Privacy Policy

Overview

Welcome to STACKT TECHNOLOGIES L.L.C’s Privacy Policy. We respect your privacy and are committed to protecting your personal data. This privacy policy is made in conformity with Federal Decree-Law No. 45/2021 on the Protection of Personal Data (“PDPL”) and other applicable data protection laws and regulations in the United Arab Emirates. We will inform you of how we handle your personal data when you sign an agreement with us, and explain your privacy rights and how the law protects you. Please also use the Glossary below to understand the meaning of some of the terms used in this privacy policy.

1:  Important information and who we are

Purpose of this privacy policy

This privacy policy aims to give you information on how we collect and process your personal data, including any data you may provide to us when you purchase a product or service.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Controller

STACKT TECHNOLOGIES L.L.C. is the Data controller and is responsible for your personal data (collectively referred to as “Stackt”, “we”, “us” or “our” in this privacy policy).

The website and services provided by Stackt are not intended to be used by children. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the Stackt team at  help@stackt.co.uk

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact us on the following email address: help@stackt.co.uk

If you wish to make a complaint about the way we’ve managed your personal information, you can lodge a written complaint with us using the contact details above. Please provide us with as much information as possible so we can investigate and respond.

We will respond to your complaint within 30 days of receiving it. If we are unable to provide a response within this timeframe due to exceptional circumstances, we will notify you and provide an updated timeframe for our response.

If you are not satisfied with our response, you may have the right to lodge a complaint with the UAE Data Office or other relevant regulatory authorities, as provided for under the PDPL.

We keep our privacy policy under regular review. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

2: The data we collect about you

Personal data, or personal information, means any data relating to an identified natural person, or one who can be identified directly or indirectly by way of linking data, using identifiers such as name, voice, picture, identification number, online identifier, geographic location, or one or more special features that express the physical, psychological, economic, cultural or social identity of such person. It does not include data where the identity has been anonymised.

When you interact with us, whether by using our website or communicating with us, we may collect, use, store and transfer different kinds of personal data about you, which we have grouped together as follows:

• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender;

• Contact Data includes billing address, delivery address, email address and telephone numbers;

• Financial Data includes bank account and payment card details;

• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us;

• Usage Data includes information about how you use our products and services;

• Marketing and Communications Data includes your preferences in receiving marketing from our third parties and us, and your communication preferences.

• Home Setup Data includes move-to and move-from addresses, moving dates, tenancy or ownership details, and other data required for the provision of home setup or utility management services (including data relating to other occupants or household members).

Where body-worn cameras are used by us in connection with the provision of our services, we may collect and process video recordings, audio recordings, photographs, and any personal data captured within such recordings. This may include your image, voice, interactions with our personnel, and other information visible or audible at the time of recording. We process such information for the purposes of providing our services, maintaining safety and security, quality assurance, staff training, investigating incidents or complaints, preventing fraud, complying with legal obligations, and establishing, exercising or defending legal claims.

We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data, but is not considered personal data in law, as this data will not directly or indirectly reveal your identity. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data, which will be used in accordance with this privacy policy.

We do not collect any sensitive personal data about you (this includes details about your family, race or ethnicity, religious, political or philosophical beliefs, sexual condition, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

3: How is your personal data collected?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity, Contact and Financial Data if you sign up for an account on our website, place an order for our goods or services, complete any online forms (such as registration forms, competitions, surveys or by reviewing the products/services you’ve ordered/received), opt in to receive our newsletters and special offers, enter a competition or promotion, participate in social media functions, or correspond with us (by email, telephone, instant messaging apps, social media or otherwise);

• Website visits. We collect non-personally identifiable information from website visitors, which may include, but is not limited to, IP address, geographical data, recorded activities on the website, browser type, date, time, details of the device and cookies;

• Contact, Financial and Transaction Data from providers of technical, payment and delivery services;

• Identity and Contact Data from publicly available sources.

4: How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you;

• Where it is necessary to protect public interest and your interests;

• Where we need to comply with a legal obligation.

In accordance with Article 4 of the PDPL, our processing of your personal data is based on your consent, except in the circumstances permitted by the PDPL where consent is not required, including those set out above (namely where processing is necessary for the performance of our contract with you, to comply with a legal obligation, or to protect the public interest or your interests). To the extent that any reference in this Privacy Policy to our legitimate interests is inconsistent with the PDPL, we will rely on your consent or on another basis permitted under the PDPL.

We request that you read this policy and the T&Cs on our website carefully before sharing your personal data with us. By browsing, visiting, accessing, or availing any services through the website, you acknowledge and accept the terms of this Privacy Policy. However, explicit consent for processing activities that require consent (such as marketing, tracking, or optional data sharing) will only be obtained through a clear affirmative action, such as ticking a box or clicking a consent button, specifically directed at that processing. You have the right to withdraw consent to marketing processing of your personal data at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data. We have also identified what our legitimate interests are, where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

Messaging App Communication

By providing your contact details and accepting these Terms, you consent to Stackt contacting you via WhatsApp and Telegram for service-related messages, including booking confirmations, reminders, order updates, and customer support.

We will only use WhatsApp and Telegram for information directly related to your requested services. Your data will be handled in line with PDPL and other applicable privacy laws.

You can withdraw consent at any time by replying “STOP”, by leaving or blocking the relevant chat, or contacting our support team.

Promotional offers from us

When you have told us you would like to receive marketing communications or when you have made a purchase using our services, our Partners and we will use your Identity, Contact, and Usage Data to occasionally send you updates, news, and offers via email, post, or other forms of media. We may use your information (including supplemental information received from partners that we append to our existing customer information as described below), to tailor these messages to you.

We also use your data to advertise and retarget advertising of our and our Partners’ products and services, including collecting your email, cookie identifiers, and device information. The legal basis for such processing depends on applicable law: where consent is required, we rely on your valid consent; where permitted, we may rely on our legitimate interests in running our business, provided your rights and interests are not overridden.

To produce aggregated statistical reports, we use your order history, provided that the result of such reports does not identify you.

Third-party marketing

Our website can contain links to and from the websites of our partners, advertisers, and affiliates (collectively our “Partners”), amongst others. If you follow a link to any of these websites, please note that this Privacy Policy does not apply to those websites. We are not responsible or liable for the privacy policies or practices of those websites, so please check their policies before you submit any personal data to those websites. We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

We use cookies, email addresses, device identifiers, and similar technologies for advertising, retargeting, and marketing purposes in accordance with applicable laws. Where the law requires consent, we will seek your express opt-in consent before processing your personal data for these purposes. Where the law permits reliance on legitimate interests for such activities, we may process your personal data on that basis, provided your fundamental rights and freedoms are not overridden.

Stackt will only process your personal data for advertising, retargeting, or marketing purposes on the legal basis permitted by applicable law. If consent is required, we will seek and rely on your valid consent. If legitimate interests are permitted, we may rely on that basis, subject to your right to object. If you withdraw your consent or object to processing, Stackt will cease processing your data for these purposes unless permitted by law to continue on another legal basis.

Opting out

You may unsubscribe from our email marketing communications by modifying your preferences in your account’s profile management section, or by following the opt-out instructions in the promotional emails that are sent to you.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

We also carry out research, analysis, and surveys on your use of our website and your views. We keep track of your spending on our website to see if you can benefit from our exclusive customer programs. Finally, we use your information to confirm your identity and perform credit checks or anti-fraud checks to ensure your financial security and to comply with our legal obligations.

5: Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table above. Purposes for which we will use your personal data.

• Internal Third Parties as set out in the Glossary;

• External Third Parties as set out in the Glossary;

• Specific third parties listed in the table;

• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

For clarity, certain third-party partners act as independent data controllers in respect of the personal data they receive from us. These partners determine the purposes and means of processing such data and process it in accordance with their own privacy policies. In these cases, Stackt is not responsible for the processing activities of those independent controllers.

We require all third-party service providers who act as our data processors to respect the security of your personal data and to treat it in accordance with the law. We do not allow our data processors to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6: Sharing your personal information overseas

We may share your personal information (including sensitive information) outside the UAE to some of the types of recipients, including our contracted service providers operating overseas, which are likely to be located in countries such as the United Kingdom. We ensure that any such transfers comply with the PDPL and other applicable regulations and that appropriate safeguards are in place to protect your data.

7: Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. This includes requiring you to set a unique username and password to access your Stackt account, not keeping any details of your credit or debit card that would enable a third party to access it in an unauthorised way (such as your CVV), and we regularly monitor our servers and IT systems for vulnerabilities and attacks.

While we implement appropriate technical and organisational measures to protect your personal data, please note that the transmission of information via the Internet is not completely secure. Although we strive to safeguard your personal data, we cannot guarantee its absolute security during transmission to or through our website.

In particular, please keep in mind that if you voluntarily disclose your personal data through means of communication other than the website in a non-protected environment (such as through email, sms, online messages) then it may be collected and used by those communication platforms outside of our or your control.

In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you, the UAE Data Office and any applicable regulator of a breach where we are legally required to do so.

8: Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means and the applicable legal, regulatory, tax, accounting or other requirements. Once Personal Data is no longer required for its original purpose, it shall be anonymised or securely erased.

9: Your privacy rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data we hold about you, which we detail below in the Glossary. Please note that we will require you to verify your identity before responding to any requests to exercise your rights and that can include asking a set of security questions to ensure it is you. When you have appointed someone else to do the request on your behalf, that person and/or organisation needs to show a valid power of attorney issued by you. We must respond to a request by you to exercise those rights without undue delay and at least within one month (although this may be extended by a further two months in certain circumstances).

• Right to obtain information: You have the right to know whether we process personal data about you, and if we do, to obtain information about the data we hold about you and certain information about how we use it and who we share it with (including the categories of personal data we share with businesses for their direct marketing uses and the names and addresses of those businesses) by submitting a request to us.

• Requesting correction of your personal data: You have the right to correct any personal data held about you that is inaccurate. You can request the correction by emailing us. Please note that in some cases we can ask you to explain in detail why you believe the personal data we hold about you to be inaccurate or incomplete so that we can assess whether a correction is required. Please note that whilst we assess whether the personal data we hold about you is inaccurate or incomplete, you may exercise your right to restrict our processing of the applicable data.

• Requesting erasure of your personal data: You may request that we erase the personal data we hold about you in certain circumstances, as detailed in PDPL. Also note that you may exercise your right to restrict our processing of the data whilst we consider your request.

• Objecting to processing of your personal data: You have the right to object to the processing of your personal data held with us in certain circumstances, as detailed in PDPL. You have the absolute right to stop your data from being used in direct marketing. We may be able to continue processing your personal data if we have a compelling reason for doing so.

• Requesting restriction of processing your personal data: You have the right to request the restriction or suppression of your personal data in certain circumstances. When processing is restricted, we are permitted to store your personal data but not further process it without your consent, except for limited purposes as detailed in PDPL. When using it for such limited purposes, we will notify you.

• Requesting the transfer of your personal data. You have the right to request that Stackt, as the data controller, transmit your personal data to another data controller on your request, if technically feasible.

• Right to withdraw consent: You have the right to withdraw your consent to the processing of your personal data at any time. Upon withdrawal, we will cease processing your data on the basis of consent. However, withdrawal of consent does not affect the lawfulness of processing carried out prior to withdrawal, nor does it obligate us to delete data that we are entitled or required to retain under another lawful basis or legal obligation. If we do not have any other lawful basis or legal obligation to continue processing or retaining your data, your data will be deleted. This approach ensures compliance with applicable data protection laws and statutory retention requirements.

However, if we refuse to give you access to, or to correct, your personal information, we will give you a notice explaining our reasons (except to the extent it would be unreasonable or unlawful for us to do so) and provide you with information on how you can complain about our refusal.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We will respond to all legitimate data subject rights requests within one month, as required by applicable law. If your request is particularly complex or you have made a number of requests, we may require additional time, in which case we will notify you and keep you updated in accordance with legal requirements.

10: Glossary

LAWFUL BASIS

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

THIRD PARTIES

Internal Third Parties

• We do not currently share your personal data with any internal third parties.

External Third Parties

• Service providers acting as processors or sub-processors based inside or outside the UAE who provide advertising services, international shipping services, transportation and cleaning services. Any transfer of Personal Data to service providers outside the UAE shall be subject to the PDPL cross-border transfer safeguards;

• Professional advisers, including lawyers, bankers, auditors and insurers based inside or outside the UAE who provide consultancy, banking, legal, insurance and accounting services;

• The UAE Data Office, UAE Federal Tax Authority, UAE Ministry of Finance, and other competent UAE regulatory authorities and other entities acting as processors or joint controllers, who require reporting of processing activities in certain circumstances, as well as any equivalent authorities in other applicable jurisdictions.

YOUR LEGAL RIGHTS

You have the right to:

Request access to your personal data. This enables you to obtain information of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, without undue delay, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data. You have the right to object where we are processing your personal data for direct marketing purposes or conducting statistical surveys, unless it is necessary to achieve public interest. You also have the right to object if we process your data in violation of processing controls prescribed by the PDPL.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

• If you want us to establish the data's accuracy;

• Where our use of the data is in violation of the agreed purposes, but you do not want us to erase it;

• Where our processing is unlawful, but you do not want us to erase it;

• Where you need us to hold the data even if we no longer require it, as you need it to establish, exercise or defend legal claims;

• You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.