This page explains what personal data Rixos Mobile Phones (trading as Rixos Phones) collects through www.servicepacklcd.com, why we collect it, who sees it and what rights you have. It is written for the UAE Personal Data Protection Law, because we are a free-zone company in Dubai, and it is written for the people we actually deal with: purchasing staff, technicians and owners of repair businesses and distribution companies.

1. Controller

Requests and questions about personal data go to the email address above and are handled by the management of the company.

2. Applicable law

We process personal data under Federal Decree-Law No. 45 of 2021 regarding the Protection of Personal Data (the "PDPL") and any regulations issued under it. DAFZA is a free zone that, unlike the DIFC and ADGM financial free zones, has no data protection law of its own, so the federal PDPL applies to us directly. The supervisory authority is the UAE Data Office.

Many of our customers are outside the UAE. When the law of your own country gives you additional rights, write to us and we will apply them as far as they are compatible with our obligations here.

3. A note on who our data subjects are

Rixos Phones is a wholesaler. We supply repair shops, service centres and distributors, not consumers, and the website is not aimed at anyone under 18. Almost all of the personal data we hold is business contact data: the name, role, email address and telephone number of a person who works for a company that asked us for a quotation. We keep that distinction in mind throughout this policy; it does not reduce your rights.

4. What we process, for which purpose, on which basis

The PDPL does not allow us to process personal data simply because we find it useful. For each processing operation below we state its purpose, the basis on which we carry it out, namely your consent or one of the exceptions in Article 4 of the PDPL, and, where the processing is not needed for the site to work, how you can stop it.

4.1 Quote requests, product questions and the contact form

You can reach us through the Contact form, the Ask Question button on a product page, by email, by telephone or through the WhatsApp link in the site header. In each case we receive what you give us: your name, company name, email address, telephone number, country, the part numbers or models you are asking about and the text of your message.

• Purpose: preparing a quotation, confirming compatibility of a part number with your device, answering the question you asked, and following up on that enquiry.
• Legal basis: steps taken at your request before a contract is concluded and, where the enquiry becomes an order, performance of that contract (PDPL Article 4). Following up on an open enquiry is part of those pre-contract steps; if you tell us you are no longer interested, we stop.
• Retention: enquiries that do not lead to a business relationship are kept for as long as necessary to deal with the enquiry and any follow-up and are then deleted, unless statutory retention applies. Enquiries that become quotations and orders are kept with the commercial file (see 4.3).

4.2 Trade account and newsletter

The site offers a My Account area for trade customers. When you register we store your name, company, email address, telephone number, address and a password, which is stored only as a salted hash. The account lets you keep your contact details on file and manage your newsletter preference. Because this is a catalogue site, the account holds no payment data and is not used to place orders; orders are agreed by quotation and written confirmation.

• Purpose: operating your account and recognising you as a trade customer.
• Legal basis: performance of the account agreement you enter into when registering.
• Newsletter: only if you tick the newsletter option in your account or enter your email address in the newsletter sign-up on the site. We then send occasional emails about new models, part numbers and stock. The newsletter list is kept in the shop's own database and is not passed to any third-party mailing service. You can switch it off in the account at any time or by emailing us; the basis is your consent.
• Retention: until you ask us to close the account, or, for the newsletter, until you unsubscribe. Accounts that stay unused for a long period are reviewed and deleted.

4.3 Orders following a quotation

If you accept a quotation we process the data needed to perform the contract: the ordering person and company, billing and delivery address, contact person at the receiving end, the goods ordered and the correspondence about the order. Payment is made as stated on the pro forma invoice. We hold only the reference data generated by the payment method used (for a bank transfer, the remitter name and payment reference); the website itself processes no payment data.

• Purpose: order confirmation, invoicing, packing and dispatch, customs documentation, after-sales support and handling of RMA returns.
• Legal basis: performance of the contract; compliance with UAE legal obligations (commercial, tax and customs record-keeping).
• Retention: for as long as UAE commercial and tax law requires us to keep business records, then deleted.

4.4 Server logs

Every request to the website is written to a server log with the IP address, date and time, the page requested, the referring page, browser type and operating system, and the HTTP status returned.

• Purpose: keeping the site secure and available, detecting abuse and diagnosing errors.
• Legal basis: writing these logs is technically necessary to deliver the site to your browser and to keep it secure. We keep them under the PDPL exceptions for processing needed to comply with our legal obligations under UAE law and to protect our rights and yours, for example when an attack or a fraud attempt has to be traced and documented.
• Retention: the hosting provider keeps server logs for a short period for security purposes and deletes them afterwards; an entry is kept longer only if it is needed for a security investigation.

4.5 Google Analytics

The site uses Google Analytics (gtag.js), a service of Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland. The site shows no cookie banner, so the Google script loads when a page is opened and sets the cookies _ga and _ga_*, which contain a random identifier. Google then reports to us which pages are viewed, in what order, from which country and on which type of device. What we see are pseudonymous usage statistics, not a profile of a named person; the identifier is never combined with your name, company or enquiries.

• Purpose: understanding which brands, models and categories visitors look for so we can organise the catalogue accordingly.
• Basis and your choice: Google Analytics is not needed for the site to work, and we do not ask for separate consent before it loads; we use it for our own business purpose of organising the catalogue, on pseudonymous data only. If you do not want it to run for you, use one of the methods below and the site works exactly the same.
• Stopping Google Analytics: block cookies from google-analytics.com in your browser settings, delete the _ga cookies, or install the Google Analytics opt-out browser add-on published by Google (tools.google.com/dlpage/gaoptout), which blocks Google Analytics on every website you visit.
• Transfer: Google Ireland Ltd. may transfer the data to Google LLC in the United States under the EU-US Data Privacy Framework and processes it under Google's own terms for Google Analytics.

4.6 Google Fonts

The typefaces on this site are loaded from Google's servers (fonts.googleapis.com and fonts.gstatic.com, operated by Google Ireland Ltd.). When a page is displayed, your browser requests the font files from Google and, in doing so, transmits your IP address to Google. Loading the typefaces this way is technically necessary to render the pages consistently across all language versions of the site; no cookie is set by this request and we receive nothing back from Google about you. We rely on the PDPL exceptions for processing needed to protect our rights and yours (a correctly displayed catalogue is the service you came for) and, where our hosting or security obligations under UAE law require it, on compliance with those obligations. Google's handling of the request is described in Google's own privacy policy.

4.7 WhatsApp link

The header contains a click-to-chat link (wa.me or api.whatsapp.com) that opens a chat with our sales number +971 55 781 2998 in the WhatsApp application on your device. Nothing is transmitted to WhatsApp until you click the link and send a message. If you do, WhatsApp, a service of Meta Platforms Ireland Ltd., processes your telephone number, the message and the related metadata under its own privacy policy, which you accepted when you installed the app. We treat the content of a WhatsApp enquiry exactly as we treat an email enquiry (4.1).

4.8 Embedded YouTube video

The site embeds one video hosted on YouTube, a service of Google Ireland Ltd., using the standard YouTube player; the video appears, for example, on the home page and the About us page. The player loads when the page is displayed, before you press play. Your browser then connects to YouTube's servers and transmits your IP address and the address of the page you are viewing, and Google or YouTube may set cookies in your browser for the player and for its own usage measurement, under Google's privacy policy. If you are signed in to a Google account at the time, Google can link the visit to that account; signing out beforehand prevents this. We receive no personal data from YouTube about you. Loading the player is part of displaying the page you have opened; if you prefer not to connect to YouTube, block third-party content or cookies for youtube.com in your browser and the rest of the page works as before.

4.9 Live chat (JivoChat)

The site embeds the JivoChat live-chat widget, a service of JivoSite Inc. (USA). The widget script loads on every page and sets cookies prefixed jv_ that identify your browser during the visit so that a conversation can continue between pages. When you open a chat, the messages you write, any name or contact details you enter, your IP address, browser type and the page you are on are transmitted to JivoChat's servers and shown to our sales team; the provider may process this data in the United States. We keep chat transcripts for as long as needed to answer the enquiry and for any order that follows. If you prefer not to use the chat, write to us by e-mail or WhatsApp instead.

5. Cookies

The site uses the following cookies. The session and notice cookies set by the site itself are needed for the site to work. The Google Analytics cookies are not: the site shows no cookie banner, so they are set when a page is opened, and section 4.5 explains how to stop them. The language versions of the site (English, German, Spanish, Italian, French, Portuguese, Arabic, Russian and Chinese) are selected through the address prefix of the page, so no cookie is needed to store your language choice.

You can delete cookies and refuse new ones in your browser settings. If you refuse the session cookie you will not be able to log in to a trade account, but you can still browse the catalogue and contact us.

6. Recipients of personal data

• Hosting: the website is hosted by Hostinger International Ltd., Larnaca, Cyprus, on servers located in the European Union. The hosting provider acts as our processor under a written data processing agreement and may only process data on our instructions.
• Carriers: for shipments we pass the consignee's name, address and telephone number to the carrier chosen for the consignment (DHL, UPS or FedEx) so that it can deliver and, where necessary, contact the receiver about customs clearance.
• Google Ireland Ltd.: for Google Analytics, Google Fonts and the embedded YouTube video, as described in 4.5, 4.6 and 4.8.
• WhatsApp (Meta Platforms Ireland Ltd.): only if you choose to contact us through the WhatsApp link.
• Banks, auditors and professional advisers: to the extent needed for payment processing, accounting and legal advice.
• Authorities: UAE customs, courts and regulators where the law obliges us to disclose.

The newsletter list is kept in the shop's own database and is not passed to any mailing service. We do not sell personal data, we do not place advertising networks or social media pixels on the site, and we do not build marketing profiles.

7. Transfers outside the UAE

Because we ship worldwide, correspondence, quotations and shipping documents naturally travel to the country where the customer is located; that transfer is necessary to perform the contract with you. The website itself is hosted in the European Union, so trade accounts, enquiries sent through the site, newsletter addresses and server logs are stored there with the hosting provider named in section 6, under its data processing agreement. Analytics data, font requests and the embedded video are processed by Google Ireland Ltd., which may transfer the data to the United States under the EU-US Data Privacy Framework, and WhatsApp conversations are processed by Meta Platforms Ireland Ltd. In all other respects personal data is stored in the UAE. Where the PDPL requires safeguards for a cross-border transfer, we rely on the necessity of the transfer for the contract, on your consent, or on contractual protections with the recipient.

8. Security

The website is served exclusively over HTTPS with HTTP Strict Transport Security. Account passwords are stored as salted hashes. Access to customer files is restricted to the staff who need them for quotations, dispatch and accounting; our ISO 9001 quality system includes document control for commercial records.

9. Your rights

Under the PDPL you may, free of charge and at any time:

• ask whether we hold personal data about you and receive a copy of it, together with the purposes, recipients and retention period;
• have inaccurate or incomplete data corrected;
• have your data erased where it is no longer needed, where you withdraw consent or where it was processed unlawfully;
• have processing restricted while a request is being examined;
• receive the data you provided in a structured, machine-readable format and have it transmitted to another controller where technically feasible;
• ask us to restrict the processing of your data (PDPL Article 16) or to stop processing for direct marketing purposes, in particular where it is used for direct marketing, where it is no longer needed for the purpose it was collected for, or where the processing is unlawful;
• withdraw consent with effect for the future, for example for the newsletter, and stop Google Analytics for your browser at any time as described in 4.5;
• not be subject to a decision based solely on automated processing. We make no such decisions.

Send requests to sales7@servicepacklcd.com from the address we have on file, or by post to the address in section 1. We may ask for information to verify that the request comes from the person concerned. We answer without undue delay and tell you if a legal obligation prevents us from complying in full. If you are dissatisfied with our answer you may lodge a complaint with the UAE Data Office.

10. Changes to this policy

We update this page when the website, our processors or the law change. The date below shows the current version; material changes are announced on the website.

Last updated: 1 October 2026.