Privacy Policy

CTW Privacy Policy

DRAFT FOR LEGAL REVIEW — NOT FOR PUBLICATION This is a first-draft working paper prepared to accelerate review by qualified UAE legal counsel. It has not been reviewed or approved by a licensed UAE lawyer and must not be published or relied upon until reviewed and approved by counsel admitted to practice in the UAE.

Privacy Policy

Computer Technology Warehouse FZ LLC ("CTW")

Version: 0.1 (Draft) Effective Date: [To be confirmed upon publication] Last Updated: 15 July 2026

1. Introduction

1.1 This Privacy Policy explains how Computer Technology Warehouse FZ LLC, a company registered in the Ras Al Khaimah Economic Zone (RAKEZ), United Arab Emirates, with its registered address at FBC5133, Compass Building, Al Shohada Road, Al Hamra Industrial Zone-FZ, Ras Al Khaimah, United Arab Emirates ("CTW," "we," "us," or "our"), collects, uses, discloses, and protects personal data in connection with our website at www.comtechwarehouse.com (the "Website") and all CTW products and services, including the WhatsApp AI Assistant service (the "Assistant Service") described specifically in Section 9.

1.2 This Policy is issued in accordance with Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (the "PDPL") and other applicable UAE federal legislation.

1.3 This Policy forms part of, and should be read together with, our Terms & Conditions.

1.4 By using the Website or any CTW Service, you acknowledge that your personal data will be processed as described in this Policy.

2. Scope and Roles

2.1 For the purposes of the PDPL, CTW acts as the "Controller" of personal data collected through the Website and its Services, except where CTW acts as a "Processor" on behalf of a Service Provider using the Assistant Service platform, in which case CTW's processing is governed by a separate data processing arrangement with that Service Provider.

2.2 This Policy applies to personal data of website visitors, prospective and existing customers, business contacts of Service Providers, and end users interacting with the Assistant Service.

3. Personal Data We Collect

3.1 Depending on how you interact with CTW, we may collect:

(a) Identity and contact data — name, business name, phone number (including WhatsApp number), email address, physical or mailing address;

(b) Transaction data — orders, quotations, invoices, payment references (excluding full card details, which are processed by third-party payment providers);

(c) Communication data — messages exchanged via WhatsApp, email, or website contact forms, including content of enquiries and booking requests;

(d) Technical data — IP address, browser type, device identifiers, and website usage data collected via cookies or similar technologies;

(e) Business information — trade license details, company registration information, and related documents where required to activate or configure a Service.

3.2 We do not intentionally collect sensitive personal data (as defined under the PDPL, including health, biometric, or religious/political information) unless separately and explicitly required for a specific Service, with appropriate consent obtained at that time.

4. How We Use Personal Data

4.1 CTW processes personal data for the following purposes, on the legal bases indicated, in accordance with Article 4 of the PDPL:

(a) to provide, operate, and maintain the Website and Services — performance of a contract with you;

(b) to process orders, bookings, and payments — performance of a contract;

(c) to communicate with you regarding enquiries, bookings, and account matters — performance of a contract and/or legitimate business interest;

(d) to improve, evaluate, and develop CTW's products and services, including AI-based systems, using anonymized or aggregated data — legitimate interest, exercised in a manner that does not identify individuals;

(e) to comply with legal and regulatory obligations under UAE law — legal obligation;

(f) to send marketing communications — consent, where required, and you may withdraw such consent at any time;

(g) to detect, prevent, and investigate fraud, misuse, or security incidents — legitimate interest and legal obligation.

4.2 Where consent is the applicable legal basis, CTW will obtain consent in a manner that is specific, informed, and capable of being withdrawn, consistent with PDPL requirements.

5. Data Sharing and Disclosure

5.1 CTW may share personal data with:

(a) Service Providers (e.g., pest control, cleaning businesses) to the extent necessary to fulfil a booking or enquiry made through the Assistant Service;

(b) Third-party service providers and processors acting on CTW's behalf, including cloud hosting, payment processing, and communications infrastructure providers (including Meta/WhatsApp), bound by contractual confidentiality and data protection obligations;

(d) Professional advisors (legal, audit, financial), where necessary for CTW's legitimate business operations;

(e) A successor entity, in connection with a merger, acquisition, or sale of CTW's business or assets.

5.2 CTW does not sell personal data to third parties.

5.3 Where personal data is transferred outside the United Arab Emirates, such transfer will be conducted in accordance with the cross-border transfer requirements of the PDPL, including, where applicable, contractual safeguards with the receiving party.

6. Data Retention

6.1 CTW retains personal data for as long as necessary to fulfil the purposes described in this Policy, including to satisfy legal, accounting, or reporting requirements under UAE law.

6.2 Conversation data from the Assistant Service is retained in accordance with CTW's data retention schedule, details of which are available upon request, and is deleted or anonymized when no longer required for the purposes described in Section 4.

7. Data Subject Rights

7.1 Subject to the conditions and exceptions set out in the PDPL, you have the right to:

(a) be informed about the processing of your personal data;

(b) access your personal data and obtain a copy of it;

(d) request erasure of your personal data, where applicable;

(e) restrict or object to certain processing, including direct marketing;

(f) request transfer of your personal data to another controller, where technically feasible;

(g) withdraw consent at any time, where processing is based on consent, without affecting the lawfulness of processing carried out prior to withdrawal.

7.2 To exercise any of these rights, contact CTW using the details in Section 11. CTW will respond in accordance with the timeframes and conditions prescribed by the PDPL and its Executive Regulations once issued.

7.3 You also have the right to lodge a complaint with the UAE Data Office or other competent regulatory authority.

8. Data Security

8.1 CTW implements technical and organizational measures designed to protect personal data against unauthorized access, disclosure, alteration, or destruction, consistent with the security obligations under the PDPL.

8.2 No system is completely secure, and CTW cannot guarantee absolute security of data transmitted over the internet or messaging platforms such as WhatsApp, which operate subject to their own security architecture.

8.3 In the event of a personal data breach that poses a risk to your rights and freedoms, CTW will notify the UAE Data Office and affected individuals as required under the PDPL.

9. WhatsApp AI Assistant Service — Supplementary Privacy Terms

This Section 9 applies specifically to the Assistant Service and supplements, without replacing, Sections 1–8 above.

9.1 Data Collected via the Assistant Service. In addition to the categories in Section 3, the Assistant Service may collect: conversation transcripts, booking preferences, responses to onboarding questions, and, where provided, business trade license or registration details submitted during Service Provider onboarding.

9.2 AI Processing. Messages exchanged through the Assistant Service are processed using automated and AI-based systems, which may include third-party AI infrastructure providers acting as processors under contractual data protection terms consistent with the PDPL.

9.3 Human Review. Conversation data may be reviewed by authorized CTW personnel for quality assurance, dispute resolution, security, and service improvement purposes, subject to confidentiality obligations.

9.4 Consent and Acceptance. By completing onboarding and tapping "I Agree" (or an equivalent affirmative step) within the WhatsApp interface, you confirm acceptance of this Policy and the Terms & Conditions applicable to the Assistant Service. CTW records the version of this Policy in effect and the date of acceptance for each Customer.

9.5 Improvement of AI Systems. CTW may use anonymized or aggregated conversation data to evaluate and improve the performance of the Assistant Service's underlying AI systems, in a manner that does not identify any individual, consistent with Section 4(d).

9.6 Third-Party Platform. The Assistant Service operates over WhatsApp, a platform provided by Meta. Your use of WhatsApp is also subject to Meta's own terms and privacy policy, over which CTW has no control.

10. Cookies and Website Tracking

10.1 The Website may use cookies and similar technologies to operate correctly, remember preferences, and analyze usage. Where such technologies process personal data, they are subject to this Policy.

10.2 You may control cookie preferences through your browser settings. Disabling certain cookies may affect Website functionality.

11. Contact and Complaints

11.1 For questions about this Policy or to exercise your data subject rights, contact CTW at info@comtechwarehouse.com.

11.2 [Data Protection Officer contact details, if and when designated in accordance with Article 10 of the PDPL, to be added here.]

12. Changes to This Policy

12.1 CTW may update this Policy from time to time. Material changes will be notified via the Website, email, or the relevant Service's communication channel, prior to taking effect.

12.2 Continued use of the Website or any Service following the effective date of an update constitutes acceptance of the updated Policy. A version history is available at www.comtechwarehouse.com/privacy/history.

13. Governing Law

13.1 This Policy is governed by the federal laws of the United Arab Emirates, as applied onshore and, where relevant, the laws of the Emirate of Ras Al Khaimah, consistent with the governing law provisions of CTW's Terms & Conditions.

End of document — Version 0.1 (Draft), 15 July 2026. Not for publication pending legal review.