1. Introduction and Scope
BALUMA VENTURES F.Z.E trading as "ZEO" ("ZEO," "we," "us," "our"), licensed by the Free Zones Authority of Ajman under trade license number 55541, respects your privacy and is committed to protecting your personal data in accordance with UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data ("PDPL") and related UAE legislation, including Federal Law No. 15 of 2020 (Consumer Protection Law) and Federal Decree-Law No. 34 of 2021 (Cybercrime).
This Privacy Policy explains what personal data we collect through zeobeauty.ae and related channels (the "Site"), why we collect it, how we use and protect it, and the rights you have over it. It applies to all visitors, registered users, and customers, regardless of where you access the Site from.
2. Personal Data We Collect
We may collect the following categories of personal data:
| Category | Examples |
|---|---|
| Identity data | Full name, title, date of birth (if provided for promotions) |
| Contact data | Email address, phone number, delivery and billing address, Emirate/country |
| Account data | Username, password (encrypted), account preferences, order history |
| Transaction data | Order details, products purchased, payment method type, invoice/TRN records (we do not store full card numbers — these are processed directly by our PCI-compliant payment provider) |
| Technical data | IP address, browser type, device identifiers, operating system, referral source |
| Usage data | Pages viewed, products browsed, cart activity, session duration, click behavior (via cookies — see Section 5) |
| Marketing preferences | Your consent status for email/SMS/WhatsApp marketing, communication history (managed via our "Notify Me" and newsletter sign-ups) |
| Customer support data | Correspondence, complaints, and any information you provide when contacting us |
We do not intentionally collect health, biometric, religious, or other special-category data. If you voluntarily disclose skin condition information to our customer service team (e.g., to request a product recommendation or report an allergic reaction), we treat this as sensitive data and process it only for that purpose with your consent.
3. How We Collect Your Data
- Directly from you: when you create an account, place an Order, subscribe to marketing via "Notify Me" or the newsletter, submit a review, or contact customer support.
- Automatically: through cookies and similar technologies when you browse the Site (see Section 5).
- From third parties: payment processors (confirming payment success/failure), delivery/courier partners (confirming delivery status), and, where applicable, social media platforms if you interact with us via Instagram/Facebook.
4. How and Why We Use Your Data (Legal Basis)
| Purpose | Legal basis under PDPL |
|---|---|
| Processing and delivering your Orders, issuing invoices | Performance of a contract with you |
| Customer support and handling complaints | Performance of a contract / legitimate interest |
| Sending order confirmations, shipping updates, and service messages | Performance of a contract |
| Sending marketing communications (new products, offers, "Notify Me" launch updates) | Your explicit consent (opt-in), withdrawable at any time |
| Fraud prevention, account security, and abuse monitoring | Legitimate interest |
| Complying with UAE tax, invoicing, consumer protection, and other legal obligations | Legal obligation |
| Improving the Site, analyzing browsing behavior, and personalizing content | Consent (via cookie settings) / legitimate interest |
We will never sell your personal data to third parties.
5. Cookies and Similar Technologies
We use cookies and similar technologies to operate the Site (essential cookies), remember your preferences (functional cookies), and understand how visitors use the Site so we can improve it (analytics cookies), and, where you consent, to show you relevant advertising (marketing cookies).
You can manage or withdraw cookie consent at any time through the cookie banner on the Site or your browser settings. Disabling non-essential cookies may affect certain features (e.g., saved cart, personalized recommendations) but will not prevent you from browsing or ordering.
6. Sharing and Disclosure of Your Data
We disclose personal data only as necessary to:
- Payment processors (e.g., card payment gateway) to complete and secure your transactions.
- Courier and logistics partners to deliver your Order and provide tracking.
- IT, hosting, and platform providers (e.g., our website hosting and e-commerce infrastructure providers) who process data on our behalf under contractual confidentiality and security obligations.
- Marketing and email platforms (e.g., our newsletter/CRM tool that powers hello@zeobeauty.ae and "Notify Me" sign-ups) and analytics platforms, only for the purposes described in Section 4 and subject to your consent where required.
- Professional advisors and regulators where necessary to comply with UAE law, respond to a lawful request from a UAE court or government authority, or protect our legal rights.
- A successor entity in the event of a merger, acquisition, or sale of ZEO's business, subject to that entity continuing to honor this Privacy Policy (or notifying you of any material change).
We require all third-party processors to protect your data with security measures at least equivalent to those described in Section 9 and to use it only for the purposes we specify.
7. Cross-Border Data Transfers
Some of our service providers (such as payment, hosting, email marketing, or analytics platforms) may process data outside the UAE, including in the European Union or the United States.
Where we transfer personal data outside the UAE, we rely on one or more of the safeguards recognized under Articles 22–23 of the PDPL:
- transferring data to a country that maintains an adequate level of data protection, or with which the UAE has a relevant data-protection agreement; or
- putting in place a binding contract with the recipient that imposes obligations equivalent to the PDPL; or
- relying on your explicit consent for a specific transfer; or
- where the transfer is necessary to perform our contract with you (for example, processing a payment or shipment).
You may contact us at info@zeobeauty.ae for more information about the specific safeguards applicable to a given transfer.
8. Data Retention
We retain personal data only for as long as necessary to fulfil the purposes described in this Policy, including:
- Order and invoice records: retained for the period required by UAE tax and commercial record-keeping law (generally at least 5 years).
- Account data: retained while your account is active, and for a reasonable period after closure to handle any related claims.
- Marketing data: retained until you withdraw consent or unsubscribe, after which we suppress your details from further marketing use.
- Customer support correspondence: retained for as long as needed to resolve your query and defend against any related claim.
When data is no longer needed, we securely delete or anonymize it.
9. Data Security and Breach Notification
We implement appropriate technical and organizational measures to protect your personal data, including encryption of data in transit (SSL/TLS), access controls, and PCI-compliant payment processing.
In the event of a personal data breach that is likely to result in a risk to your rights, we will notify the UAE Data Office within 72 hours of becoming aware of the breach and will notify affected individuals without undue delay, in accordance with the PDPL.
10. Your Rights
Under the PDPL, you have the right to:
- Be informed about how your personal data is processed (this Policy);
- Access the personal data we hold about you;
- Correct inaccurate or incomplete data;
- Erase your data, subject to legal retention obligations (e.g., invoicing records);
- Restrict or object to certain processing, including direct marketing;
- Data portability, where technically feasible; and
- Withdraw consent at any time where processing is based on consent, without affecting the lawfulness of processing carried out before withdrawal.
To exercise any of these rights, contact us using the details in Section 12. We will respond within a reasonable time and, where we cannot fulfil a request (for example, due to a legal retention obligation), we will explain why.
11. Children's Data
The Site is not directed at children. We do not knowingly collect personal data from individuals under 18. If you believe a child has provided us with personal data, please contact us so we can delete it.
12. Privacy Contact
For any question, request, or complaint about this Privacy Policy or our handling of your personal data, please contact:
Privacy Contact: ZEO Customer Care Email: info@zeobeauty.ae (for data access/correction/erasure requests) or support@zeobeauty.ae (if related to an existing order) Company: BALUMA VENTURES F.Z.E Address: Office B.C. 1308278, Ajman Free Zone C1 Building, Ajman Free Zone, Ajman, United Arab Emirates
If you are not satisfied with our response, you may also lodge a complaint with the UAE Data Office, the regulator responsible for enforcing the PDPL.
13. Marketing Consent and Opt-Out
We only send marketing communications if you have opted in (e.g., at checkout, account sign-up, or by clicking "Notify Me" on the Site). These emails are sent from hello@zeobeauty.ae. You can withdraw consent at any time by clicking "unsubscribe" in any marketing email, adjusting your account preferences, or emailing hello@zeobeauty.ae. We will action opt-out requests promptly and will continue to send essential transactional communications (e.g., order confirmations) regardless of your marketing preference, as these are necessary to perform our contract with you.
14. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices or UAE law. We will post the updated version on the Site with a revised "Last updated" date, and where changes are material, we will provide additional notice (e.g., by email or a Site banner).