1. Definitions and Interpretation

In this Privacy Policy, the following terms shall have the meanings set out below:

• "Personal Data" means any information relating to an identified or identifiable natural person ("Data Subject") [citation:1].
• "Processing" means any operation performed on Personal Data, whether by automated means, such as collection, recording, organization, storage, adaptation, retrieval, consultation, use, disclosure, dissemination, alignment, combination, restriction, erasure, or destruction [citation:1].
• "Controller" means the natural or legal person, public authority, agency, or other body which alone or jointly with others determines the purposes and means of the Processing of Personal Data [citation:1].
• "Processor" means a natural or legal person, public authority, agency, or other body which Processes Personal Data on behalf of the Controller [citation:1].
• "Data Subject" means an identified or identifiable natural person whose Personal Data is processed.
• "UAE" means the United Arab Emirates.

2. Information We Collect

We may collect the following categories of Personal Data from you:

2.1 Information You Provide Directly

• Identity Data: Full name, job title, company name, and professional credentials.
• Contact Data: Email address, phone number, physical address, and billing address.
• Transaction Data: Purchase history, order details, payment information, and delivery preferences.
• Communication Data: Information contained in your inquiries, emails, phone calls, or messages to us.
• Account Data: Username, password, and account preferences if you register on our website.

2.2 Information Collected Automatically

• Technical Data: IP address, browser type and version, time zone setting, browser plug-in types, operating system and platform, and device information.
• Usage Data: Information about how you use our website, products, and services, including pages visited, time spent, clickstream data, and navigation paths.
• Location Data: Approximate geographic location based on your IP address.

2.3 Information from Third Parties

• Analytics providers such as Google Analytics;
• Advertising networks; and
• Payment processing service providers.

2.4 Sensitive Personal Data

We do not intentionally collect sensitive personal data such as health information, biometric data, political opinions, religious beliefs, or criminal records. Please do not provide such information to us [citation:1].

3. How We Collect Your Information

We collect Personal Data through the following methods:

• Direct Interactions: When you fill out forms on our website, place an order, create an account, subscribe to our newsletter, request a quote, or contact us by email, phone, or in person.
• Automated Technologies: As you interact with our website, we automatically collect Technical Data and Usage Data using cookies, server logs, and other similar technologies.
• Third Parties: We may receive Personal Data from business partners, subcontractors, payment providers, and analytics providers.

4. Legal Basis for Processing

Under UAE PDPL, we must have a legal basis to process your Personal Data [citation:1]. Our legal bases include:

• Consent: You have given clear, specific, and unambiguous consent for us to process your Personal Data for a specific purpose. You have the right to withdraw your consent at any time [citation:1].
• Contract Performance: Processing is necessary for the performance of a contract with you or to take steps at your request before entering into a contract.
• Legal Obligation: Processing is necessary for compliance with a legal obligation to which we are subject under UAE law.
• Legitimate Interests: Processing is necessary for our legitimate business interests, provided such interests do not override your fundamental rights and freedoms. These interests include operating our business, preventing fraud, improving our products and services, and direct marketing (subject to your rights).
• Public Interest: Processing is necessary for reasons of public interest as specified under UAE law [citation:1].

5. How We Use Your Information

We use your Personal Data for the following purposes:

5.1 To Provide Our Products and Services

• Process and fulfill your orders, including payment processing and delivery coordination;
• Manage your account and provide customer support;
• Communicate with you regarding your orders, inquiries, or requests;
• Provide you with product quotations and technical specifications.

5.2 To Improve Our Business

• Analyze website usage and customer preferences to improve our website, products, and services;
• Conduct market research and business analytics;
• Develop new products and services.

5.3 Marketing and Communications

• Send you promotional materials, newsletters, and special offers (only with your consent where required);
• Notify you about changes to our products, services, or policies;
• Respond to your inquiries and feedback.

5.4 Legal and Compliance

• Comply with legal and regulatory obligations under UAE law;
• Detect, investigate, and prevent fraud, security incidents, or other unlawful activities;
• Establish, exercise, or defend legal claims.

6. Cookies and Tracking Technologies

6.1 We use cookies and similar tracking technologies to collect and store certain information about your interactions with our website. Cookies are small text files placed on your device when you visit a website [citation:2].

6.2 Types of Cookies We Use

• Essential Cookies: Necessary for the operation of our website, enabling core functionality such as shopping cart and secure login.
• Functional Cookies: Remember your preferences and settings to enhance your experience.
• Analytical/Performance Cookies: Help us understand how visitors use our website, allowing us to improve functionality and content.
• Targeting/Advertising Cookies: Used to deliver relevant advertisements and track marketing campaign effectiveness.

6.3 Managing Cookies

You can manage your cookie preferences through your browser settings. Most browsers allow you to refuse cookies or alert you when cookies are being sent. However, please note that disabling essential cookies may affect the functionality of certain parts of our website [citation:2].

6.4 Third-Party Cookies

We may use third-party service providers such as Google Analytics to analyze website traffic. These providers may set their own cookies to collect information about your online activities. We do not control these third-party cookies [citation:2].

7. Sharing Your Information

7.1 We may share your Personal Data with the following categories of recipients:

• Service Providers: Third-party vendors who provide services on our behalf, such as payment processors, shipping carriers, IT service providers, marketing platforms, and customer support tools.
• Business Partners: Trusted partners who assist us in delivering our products and services, including equipment manufacturers and logistics companies.
• Professional Advisors: Lawyers, accountants, auditors, and insurers who provide professional services to us.
• Law Enforcement and Regulators: When required by law, court order, or government regulation, including compliance with UAE PDPL and other applicable laws [citation:1].
• Corporate Transactions: In connection with a merger, acquisition, reorganization, sale of assets, or similar business transaction.

7.2 We do not sell your Personal Data to third parties for their own marketing purposes [citation:2].

7.3 We require all third parties to respect the security of your Personal Data and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Data for their own purposes [citation:1].

8. International Data Transfers

8.1 We may transfer your Personal Data to countries outside the United Arab Emirates for processing. Under UAE PDPL, Personal Data may be transferred outside the UAE only to countries that provide an adequate level of protection for Personal Data or under specific conditions [citation:1].

8.2 Transfer Mechanisms

When we transfer your Personal Data internationally, we rely on one or more of the following safeguards:

• Adequacy Decisions: Transfers to countries that the UAE Data Office recognizes as providing an adequate level of data protection;
• Standard Contractual Clauses: Contractual arrangements approved by the UAE Data Office that ensure appropriate data protection safeguards;
• Your Explicit Consent: Transfers based on your explicit consent, provided such transfer does not conflict with UAE public or security interests [citation:1];
• Contract Necessity: Transfers necessary for the performance of a contract with you or for the implementation of pre-contractual measures [citation:1];
• Legal Claims: Transfers necessary for the establishment, exercise, or defense of legal claims [citation:1];
• Public Interest: Transfers necessary for important public interest reasons [citation:1].

8.3 Recipient Countries

Your Personal Data may be transferred to and processed in countries including but not limited to the United States, European Union member states, China, India, and other countries where our service providers are located.

9. Data Security

9.1 We implement appropriate technical and organizational security measures to protect your Personal Data from unauthorized access, alteration, disclosure, or destruction. These measures include [citation:2]:

• Secure Socket Layer (SSL) encryption for data transmitted through our website;
• Firewalls and intrusion detection systems;
• Access controls and authentication protocols;
• Regular security assessments and vulnerability testing;
• Employee training on data protection and privacy practices.

9.2 While we strive to protect your Personal Data, no method of transmission over the internet or electronic storage is 100% secure. We cannot guarantee absolute security [citation:2].

9.3 In the event of a data breach that is likely to result in a risk to your rights and freedoms, we will notify you and the relevant authorities as required under UAE PDPL [citation:1].

10. Data Retention

10.1 We retain your Personal Data only for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements.

10.2 Retention Periods

• Order and Transaction Data: Retained for 10 years to comply with UAE tax and commercial record-keeping requirements.
• Account Data: Retained as long as your account is active and for a reasonable period thereafter.
• Marketing Data: Retained until you withdraw your consent or opt out of marketing communications.
• Website Usage Data: Retained for up to 26 months for analytics purposes.

10.3 When we no longer need your Personal Data, we will securely delete or anonymize it. If deletion is not immediately possible (for example, because the data is stored in backup archives), we will securely isolate your Personal Data from further processing until deletion is possible.

11. Your Rights

Under UAE PDPL, you have the following rights regarding your Personal Data [citation:1]:

• Right to Access: You have the right to obtain confirmation from us as to whether we process your Personal Data and, if so, to access that Personal Data.
• Right to Rectification: You have the right to request correction of inaccurate or incomplete Personal Data concerning you.
• Right to Erasure (Right to be Forgotten): You have the right to request deletion of your Personal Data under certain circumstances, including when the data is no longer necessary for the purposes for which it was collected.
• Right to Restriction of Processing: You have the right to restrict processing of your Personal Data under certain circumstances, such as when you contest the accuracy of the data.
• Right to Data Portability: You have the right to receive your Personal Data in a structured, commonly used, and machine-readable format and to transmit that data to another controller.
• Right to Object: You have the right to object to processing of your Personal Data based on legitimate interests or for direct marketing purposes.
• Right to Withdraw Consent: Where processing is based on your consent, you have the right to withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing based on consent before its withdrawal [citation:1].
• Right to Lodge a Complaint: You have the right to lodge a complaint with the UAE Data Office or other relevant supervisory authority if you believe our processing of your Personal Data violates applicable law [citation:1].

11.2 How to Exercise Your Rights

To exercise any of these rights, please contact us using the information provided in Section 15. We will respond to your request within 30 days as required under UAE PDPL [citation:1].

We may need to verify your identity before processing your request. We will not charge a fee for exercising your rights unless your request is manifestly unfounded or excessive.

12. Children's Privacy

Our website and services are not directed to individuals under the age of 18. We do not knowingly collect Personal Data from children under 18. If you are a parent or guardian and believe your child has provided us with Personal Data without your consent, please contact us. If we become aware that we have collected Personal Data from a child under 18 without verification of parental consent, we will take steps to delete that information.

13. Third-Party Links

Our website may contain links to third-party websites, plug-ins, or applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy practices. When you leave our website, we encourage you to read the privacy policy of every website you visit.

14. Changes to This Privacy Policy

14.1 We reserve the right to update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors. Any changes will become effective when we post the revised Privacy Policy on our website [citation:2].

14.2 We will notify you of material changes by:

• Posting a prominent notice on our website; and/or
• Sending an email to the address associated with your account.

14.3 The "Last Updated" date at the top of this Privacy Policy indicates when it was last revised. Your continued use of our website or services after any changes constitutes your acceptance of the revised Privacy Policy.

15. Contact Information

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us using the following information:

• Data Controller: Excel Kitchen LLC
• Email: [email protected]
• Phone: +971 4 267 9180
• Address: Excel Kitchen LLC, Warehouse No. 8 Amman St - Al Qusais Ind. Third - Dubai