.

(2) Service cookies that help us to make our website work as efficiently as possible; remember your registration and
login details; remember your settings preferences; to detect what device you are using and adapt how we present our
services according to the screen size of that device; and meter the number of pages you view for the purpose of
administering subscriptions to Al Bahar Perfumes site.

(3) Third party advertising and analytics cookies, which are placed by or on behalf of independent advertisers who
are advertising on our site. These cookies may be placed within the advertisement and elsewhere on our site by us or
by your browser. They can allow the advertiser or your browser to tailor advertising to you when you visit other
websites. They are used for statistical analysis by allowing the advertiser to count how many people have seen their
advertisement or have seen it more than once, to make sure you are not repeatedly served with the same advertising
messages.

(4) We also place third party cookies to enable the serving of our own advertisements, for example, for our
subscriptions offers, on other websites. These advertisements will be based on your browsing behaviour on our
website and will be tailored to your interests. The information we gather from your visit is limited to page URLs.
For instance, if you are particularly interested in Food and Drink articles, the subscription offer advertisements
served to you when you visit your Facebook account will feature our Food and Drink content.

6.4 We may use selected data management providers for our own purposes such as and/or similar to those described,
above.

6.5 We have no access to third party cookies and third party organisations have no access to ours. The third party
organisations that place cookies, including your browser (such as Google), Ozone, data management providers and the
third party companies who pay for advertising and analytics services using this information, will have their own
privacy policies.

7. Managing your cookies preferences

7.1 Most browsers allow you to turn off cookies. To do this look at the “help” menu on your browser. Switching off
cookies may restrict your use of the website and/or delay or affect the way in which it operates. We also provide
our own cookie management tool for you to make more specific choices about how cookies are used for your visits to
our site..

7.2 We use various third parties to provide us with information to help us learn about how users use our website. To
find out more about how we use these third party services click on their names, below, to view their websites and
privacy policies.

7.3 If you would like to disable “third party” cookies generated by advertisers or providers of targeted advertising
services, you can turn them off by going to the third party’s website and getting them to generate a one-time “no
thanks” cookie that will stop any further cookies being written to your device. Here is a link to the third party
advertising platform we use, which has instructions on how to do this:

adssettings.google.com/authenticated

Please note that even after disabling this, you may still see “non-personalised” advertisements that may appear
materially the same as the “personalised” ones. This is simply a function of what advertisers and partners we are
working with, and does not mean your preferences have not been applied.

Please note also that the likes of Google, with whom we work to serve advertising, will still use cookies for
necessary administrative purposes after you have amended your personalised advertising settings. These purposes
include frequency capping (namely to stop users being served the same advertisements repeated), aggregated reporting
of engagement (on a non-personal basis) and to combat fraud and abuse (for example, to prevent bogus click-throughs
by web hosts to inflate the value of their platform).

7.4 We also use a data management platform. We use the data this platform records, including data gathered through
cross-device tracking, to better understand our users’ interests, so that we can provide better and relevant TMG and
Advertiser services based on this information.

7.5 When you share stories using social media, for example Facebook, the social media company will drop cookies and
identifiers to track this.

7.6 You can also visit the trade body representing these advertising companies for more information on how to opt
out of these cookies: youronlinechoices.com

8. Ad Blockers

8.1 We use JavaScript to detect ad blockers. We use the script in the source code of our website. It confirms
advertisements are correctly displayed on your device by simulating the display of the advertisement.

8.2 By detecting ad blockers, we do not store any information on your device and we do not process any of your
personal data.

8.3 We may display a message to advise you that we have detected that you are using and ad blocker

8.4 We reserve the right to restrict your access to some or all of our website while you have an ad blocker turned
on.

9. Protecting your information

9.1 The password you provide when registering with the website is encrypted to ensure protection against
unauthorised access to your personal information.

9.2 We invest in high-quality security and do our utmost to protect user privacy. No data transmission over the
Internet can be entirely secure, and therefore we cannot guarantee the security of your personal information and/or
use of the website. Any information that you send is at your own risk and may be read by others. However once we
have received your personal information we use strict procedures to protect the security of your personal
information.

10. Disclosing your information

10.1 Selling our businesses. We may disclose your personal information to third parties and their advisers if we are
approached by a potential buyer in connection with the potential sale of our business or of any part of it
(including any of Our Brands). Should we proceed to sell or reconstitute any part of our business that holds your
personal information, it will be necessary in some circumstances to share or transfer that information to the buyer
or new entity: for example, so that they can continue to provide continuity of service to you. You will always be
notified of such a change of control or ownership, and will be given the opportunity to object or opt out of any
further communications from us or the buyer or new entity, except where such use of your personal information is
necessary for a lawful purpose (such as a legal obligation or right, or where necessary to perform an existing
contract with you)

10.2 Your internet browser or other accounts. Depending on which browser you use to visit our site, and in
accordance with your browser cookie preferences (see above), your browser (such as Google) may collect information
about you and your visit for its own services, including those services such as segmented or personalised
advertising that it provides to us and other sites. If you use social media sign-on (such as with Facebook), you
will be enabling sharing of information between us and that site in the manner set out in Section 3.1(5) above and
any notices provided to you. You can de-link your social sign-in as set out in Section 5.2.

10.3 Our partners. Except as set out in Section 10.1 or 10.2 above, we never sell personal information, or pass it
to third parties outside of the Telegraph Media Group for their own marketing purposes, without your permission. We
sometimes provide your personal information to third parties who are our subcontractors or providers of various
products and services on our behalf e.g. the providers of the branded services listed below (Our Brands and their
Service Providers) and intermediaries, in order to fulfil those orders. Your personal information will always be
subject to appropriate protections under contract. Where you are engaging with Our Brands for products and services,
you will sometimes contract with our Service Providers and may choose to provide them with personal information or
permissions directly.

10.4 Legal requirements. We may disclose your personal information if we are required to do so by law, or if in good
faith we believe such action is necessary to comply with the law a legal obligation.

10.5 Verification of circulation figures. We may disclose subscribers’ personal information including: name,
address, email address and telephone number and payment details (though no bank or credit card account details) to
the Audit Bureau of Circulation (ABC) for the sole purpose of verifying our newspaper circulation figures. ABC’s
Privacy Policy can be found here.

10.6 Data processors. In common with most organisations, some of our functions using your personal information are
outsourced to contractors (for example, Sourcepoint who manage our cookies consents or our other software
providers). Any processing of personal information by these contractors will only be for these carefully defined
purposes, and will be adequately and lawfully protected under contract, including requirements of confidentiality
and data security.

11. Where we store your personal information

11.1 The personal information that we collect from you will sometimes be sent and stored outside the European
Economic Area (“EEA”) in order to carry out the activities listed in “Use of Your Information”. Except where this is
on your specific instructions, this will always be subject to adequate safeguards as to the protection and security
of your personal data. Further details are available on enquiry from data.admin@albaharperfumes.com.

11.2 We will only keep your personal information for as long as we need it for a lawful purpose: whether because of
the products and services we have provided to you, for example as a subscriber or registered user (and to allow for
reasonable retention of records afterwards to reflect legal requirements or limitation periods),or because we
believe you still wish to hear from us. This is again separate from our role as a media organisation and the
information we are lawfully able keep in the public interest because it is relevant to our journalism and publishing
activities.

12. Changes to this Policy

12.1 If we change our Policy, we will post the changes on this page. Please check the website regularly for any
changes to this Policy. However, from 25 May 2018 any significant changes will be provided to you directly where
possible.

12.2 The previous Privacy Policy was dated 10TH May, 2018.

13. If you don’t feel we’re adhering to this Policy, what should you do?

13.1 You have the following rights:

(1) To obtain access to, and copies of, the personal data that we hold about you, or require that it is transmitted
to another data controller;

(2) To request that we restrict our data processing activities or cease processing your personal data in certain
ways, for example because you do not consider it lawful;

(3) To require us not to send you marketing communications;

(4) To withdraw your consent, where we are relying on it to process your personal data;

(5) To object to how we process your personal data, in particular where we are relying on our legitimate interests;
and

(6) To ask us to erase the personal data we hold about you, for example because it is causing you distress or you
believe it to be no longer relevant, or to correct the information if it is incorrect.

If you would like to exercise any of your rights as stated above, you can do so by mailing admin@albaharperfumes.com.

Please note that the above rights are not absolute, and we will be entitled to refuse requests where exceptions
apply (including where we are processing it in our capacity as a media organisation).

Automated decision making

You also have the right to object to automated decision-making, including by means of profiling. Although we use
various algorithms and automated criteria to help us serve advertising in the manner set out in this Policy, this
results in segmented advertising (by category of user) rather than specific decisions being made about you. This can
in any event be controlled through your cookie and ad preferences.

If we change how we use this technology in the future, we will let you know if it affects you via this Policy (and
significant changes or effects we will notify directly).

14. If you don’t feel we’re adhering to this Policy, what should you do?

14.1 If you believe that we have not adhered to this Policy, please notify us by email at admin@albaharperfumes.com
and we will try to solve the problem promptly. If you are not satisfied with our response, or have any other
queries, you can also contact the Information Commissioner.

This policy was last updated on 20.06.2021.

Our Brands

Al Bahar Perfumes brands and their suppliers change from time to time. The following list was updated on 20 Juny
2021.