PRIVACY POLICY

Kingswell Services - FZCO

Last Updated: 18/5/2026

1. Introduction:

a. This Privacy Policy explains how Kingswell Services - FZCO, a free zone company

incorporated in Dubai, United Arab Emirates, hereinafter referred to as (“Kingswell”,

“we”, “us”, or “our”) collects, uses, stores, discloses, transfers, protects, and otherwise

processes Personal Data.

b. Kingswell operates as a Dubai-based concierge, service coordination, and electronic

services brokerage platform. Kingswell connects clients with independent third-party

providers through a centralised service platform and manages request handling,

communications, provider coordination, booking support, payment collection, provider

settlement, service follow-up, and quality control.

c. This Privacy Policy applies to all users, clients, corporate clients, authorised

representatives, service recipients, visitors, service providers, vendors, and other persons

who access, use, communicate with, transact through, or otherwise interact with

Kingswell through any Platform.

d. The Platform may include Kingswell’s website, Telegram mini app, WhatsApp service

channel, social media channels, referral links, QR codes, mobile/web applications,

checkout/payment interfaces, customer support tools, and any other digital or

communication channel used by Kingswell.

e. By accessing the Platform, accepting the Terms of Use, submitting a request, providing

your phone number, communicating with Kingswell, making a payment, uploading

documents, or receiving services, you acknowledge that you have read, understood, and

accepted this Privacy Policy.

f. If you do not agree to the collection and processing of Personal Data required for

Kingswell to operate, coordinate, process, confirm, deliver, manage, or support the

requested services, you must not use the Platform or request services from Kingswell.

2. Definitions;

a. “Kingswell”, “we”, “us”, and “our” mean Kingswell Services - FZCO.

b. “User”, “Client”, “you”, and “your” mean any person or entity accessing or using the

Platform, submitting a request, communicating with Kingswell, making a booking,

making a payment, receiving services, or otherwise interacting with Kingswell.

c. “Platform” means Kingswell’s website, Telegram mini app, WhatsApp service flow,

mobile/web application, payment flow, social media channels, QR codes, referral links,

communication channels, and related digital infrastructure.

d. “Services” means Kingswell’s concierge, marketplace, electronic brokerage,

coordination, facilitation, payment handling, provider assignment, customer support,

quality control, complaint management, and related services.

e. “Third-Party Provider” means any independent provider, supplier, vendor,

contractor, operator, technician, delivery provider, cleaning provider, maintenance

provider, automotive provider, yacht or tour operator, flower/gift provider, or other third

party involved in providing or supporting services arranged through Kingswell.

f. “Personal Data” means any information relating to an identified or identifiable natural

person.

g. “Processing” means any operation performed on Personal Data, including collection,

recording, storage, use, disclosure, transfer, amendment, retrieval, restriction, deletion,

or destruction.

3. Scope and Applicability:

a. This Privacy Policy applies to Personal Data processed by Kingswell in connection with:

i. Platform access and use;

ii. Telegram and WhatsApp service functionality;

iii. service requests and bookings;

iv. client communications;

v. provider assignment and service coordination;

vi. online and offline payments;

vii. invoicing and accounting;

viii. refunds, cancellations, and chargebacks;

ix. customer support and complaint handling;

x. quality control and operational monitoring;

xi. corporate accounts;

xii. provider onboarding and provider management;

xiii. legal, regulatory, compliance, audit, and dispute-related matters; and

xiv. business administration and improvement.

b. This Privacy Policy does not replace or control the privacy policies of Telegram,

WhatsApp/Meta, Stripe, banks, card issuers, cloud providers, analytics providers, social

media platforms, or Third-Party Providers acting independently.

c. Where a third party independently determines how and why it processes your Personal

Data, that third party is responsible for its own privacy practices, terms, security

controls, and compliance obligations.

4. Personal Data We May Collect:

a. Client/User Data: Depending on the service requested and your interaction with

Kingswell, we may collect:

i. name;

ii. email address;

iii. phone number;

iv. address, delivery address, or service location;

v. payment and billing information;

vi. invoice and payment history;

vii. refund and chargeback records;

viii. location data where relevant to service delivery;

ix. IP address;

x. device information;

xi. browser information;

xii. operating system and usage data;

xiii. cookies and analytics data;

xiv. Telegram username, user ID, phone number, account information, and related

interaction data where applicable;

xv. WhatsApp number, profile information, and related communication records

where applicable;

xvi. chat messages, voice notes, files, attachments, and service instructions;

xvii. service request details;

xviii. booking records;

xix. customer support records;

xx. complaint records;

xxi. uploaded documents;

xxii. photographs or videos relating to service requests, property condition, vehicle

condition, delivery items, complaints, or service evidence;

xxiii. client preferences and special instructions;

xxiv. marketing communication preferences;

xxv. any other information voluntarily provided to Kingswell; and

xxvi. Any other information or documents where reasonably needed.

b. Vehicle-Related Data: For automotive services, Kingswell may additionally collect:

i. Emirates ID;

ii. driving licence;

iii. vehicle registration card / Mulkiya;

iv. vehicle make, model, year, plate number, chassis/VIN details, and registration

details;

v. vehicle photographs and videos;

vi. vehicle inspection-related information;

vii. insurance information where required;

viii. registration renewal documents;

ix. information relating to fines, encumbrances, testing, transfer, or registration

requirements where relevant;

x. any additional documents reasonably required to coordinate automotive services;

and

xi. Any other information or documents where reasonably needed.

c. Corporate Client Data: For corporate clients, Kingswell may collect:

i. company name;

ii. trade licence;

iii. registered office address;

iv. billing address;

v. authorised signatory or contact person details;

vi. authorised representative details;

vii. employee/user details;

viii. corporate contact details;

ix. VAT information;

x. billing, invoicing, and payment information;

xi. service request history;

xii. account usage records;

xiii. internal approval or authorisation details where provided; and

xiv. Any other information or documents where reasonably needed.

d. Provider Data: Where Kingswell works with Third-Party Providers, Kingswell may

collect:

i. provider legal name or trade name;

ii. trade licence;

iii. authorised signatory or contact person details;

iv. Emirates ID, passport, visa, or identification documents where reasonably

required;

v. VAT certificate;

vi. bank account and payment details;

vii. insurance documents;

viii. service scope and capability details;

ix. pricing information;

x. availability information;

xi. service performance records;

xii. reviews and ratings;

xiii. complaint history;

xiv. incident records;

xv. provider communications;

xvi. documents required for onboarding, due diligence, settlement, quality control,

compliance, or dispute handling; and

xvii. Any other information or documents where reasonably needed.

5. How We Collect Personal Data:

a. Kingswell may collect Personal Data directly from you when you:

i. access the Platform;

ii. use the Telegram mini app;

iii. communicate through WhatsApp;

iv. submit a service request;

v. provide your phone number;

vi. request a quotation;

vii. confirm a booking;

viii. make a payment;

ix. upload documents, photographs, videos, or service evidence;

x. communicate with support;

xi. submit a complaint;

xii. respond to feedback requests;

xiii. interact with referral links, QR codes, or social media links; or

xiv. otherwise provide information to Kingswell.

b. Kingswell may also collect Personal Data from:

i. Third-Party Providers;

ii. payment gateways;

iii. banks or card issuers;

iv. Telegram;

v. WhatsApp/Meta;

vi. corporate clients;

vii. referral partners;

viii. analytics tools;

ix. marketing tools;

x. cloud and hosting providers;

xi. government or regulatory sources where applicable; and

xii. publicly available sources.

6. Purposes of Processing:

Kingswell may process Personal Data for the following purposes:

a. providing access to the Platform;

b. enabling Telegram and WhatsApp functionality;

c. identifying Users and communication channels;

d. processing service requests;

e. assigning and coordinating Third-Party Providers;

f. confirming bookings;

g. arranging service delivery;

h. sending confirmations, reminders, updates, and support messages;

i. processing payments, deposits, prepayments, refunds, and chargebacks;

j. issuing invoices and receipts;

k. managing provider settlement;

l. managing corporate accounts;

m. handling customer support requests;

n. receiving, assessing, and resolving complaints;

o. monitoring service quality;

p. maintaining records of requests, bookings, payments, and communications;

q. preventing fraud, misuse, circumvention, non-payment, and unlawful conduct;

r. conducting security monitoring;

s. improving the Platform and service workflows;

t. analytics and operational reporting;

u. automation and workflow optimisation;

v. personalising user experience and service recommendations;

w. sending marketing communications;

x. enforcing Kingswell’s Terms of Use;

y. legal claims, dispute resolution, evidence preservation, and debt recovery;

z. complying with UAE laws, free zone requirements, tax, accounting, audit, regulatory,

and reporting obligations; and

aa. business restructuring, financing, investment, acquisition, sale, transfer, or corporate

reorganisation.

7. Legal Grounds for Processing and Required Consent:

a. Kingswell may process Personal Data where one or more lawful grounds applies,

including:

i. the processing is necessary to provide access to the Platform;

ii. the processing is necessary to receive, review, confirm, coordinate, perform,

support, or complete a service request;

iii. the processing is necessary to communicate with you through Telegram,

WhatsApp, phone, email, SMS, or other channels;

iv. the processing is necessary for payment collection, invoicing, provider

settlement, refunds, chargebacks, or accounting;

v. the processing is necessary for contractual necessity or pre-contractual;

vi. the processing is necessary to comply with legal, regulatory, tax, audit,

vii. accounting, law enforcement, court, free zone, or government requirements;

viii. the processing is necessary for Kingswell’s legitimate business purposes,

including service coordination, fraud prevention, operational management,

complaint handling, legal protection, and platform security, where permitted by

applicable law;

ix. the processing is necessary to protect Kingswell’s rights, property, operations,

reputation, legal position, users, providers, or the public;

x. you have provided consent where consent is specifically required; or

xi. the processing is otherwise permitted under applicable UAE law.

b. Certain Personal Data is operationally and legally required for Kingswell to provide the

Platform and Services. This may include your phone number, service request details,

communication records, payment details, service location, delivery information,

documents required for specific service categories, and other information reasonably

necessary to process or fulfil your request.

c. If you do not provide the Personal Data required for a particular service, or if you do not

consent to the processing of Personal Data where consent is required, Kingswell may be

unable to provide access to the Platform, process your request, confirm a booking, collect

payment, assign a Third-Party Provider, provide customer support, process a refund,

handle a complaint, or complete the relevant service.

d. Where consent is required by applicable law for specific processing activities, such

consent is a condition for Kingswell providing the relevant service or functionality. If you

refuse or withdraw consent required for such service or functionality, Kingswell may

suspend, restrict, cancel, or refuse the relevant service or your access to the Platform.

e. Withdrawal of consent does not affect processing already carried out lawfully before

withdrawal, nor does it prevent Kingswell from continuing to process Personal Data

where such processing is required or permitted for legal compliance, contractual

necessity, payment records, accounting, tax, audit, dispute resolution, fraud prevention,

enforcement of Terms, safety, regulatory reporting, or Kingswell’s legitimate lawful

purposes.

f. Kingswell shall not be liable for inability to provide Services, delays, cancellation,

incomplete service delivery, refund limitations, or loss of functionality arising from your

refusal to provide required Personal Data or withdrawal of required consent.

8. Phone Number Requirement:

a. Kingswell requires a valid phone number for most service flows.

b. Where you access the Platform through Telegram, your phone number may be shared

automatically depending on Telegram functionality.

c. Where you access Kingswell through WhatsApp, your WhatsApp number and related

communication information may be processed as part of the service flow.

d. Without a valid phone number, Kingswell may be unable to process your request,

confirm your identity, communicate with you, assign providers, send updates, process

payments, handle complaints, or complete services.

9. Payment and Billing Data:

a. Kingswell may use third-party payment processors, including Stripe or any replacement

payment gateway.

b. Kingswell may collect and process payment status, transaction references, invoice

details, billing details, payment confirmations, refund records, chargeback records, and

settlement information.

c. Full card details may be processed directly by the payment gateway, bank, card issuer, or

payment network. Kingswell may not store full card numbers unless expressly stated and

legally permitted.

d. Payment processors, banks, card issuers, and payment networks may independently

process Personal Data under their own terms and privacy policies.

e. Kingswell is not responsible for independent acts, omissions, outages, security practices,

decisions, rejected payments, frozen funds, chargebacks, or delays caused by payment

gateways, banks, card issuers, or payment networks beyond Kingswell’s reasonable

control.

10. Sharing of Personal Data:

a. Kingswell may share Personal Data with:

i. Third-Party Providers;

ii. payment processors, including Stripe or replacement gateways;

iii. banks, card issuers, and financial institutions;

iv. Telegram;

v. WhatsApp/Meta;

vi. cloud hosting providers;

vii. CRM, ticketing, workflow, and customer support tools;

viii. analytics providers;

ix. marketing platforms;

x. software developers;

xi. app developers;

xii. IT providers;

xiii. cybersecurity providers;

xiv. accounting providers;

xv. legal advisers;

xvi. auditors;

xvii. insurers;

xviii. debt recovery providers;

xix. corporate clients where applicable;

xx. affiliates, investors, purchasers, successors, assignees, restructuring parties, or

financing parties;

xxi. free zone authorities;

xxii. regulators, courts, law enforcement, government authorities, and public bodies

where required or permitted; and

xxiii. any other party where disclosure is necessary for the relevant purpose or

permitted by law.

b. Kingswell will seek to share only the Personal Data reasonably necessary for the relevant

purpose, subject to applicable law, operational requirements, service requirements, and

legal protection needs.

c. Third-Party Providers may receive your name, phone number, address, service location,

service details, documents, photographs, timing requirements, special instructions, and

other information necessary to perform or coordinate the requested service.

11. Third-Party Platforms and Technology Providers:

a. Kingswell’s services may depend on third-party platforms, including Telegram,

WhatsApp/Meta, Stripe, cloud hosting providers, analytics tools, CRM tools, payment

interfaces, social media platforms, and communication systems.

b. Kingswell does not control the independent data practices, account rules, platform

availability, technical changes, outages, delivery failures, content policies, or security

practices of such third parties.

c. You are responsible for reviewing and complying with the terms and privacy policies of

any third-party platform you use to access or interact with Kingswell.

12. Cross-Border Transfers:

a. Personal Data may be stored, accessed, processed, or transferred inside or outside the

UAE.

b. Kingswell’s technology providers, hosting providers, payment processors, support tools,

analytics tools, providers, advisers, affiliates, or other recipients may be located outside

the UAE.

c. By using the Platform and providing Personal Data, you acknowledge that your Personal

Data may be transferred internationally where necessary for service delivery, payment

processing, technology infrastructure, support, analytics, compliance, or business

operations.

d. Kingswell will take reasonable steps, where required by applicable law, to ensure

appropriate protection for cross-border transfers.

13. Data Accuracy:

a. You must ensure that all Personal Data, documents, images, instructions, and service

information provided to Kingswell are accurate, complete, current, and not misleading.

b. Kingswell may rely on the information you provide without independently verifying

every detail.

c. Kingswell shall not be responsible for delays, failed bookings, wrong deliveries, payment

issues, provider errors, rejected services, authority rejection, complaint rejection, or

losses arising from inaccurate, incomplete, outdated, or misleading information provided

by you.

14. Data Retention:

a. Kingswell may retain Personal Data for as long as reasonably necessary for:

i. service provision;

ii. booking records;

iii. payment and invoicing;

iv. tax, VAT, accounting, and audit purposes;

v. provider settlement;

vi. complaint handling;

vii. dispute resolution;

viii. fraud prevention;

ix. enforcement of Terms;

x. legal claims;

xi. regulatory compliance;

xii. business records; and

xiii. legitimate operational purposes.

b. Retention periods may vary depending on the type of data, service category, legal

limitation periods, regulatory requirements, dispute risk, payment status, and business

needs.

c. Kingswell may retain Personal Data after your relationship with Kingswell ends where

retention is required or permitted for legal, regulatory, tax, accounting, audit, security,

fraud prevention, dispute resolution, or legitimate business purposes.

15. Security:

a. Kingswell applies reasonable technical and organisational measures designed to protect

Personal Data.

b. Such measures may include access controls, internal confidentiality controls, limited

access permissions, secure service providers, cloud security tools, provider due diligence,

system monitoring, operational procedures, and data minimisation where commercially

appropriate.

c. Kingswell does not guarantee absolute security. No digital platform, messaging

application, payment system, cloud environment, internet transmission, or electronic

communication method is completely secure.

d. You are responsible for securing your own device, Telegram account, WhatsApp account,

phone number, email, payment cards, passwords, and communication channels.

16. Cookies and Analytics:

a. Kingswell may use cookies, pixels, analytics tools, device identifiers, and similar

technologies to operate the Platform, measure usage, improve functionality, assess

marketing performance, monitor security, identify technical issues, and optimise user

experience.

b. You may restrict cookies through your browser or device settings. Restricting cookies

may affect Platform functionality.

c. Third-party platforms may use their own cookies, analytics, and tracking technologies in

accordance with their own policies.

17. Marketing Communications:

a. Kingswell may send you promotional communications, service recommendations, offers,

updates, and marketing messages where permitted by applicable law.

b. Marketing may be sent through WhatsApp, Telegram, email, SMS, calls, social media, or

Platform notifications.

c. You may opt out of marketing communications by using available unsubscribe methods

or contacting Kingswell at support@kingswell.ae.

d. Even if you opt out of marketing, Kingswell may still send you operational, transactional,

payment, booking, legal, complaint, safety, or account-related communications.

18. User Rights:

a. Subject to applicable law, verification requirements, exemptions, and legal limitations,

you may request:

i. access to Personal Data;

ii. correction of inaccurate Personal Data;

iii. data portability where applicable; and

iv. marketing opt-out.

b. Requests must be sent to support@kingswell.ae.

c. Kingswell may request verification of identity, authority, account ownership, or

additional details before actioning any request.

d. Kingswell may refuse, limit, delay, or condition a request where permitted by law,

including where Personal Data is required for service delivery, legal compliance,

payment records, tax, audit, accounting, dispute resolution, fraud prevention, regulatory

reporting, safety, enforcement of Terms, or legitimate lawful purposes.

e. Submitting a rights request does not automatically suspend payment obligations,

cancellation charges, complaint deadlines, legal rights, provider obligations, or

service-specific conditions.

19. Deletion Requests:

a. You may request deletion of Personal Data by contacting Kingswell.

b. Kingswell may retain Personal Data where necessary or permitted for:

i. pending or completed bookings;

ii. invoices and payment records;

iii. VAT, tax, accounting, and audit requirements;

iv. chargebacks and refunds;

v. complaint handling;

vi. legal claims and evidence;

vii. fraud prevention;

viii. provider performance records;

ix. compliance obligations;

x. enforcement of Terms; or

xi. legitimate lawful business purposes.

c. Deletion of required Personal Data may prevent Kingswell from providing Services,

processing bookings, managing complaints, issuing refunds, or supporting your account.

20. Children and Minors:

a. The Platform is intended for users with legal capacity to enter into transactions.

b. Kingswell does not knowingly provide services directly to minors without appropriate

parent, guardian, or authorised adult involvement where required.

c. Kingswell may refuse, cancel, or restrict services where it reasonably believes that the

user lacks legal capacity or required authority.

21. Uploaded Documents, Photos, and Videos:

a. You may be required to upload or send documents, photographs, videos, identification

documents, vehicle documents, property images, complaint evidence, or other materials.

b. You must ensure that such materials are lawful, accurate, relevant, and do not violate

privacy, confidentiality, intellectual property, reputation, defamation, cybercrime, public

order, or morality requirements.

c. Kingswell may use such materials for service coordination, provider assignment, quality

control, payment verification, complaint handling, legal compliance, dispute resolution,

fraud prevention, and evidence preservation.

22. Security Incidents:

a. If Kingswell becomes aware of a security incident involving Personal Data, Kingswell will

assess the nature, scope, risk, and likely impact of the incident.

b. Kingswell may take reasonable remedial actions, including investigation, access

restriction, system mitigation, provider notification, legal review, user notification, and

regulatory notification where required by law.

c. Kingswell does not guarantee that every incident will require user notification, and

notification will be assessed in accordance with applicable law and risk.

23. Business Transfers:

a. Kingswell may disclose or transfer Personal Data in connection with a proposed or actual

investment, merger, acquisition, financing, restructuring, sale, transfer of assets,

corporate reorganisation, insolvency, or similar transaction.

b. Any recipient may use Personal Data for evaluation, completion, transition,

continuation, or administration of the relevant transaction, subject to applicable law.

24. Amendments to This Privacy Policy:

a. Kingswell may amend, update, replace, or revise this Privacy Policy at any time.

b. Amendments may be made to reflect legal changes, regulatory requirements, Platform

updates, service changes, technology provider changes, payment changes, business

restructuring, operational changes, or risk management requirements.

c. Updated versions may be published on the Platform or made available through

Kingswell’s digital channels.

d. Updates become effective from publication or from the date stated in the updated

Privacy Policy.

e. By continuing to access or use the Platform, submit requests, communicate with

Kingswell, make payments, or receive services after an updated Privacy Policy becomes

available, you acknowledge and agree to the updated Privacy Policy.

25. Acknowledgement and Acceptance:

a. By accessing or using the Platform, submitting a request, providing Personal Data,

making a booking, making payment, or receiving services from Kingswell, you confirm

that you have read, understood, and accepted this Privacy Policy.

b. You further acknowledge that Kingswell may be unable to provide services where

required Personal Data is not provided or where required processing is refused.

26. Contact:

Contact: support@kingswell.ae