Privacy Policy

Eastwood General Trading L.L.C. ("Eastwood", "we", "our" or "us") respects your privacy and is committed to protecting your personal information.

This Privacy Policy explains how we collect, use, disclose, store and protect personal information when you access or use www.eastwoodintl.com, the Eastwood mobile application and any related products or services (collectively, the "Platform"). We process personal information in accordance with Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data and other applicable UAE laws.

By accessing or using the Platform, you acknowledge that you have read and understood this Privacy Policy.

Company Information

Scope of This Policy

This Privacy Policy applies to:

1. visitors to the Platform;
2. registered customers;
3. individuals placing Orders through the Platform;
4. individuals receiving deliveries from Eastwood;
5. individuals contacting Eastwood; and
6. users interacting with Eastwood marketing communications.

Information We Collect

Information You Provide Directly

We may collect information that you provide directly to us, including:

1. full name;
2. date of birth;
3. email address;
4. mobile telephone number;
5. delivery address;
6. billing address;
7. government-issued identification details;
8. account credentials;
9. customer support communications;
10. reviews, ratings and feedback; and
11. marketing preferences.

Identity Verification Information

To comply with legal, regulatory and operational requirements, including the requirement that customers are aged 21 or over, Eastwood may collect:

1. government-issued identification documents (Emirates ID or passport);
2. UAE Pass verification results;
3. date of birth information;
4. verification records;
5. fraud prevention information; and
6. identity verification outcomes.

Delivery Verification Information

When an Order is delivered, Eastwood collects:

1. a photograph of the recipient's original identification document;
2. the recipient's signature or other proof of receipt;
3. the delivery date, time and location;
4. the delivery receipt slip; and
5. where a delivery is refused, the reason for the refusal.

Transaction Information

We may collect information relating to transactions, including:

1. order history;
2. purchased products;
3. invoices;
4. payment status;
5. refunds;
6. Wallet activity; and
7. promotional redemptions.

Payment Information

Payment transactions are processed by third-party payment providers. Eastwood does not store complete payment card details.

We may retain:

1. transaction references;
2. payment status information; and
3. partial card information, where provided by payment processors.

Technical Information

When you use the Platform, we may automatically collect:

1. IP address;
2. browser type;
3. device type;
4. operating system;
5. device identifiers;
6. application version;
7. language preferences; and
8. session information.

Usage Information

We may collect information about how you interact with the Platform, including:

1. pages visited;
2. products viewed;
3. searches performed;
4. clicks and interactions;
5. referral sources; and
6. time spent on the Platform.

Location Information

We may collect location information, including:

1. delivery location information;
2. approximate location information; and
3. location information provided through device settings, where permission is granted.

How We Use Your Information

We may use personal information for the following purposes.

Account Administration

1. creating Accounts;
2. maintaining Accounts;
3. authenticating users; and
4. providing customer support.

Order Fulfilment

1. processing Orders;
2. coordinating deliveries;
3. verifying the identity and age of the recipient at delivery;
4. handling returns;
5. managing refunds; and
6. communicating about Orders.

Identity Verification

1. age verification;
2. fraud prevention;
3. security checks; and
4. legal compliance.

Customer Communications

1. order confirmations;
2. delivery notifications;
3. support responses; and
4. service announcements.

Marketing

Subject to applicable laws and customer preferences, Eastwood may send:

1. promotional communications;
2. offers;
3. product announcements; and
4. marketing campaigns.

Customers may opt out of marketing communications at any time.

Analytics and Improvements

1. improving the user experience;
2. analysing Platform performance;
3. improving products and services; and
4. conducting research and analytics.

Security and Fraud Prevention

1. detecting suspicious activity;
2. preventing fraud;
3. investigating security incidents; and
4. enforcing our policies.

Legal Compliance

1. complying with applicable laws;
2. responding to regulatory requirements;
3. maintaining the delivery and verification records required by the Department of Culture and Tourism – Abu Dhabi ("DCT") and making them available to DCT for review on request, within two (2) working days, or immediately during an inspection;
4. responding to lawful requests from authorities; and
5. establishing, exercising or defending legal claims.

Legal Basis for Processing

Where applicable, Eastwood may process personal information on one or more of the following grounds:

1. performance of a contract;
2. compliance with legal obligations, including DCT requirements;
3. legitimate business interests;
4. customer consent; and
5. protection of rights, safety and security.

Disclosure of Information

Service Providers

All deliveries are made by Eastwood's own delivery staff. Eastwood may share information with trusted service providers, including:

1. payment processors;
2. delivery-management and route-planning software providers;
3. cloud hosting providers;
4. customer support platforms;
5. analytics providers;
6. marketing platforms; and
7. fraud prevention providers.

Service providers may only process information for authorised purposes.

Corporate Transactions

Information may be transferred in connection with:

1. mergers;
2. acquisitions;
3. restructurings;
4. asset sales; or
5. financing transactions.

Legal and Regulatory Authorities

We may disclose information where required by:

1. law;
2. court orders;
3. governmental authorities; or
4. regulatory authorities, including DCT.

Protection of Rights

We may disclose information where reasonably necessary to:

1. protect Eastwood;
2. protect customers;
3. prevent fraud; or
4. enforce contractual rights.

Eastwood does not sell personal information.

International Transfers

Eastwood may use service providers located in other jurisdictions. As a result, personal information may be processed, transferred or stored outside the United Arab Emirates.

Where international transfers occur, Eastwood will take reasonable measures to ensure that appropriate safeguards are in place.

Data Retention

Eastwood retains information only for as long as reasonably necessary to:

1. provide services;
2. comply with legal obligations;
3. resolve disputes;
4. enforce agreements; and
5. protect business interests.

In particular, identity verification and delivery records are retained for seven (7) years, and invoices and transaction records for ten (10) years. Other retention periods may vary depending on the nature of the information.

Upon expiry of the applicable retention period, information may be deleted, anonymised or securely archived.

Data Security

Eastwood maintains reasonable technical, organisational and administrative measures designed to protect personal information against:

1. unauthorised access;
2. unauthorised disclosure;
3. misuse;
4. alteration;
5. destruction; and
6. loss.

No security system is completely secure, and Eastwood cannot guarantee absolute security.

Customer Rights

Subject to applicable law, customers may have rights including:

1. access to personal information;
2. correction of inaccurate information;
3. deletion of information;
4. restriction of processing;
5. withdrawal of consent;
6. objection to certain processing activities; and
7. portability of information.

Requests may be submitted using the contact details provided in this Policy. Eastwood will respond within 30 days of receiving a verified request, and may request verification of identity before responding. Some information, such as delivery and transaction records, may need to be retained to meet legal obligations.

Marketing Communications

Opt-In Marketing

Eastwood operates marketing communications on an opt-in basis.

Withdrawal

Customers may withdraw consent at any time by:

1. using unsubscribe links;
2. updating account settings; or
3. contacting support.

Transactional Communications

Certain service-related communications may continue regardless of marketing preferences, including:

1. order updates;
2. delivery notifications;
3. security alerts; and
4. account communications.

Cookies and Tracking Technologies

Eastwood uses cookies and similar technologies. Further details are provided in the Eastwood Cookie Policy.

Third-Party Links

The Platform may contain links to third-party websites or services. Eastwood is not responsible for the privacy practices of third parties. Customers should review the privacy policies of third-party websites independently.

Age Restriction

The Platform is intended solely for individuals aged 21 years and older. Eastwood does not knowingly collect personal information from individuals under 21 years of age.

Changes to This Policy

Eastwood may update this Privacy Policy from time to time. Updated versions will be published on the Platform. Continued use of the Platform following publication of an update constitutes acceptance of the revised Policy.

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