Privacy Policy
A Liusie General Trading LLC (ALGT) — including the ELC Toys & The Entertainer brands
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 and digital tools, 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. Where the EU or UK General Data Protection Regulation (GDPR) applies to an individual, we also honour the rights and transparency obligations it provides.
This policy covers the personal data of:
We provide an internal AI assistant — known as Jack (or the name configured for your organisation) — to help our staff quickly find answers about company policies and procedures. Because this assistant uses artificial intelligence, we want to be completely transparent, up front, about how it works and how it handles your information.
Jack is a conversational assistant powered by a large language model (LLM). When you type or speak a question, your message is sent securely to our AI provider (Anthropic, using the Claude model) which generates a response grounded in our approved policy documents. Jack is a support tool — it is not a lawyer, HR advisor, or medical professional, and it does not replace advice from HR, your manager, or a qualified professional.
Where UK/EU GDPR applies, our legal bases are our legitimate interests in operating an efficient internal support tool and improving our policies and staff experience, and, where relevant, managing the employment relationship. Providing your name is optional and never required to get help.
Jack does not make any automated decision that produces legal or similarly significant effects about you — it does not decide anything about your pay, discipline, or employment. It only provides information and guidance, and a human is always responsible for any actual decision.
AI assistants can occasionally produce information that is incomplete or incorrect. Always confirm anything important with your manager or HR before relying on it.
Your conversations are logged and may be reviewed by authorised members of the management team to monitor quality, improve the service, and identify gaps in our policies. Please do not enter sensitive personal information (such as health details) into the assistant — for those matters contact HR directly and in confidence.
Your messages are shared with our AI processor (Anthropic) solely to generate a response, under a contract that requires them to protect your data and process it only on our instructions. Your messages are not used to train their models. Data may be processed outside the UAE; where this happens we rely on the safeguards described in the "International Data Transfers" section below.
All of the rights in the "Your Privacy Rights" section below apply to the data processed by the assistant — including access, correction, deletion, and the right to object. To exercise them, use the contact details at the end of this policy.
We run one official ELC Customer Services WhatsApp number for customer enquiries. Because parts of this service use artificial intelligence, we want to be completely transparent about how it works and how your information is handled.
When you message our WhatsApp number, an AI assistant may answer common questions — our returns policy, store locations and opening hours, and products available on our website. The assistant always tells you it is an AI in its first message, and you can ask for a human at any time. Anything the AI cannot answer is handed to a member of our customer service team, and the handover is made clear in the conversation. AI is also used to help our team translate replies into your language (translated replies carry a short note saying so) and to improve the clarity of their messages — a named human agent remains responsible for everything they send.
We process this information to answer your enquiry and provide customer service (performance of a contract / legitimate interests), and we keep the conversation record to evidence what was said and agreed, including for complaint handling and legal purposes.
The AI assistant does not make any decision with legal or similarly significant effect. It cannot approve refunds, make exceptions to policy, or confirm store stock — those always go to a human member of the team.
Messages are carried by WhatsApp (Meta) under their own terms and privacy policy. To generate AI responses and translations, message content is shared with our AI processor (Anthropic) solely for that purpose, under a contract that requires them to protect your data and process it only on our instructions; your messages are not used to train their models. Data may be processed outside the UAE — see "International Data Transfers" below.
All of the rights in the "Your Privacy Rights" section below apply — including access, correction, deletion, and the right to object. To exercise them, use the contact details at the end of this policy.
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 and app usage data, IP address and device information, browser type and operating system, cookies and tracking technologies.
Communication Records: customer service interactions, email correspondence, and messages sent to our digital tools including the staff assistant.
Where you work for us, we may hold:
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.
We collect information through direct interactions (forms, applications, communications); website and app 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); and store security and monitoring systems (CCTV).
We use your personal information for business operations (processing orders and transactions, customer service and support, managing supplier and vendor relationships, business communications); service delivery (product distribution and logistics, warranty and after-sales service, technical support, account management); legal and compliance (complying with UAE and regional laws, meeting regulatory requirements, internal audits, resolving disputes); and marketing and communications (promotional materials with consent, market research, product development, managing communication preferences).
Where you are a job applicant, employee, or worker, we use your information to assess applications and manage recruitment; 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; and meet legal, regulatory, immigration, and tax obligations.
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 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; and protection of vital interests in an emergency.
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.
We do not sell your personal data. We may share it with:
Where we use processors, we require them to keep personal data secure and to process it only on our documented instructions.
As a regional business operating across the GCC and working with international partners and service providers, 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 (and, where GDPR applies, appropriate safeguards such as standard contractual clauses), including appropriate contractual safeguards and, where required, your consent.
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.
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 |
| Staff assistant conversation logs | Retained while useful for quality and policy improvement, then deleted or anonymised | Legitimate interest in improving the service and our policies |
| Customer service WhatsApp conversations | Retained while needed to handle your enquiry and as a business record of what was agreed, then deleted or anonymised | Customer service, complaint handling, and legal obligations |
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.
Subject to applicable law, you have the right to:
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.
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.
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.
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.
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 (or your local supervisory authority where GDPR applies).
This policy does not form part of any employee's contract of employment and may be amended at any time.