# Privacy Policy
**Last updated: [DATE]**
## 1. Introduction
Welcome to Phoenix Car Keys.
Phoenix Car Keys provides an online booking and dispatch service that connects customers in the United Arab Emirates with independent local automotive locksmiths and service providers.
This Privacy Policy explains how **[FULL LEGAL COMPANY NAME]**, trading as **Phoenix Car Keys** (“Phoenix Car Keys”, “we”, “us” or “our”), collects, uses, stores, shares and protects your personal information when you:
* visit our website;
* contact us by telephone, WhatsApp, email, online form or another communication channel;
* request or book an automotive locksmith service;
* make a booking payment or booking fee payment;
* communicate with one of our customer service representatives; or
* otherwise use our services.
For the purposes of applicable data protection law, the data controller is:
**[FULL LEGAL COMPANY NAME]**
Company registration number: **[REGISTRATION NUMBER]**
Registered address: **[REGISTERED ADDRESS]**
Email: **[PRIVACY EMAIL ADDRESS]**
Telephone: **[TELEPHONE NUMBER]**
Where services are provided through a locally registered UAE entity, its details should also be stated here:
**[UAE LEGAL ENTITY NAME, IF APPLICABLE]**
Trade licence number: **[LICENCE NUMBER]**
Registered address: **[UAE ADDRESS]**
## 2. Personal Information We Collect
Depending on how you interact with us, we may collect the following information:
### 2.1 Contact information
* your name;
* telephone number;
* email address;
* WhatsApp or other messaging details; and
* your preferred method of communication.
### 2.2 Service and booking information
* your current location or the location where assistance is required;
* vehicle make, model, registration number and approximate year;
* information about the key, lock, immobiliser or access problem;
* photographs or videos voluntarily provided by you;
* booking date and time;
* call recordings, messages and service notes;
* information concerning cancellation, attendance and completion of the service; and
* details of the locksmith or service provider assigned to the booking.
Please do not provide unnecessary sensitive information through our website, telephone service, WhatsApp or online forms.
### 2.3 Payment and transaction information
We may collect:
* the amount paid;
* transaction date and status;
* booking fee or deposit details;
* refund information; and
* limited payment-related information supplied by our payment processor.
Payment card details are normally processed directly by an authorised third-party payment provider. We do not normally receive or store your complete card number or security code.
### 2.4 Website and technical information
When you use our website, certain information may be collected automatically, including:
* IP address;
* browser type and version;
* device type;
* operating system;
* approximate location derived from your IP address;
* referring website or advertisement;
* date and time of access;
* pages visited;
* links selected;
* form interactions;
* cookie identifiers; and
* website performance and diagnostic information.
## 3. How We Collect Your Information
We may collect information:
* directly from you;
* through our website and booking forms;
* during telephone calls;
* through WhatsApp, SMS, email or social media;
* from the locksmith or service provider assigned to your booking;
* from payment processors;
* through cookies and similar technologies;
* from advertising and analytics providers; and
* from publicly available sources where permitted by law.
## 4. How We Use Your Information
We may process your information to:
* respond to your enquiry;
* assess your automotive locksmith requirements;
* identify and contact an available local locksmith;
* arrange and administer your booking;
* provide your relevant booking details to the assigned locksmith;
* confirm your identity, vehicle details and service location;
* communicate arrival estimates, pricing information and service updates;
* process booking fees, payments and refunds;
* manage cancellations, complaints and disputes;
* provide customer support;
* monitor the quality and safety of our services;
* prevent fraud, misuse and unauthorised bookings;
* maintain business, financial and service records;
* comply with legal, regulatory, tax and accounting obligations;
* improve our website, advertising and customer service;
* analyse website traffic and advertising performance; and
* send marketing communications where you have consented or where otherwise permitted by applicable law.
We will not use your personal information for purposes that are materially incompatible with those described in this Privacy Policy unless we inform you or obtain any consent required by law.
## 5. Legal Grounds for Processing
Depending on the circumstances, we may process personal information on one or more of the following grounds:
* your consent;
* taking steps at your request before entering into an agreement;
* performing our agreement with you;
* complying with a legal obligation;
* protecting the rights and interests of you or another person;
* establishing, exercising or defending legal claims; and
* pursuing our legitimate business interests where permitted by applicable law and where those interests do not improperly override your privacy rights.
Where processing is based on consent, you may withdraw that consent by contacting us. Withdrawal will not affect processing lawfully carried out before consent was withdrawn.
## 6. Sharing Information with Local Locksmiths
Phoenix Car Keys may act as a booking, dispatch or referral service. The locksmith who attends your location may be an independent local service provider rather than an employee of Phoenix Car Keys.
To arrange the requested service, we may share relevant information with an available locksmith or service provider, including:
* your name;
* telephone number;
* service location;
* vehicle details;
* the nature of the problem;
* photographs or other information you provide; and
* booking and timing information.
We will only share information that is reasonably necessary to arrange or provide the requested service.
Once an independent locksmith receives your information, that locksmith may have separate legal responsibilities regarding its use and protection. Where appropriate, customers should review the locksmith’s own privacy information.
## 7. Other Parties with Whom We May Share Information
We may also share personal information with:
* website hosting and IT service providers;
* customer relationship management and telephone system providers;
* payment processors and banks;
* email, SMS and messaging service providers;
* analytics and advertising providers, including Google;
* professional advisers, including lawyers, accountants and insurers;
* fraud prevention and security providers;
* government authorities, regulators, courts or law-enforcement agencies where required by law; and
* potential purchasers, investors or professional advisers in connection with a legitimate corporate transaction.
We do not sell your personal information to third parties.
We may disclose information where reasonably necessary to comply with applicable law, respond to a lawful request, protect customers or service providers, prevent fraud or protect our legal rights.
## 8. International Transfers
Phoenix Car Keys, its website infrastructure, customer service operations, payment providers or other service providers may be located outside the United Arab Emirates, including in the United Kingdom or other countries.
As a result, personal information collected from customers in the UAE may be accessed, stored or processed outside the UAE.
Where we transfer personal information internationally, we will take reasonable steps to ensure that the transfer is made in accordance with applicable data protection requirements and that appropriate contractual, organisational or technical safeguards are used where required.
By requesting a service, you acknowledge that relevant booking information may need to be shared between Phoenix Car Keys, its systems and the local locksmith assigned to your request.
## 9. Google Ads, Analytics and Advertising
We may use Google Ads, Google Analytics and similar services to:
* understand how visitors use our website;
* measure advertising performance;
* identify which advertisements or search terms resulted in enquiries;
* prevent advertising fraud;
* improve our website and advertising campaigns; and
* display relevant advertisements to previous website visitors where permitted.
These providers may collect device information, IP addresses, cookie identifiers and information about your interaction with our website and advertisements.
You can manage non-essential cookies through our cookie banner or browser settings. Google also provides its own tools for managing advertising preferences.
## 10. Cookies
Our website may use cookies and similar technologies.
Cookies are small files placed on your device that help a website function, remember preferences, analyse usage and measure advertising performance.
We may use:
* **strictly necessary cookies**, required for the website and booking functions to operate;
* **functionality cookies**, which remember preferences;
* **analytics cookies**, which help us understand website usage; and
* **advertising cookies**, which help measure campaigns and deliver relevant advertisements.
Where required, non-essential cookies will not be activated until you have made a selection through our cookie consent tool.
You may change your cookie preferences or delete cookies through your browser. Disabling certain cookies may affect website functionality.
Further information should be provided in our separate Cookie Policy or cookie settings panel.
## 11. Telephone Calls and Messages
Calls with Phoenix Car Keys may be recorded or monitored for:
* training;
* quality assurance;
* booking verification;
* complaint handling;
* fraud prevention; and
* establishing what was agreed between the customer and Phoenix Car Keys.
Where calls are recorded, we will provide an appropriate notification where required.
Messages sent through WhatsApp, SMS or other third-party platforms may also be processed by the operator of that platform under its own privacy terms.
## 12. Data Retention
We retain personal information only for as long as reasonably necessary for the purposes for which it was collected, including:
* arranging and completing the requested service;
* handling refunds, cancellations and complaints;
* maintaining financial and transaction records;
* complying with tax, accounting and regulatory requirements;
* preventing fraud; and
* establishing, exercising or defending legal claims.
Different categories of information may be retained for different periods.
When personal information is no longer required, we will take reasonable steps to delete, anonymise or securely dispose of it, subject to any legal requirement to retain it.
## 13. Data Security
We use reasonable technical and organisational measures intended to protect personal information against:
* unauthorised access;
* accidental loss;
* misuse;
* alteration;
* disclosure; and
* destruction.
These measures may include access restrictions, passwords, secure systems, encryption where appropriate, staff procedures and service-provider controls.
However, no website, telephone system, messaging platform or internet transmission can be guaranteed to be completely secure. You provide information electronically at your own risk, subject to your rights under applicable law.
We will never ask you to send your full payment card security code through WhatsApp, email or an ordinary website message.
## 14. Your Rights
Subject to applicable law and any relevant exceptions, you may have the right to:
* request information about the personal data we process;
* request access to your personal data;
* request correction of inaccurate or incomplete information;
* request deletion of personal information;
* request restriction or suspension of certain processing;
* object to certain processing;
* request transfer of your information where applicable;
* withdraw consent where processing is based on consent;
* object to direct marketing;
* request review of certain automated decisions, where applicable; and
* submit a complaint to the relevant authority.
To exercise any of these rights, contact us using the details in Section 19.
We may request reasonable evidence of identity before responding. Certain requests may be refused or limited where permitted by law, including where information must be retained for legal, financial, fraud-prevention or dispute-resolution purposes.
## 15. Marketing Communications
We may send you information about our services, promotions or related products where:
* you have provided consent; or
* marketing is otherwise permitted by applicable law.
You may opt out at any time by:
* selecting the unsubscribe option in an email;
* replying “STOP” where that option is provided;
* contacting us by email or telephone; or
* following the instructions included in the communication.
Opting out of marketing will not prevent us from sending essential booking, service, payment, safety or account-related communications.
## 16. Children’s Privacy
Our services are not intended to be booked independently by children.
We do not knowingly collect personal information from children without appropriate authorisation. If you believe that a child has provided us with personal information without appropriate consent, please contact us so that we can investigate and take appropriate action.
## 17. External Links
Our website may contain links to websites or services operated by third parties.
We do not control and are not responsible for the privacy practices, security or content of third-party websites. You should review the privacy policy of any external website before providing personal information.
## 18. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect:
* changes to our business;
* changes to the services we provide;
* changes to our technology or service providers; or
* changes to legal or regulatory requirements.
The revised version will be published on this page with an updated “Last updated” date.
Where an update materially affects how we use personal information, we will provide additional notice where reasonably appropriate or legally required.
## 19. Contact Us
For privacy questions, requests or complaints, contact:
**Phoenix Car Keys**
Legal entity: **[FULL LEGAL COMPANY NAME]**
Registered address: **[REGISTERED ADDRESS]**
UAE address, if applicable: **[UAE ADDRESS]**
Email: **[PRIVACY EMAIL ADDRESS]**
Telephone: **[TELEPHONE NUMBER]**
Please include sufficient information for us to identify your booking and understand your request, but do not send full payment card details or unnecessary sensitive information.
If you are not satisfied with our response, you may also have the right to submit a complaint to the relevant data protection, consumer protection or regulatory authority.