Privacy Policy
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
📜 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)
Transparency about collection & use (this Policy).
Request a copy of your personal data.
Correct inaccurate or incomplete data.
Request deletion when data no longer needed.
Limit processing in specific cases.
Receive machine-readable copy.
Absolute right to stop marketing communications.
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
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.