1. Introduction
A Liusie General Trading LLC (“ALGT,” “we,” “us,” or “our”) is committed to protecting your privacy and personal information. This Privacy Policy explains how we collect, use, process, and protect your personal data when you interact with our services, visit our facilities, use our websites, work for us, apply to work with us, or engage with our brands including ELC Toys and The Entertainer.
ALGT operates from Plot C22, International Media Production Zone, Dubai, United Arab Emirates, and serves customers across the Middle East region including the UAE, Qatar, Saudi Arabia, Oman, Bahrain, and Kuwait.
This policy complies with UAE Federal Decree-Law No. 45 of 2021 regarding the Protection of Personal Data, the Executive Regulations issued under it, and other applicable data protection regulations in the jurisdictions where we operate.
Who this policy applies to
This policy covers the personal data of:
- Customers and members of the public who shop in our stores or online
- Suppliers, vendors, contractors, and business partners
- Website and digital service users
- Job applicants and candidates
- Employees, workers, and former employees
2. Information We Collect
2.1 Customer, Supplier, and Website User Information
We may collect the following types of personal information:
Contact Information:
- Full name
- Email address
- Phone numbers
- Mailing address
- Emirate and nationality
Business Information:
- Company name and details
- Job title and department
- Business contact information
- Professional relationship with ALGT
Transaction Information:
- Purchase history
- Payment information
- Billing and shipping addresses
- Product preferences
Digital Information:
- Website usage data
- IP address and device information
- Browser type and operating system
- Cookies and tracking technologies
Communication Records:
- Customer service interactions
- Email correspondence
- Survey responses and feedback
- Marketing communications preferences
2.2 Employee, Worker, and Job Applicant Information
Where you apply to work with us or are employed or engaged by us, we collect and process personal data necessary to manage the recruitment process and the employment relationship. This may include:
Identity and Contact Information:
- Full name, date of birth, and gender
- Passport, Emirates ID, and visa or residency details
- Nationality and immigration status
- Home address, personal email, and telephone numbers
- Emergency contact and next-of-kin details
- Photographs for identification and access purposes
Recruitment Information:
- CV, application form, and cover letter
- Qualifications, references, and employment history
- Interview notes and assessment results
- Right-to-work and visa eligibility documentation
Employment and Payroll Information:
- Job title, department, store location, and reporting line
- Contract of employment and terms and conditions
- Salary, allowances, bank account, and payment records
- Working hours, attendance, leave, and absence records
- Performance reviews, training, and disciplinary records
- End-of-service and gratuity calculations
Workplace and Systems Information:
- System login, access, and device usage records
- CCTV and store security footage
- Records held in operational systems used to manage stores and staff
2.3 Special Category and Sensitive Information
In limited circumstances, and only where permitted or required by law, we may process more sensitive information such as health and medical information (for sickness absence, fitness to work, insurance, and workplace adjustments), and information relating to workplace incidents or investigations. We apply additional safeguards to this information and access is restricted to those who need it.
2.4 Information Collection Methods
We collect information through:
- Direct interactions (forms, applications, communications)
- Website visits and online activities
- Recruitment, onboarding, and employment processes
- Third-party sources (business partners, vendors, recruitment agencies, references)
- Public sources where legally permissible
- Automated technologies (cookies, analytics tools)
- Store security and monitoring systems (CCTV)
3. How We Use Your Information
3.1 Primary Purposes
We use your personal information for:
Business Operations:
- Processing orders and transactions
- Providing customer service and support
- Managing supplier and vendor relationships
- Conducting business communications
Service Delivery:
- Product distribution and logistics
- Warranty and after-sales service
- Technical support and maintenance
- Account management
Legal and Compliance:
- Complying with UAE and regional laws
- Meeting regulatory requirements
- Conducting internal audits
- Resolving disputes and legal proceedings
Marketing and Communications:
- Sending promotional materials (with consent)
- Market research and analysis
- Product development
- Managing communication preferences
3.2 Employment Purposes
Where you are a job applicant, employee, or worker, we use your information to:
- Assess applications and manage recruitment and selection
- Verify identity, right to work, and visa eligibility
- Administer contracts, payroll, benefits, and end-of-service entitlements
- Manage attendance, leave, scheduling, and store operations
- Support training, performance management, and career development
- Manage health, safety, and welfare at work
- Conduct disciplinary, grievance, and investigation processes
- Maintain security of premises, stock, and systems
- Meet legal, regulatory, immigration, and tax obligations
3.3 Legal Basis for Processing
We only process personal data where we have a lawful basis to do so. Depending on the circumstances, this will be one or more of the following:
- Performance of a contract with you, or to take steps before entering a contract
- Compliance with a legal or regulatory obligation
- Our legitimate business interests, where these are not overridden by your rights
- Your consent, which you may withdraw at any time
- Protection of vital interests in an emergency
4. CCTV and Workplace Monitoring
We operate CCTV cameras in till and customer areas of our stores, and at our facilities, where installed. CCTV is used for the safety of staff and customers, the prevention and detection of crime, and the protection of stock and property. Access to footage is restricted to authorised personnel, including authorised remote monitoring, and footage is retained for a limited period before secure deletion unless required for an investigation or legal proceedings.
Company IT equipment, systems, accounts, and internet access are provided for work purposes. As set out in our IT Equipment Policy, we may monitor their use to protect security, ensure appropriate use, and meet legal and regulatory obligations. Monitoring is proportionate, and staff are informed of it through this policy and related employment policies. We do not place CCTV in private areas such as changing or rest rooms.
About the ELC Shift app (operational note)
The ELC Shift staff & manager app is one of the operational systems referred to in sections 2.2 and 4. On ALGT's behalf it records work-scheduling data: clock-in / clock-out times, the 6-digit PIN you use to sign in, holiday / sick / TOIL balances, and store checklists and logs. For area managers, when you submit a store-visit report the app also records the device location at that moment (you are asked for permission first; the report submits whether or not you allow it). This information is held within ALGT's systems and used to run rotas, pay, and compliance — it is governed by the policy on this page.
5. Data Sharing and Disclosure
We do not sell your personal data. We may share it with:
- Group companies and franchise partners, including TEAL Group (The Entertainer), for legitimate business purposes
- Service providers who process data on our behalf (for example payroll, IT, insurance, logistics, and banking partners), under written contracts
- Government authorities, regulators, and law enforcement where required by law
- Professional advisers such as lawyers, auditors, and insurers
- Parties involved in a business sale, merger, or reorganisation
Where we use processors, we require them to keep personal data secure and to process it only on our documented instructions.
6. International Data Transfers
As a regional business operating across the GCC and working with international partners, your personal data may be transferred to and stored in countries outside the UAE. Where we transfer personal data internationally, we take steps to ensure an adequate level of protection in line with UAE Federal Decree-Law No. 45 of 2021, including appropriate contractual safeguards and, where required, your consent.
7. Data Security
We apply appropriate technical and organisational measures to protect personal data against unauthorised access, loss, misuse, or disclosure. These include access controls, restricted system permissions, secure storage, staff confidentiality obligations, and ongoing review of our security practices. In the event of a personal data breach that poses a risk to individuals, we will notify the relevant authority and affected individuals in line with our legal obligations.
8. Data Retention
We keep personal data only for as long as necessary for the purposes set out in this policy, and to meet legal, regulatory, tax, and accounting requirements. When data is no longer needed, it is securely deleted or anonymised. The periods below reflect current UAE legal requirements and should be confirmed for Qatar and any other market in which we operate:
| Data category | Typical retention period | Reason |
|---|---|---|
| Customer transaction and accounting records | Minimum 7 years | Corporate Tax Law (5 years under VAT Law) |
| Marketing contact data | Until consent is withdrawn | Consent-based |
| Unsuccessful job applicants | Up to 12 months | Recruitment and recordkeeping |
| Employee records (during employment) | Duration of employment | Managing the employment relationship |
| Employee records (after leaving) | At least 2 years after end of service | UAE Labour Law (Federal Decree-Law No. 33 of 2021) |
| Payroll and end-of-service records | Minimum 7 years | Corporate Tax, audit, and gratuity claims |
| CCTV footage | Limited period, then deleted | Security; retained longer only if needed for an investigation |
Note: periods reflect current UAE law (employment records under Federal Decree-Law No. 33 of 2021; tax records under Federal Decree-Law No. 47 of 2022 and Federal Decree-Law No. 8 of 2017). Equivalent Qatar requirements should be confirmed. Where more than one rule applies to the same record, the longer period governs.
9. Your Privacy Rights
Subject to applicable law, you have the right to:
- Be informed about how your personal data is used
- Access the personal data we hold about you
- Request correction of inaccurate or incomplete data
- Request deletion of your data in certain circumstances
- Restrict or object to certain processing
- Request transfer of your data to another party where applicable
- Withdraw consent at any time, where processing is based on consent
- Lodge a complaint with the UAE Data Office
To exercise any of these rights, please contact us using the details below. We may need to verify your identity before responding. We will respond within the timeframes required by law. Note that some rights, particularly the right to deletion, are limited where we are required to retain data to meet legal, employment, tax, or contractual obligations.
10. Cookies and Tracking Technologies
Our websites and digital services use cookies and similar technologies to operate the site, remember your preferences, analyse usage, and support marketing. You can manage cookies through your browser settings. Disabling some cookies may affect how parts of our sites function. Non-essential cookies are used only with your consent.
11. Children's Privacy
As a retailer of toys and children's products through ELC and The Entertainer, we recognise our responsibility towards children. Our services are directed at parents, guardians, and adult customers. We do not knowingly collect personal data directly from children without parental or guardian consent. Where we become aware that we hold a child's data without an appropriate basis, we will delete it. Any data relating to children is handled with particular care and is not used for behavioural marketing.
12. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, services, or legal requirements. The latest version will be made available to customers and staff, and the Last Updated date at the top of this document will be revised. Material changes affecting employees will be communicated through our internal channels.
13. Contact Us
If you have any questions about this Privacy Policy, wish to exercise your rights, or want to raise a concern about how we handle personal data, please contact us:
A Liusie General Trading LLC (ALGT)
- Plot C22, International Media Production Zone, Dubai, United Arab Emirates
- Data protection contact: info@algt-me.com
If you are not satisfied with our response, you have the right to contact the UAE Data Office.
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