Where we share data with the FTA or other governmental authorities so they can carry out their own legal duties, those authorities are responsible for their own use of the data. 

Where our service providers act on our instructions, they only use the data as we tell them to, under a data processing agreement that covers confidentiality, security, use of sub-processors, help with rights requests, breach reporting, deletion or return of data at the end of the service, and audit rights. 

3.4 Personal data we collect 

What we collect depends on how you interact with us and which service or channel is used. It may include: 

3.4.1 All services 

3.4.2 Tax Refund for Tourists (TRS) 

Much of this information reaches us from the retail store registered with Planet, where you made your purchase, rather than directly from you. See section 3.5. 

3.4.3 App and Shopper Portal 

When you sign in with Google or Apple, your email address is retrieved from the chosen provider with your explicit permission. We do not access any personal data beyond what is required for authentication unless you explicitly authorise it. 

3.4.4 Facial scan and biometric data 

3.6.2 App and Shopper Portal 

Where consent is the applicable basis, it is requested before the relevant biometric capture. You may decline or withdraw consent, but you will then be unable to use the biometric verification enabled App and Smart Gate journey and must use the staffed, passport-based validation route. Withdrawal does not affect earlier lawful processing or records that must be retained by law or at the FTA's instruction. 

If the scan does not match: during App registration, you can retry. If matching still fails, you cannot register in the App and must use the standard passport-based process at the airport. At the airport, a mismatch is identified by Planet staff, who will review your case in person before inspection proceeds. 

Biometric data is used only for TRS identity verification, validation, security, fraud prevention and related audit or compliance purposes. It is not used for marketing. 

3.6.4 Website, communications and marketing 

3.6.5 Running our own business 

Where we rely on legitimate interests, those interests may include providing and improving our services, supporting shoppers and merchants, preventing fraud, protecting our systems, managing business operations and communicating about our services. We balance these interests against your rights and freedoms. 

Some personal data is needed to operate the TRS, check eligibility, process a Refund or meet legal requirements. If you do not provide information that is needed, we may not be able to provide the service, process the Refund or respond to your request. 

If we want to use personal data for a new purpose that is not compatible with the purpose for which it was collected, we will provide further information before starting that new use where required by law. 

3.7 Special category data and children's data 

Facial scans, passport portraits and biometric templates are treated as sensitive personal data.  

We process them for the specified purposes described in section 3.6.3, limit collection to what is relevant and necessary, maintain appropriate accuracy, security and access controls, document the processing, and apply the approved retention and deletion rules.  

We maintain the required data protection and AI risk assessments for the service and update them when the purpose, model, matching method, data categories, suppliers, storage location, retention period or automated outcomes materially change. 

We do not use the biometric system to infer emotions or characteristics such as ethnicity, religion, health or political opinions. We do not otherwise need special category data to provide our services, and we may process it only if it is required by law or included by you in a message to us. 

Some people who use our services may be under 18. If we process personal data about a child, we will use clear language where the information is meant for that child. We may also ask for help from a parent or guardian where this is required or appropriate.  

3.8 Who we share personal data with 

We may share personal data with the categories of recipients listed below where this is needed to operate the TRS, process Refunds, comply with law, prevent fraud, support shoppers and merchants, operate our systems, respond to public authorities or protect our legal rights. We do not sell personal data. 

3.11 How we protect your data 

We use appropriate technical and organisational measures to help keep personal data safe and to protect its security and integrity.  

These include access and administration controls, so only authorised people can see your data; secure systems and networks hosted in the UAE for biometric data; monitoring and logging; staff training; and checks on the providers we work with.  

We keep these measures under review and take reasonable steps to protect personal data against unauthorised access, loss, destruction, misuse, change or disclosure. 

Access to biometric data is restricted to authorised Planet personnel and service providers who need it to operate, secure or support the service, and to the FTA or other competent authorities where required. We also apply governance, testing and monitoring measures intended to identify material errors, bias, security weaknesses and unauthorised use. 

3.12 Marketing and your choices 

If we send you information, news or promotions such as event invitations, we will only do so where the law allows.  

You can opt out at any time by using the unsubscribe link in our messages or by contacting us using the details in this notice. Opting out of marketing will not stop service messages that we need to send you, such as messages about your Refund. 

Biometric data and location data are never used for marketing. We do not knowingly send marketing to people under 18. 

3.13 Your privacy rights 

Depending on which law applies, you may have the rights listed below. These rights may be limited where Planet or the FTA must keep or use data to comply with the TRS, tax, fraud prevention, legal claims, audit or other legal obligations. 

To use your rights in relation to the UAE TRS, including your biometric data, contact data.protection.uae@weareplanet.com or our Data Protection Officer at data.protection@weareplanet.com.  

Please give us enough information to identify you and find the relevant record, for example the type of transaction, the service involved and your connection to Planet, since We may need to check your identity before responding. We will respond within the time required by law. 

If we received your data from someone else, you can ask us where it came from. 

3.14 Cookies and similar technologies 

Our websites, the Shopper Portal and online services may use cookies and similar technologies. These help the service work, remember your choices, measure website performance for statistical and marketing purposes, improve services and support security.  

We only use non-essential cookies where the law allows, including with your consent where this is required. You may withdraw consent to cookies at any time, unless they are strictly necessary for the website to work, through our cookie settings or your browser settings. 

The App requests camera access for passport scanning, live facial capture and airport QR-code scanning, and may request location access for airport validation, security and eligibility checks. 

The App displays a specific permission explanation at the point the relevant capability is needed but if you refuse or later disable a permission, the relevant feature may not work.  

You can manage permissions through your device settings. 

3.15 Automated tools, AI and automated decision-making 

Automated checks. We use automated tools to help with fraud prevention, transaction checks, financial crime screening, security, eligibility checks and running our services. These tools may flag a transaction or Refund for review. 

Facial recognition and AI. The facial verification service uses artificial intelligence and biometric matching technology supplied through our contracted technology providers. The system performs liveness and image quality checks, compares your live facial scan with your passport portrait, creates or compares biometric templates, retrieves your TRS profile and routes you to a refund kiosk or to goods inspection. The AI output consists of match, liveness or quality results and related technical signals. 

Accuracy. Biometric matching is probabilistic. It can produce false matches or failed matches and may be affected by lighting, camera quality, connectivity, face coverings, accessories, pose or other conditions. 

Transparency. Before an AI-enabled facial scan, we show a notice explaining that AI and biometric technology are in use, the purpose of the scan, the main information used, the possible outcome and the fallback route, with a link to this notice. 

Automated decisions and human involvement. Routing to a refund kiosk or to goods inspection is automated. An unsuccessful or uncertain match is not, by itself, a final decision that you are not entitled to a Refund. A mismatch is reviewed in person by Planet staff before inspection proceeds, and you may be asked to present your original passport or other information needed to review the journey. You can ask for staff assistance, explain the issue and challenge the outcome. 

AI model training. Shopper facial scans, passport portraits, biometric templates and TRS records are not used to train or improve a general-purpose AI model and are not made available to a technology provider for its own model training, unless Planet or the FTA first establishes a separate lawful basis, provides any required notice and obtains any required consent. This does not prevent controlled testing, validation, security monitoring or maintenance needed to operate the contracted biometric service, subject to documented instructions and access controls. 

You may contact data.protection.uae@weareplanet.com or data.protection@weareplanet.com to obtain information about the AI-enabled processing, request access or correction, withdraw consent where consent is the applicable basis, object to or request restriction where available, and request human assistance in relation to a failed or uncertain automated result. Requests remain subject to the TRS rules and any lawful requirement of the FTA to retain or process particular records. 

If our use of automated decision-making changes in the future, we will update this notice and explain your rights, as required by law. 

3.16 Contact us 

If you have questions about this Privacy Notice, how we use personal data, or the safeguards used for an international transfer, contact  data.protection.uae@weareplanet.com or our Data Protection Officer at data.protection@weareplanet.com. Our business contact details are listed in section 3.1. 

This notice is available through the App, the relevant App store listing and our website, and in other languages and accessible formats on request. 

3.17 Complaints 

If you are concerned about how we use your personal data, you can contact our Data Protection Officer at data.protection@weareplanet.com or data.protection.uae@weareplanet.com. Please include enough information to help us understand the issue. We will review your concern and respond within the time required by law. 

You also have the right to complain to the competent data protection authority in the UAE. 

3.18 Changes to this notice 

We may update this Privacy Notice from time to time, for example if our services, FTA requirements, legal duties, data uses, recipients, transfers, retention periods or contact details change. We publish the latest version through the App, the Shopper Portal and our website, and we show the effective date at the top of this notice. 

If a change is important, we will take reasonable steps to bring it to the attention of affected people where required by law or appropriate in the circumstances.