Privacy Policy

PRIVACY POLICY

LOCKERS SHOP S.A.R.L.
Effective Date: 2025

 Last Updated: July 2025

 1. INTRODUCTION AND SCOPE

This Privacy Policy ("Policy") governs the collection, processing, storage, and disclosure of personal information by Lockers Shop S.A.R.L., a Lebanese limited liability company ("Company," "we," "us," or "our"), through our website located at lockersshop.com (the "Website") and related services (collectively, the "Services").

BY ACCESSING OR USING OUR SERVICES, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTOOD, AND AGREE TO BE BOUND BY THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THE TERMS OF THIS POLICY, YOU MUST NOT ACCESS OR USE OUR SERVICES.

This Policy applies to all users, customers, and visitors of our Services, regardless of geographic location, and governs our practices concerning the collection and processing of personal data in accordance with applicable Lebanese privacy laws and international privacy standards.

2. DEFINITIONS

For purposes of this Policy, the following definitions shall apply:

"Personal Data" means any information relating to an identified or identifiable natural person, including but not limited to name, address, email address, telephone number, payment information, and online identifiers.

"Processing" means any operation performed on personal data, including collection, recording, organization, storage, adaptation, retrieval, consultation, use, disclosure, and deletion.

"Data Subject" means the natural person to whom the personal data relates.

"Controller" means the natural or legal person who determines the purposes and means of processing personal data.

3. DATA CONTROLLER

Lockers Shop S.A.R.L., registered under Lebanese law, serves as the data controller for all personal data processed through our Services. Our registered office is located at Beirut, Lebanon.

4. CATEGORIES OF PERSONAL DATA COLLECTED

We collect and process the following categories of personal data:

4.1 Information You Provide Directly

Identity Information: Full name, date of birth, gender

Contact Information: Email address, telephone number, postal address, WhatsApp contact details

Account Information: Username, password, account preferences

Transaction Information: Purchase history, payment method details, billing address, shipping address

Communication Data: Messages sent through our WhatsApp customer service, chat transcripts, customer service correspondence 

4.2 Information Collected Automatically

Technical Data: IP address, browser type and version, device type, operating system, referral URLs

Usage Data: Pages visited, time spent on pages, click-through rates, download errors, length of visits

Location Data: General geographic location derived from IP address

Cookie Data: Information collected through cookies and similar tracking technologies

4.3 Information from Third Parties

Payment Processors: Transaction verification and fraud prevention data

WhatsApp Business API: Communication metadata and delivery status

Social Media Platforms: Public profile information when you interact with our social media presence

5. LEGAL BASIS FOR PROCESSING

We process personal data based on the following lawful grounds:

5.1 Contractual Necessity

Processing necessary for the performance of our contract with you, including:

Order fulfillment and delivery

Customer service provision

Account management

5.2 Legitimate Interests

Processing necessary for our legitimate business interests, including:

Website optimization and security

Marketing and business development

Fraud prevention and detection

Quality assurance and improvement

5.3 Legal Compliance

Processing necessary to comply with legal obligations, including:

Tax and accounting requirements

Anti-money laundering regulations

Consumer protection laws

5.4 Consent

Where explicitly provided, including:

Marketing communications

Optional data collection

Non-essential cookies

6. PURPOSES OF DATA PROCESSING

We process personal data for the following purposes:

6.1 Service Provision

Processing and fulfilling orders

Managing customer accounts

Providing customer support through WhatsApp and other channels

Facilitating payment processing

Arranging delivery and logistics

6.2 Business Operations

Improving our products and services

Conducting market research and analytics

Managing inventory and supply chain

Maintaining business records

6.3 Marketing and Communications

Sending promotional materials and offers (with consent)

Personalizing shopping experiences

Conducting customer satisfaction surveys

Managing loyalty programs

6.4 Legal and Security

Preventing fraud and unauthorized access

Ensuring website security and functionality

Complying with legal and regulatory requirements

Protecting our rights and interests

7. DATA SHARING AND DISCLOSURE

We may share personal data with the following categories of recipients:

7.1 Service Providers

Payment Processors: OMT, LibanPost, Whish Money, Cedar Rose, and other authorized payment service providers

Logistics Partners: Delivery companies and shipping providers

Technology Providers: WhatsApp Business API, website hosting, and cloud storage services

Professional Advisors: Legal counsel, accountants, and business consultants

7.2 Business Transfers

In the event of a merger, acquisition, reorganization, or sale of assets, personal data may be transferred to the acquiring entity, subject to appropriate safeguards.

7.3 Legal Requirements

We may disclose personal data when required by law, court order, or regulatory authority, or to protect our rights, property, or safety, or that of others.

7.4 Consent-Based Sharing

We may share data with third parties when you have provided explicit consent for such sharing.

WE DO NOT SELL, RENT, OR TRADE PERSONAL DATA TO THIRD PARTIES FOR COMMERCIAL PURPOSES.

8. INTERNATIONAL DATA TRANSFERS

Given our operations in Lebanon and service provision to the GCC region, we may transfer personal data internationally. Such transfers are conducted in accordance with applicable data protection laws and subject to appropriate safeguards, including:

Standard contractual clauses approved by relevant authorities

Adequacy decisions by competent authorities

Binding corporate rules or codes of conduct

Explicit consent where required

9. DATA RETENTION

We retain personal data for the following periods:

9.1 Customer Data

Active Customers: During the relationship and for seven (7) years thereafter for legal and tax compliance

Inactive Customers: Five (5) years from last interaction, unless longer retention is required by law

9.2 Transaction Records

Purchase Records: Ten (10) years from transaction date

Payment Information: As required by payment card industry standards and applicable law

9.3 Communication Records

Customer Service: Three (3) years from last communication

Marketing Communications: Until consent is withdrawn or customer opts out

9.4 Technical Data

Website Analytics: Two (2) years from collection

Security Logs: One (1) year from creation

Data may be retained longer if required by legal proceedings, investigations, or regulatory requirements.

10. DATA SUBJECT RIGHTS

Subject to applicable law, you have the following rights regarding your personal data:

10.1 Right of Access

You may request information about the personal data we process about you.

10.2 Right to Rectification

You may request correction of inaccurate or incomplete personal data.

10.3 Right to Erasure

You may request deletion of personal data in certain circumstances.

10.4 Right to Restrict Processing

You may request limitation of processing in specific situations.

10.5 Right to Data Portability

You may request transfer of data to another controller in certain circumstances.

10.6 Right to Object

You may object to processing based on legitimate interests or for direct marketing purposes.

10.7 Right to Withdraw Consent

Where processing is based on consent, you may withdraw such consent at any time.

To exercise these rights, please contact us using the information provided in Section 14.

11. SECURITY MEASURES

We implement appropriate technical and organizational measures to protect personal data against unauthorized access, alteration, disclosure, or destruction, including:

11.1 Technical Safeguards

Encryption of data in transit and at rest

Secure socket layer (SSL) protocols

Regular security assessments and updates

Access controls and authentication systems

11.2 Organizational Measures

Staff training on data protection

Regular security policy reviews

Incident response procedures

Third-party security assessments

While we strive to protect personal data, no method of transmission or storage is completely secure. We cannot guarantee absolute security.

12. COOKIES AND TRACKING TECHNOLOGIES

We use cookies and similar technologies to enhance user experience and analyze website performance. Our Cookie Policy, available separately, provides detailed information about:

Types of cookies used

Purposes of tracking

Cookie management options

Third-party cookie practices

By continuing to use our Services, you consent to our use of cookies in accordance with our Cookie Policy.

13. THIRD-PARTY SERVICES

Our Services may integrate with third-party platforms, including:

13.1 WhatsApp Business

Purpose: Customer communication and order management

Data Shared: Contact information, message content, transaction details

Privacy Policy: Available at https://www.whatsapp.com/legal/privacy-policy-eea

13.2 Payment Processors

Purpose: Transaction processing and fraud prevention

Data Shared: Payment information, transaction details, identity verification data

Security Standards: PCI DSS compliance required

13.3 Analytics Services

Purpose: Website optimization and user behavior analysis

Data Shared: Anonymized usage data, technical information

Opt-out Options: Available through browser settings or preference center

WE ARE NOT RESPONSIBLE FOR THE PRIVACY PRACTICES OF THIRD PARTIES. WE ENCOURAGE YOU TO REVIEW THEIR PRIVACY POLICIES.

14. CONTACT INFORMATION

For questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

Lockers Shop S.A.R.L.
Data Protection Officer
Address: [Complete Address]
Lebanon

Email: privacy@lockersshop.com

Response Time: We will respond to privacy inquiries within thirty (30) days of receipt.

15. CHANGES TO THIS POLICY

We reserve the right to modify this Privacy Policy at any time. Changes will be effective immediately upon posting on our Website. Material changes will be communicated through:

Prominent notice on our Website

Email notification to registered users

WhatsApp broadcast (where applicable)

Your continued use of our Services after changes constitute acceptance of the updated Policy.

16. GOVERNING LAW AND JURISDICTION

This Privacy Policy is governed by the laws of Lebanon. Any disputes arising from or relating to this Policy shall be subject to the exclusive jurisdiction of the Lebanese courts.

17. SEVERABILITY

If any provision of this Privacy Policy is deemed invalid or unenforceable, the remaining provisions shall remain in full force and effect.

© 2025 Lockers Shop S.A.R.L. All rights reserved.

This Privacy Policy was last updated on July 2025 . For the most current version, please visit lockersshop.com/privacy-policy