Privacy Policy

1. About this policy

This Privacy Policy explains how Alto Turnkey Design Services - FZCO ("alto", "we", "us" or "our"), a free zone company licensed by the Dubai Integrated Economic Zones Authority (IFZA) under Trade Licence No. 88580, with registered address DSO-IFZA, IFZA Properties, Dubai Silicon Oasis, Dubai, United Arab Emirates collects, uses, shares and protects your personal data when you visit altofurnishing.com (the "Site"), enquire about or use our services, register as a referral partner, hold a client or agent account, or otherwise interact with us.

It also explains your rights under UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (the "PDPL") and its implementing regulations, and how to exercise them.

Please read this policy together with our Terms & Conditions. By using the Site or providing us with your personal data, you acknowledge that you have read and understood this policy.

2. Who we are

Alto Turnkey Design Services - FZCO ("alto", "we", "us" or "our"), a free zone company licensed by the Dubai Integrated Economic Zones Authority (IFZA) under Trade Licence No. 88580, with registered address DSO-IFZA, IFZA Properties, Dubai Silicon Oasis, Dubai, United Arab Emirates is the controller responsible for your personal data — that is, the party that determines how and why it is processed.

If you have any question about this policy or about how we handle your personal data, contact us at hello@altofurnishing.com.

3. The personal data we collect

We collect personal data that you provide to us, that we collect automatically when you use the Site, and that we receive from third parties.

Information you provide to us includes:

• Identity and contact details — your name, email address, telephone number (and its country code), and company or agency name.
• Enquiry and booking details — the content of the messages you send us, and the information you provide when you book a consultation (including scheduling details handled by our booking provider).
• Referral partner details — where you register as an agent: professional information such as your speciality, sale type, areas of focus and role; and, where you join our referral programme, payout details such as beneficiary name and bank account (IBAN).
• Order and property details — where you configure or place an order: information about your property, your package selections, and delivery and installation details.
• Payment information — where you pay online, your payment is processed securely by Stripe, our third-party payment provider; we receive confirmation and limited transaction details but do not store full card numbers.
• Account details — where you hold a client or agent portal account: your login credentials and your activity within the portal.
• Correspondence — records of your communications with us by email, telephone, messaging or other channels.

Information we collect automatically includes:

• Technical and usage data — such as your IP address, approximate location, device and browser type, and the pages you view and how you interact with the Site, collected through our hosting platform's privacy-friendly analytics, which report aggregate usage and do not identify you individually.
• Cookies and similar technologies — see section 5 below.

Information we receive from third parties includes information from referral partners or agents who introduce you to us, from our service providers (such as our booking, payment and automation providers), and from publicly available sources.

4. How and why we use your personal data

We use your personal data to:

• respond to your enquiries and provide information about our services;
• schedule, prepare for and conduct consultations;
• prepare quotations, configure packages, and process and fulfil orders, including delivery and installation;
• process payments and maintain financial and accounting records;
• administer our referral programme, including calculating and paying referral rewards;
• create, manage and secure client and agent portal accounts;
• operate, maintain, secure, personalise and improve the Site and our services;
• send you service and transactional messages, such as confirmations, account notices and updates;
• comply with our legal, regulatory, tax and accounting obligations; and
• establish, exercise or defend legal claims, and prevent fraud or misuse.

Under the PDPL, we process your personal data where one or more of the following applies: you have given your consent; the processing is necessary to enter into or perform a contract with you; the processing is necessary to comply with a legal obligation to which we are subject; or the processing is necessary for our legitimate interests in operating, securing and improving our business, provided those interests are not overridden by your rights and freedoms.

5. Cookies and analytics

Our Site uses a limited number of cookies and similar technologies:

• Essential cookies — necessary for the Site to load and function correctly.
• Analytics — we use our website platform's built-in, privacy-friendly analytics to understand aggregate Site usage. This is designed to operate without tracking cookies and does not identify you individually.
• Third-party cookies — certain pages, such as our consultation booking page, load tools provided by third parties (for example our scheduling provider), which may set their own cookies. Those cookies are governed by the relevant provider's own privacy policy.

You can control or delete cookies through your browser settings. Disabling some cookies may affect how parts of the Site work.

6. Marketing communications

At present we use your details primarily to respond to you and to provide our services, and we send service and transactional messages relating to your enquiry, order or account.

If we send marketing communications in the future, we will do so only where permitted by law and, where required, with your consent. You will be able to opt out of marketing at any time, using the unsubscribe link in any marketing email or by contacting us. Opting out of marketing does not stop essential service or transactional messages.

7. How we share your personal data

We do not sell your personal data. We share it only where necessary, with:

• Service providers who process personal data on our behalf and on our instructions, including our website hosting and analytics provider, our consultation-scheduling provider, our workflow-automation and database (CRM) providers, our email provider, and our payment provider (Stripe). These providers are bound by confidentiality and data-protection obligations and may only use your data to provide services to us.
• Professional advisers, such as our lawyers, accountants, auditors and insurers, where necessary.
• Authorities, regulators or law-enforcement bodies, where we are required to do so by law or to establish, exercise or defend legal rights.
• A successor entity, in connection with a sale, merger, financing or reorganisation of our business, subject to appropriate confidentiality protections.

8. International transfers

We are based in the United Arab Emirates. Some of our service providers are located outside the UAE, which means your personal data may be transferred to, stored in, or accessed from other countries.

Where we transfer personal data outside the UAE, we take steps to ensure it remains protected in accordance with the PDPL — for example by transferring to jurisdictions recognised as providing an adequate level of protection, by putting appropriate contractual safeguards in place, or on the basis of your consent, as permitted by law.

9. How we protect your personal data

We maintain appropriate technical and organisational measures designed to protect your personal data against unauthorised or unlawful access, loss, misuse, disclosure or alteration.

No method of transmission over the internet or of electronic storage is completely secure, and while we work to protect your personal data we cannot guarantee its absolute security. You are responsible for keeping any portal login credentials confidential and for notifying us of any suspected unauthorised use.

10. How long we keep your personal data

We keep your personal data only for as long as necessary for the purposes set out in this policy — including to provide our services, maintain your account, operate our referral programme, and meet our legal, tax and accounting obligations.

Retention periods vary depending on the nature of the data and the applicable legal requirements. When your personal data is no longer needed, we securely delete or anonymise it.

11. Your rights

Subject to the PDPL and any applicable conditions and exemptions, you have the right to:

• be informed about how we process your personal data;
• request access to the personal data we hold about you;
• request correction of personal data that is inaccurate or incomplete;
• request the erasure of your personal data;
• request that we restrict or stop processing your personal data;
• object to the processing of your personal data;
• request the transfer of certain of your personal data to you or another party (portability);
• withdraw your consent at any time, without affecting the lawfulness of processing carried out before withdrawal; and
• lodge a complaint with the UAE Data Office.

12. How to exercise your rights

To exercise any of these rights, contact us at hello@altofurnishing.com. We may ask you to verify your identity before we respond, to protect your data.

We will respond within the timeframes required by law. Exercising your rights is normally free of charge, although we may charge a reasonable fee, or decline to act, where a request is manifestly unfounded or excessive, as permitted by law. In some cases, fulfilling a request may mean we can no longer provide certain services to you.

13. Children's data

Our Site and services are directed at property investors and industry professionals and are not intended for children under 18. We do not knowingly collect personal data from children. If you believe a child has provided us with personal data, please contact us and we will delete it.

14. Third-party sites and services

Our Site links to other services we operate, including our order configurator and our client and agent portals, and may link to external websites. This policy does not cover third-party websites or services, and we are not responsible for their content or privacy practices. Please review the privacy policy of any third-party service before providing it with your personal data.

15. Automated decision-making

We do not make decisions that produce legal effects concerning you, or that similarly significantly affect you, based solely on automated processing of your personal data.

16. Changes to this policy

We may update this policy from time to time to reflect changes in our practices or in the law. The current version is always available on the Site, and the "Last updated" date below shows when it was last revised. Where changes are material, we will take reasonable steps to notify you.

17. Contact us

This Site and your personal data are controlled by Alto Turnkey Design Services - FZCO ("alto", "we", "us" or "our"), a free zone company licensed by the Dubai Integrated Economic Zones Authority (IFZA) under Trade Licence No. 88580, with registered address DSO-IFZA, IFZA Properties, Dubai Silicon Oasis, Dubai, United Arab Emirates.

For any privacy question, or to exercise your rights, email us at hello@altofurnishing.com. You also have the right to contact the UAE Data Office, the federal supervisory authority for data protection in the United Arab Emirates, if you have concerns about how your personal data is handled.