1. INTRODUCTION

This Privacy Notice describes how Xcite, the owner and/or operator of this Site, collects and Processes your Personal Data for the promotion, fulfillment and provision of Xcite Services. By visiting this Site, providing your Personal Data or checking or purchasing Xcite Services, you expressly agree to be bound by the terms and conditions of this Privacy Notice. If you do not agree, please do not use or access this Site or use any Xcite Services.

2. DEFINITIONS

“Affiliate” means, with respect to any person or entity, any other person or entity who, directly or indirectly, through one or more intermediaries, Controls, is Controlled by or is under common Control with such person or entity;

“Alghanim Services” means the products and services offered by Alghanim online on any website, in showrooms and/or service and call centers; including without limitation the Xcite Services;

“Alghanim” means the group of companies composes of Xcite and all its Affiliates under Alghanim Industries;

“Applicable Laws” means any Personal Data privacy or protection law, statute, treaty, rule, regulation, regulatory or legislative requirement, ordinance, license, restriction, judicial or administrative order, code, common law or other pronouncement having the effect of law in the State of Kuwait;

“Child” means is a natural person who has not attained 20 years of age;

“Control” including the terms “controlling”, “controlled by” and “under common control with” means the possession, directly or indirectly, of more than 50% of the power to direct or cause the direction of the management and policies of a person or entity, whether through the ownership of voting securities, as trustee or executor or as general partner, by contract or otherwise, including the ownership, directly or indirectly, of securities having the power to elect a majority of the board of directors or similar body governing the affairs of such person or entity;

“Data Subject” or “you” means an identified or identifiable living individual natural person to whom Personal Data relates and that is using this Site or Xcite Services;

“Personal Data” means any information relating to a Data Subject who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that Data Subject;

“Privacy Notice” means this set of terms and conditions that regulates the Processing of the Personal Data;

“Processing”means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;

“Site”means the website, the primary home page of which is identified by the url www.xcite.com and any mobile device application or desktop application, developed by Alghanim or on its behalf, and any successor or replacement of such;

“Sensitive Personal Data”means Personal Data that reveals your racial or ethnic origin, religious, political or philosophical beliefs or trade union membership, genetic data, biometric data for the purposes of unique identification;

“Xcite” or “we” means Xcite General Trading Co. SPC; and

“Xcite Services” means the products and services offered by Xcite whether online on this Site or any other website, in showrooms and/or service and call centers that reference to this Privacy Policy.

3. WHAT PERSONAL DATA DO WE COLLECT

We collect your Personal Data in order to provide and continually improve Xcite Services. We collect the various types of Personal Data:

3.1 Personal Data provided by Data Subject.

In order to provide seamless customer experience, we receive and store your Personal Data in relation to Xcite Services, including without limitation:

• A) name, address and phone numbers;
• B) payment information;
• C) age.
• D) personal description and photograph in your profile.
• E) information and documents regarding identity, including Civil ID, National ID and driver's license numbers.
• F) financial information.
• G) CCTV records in Alghanim showrooms and service and customer care centers and.
• H) credit history information.

3.2 Automated Information

We automatically collect and store certain types of Personal Data about your use of Alghanim Services. We use “cookies” and other unique identifiers, and we obtain certain types of Personal Data when your web browser or device accesses Alghanim Services. We may collect automatic Personal Data from, including without limitation:

• A) the internet protocol (IP) address used to connect your computer to the internet;
• B) login, email address and password.
• C) the location of your device or computer.
• D) device metrics such as when a device is in use, application usage, connectivity data, and any errors or event failures.
• E) version and time zone settings; and.
• F) purchase history.

3.3 Information from other Sources

We might receive Personal Data about you from third-parties’ sources including Alghanim, such as updated delivery and address Personal Data from our carriers, which we use to correct our records and deliver your next purchase more easily. However, we are not responsible for the privacy practices of such third-party websites which we do not own, manage or control. We may collect Personal Data from other sources, including without limitation:

• A) updated delivery and address information from third parties.
• B) search results and links, including paid listings.
• C) third-parties’ applications or websites through which you allow us to collect, share and/or use your Personal Data; and.
• D) third-parties’ sources that provides marketing or demographic information about you to enhance our ability to tailor our content and offer you Alghanim Services that we believe may be of interest to you.

4. FOR WHAT PURPOSES DO WE USE YOUR PERSONAL DATA

Alghanim uses your Personal Data to operate, provide, develop and improve Alghanim Services, including without limitation:

4.1 Purchase, Delivery and Promotion

Alghanim uses your Personal Data to take and handle orders, deliver products and services, process payments and communicate with you about orders, products, services and promotional offers of Alghanim Services.

4.2 Alghanim Business Purposes

When applicable, Alghanim uses your Personal Data to marketing to you, answering your queries, considering your employment application, running data analysis, and for administrative purposes and for accounting, tax and audit requirements.

4.3 Provide troubleshoot and Improve Alghanim Services.

Alghanim uses your Personal Data to provide functionality, analyze performance, fix errors and improve the usability and effectiveness of Alghanim Services.

4.4 Recommendations and Personalization

Alghanim uses your Personal Data to recommend products and services that might be of interest to you, identify your preferences, and personalize your experience with Alghanim.

4.5 Comply with Legal Obligations

In certain cases, Alghanim collects and uses your Personal Data to comply with the Applicable Laws.

4.6 Communicate with You

Alghanim uses your Personal Data to communicate with you in relation to Alghanim Services via different channels (e.g., by phone, email).

4.7 Advertising

Alghanim uses your Personal Data to display interest-based ads for features, products, and services that might be of interest to you. Alghanim does not use Personal Data that personally identifies you to display interest-based ads.

4.8 Fraud Prevention and Credit Risks

Alghanim uses your Personal Data to prevent and detect fraud and abuse in order to protect the security of Xcite and Alghanim and their customers. Alghanim may also use scoring methods to assess and manage risks.

5. DISCLOSURE AND SHARING OF YOUR PERSONAL DATA

5.1We may share your Personal Data within Alghanim to provide you access to Alghanim Services. Alghanim may market to you Alghanim Services as a result of such sharing unless you explicitly opt-out.

5.2 Alghanim may be required to disclose and share your Personal Data to comply with the legal obligations, and to prevent, detect, mitigate, and investigate fraudulent or illegal activities related to Alghanim Services. Alghanim may disclose Sensitive Personal Data to government agencies or other authorized law enforcement agencies if it is required to do so by law or in good faith that such disclosure is reasonably necessary to respond to subpoenas, court orders, or other legal process. Alghanim may disclose Personal Data to law enforcement offices, third party rights owners, or others in the good faith belief that such disclosure is reasonably necessary to enforce its terms or Privacy Notice, respond to claims that an advertisement violates the rights of a third party or protect the rights, property or personal safety of its users or the general public.

5.3 nim might share your Personal Data with its third-party vendors and service providers (including without limitation the service providers of this Site solutions and the sellers on this Site), when required for its business purposes to conduct and facilitate Alghanim Services and its marketing and advertising activities.

5.4 Alghanim will share some or all your Personal Data with another business entity should we plan to merge with, or be acquired by that business entity, or re-organization, amalgamation, restructuring of business. Should such a transaction occur, that other business entity (or the new combined entity) will be required to follow terms at least as extensive as this Privacy Notice with respect to your Personal Data.

6. DATA SUBJECT RIGHTS

Where we Process your Personal Data, you have a number of rights over how the Personal Data is Processed and you can exercise these rights at any point. We have provided an overview of these rights below together with what this entails for you. You can exercise your rights by submitting a Data Subject Rights (DSR) request form available on this Site.

6.1 Right to be Informed

You have the right to be provided with clear, transparent, and easily understandable information about how we use your Personal Data.

6.2 Right to Access

You have the right to receive a copy of the Personal Data that we hold about you and to check that we are lawfully Processing it as per the Applicable Laws.

6.3 Right to Rectification

You have the right to rectify any incomplete or inaccurate Personal Data that we hold about you. We may need to verify the accuracy of any new Personal Data that you provide to us.

6.4 Right to Erasure

You have the right to ask us to delete or remove Personal Data where there is no good reason for us continuing to Process it. However, we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

6.5 Right to Object

In case it is proven that we are not compliant with this Privacy Notice or the Applicable Laws, you have the right to object to certain types of Processing, including Processing for direct marketing (i.e., receiving emails from us notifying you or being contacted with varying potential opportunities).

6.6 Right to Restrict Data Processing.

You have the right to restrict the Processing of your Personal Data in the following scenarios:

• A) if you want us to establish the Personal Data’s accuracy;
• B) where our use of the data is unlawful, but you do not want us to erase it;
• C) where you need us to hold the Personal Data even if we no longer require it as you need it to establish, exercise or defend legal claims; and
• D) you have objected to our Process of your Personal Data, but we need to verify whether we have overriding legitimate grounds to use it.

6.7 Right to Data Portability.

We shall provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used and machine readable format. This means it can be moved, copied or transmitted electronically under certain circumstances.

6.8 Right to Withdraw Consent.

Your consent to this Privacy Policy as stated hereunder is the legal basis of Alghanim Processing to your Personal Data. However, you have the right to withdraw your consent at any time; nonetheless if you do so, it does not mean that the Processing of your Personal Data with your consent up to that successful withdrawal is unlawful. You can withdraw your consent to the Processing of your Personal Data at any time by contacting us at dpo@alghanim.com

6.9 Rights to Automated Decision-making and Profiling:

You have the right not to be subject to a decision which is based solely on automated Processing and which produces legal or other significant effects on you. In particular, you have the right to:

• A) obtain human intervention;
• B) express your point of view; and
• C) obtain an explanation of the decision reached after an assessment.

6.10 Right to Lodge a Complaint to the Competent Data Protection Authority.

lodge a complaint to the Competent Data Protection Authority in case you consider that the Processing of your Personal Data infringes any of your rights or provisions related to the Applicable Laws.

7. FEES FOR EXCESSIVE OR UNREASONABLE REQUESTS

You will not have to pay a fee to access your Personal Data or to exercise any of the other rights. However, we may charge a reasonable fee if we believe that your request for access unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

8. TIMELINES TO RESPOND TO DATA SUBJECT REQUESTS

We try to respond to all legitimate requests within 30 days. Occasionally, it may take us longer if your request is particularly complex or you have made a number of requests. In this case, we shall notify you and keep you updated.

9. WHAT WE MAY NEED FROM YOU

We may need to request specific information from you to help us confirm your identity and ensure your right to access the Personal Data (or to exercise any of your other rights). This is another appropriate security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. If you wish to exercise any of the rights set out above, please contact us atdpo@alghanim.com.

10. PERSONAL DATA OF CHILDREN

We do not knowingly solicit or collect Personal Data from Childs. If you have shared any Personal Data of a Child, you represent and warrant that you have the authority to do so and permit Alghanim to use the Personal Data in accordance with this Privacy Notice.

11. HOW LONG WE RETAIN YOUR PERSONAL DATA

Alghanim retains your Personal Data in accordance with Appliable Laws, for a period no longer than is required for the purpose for which it was collected or as required under Applicable Laws.

Alghanim retains your Personal Data where it has legitimate interest, performance of the contract, vital interest of Data Subject or of another natural person, performance of a task carried out in the public interest or in the exercise of official authority vested or for the purposes of satisfying any legal, accounting, or other regulatory reporting requirements or with your consent. After that, Alghanim will either delete it or anonymize it so that it cannot be linked back to you. However, Alghanim may retain your Personal Data if it believes it may be necessary to prevent fraud or future abuse, to enable Alghanim to exercise its legal rights and/or defend against legal claims or if required by the Applicable Laws or for other legitimate purposes. Alghanim may continue to retain your Personal Data in anonymized form for analytical and research purposes.

12. HOW DO WE PROTECT YOUR PERSONAL DATA

Where we Process your Personal Data, you have a number of rights over how the Personal Data is Processed and you can exercise these rights at any point. We have provided an overview of these rights below together with what this entails for you. You can exercise your rights by submitting a Data Subject Rights (DSR) request form available on this Site.

12.1 In an endeavor to protect your Personal Data from unauthorized access, disclosure, loss, damage or misuse, we adopt security practices and procedures, at our choice, in line with the Applicable Laws or the

international standards such as ISO/IEC 27001:2013. We design our systems with security and privacy in mind. We adopt industry standard security measures and keep updating our systems from time to time to protect your Personal Data against any hacking or virus dissemination. We use various methods to safeguard Personal Data as mentioned below:

• A) Physical Measures. Locked file cabinets, restriction on access to offices and alarm systems.
• B) Technical Tools. Passwords and encryption using generally industry best practices.
• C) Organizational Controls. Confidentiality agreements, limiting access on a need-to-know basis, staff training and security clearances.
• D) Online Security. We incorporate security measures such as encryption and authentication tools to protect your Personal Data from unauthorized use. Firewalls are utilized to protect our servers and network from unauthorized users accessing and tampering with files and other Personal Data that we store. In addition, we conduct regular malware scanning to prevent Personal Data from getting compromised.

12.2 Your Personal Data is contained behind secured networks and is only accessible by a limited number of people who have special access rights to such systems and are required to keep the Personal Data confidential. In addition, all Sensitive Personal Data and credit information that you supply is encrypted via Secure Socket Layer (SSL) technology.

13. AUTOMATED DECISION MAKING & CUSTOMER PROFILING

Automated decisions are decisions concerning you which are made automatically on the basis of a computer determination (using software algorithms), without human intervention. We use your Personal Data to build profiles that we create by analyzing the information about your online surfing, searching and buying behavior and your interactions with us by building segments (creating groups that have certain common characteristics) and by placing your Personal Data in one or more segments. These segments are used by us to personalize this Site and our communications to you (such as showing relevant content to you when you visit this Site) and to display relevant offers and advertisements.

We perform automated decision making and profiling to analyze and profile your shopping preferences (market, customer and product analysis etc.) to enable us to review, develop and improve Alghanim Services and to enable us to provide you and other customers with relevant information through our marketing programs. We may use your Personal Data to make decisions using computerized technology. We may keep you informed of such products and services including special offers, discounts, offers, competitions and so on by e-mail, telephone (including automated calls), SMS text messages and other electronic messages such as picture messaging, post, fax or otherwise.

We will not make decisions based solely on automated decision making that have significant impact on you. If we do so, we shall notify you and provide you with clear information about our decision to rely on automated Processing to make our decision and our lawful basis for doing so.

When using automated decision-making, we will provide you with further information about the logic involved, as well as the significance and the envisaged consequences to you.

14. CHANGE OF PURPOSE

We will only use your Personal Data for the purposes stated in this Privacy Policy, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. If you wish to get an explanation as to how the Processing for the new purpose is compatible with the original purpose, please contact the Data Protection Officer using the contact details provided in this Privacy Notice.

15. AGGREGATED DATA OR PSEUDONYMISED DATA

Alghanim may also collect and/or generate anonymized and aggregated information from your use of the Alghanim Services. The anonymized or aggregated information is not Personal Data since we are not able to re-identify you using any means available to us from that anonymized or aggregated information. The anonymized and aggregated information is used for a variety of functions, including to help us identify and remediate any bugs, and to improve the performance of Alghanim Services. Alghanim may use such information in a number of ways, including internal analysis, analytics and research. Alghanim may share this information with third parties for its or their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you.

16. HOW DO WE USE COOKIES

Cookies are small data files transferred to your device's storage by a website, while using a web browser (if you allow). They keep a record of your activities on this Site to make your subsequent visits to the Site more efficient. The cookies may store a variety of information, including, the number of times that you access this Site, registration information and the number of times that you view a particular page or other item on this Site. The use of cookies is a common practice adopted by most major sites to better serve their clients. Most browsers are designed to accept cookies, but they can be easily modified to block cookies. By continuing the use of Alghanim Services, you are agreeing to Alghanim use of cookies. If you do not agree to Alghanim use of cookie, you can block them in your browser settings, however you may lose some functionality on this Site. For more information about out cookies and how we use them, please read the Cookie Notice.

17. DATA PROTECTION OFFICER

Alghanim has appointed a Data Protection Officer (DPO) to contact if you have any questions or concerns about Alghanim’s Personal Data Processing activities. If you have any questions or concerns about this Privacy Notice or how we handle your Personal Data, please contact the DPO at xxx@alghanim.com.

DPO Name	RISHABH R GAIKWAD
DPO Address	Alghanim Industries Al Hamra Tower, 70th – 73rd floor, Kuwait City
Email Address	dpo@alghanim.com
Contact Number	1881 111

18. CONSENT, INDEMNITY AND LIMITATION OF LIABILITY

In accordance with this Privacy Notice, you hereby explicitly grant Alghanim the right to Process your Personal Data, internally or with third parties, for the purposes described herein. You certify that you submitted your Personal Data voluntarily and that such Personal Data is true, accurate, complete and up to date.

You agree to defend, indemnify and hold Alghanim, its shareholders, officers, directors and employees harmless from and against any and all claims, liabilities, damages, losses or expenses (including without limitation settlement amounts and reasonable legal fees and out-of-pocket expenses), arising out of or in any way connected with your access to or use of this Site.

Alghanim, its directors and employees, shall not be liable in any manner whatsoever for any direct, indirect, incidental, consequential, or punitive damages (including without limitation, loss of profits, business interruption, loss of programs on your information system), arising out of or related to: (i) the use of, access of, or inability to use the information or hyperlinks available on this Site, Alghanim Services or any seller services; (ii) your provision of any information including your Personal Data; (iii) any default, delays, omissions, interruptions and inaccuracies resulting directly or indirectly from any cause, including without limitation, the unauthorized access or misuse of the Personal Data by any third party, failure of network services, this Site or any solution that operates this Site; or (iv) Alghanim’s acts or negligence or any of its third party service providers, agents or employees.

TO THE FULLEST EXTENT PERMITTED BY APPLICABLE LAWS, ALGHANIM DISCLAIMS AND EXCLUDES ALL WARRANTIES AND REPRESENTATIONS, EXPRESS, IMPLIED OR STATUTORY, WITH RESPECT TO THIS SITE OR AS A RESULT OF YOUR USE OF THIS SITE OR ALGHANIM SERVICES, OR WITH RESPECT TO THE ACCURACY, CURRENCY OR COMPLETENESS OF THE INFORMATION PROVIDED BY ALGHANIM, INCLUDING WITHOUT LIMITATION THE IMPLIED WARRANTIES OF FITNESS FOR A PARTICULAR PURPOSE AND NON-INFRINGEMENT OF A PATENT, TRADEMARK OR OTHER INTELLECTUAL PROPERTY RIGHT. THIS SITE, INCLUDING WITHOUT LIMITATION, ALL CONTENT, INFORMATION AND LINKS CONTAINED THEREIN, IS PROVIDED "AS-IS" WITHOUT ANY WARRANTY THAT IT WILL BE UNINTERRUPTED OR ERROR-FREE. THIS EXCLUSION OF LIABILITY APPLIES TO ALL CAUSES OF ACTIONS, WHETHER BASED ON CONTRACT, WARRANTY, TORT OR ANY OTHER LEGAL THEORIES.

19. INTELLECTUAL PROPERTY RIGHTS

This Site and all of its content including without limitation all text, graphics and html codes, all product names, trade names, service names, domain names, tag lines, or logotype distinguished in form, text, or otherwise from surrounding text are copyright materials and may not be printed, copied, posted, reproduced, used (including photos of faces) or otherwise distributed in whole or in part, without Alghanim prior written approval.

20. CHANGES TO THIS PRIVACY NOTICE

We may update this Privacy Notice from time to time in response to emerging legal, technical, contractual, regulatory or business developments. When we update our Privacy Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make. Your continuance use of this Site will be considered as a consent to such changes. We shall obtain your consent to any material Privacy Notice changes if and where this is required by Applicable Laws.

You can see when this Privacy Notice was last updated by checking the “last modified” date displayed at the end of this Privacy Notice.

If you have any questions about this Privacy Notice, please contact the DPO at dpo@alghanim.com.

Last modified: [June 04, 2022]

Contact Us

If you have any comments or queries in connection with our Terms and/or Privacy Policy, you can contact us by sending an email on Xsupport@xcite.com or call our customer service at 180-3535. Address:

Xcite General Trading Co. SPC