Kulushi FZE-LLC ("Kulushi", "we", "our", "us") respects your privacy and is committed to protecting your personal data. This Privacy Policy outlines the types of data we collect, how we use it, where it's stored, and your rights regarding that information. This Policy is designed to comply with applicable data protection laws, including UAE Federal Decree-Law No. 45 of 2021 and, where applicable, the GDPR.
1. Information We Collect
- Full name, email address, and phone number;
- Nationality or ID details (where required for ticket registration);
- Event preferences, ticket requests, and purchase history;
- Communication records from WhatsApp, email, and submitted forms;
- IP address and device/browser information when using our website.
Kulushi does not collect or store your card number, CVV, or other card credentials. See Section 5 (Payment Information) below.
2. Purpose and Use of Data
- To process concierge service or event ticket requests;
- To issue invoices and register bookings with official providers;
- To communicate confirmations, updates, and offers;
- To ensure security, prevent fraud, and support service delivery.
Kulushi does not sell, rent, or share personal data with third parties for their own marketing purposes.
3. Legal Basis for Processing
By engaging with Kulushi, you acknowledge that Kulushi can process your data on the following basis:
- Your consent (e.g. submitting a form or opting into updates);
- Fulfilling a contractual obligation (e.g. confirming and issuing tickets);
- Compliance with legal obligations (e.g. tax, accounting, regulatory checks);
- Legitimate business interests (e.g. internal reporting, customer service).
4. Data Storage and Protection
We securely store personal data using encrypted, access-controlled systems such as Google Workspace (Drive, Sheets, Gmail), iCloud, and Zoho CRM. Only authorised personnel have access to your data.
5. Payment Information
Kulushi does not hold or store your card details. All payments are processed directly by our payment gateway provider, Stripe, a PCI-DSS compliant payment processor. Stripe collects and stores your card number, expiry, and CVV under its own privacy and security terms; Kulushi never receives or retains this data.
Kulushi's own bank account (held with WIO Bank PJSC) is used only to receive settlement funds from Stripe and, where applicable, to remit Seller payouts. This is separate from, and does not involve access to, your card details.
6. Data Sharing and Third Parties
Set out below are the types of third parties with which we will share your personal data:
- Event organisers, ticket vendors, and hospitality partners;
- Service providers including Zoho, Google, Apple, WhatsApp, and Stripe;
- Legal or regulatory authorities when required by law.
7. Retention of Data
We retain personal data only as long as necessary to complete your request or booking and to comply with our legal and financial obligations. You may request deletion of your data at any time, subject to legal limits.
8. Your Data Rights
You have the right to request the following from Kulushi, to:
- Access the data we hold about you;
- Correct any inaccuracies;
- Request deletion of your data;
- Withdraw consent at any time;
- Lodge a complaint with a data protection authority, where applicable.
To exercise these rights, contact us at info@kulushi.ae.
9. International Transfers
Some of our service providers are located outside the UAE, including cloud-based systems and Stripe. We ensure all such transfers are protected by appropriate safeguards.
11. Security Measures
Kulushi uses appropriate technical and organisational safeguards to protect your personal data against unauthorised access, disclosure, alteration, or destruction. Payment security is handled by Stripe as described in Section 5.
12. Contact
Questions or data requests: Jim Darlow, info@kulushi.ae.
13. Changes to This Policy
We may update this Privacy Policy from time to time. Changes will be posted on our website; you are encouraged to review the policy regularly. The Privacy Policy posted on the website will be the policy at the given time.
Kulushi FZE-LLC, Business Centre, Sharjah Publishing City (SPC) Freezone, Sharjah, UAE. Licence No. 4311177. TRN 104314497900003.