<br /> Privacy Policy | Refurbished & Used Electronics – UAE PDPL Compliant<br />

Privacy Policy

📅 Last Updated: — aligns with UAE PDPL & Digital Commerce
Law

1. Introduction

Welcome to (“Company,” “we,”
“us,” or “our”). We are committed to protecting your personal data
and respecting your privacy rights in compliance with
Federal Decree-Law No. 45 of 2021 on the Protection of Personal
Data (“PDPL”),
Federal Decree-Law No. 14/2023 on Trading by Modern Technological
Means (“Digital Commerce Law”), and other applicable UAE legislation.

This Privacy Policy explains how we collect, use, disclose, and
safeguard your personal data when you visit our website
(the “Site”) or purchase
refurbished and used laptops and related products (“Products”) from
us. Please read this policy carefully to understand
our practices regarding your personal data.

2. Definitions

Term	Meaning under PDPL
Personal Data	Any information relating to an identified or identifiable natural person, including name, ID number, location data, online identifier, or factors specific to physical, economic, cultural or social identity.
Sensitive Personal Data	Data revealing racial/ethnic origin, political opinions, religious beliefs, criminal records, health data, biometric data.
Processing	Any operation performed on personal data (collection, storage, use, sharing, transfer, deletion).
Data Controller	determines purposes and means of processing.
Data Subject	You (the user/customer).

3. Data Controller Information

🏢 Company Name:
📜 Trade License Number:
📍 Physical Address:
✉️ Email Address:
📞 Phone Number:

As required by the Digital Commerce Law, we make our license,
contact details, and physical address publicly available and ensure
that our privacy practices align with strict transparency and
consumer data protection standards mandated for all digital
platforms.

4. Personal Data We Collect

Category	Examples
Identity Data	Full name, title, date of birth (if required), government-issued ID number (only where legally required)
Contact Data	Billing and delivery address, email address, phone number
Financial Data	Payment card details, bank account information (tokenized, PCI DSS-compliant)
Transaction Data	Products purchased, order history, delivery tracking, returns/warranty records
Technical Data	IP address, browser type, OS, device type, time zone setting
Usage Data	Pages viewed, searches, clicks, time spent, interaction patterns
Account Data	Username, password, wish lists, preferences, customer feedback
Communication Data	Correspondence with customer support (email, WhatsApp, phone)

We do not knowingly collect sensitive personal data
(health or biometric data). If sensitive data is processed under
exceptional circumstances, we obtain explicit consent and strict
PDPL adherence.

5. How We Use Your Personal Data

Purpose	Data Categories Used
Process & deliver orders (payments, shipping, returns)	Identity, Contact, Financial, Transaction
Manage account registration & security	Identity, Contact, Account
Order communication & delivery status	Identity, Contact, Transaction
Customer service, warranty claims, complaints	Identity, Contact, Communication, Transaction
Marketing communications (only with prior consent)	Identity, Contact, Account
Site improvement & analytics	Technical, Usage
Security, fraud detection, legal compliance	Technical, Usage, Transaction, etc.

6. Legal Basis for Processing (PDPL)

We process personal data only on valid legal grounds:
Consent (marketing, non-essential cookies),
Contractual Necessity (order fulfillment),
Legal Obligation (tax/commercial records), and
Legitimate Interests (service improvement, network
security) where your fundamental rights are not overridden.

7. Cookies and Tracking Technologies

Our Site uses cookies: strictly necessary (no consent required),
analytics, functional, and marketing cookies. Under PDPL,
consent must be obtained before placing
non-essential cookies. A cookie banner will appear on your first
visit, and you may adjust preferences via “Cookie Settings”.

8. How We Share Your Personal Data

We do not sell, rent, or trade your personal data. Sharing occurs
with:

Service providers (payment processors, logistic
partners, IT support) under strict contractual safeguards.
Regulatory authorities when required by law.
Business transfers (merger/acquisition) with
prior notice.
Professional advisors (legal, accounting).

All third parties respect security and confidentiality, as required
by Digital Commerce Law (encryption & secure payment gateways).

9. International Data Transfers

Your personal data is stored on servers within the United Arab
Emirates. Any rare transfer outside UAE will only occur if the
recipient country provides adequate protection, appropriate
safeguards are in place, or after obtaining your explicit consent.

10. Data Retention

We retain data only as necessary: Account Data —
active account + 5 years after last purchase;
Transaction Data — minimum 5 years (UAE commercial
& tax law); Marketing Data — until consent
withdrawal. After retention expiry, data is securely deleted or
anonymized.

11. Your Data Subject Rights (PDPL)

🔍 Right to be Informed
Transparency about
collection & use (this Policy).
📁 Right of Access
Request a copy of your
personal data.
✏️ Right to Rectification
Correct inaccurate
or incomplete data.
🗑️ Right to Erasure
Request deletion when
data no longer needed.
⏸️ Right to Restrict Processing
Limit
processing in specific cases.
📎 Right to Data Portability
Receive
machine-readable copy.
🚫 Right to Object to Direct Marketing
Absolute right to stop marketing communications.
⚖️ Right to Withdraw Consent
Withdraw
consent anytime where processing is based on consent.

To exercise any rights, contact us at
. We respond within 30
calendar days (extendable by 30 days for complex requests). Identity
verification may be required.

12. Security Measures

We implement SSL/TLS encryption, access controls (role-based, MFA),
PCI DSS-compliant payment gateways, regular security audits, staff
training, and contractual security obligations for processors. In
case of a data breach likely to prejudice your privacy, we notify
UAE Data Office and affected data subjects without undue delay.

13. Children’s Data

Our Site is not directed to children under 13. We do not knowingly
collect personal data from minors under 13 in compliance with UAE
Federal Decree-Law on Digital Safety of the Child. If you believe we
have inadvertently collected such data, please contact us for
immediate deletion.

14. Marketing Communications

We send marketing emails/SMS/WhatsApp only after obtaining your
explicit prior consent. You can opt out anytime via “unsubscribe”
link, replying “STOP”, or contacting customer support.
Transactional/service messages are not affected.

15. Third-Party Links

Our Site may contain links to external websites. This Privacy Policy
does not apply to those third-party sites. We encourage you to read
their privacy policies.

16. Updates to This Privacy Policy

We review and may update this policy periodically. Significant
changes will be notified via prominent notice on the Site or email
(when appropriate). Continued use after the “Last Updated” date
constitutes acceptance.

17. How to Contact Us

✉️ Email:
📞 Phone:
🏛️ Postal Address:
🛡️ DPO:

18. Complaints

If you believe your data protection rights have been violated,
please contact us first. You also have the right to lodge a
complaint with the UAE Data Office or seek judicial
remedy in Dubai courts. The Dispute Resolution Committee under the
Digital Commerce Law may also hear certain digital transaction
disputes.

19. Governing Law & Dispute Resolution

This Privacy Policy shall be governed by the laws of the United Arab
Emirates as applicable in the Emirate of Dubai. Any dispute shall be
subject to the jurisdiction of the competent courts of Dubai, UAE,
unless a dedicated Dispute Resolution Committee handles the matter.