KEEP IN TOUCH PRIVACY POLICY
Version 3.0 · Effective from: 9 August 2026 · Last updated: 9 August 2026
This Policy is published in English. An Arabic version will be published in a later release.
1. The data controller
KEEP IN TOUCH SELLING PRODUCTS & SERVICES BY AUTOMATIC VENDING MACHINES L.L.C., Trade Licence No. 1144640, having its registered address at Arenco Offices DIP, Building 3, Office 116, Dubai Investments Park, Dubai, United Arab Emirates (the "Company"), is the data controller in respect of the personal data described in this Policy, and accordingly determines what personal data is collected, for what purposes and by what means it is protected.
Contact for privacy matters: in the App, Support section; help@kit-rent.com; +971 4 576 0715; Arenco Offices DIP, Building 3, Office 116, Dubai Investments Park, Dubai, United Arab Emirates.
2. Scope
2.1 This Policy covers all personal data processed by the Company in connection with:
(a) the KEEP IN TOUCH mobile application and the website https://www.kit-rent.com (together, the "Platform");
(b) the rental and return of Power Banks at the Company's Stations;
(c) payments, refunds and disputes;
(d) customer support provided through the App, by telephone, by e-mail and through the "Contact Us" form; and
(e) record-keeping required of the Company.
2.2 This Policy is the Company's single privacy notice. It replaces the previous Privacy Policy and the previous Personal Data Policy, both dated 5 March 2025, which are withdrawn and no longer apply. A copy of the withdrawn Personal Data Policy is available upon request.
3. Categories of personal data collected
3.1 Account data. The User's unique user ID and, depending upon the method of registration, the User's mobile number verified by one-time passcode, or the identifier and e-mail address supplied by Apple or Google upon sign-in with that account. Where the User signs in with Apple and elects to conceal the e-mail address, the Company receives only the relay address generated by Apple and not the User's actual address. This category also comprises the status of the Account and the version of the Company's terms accepted by the User together with the date of acceptance. Source: the User upon registration; Apple or Google, where their sign-in is used.
3.2 Rental data. The Power Bank taken, identified by serial number; the Station and address from which it was taken; the date and time of rent and of return; the duration; and the resulting charges. Source: automatically, from the Station and the App.
3.3 Location data. The location of the Station at which the User rents and returns a Power Bank; and, where the User enables it, the location of the User's device, so that the App may display nearby Stations. Source: the Station; and the User's device, with the User's permission, which may be withdrawn in the device settings.
3.4 Payment data. The type and last four digits of the User's card; the payment token issued by the Company's payment provider or by Apple Pay or Google Pay; transaction amounts, refunds and chargebacks. The Company does not store the User's full card number, expiry date or security code. Source: the Company's payment service provider; Apple Pay and Google Pay.
3.5 Device and technical data. Device type; unique device identifiers, which may include IMEI, BSSID, Android ID and the MAC address of the device's wireless interface; mobile network; operating system; browser type; time zone; application version; crash and diagnostic logs; and IP address. The Company does not collect an advertising identifier. Source: automatically, from the App.
3.6 Support and complaint data. The User's name, e-mail address and telephone number where given; the content of the User's message or call; and the Company's response, including anything submitted through the Support section of the App or through the "Contact Us" form. Source: the User.
3.7 Marketing preferences. Whether the User has opted in to marketing, and the dates of opting in and opting out. Source: the User.
3.8 The Company does not deliberately collect sensitive personal data, and requests that the User does not submit such data to it.
4. Purposes of processing and legal bases
4.1 Creating and operating the Account; verifying the User's number or Apple or Google sign-in; and sending the User notices concerning the Service and concerning changes to the Company's documents, in the App and by e-mail. Categories used: account data and device data. Legal basis: necessary for the performance of the Company's contract with the User.
4.2 Providing a Rental, comprising the release of a Power Bank and the registration of its return. Categories used: account, rental, location of the Station, and device data. Legal basis: necessary for the performance of the Company's contract with the User.
4.3 Charging the User, making refunds and issuing receipts. Categories used: account, rental and payment data. Legal bases: necessary for the performance of the Company's contract with the User; and compliance with accounting law.
4.4 Displaying nearby Stations and the number of Power Banks and vacant slots at each. Categories used: device location data. Legal basis: the User's consent, given in the device settings and withdrawable at any time.
4.5 Support, complaints and disputes. Categories used: all categories relevant to the matter. Legal bases: necessary for the performance of the Company's contract with the User; and the establishment, exercise or defence of legal claims.
4.6 Maintaining the Company's Stations and Power Banks in working order, and investigating faults, damage, loss and misuse. Categories used: rental, device and Station location data. Legal bases: necessary for the performance of the Company's contract with the User; and the establishment, exercise or defence of legal claims.
4.7 Security of the Platform and prevention of fraud. Categories used: account, device, payment and rental data. Legal bases: necessary for the performance of the Company's contract with the User; and compliance with legal obligations.
4.8 Recovering amounts owed by the User, and applying the rule that an Account may not be deleted while a debt remains outstanding. Categories used: account, rental and payment data. Legal bases: necessary for the performance of the Company's contract with the User; and the establishment, exercise or defence of legal claims.
4.9 Statistical analysis for the improvement of the Service, using aggregated or anonymised data. Categories used: rental and device data. Legal basis: aggregated or anonymised data ceases to be personal data once it can no longer identify the User.
4.10 Marketing communications concerning KEEP IN TOUCH. Categories used: account data and marketing preferences. Legal basis: the User's separate and express consent only, which may be withdrawn at any time, whereupon the Company shall cease such communications.
4.11 Compliance with legal obligations and with requests made by authorities under the law. Categories used: as required. Legal basis: compliance with obligations imposed upon the Company by the law of the United Arab Emirates.
4.12 Automated decisions. Rental charges are calculated automatically by the Company's systems, including the automatic extension of a Rental up to 7 days and the charge resulting therefrom, and an Account may be suspended automatically upon defined criteria, such as an unreturned Power Bank or a failed payment. The User may request review of any such decision by a member of the Company's personnel, through the Support section of the App, and the Company shall carry out that review.
4.13 The Company does not process the User's personal data for any purpose not stated in this clause 4 without informing the User and, where required, obtaining the User's consent.
5. Retention periods
5.1 Account data is retained for the lifetime of the Account. By way of exception, where the Account cannot be deleted because the User owes money to the Company in respect of the Service, in accordance with clause 16.1 of the User Agreement, the account data is retained until that debt is resolved.
5.2 Rental and location data is retained indefinitely and is not deleted.
5.3 Device and technical data is retained indefinitely and is not deleted.
5.4 Support and complaint records are retained for 1 year from the closure of the matter, that period covering the window of 1 year within which the User may request review of a charge under clause 6.1 of the Payment and Refund Policy.
5.5 Payment data and payment records are retained for 5 years.
5.6 Records of consent and of accepted versions of the Company's terms are retained for so long as the Company requires them in order to evidence the User's acceptance. No fixed period applies.
5.7 The Company does not retain personal data after the purpose for which it was collected has been fulfilled, unless the Company is required by law to retain it or requires it in order to establish, exercise or defend a legal claim. Upon the expiry of a retention period the Company deletes the data or anonymises it so that it can no longer identify the User.
6. Recipients
6.1 The Company discloses personal data to:
(a) its service providers, comprising hosting and cloud infrastructure, the application and Station platform provider, its payment service provider, SMS and e-mail delivery, customer support tools and analytics. Such providers act upon the Company's instructions, under a written contract requiring them to protect the data and to use it only for the purposes specified by the Company;
(b) authorities, where the Company is required to disclose data by law or by a competent authority acting under the law;
(c) professional advisers, where necessary for the establishment, exercise or defence of a legal claim; and
(d) a purchaser or successor, in the event of a transfer of the Company's business, subject to the same protection.
6.2 The Company does not disclose the User's personal data to the Venues that host its Stations. A Venue receives commercial reporting concerning revenue at its location and does not receive the User's identity, contact details, card data or rental history.
6.3 The Company does not sell personal data. The User's full card details are not stored, sold, disclosed, rented or leased to any person.
7. Storage and transfers outside the United Arab Emirates
7.1 Certain personal data of the User is processed outside the United Arab Emirates, in India, by service providers acting upon the Company's instructions.
7.2 Where the Company transfers personal data outside the United Arab Emirates, it does so only where the destination affords an adequate level of protection recognised for that purpose, or under a contract requiring the recipient to apply the protections required by the personal data protection law of the United Arab Emirates, or with the User's express consent, or where the transfer is necessary for the performance of the Company's contract with the User.
8. Security measures
The Company applies technical and organisational measures appropriate to the risk, including encryption of data in transit and at rest, pseudonymisation where practicable, access control on a need-to-know basis, logging, secure development and change control, backup and recovery, and periodic testing and review of those measures. No system can be guaranteed to be entirely secure; the Company treats the security of the User's data with due seriousness and reviews it regularly.
9. Personal data breaches
Where personal data is lost, disclosed or accessed without authorisation in a manner that would prejudice its privacy, confidentiality or security, the Company shall investigate immediately, take corrective action, report the breach to the UAE Data Office, and notify the User where the breach affects the User's data in that manner, stating what has occurred and what the Company has done.
10. Rights of the User
10.1 The User has the right:
(a) to be informed of the categories of personal data processed, the purposes and legal bases of processing, the recipients, the retention periods, the manner in which automated decisions are made, the protections applicable to any transfer outside the United Arab Emirates, the consequences of a breach, and the manner of complaining;
(b) to obtain a copy of the User's personal data, free of charge;
(c) to receive that data in a structured, machine-readable format and to request its transfer to another controller where technically feasible;
(d) to have inaccurate data corrected;
(e) to have the data erased, subject to periods for which the Company is required by law to retain it;
(f) to restrict processing in the cases permitted by law;
(g) to object to and stop processing, including, at any time and without stating a reason, processing for the purposes of direct marketing;
(h) to withdraw any consent given, at any time, such withdrawal not affecting processing carried out before it;
(i) to object to a decision taken by automated processing having legal effects for the User or seriously affecting the User, and to request review by a natural person; and
(j) to complain, to the Company and to the UAE Data Office.
10.2 Exercise of rights. The User shall contact the Company through the App, in the Support section, or at help@kit-rent.com. The Company shall respond within 3 working days, that being the period the Company applies to every complaint, dispute and request addressed to it. The Company may require the User to confirm the User's identity. The Company may refuse a request only in the limited cases permitted by law, such as where the request is excessively repetitive, conflicts with a judicial investigation, would compromise information security or would affect the privacy of another person, and shall in such case state its reasons.
11. Children
The Service is intended for persons aged 18 years and over. The Company does not knowingly collect data concerning children. Any person who believes that the Company holds data concerning a child shall notify the Company through the Support section of the App or at help@kit-rent.com, and the Company shall delete that data.
12. Contact and complaints
12.1 The Company: in the App, Support section; help@kit-rent.com; +971 4 576 0715; Arenco Offices DIP, Building 3, Office 116, Dubai Investments Park, Dubai, United Arab Emirates.
12.2 The UAE Data Office: the User may file a complaint with the UAE Data Office where the User believes that the Company has processed the User's personal data in breach of the law.
12.3 Consumer complaints concerning charges, refunds or the Service are to be addressed to the Company in the first instance and thereafter to the Dubai Corporation for Consumer Protection and Fair Trade, in accordance with clause 15 of the User Agreement.
13. Amendment of this Policy
The Company reviews this Policy regularly. Where the Company amends it, the Company shall publish the amended version at the address stated above bearing a new version number and effective date and, where the amendment is significant, shall notify the User in the App and by e-mail before it takes effect. Previous versions are available upon request.
KEEP IN TOUCH SELLING PRODUCTS & SERVICES BY AUTOMATIC VENDING MACHINES L.L.C. · Trade Licence No. 1144640 · Arenco Offices DIP, Building 3, Office 116, Dubai Investments Park, Dubai, United Arab Emirates · Data controller
Version 3.0 — Effective 9 August 2026. Supersedes the Privacy Policy dated 5 March 2025 and the Personal Data Policy dated 5 March 2025. Governing law and jurisdiction: clauses 18.10 and 15.5 of the User Agreement.
This Policy is published in English. An Arabic version will be published in a later release.
1. The data controller
KEEP IN TOUCH SELLING PRODUCTS & SERVICES BY AUTOMATIC VENDING MACHINES L.L.C., Trade Licence No. 1144640, having its registered address at Arenco Offices DIP, Building 3, Office 116, Dubai Investments Park, Dubai, United Arab Emirates (the "Company"), is the data controller in respect of the personal data described in this Policy, and accordingly determines what personal data is collected, for what purposes and by what means it is protected.
Contact for privacy matters: in the App, Support section; help@kit-rent.com; +971 4 576 0715; Arenco Offices DIP, Building 3, Office 116, Dubai Investments Park, Dubai, United Arab Emirates.
2. Scope
2.1 This Policy covers all personal data processed by the Company in connection with:
(a) the KEEP IN TOUCH mobile application and the website https://www.kit-rent.com (together, the "Platform");
(b) the rental and return of Power Banks at the Company's Stations;
(c) payments, refunds and disputes;
(d) customer support provided through the App, by telephone, by e-mail and through the "Contact Us" form; and
(e) record-keeping required of the Company.
2.2 This Policy is the Company's single privacy notice. It replaces the previous Privacy Policy and the previous Personal Data Policy, both dated 5 March 2025, which are withdrawn and no longer apply. A copy of the withdrawn Personal Data Policy is available upon request.
3. Categories of personal data collected
3.1 Account data. The User's unique user ID and, depending upon the method of registration, the User's mobile number verified by one-time passcode, or the identifier and e-mail address supplied by Apple or Google upon sign-in with that account. Where the User signs in with Apple and elects to conceal the e-mail address, the Company receives only the relay address generated by Apple and not the User's actual address. This category also comprises the status of the Account and the version of the Company's terms accepted by the User together with the date of acceptance. Source: the User upon registration; Apple or Google, where their sign-in is used.
3.2 Rental data. The Power Bank taken, identified by serial number; the Station and address from which it was taken; the date and time of rent and of return; the duration; and the resulting charges. Source: automatically, from the Station and the App.
3.3 Location data. The location of the Station at which the User rents and returns a Power Bank; and, where the User enables it, the location of the User's device, so that the App may display nearby Stations. Source: the Station; and the User's device, with the User's permission, which may be withdrawn in the device settings.
3.4 Payment data. The type and last four digits of the User's card; the payment token issued by the Company's payment provider or by Apple Pay or Google Pay; transaction amounts, refunds and chargebacks. The Company does not store the User's full card number, expiry date or security code. Source: the Company's payment service provider; Apple Pay and Google Pay.
3.5 Device and technical data. Device type; unique device identifiers, which may include IMEI, BSSID, Android ID and the MAC address of the device's wireless interface; mobile network; operating system; browser type; time zone; application version; crash and diagnostic logs; and IP address. The Company does not collect an advertising identifier. Source: automatically, from the App.
3.6 Support and complaint data. The User's name, e-mail address and telephone number where given; the content of the User's message or call; and the Company's response, including anything submitted through the Support section of the App or through the "Contact Us" form. Source: the User.
3.7 Marketing preferences. Whether the User has opted in to marketing, and the dates of opting in and opting out. Source: the User.
3.8 The Company does not deliberately collect sensitive personal data, and requests that the User does not submit such data to it.
4. Purposes of processing and legal bases
4.1 Creating and operating the Account; verifying the User's number or Apple or Google sign-in; and sending the User notices concerning the Service and concerning changes to the Company's documents, in the App and by e-mail. Categories used: account data and device data. Legal basis: necessary for the performance of the Company's contract with the User.
4.2 Providing a Rental, comprising the release of a Power Bank and the registration of its return. Categories used: account, rental, location of the Station, and device data. Legal basis: necessary for the performance of the Company's contract with the User.
4.3 Charging the User, making refunds and issuing receipts. Categories used: account, rental and payment data. Legal bases: necessary for the performance of the Company's contract with the User; and compliance with accounting law.
4.4 Displaying nearby Stations and the number of Power Banks and vacant slots at each. Categories used: device location data. Legal basis: the User's consent, given in the device settings and withdrawable at any time.
4.5 Support, complaints and disputes. Categories used: all categories relevant to the matter. Legal bases: necessary for the performance of the Company's contract with the User; and the establishment, exercise or defence of legal claims.
4.6 Maintaining the Company's Stations and Power Banks in working order, and investigating faults, damage, loss and misuse. Categories used: rental, device and Station location data. Legal bases: necessary for the performance of the Company's contract with the User; and the establishment, exercise or defence of legal claims.
4.7 Security of the Platform and prevention of fraud. Categories used: account, device, payment and rental data. Legal bases: necessary for the performance of the Company's contract with the User; and compliance with legal obligations.
4.8 Recovering amounts owed by the User, and applying the rule that an Account may not be deleted while a debt remains outstanding. Categories used: account, rental and payment data. Legal bases: necessary for the performance of the Company's contract with the User; and the establishment, exercise or defence of legal claims.
4.9 Statistical analysis for the improvement of the Service, using aggregated or anonymised data. Categories used: rental and device data. Legal basis: aggregated or anonymised data ceases to be personal data once it can no longer identify the User.
4.10 Marketing communications concerning KEEP IN TOUCH. Categories used: account data and marketing preferences. Legal basis: the User's separate and express consent only, which may be withdrawn at any time, whereupon the Company shall cease such communications.
4.11 Compliance with legal obligations and with requests made by authorities under the law. Categories used: as required. Legal basis: compliance with obligations imposed upon the Company by the law of the United Arab Emirates.
4.12 Automated decisions. Rental charges are calculated automatically by the Company's systems, including the automatic extension of a Rental up to 7 days and the charge resulting therefrom, and an Account may be suspended automatically upon defined criteria, such as an unreturned Power Bank or a failed payment. The User may request review of any such decision by a member of the Company's personnel, through the Support section of the App, and the Company shall carry out that review.
4.13 The Company does not process the User's personal data for any purpose not stated in this clause 4 without informing the User and, where required, obtaining the User's consent.
5. Retention periods
5.1 Account data is retained for the lifetime of the Account. By way of exception, where the Account cannot be deleted because the User owes money to the Company in respect of the Service, in accordance with clause 16.1 of the User Agreement, the account data is retained until that debt is resolved.
5.2 Rental and location data is retained indefinitely and is not deleted.
5.3 Device and technical data is retained indefinitely and is not deleted.
5.4 Support and complaint records are retained for 1 year from the closure of the matter, that period covering the window of 1 year within which the User may request review of a charge under clause 6.1 of the Payment and Refund Policy.
5.5 Payment data and payment records are retained for 5 years.
5.6 Records of consent and of accepted versions of the Company's terms are retained for so long as the Company requires them in order to evidence the User's acceptance. No fixed period applies.
5.7 The Company does not retain personal data after the purpose for which it was collected has been fulfilled, unless the Company is required by law to retain it or requires it in order to establish, exercise or defend a legal claim. Upon the expiry of a retention period the Company deletes the data or anonymises it so that it can no longer identify the User.
6. Recipients
6.1 The Company discloses personal data to:
(a) its service providers, comprising hosting and cloud infrastructure, the application and Station platform provider, its payment service provider, SMS and e-mail delivery, customer support tools and analytics. Such providers act upon the Company's instructions, under a written contract requiring them to protect the data and to use it only for the purposes specified by the Company;
(b) authorities, where the Company is required to disclose data by law or by a competent authority acting under the law;
(c) professional advisers, where necessary for the establishment, exercise or defence of a legal claim; and
(d) a purchaser or successor, in the event of a transfer of the Company's business, subject to the same protection.
6.2 The Company does not disclose the User's personal data to the Venues that host its Stations. A Venue receives commercial reporting concerning revenue at its location and does not receive the User's identity, contact details, card data or rental history.
6.3 The Company does not sell personal data. The User's full card details are not stored, sold, disclosed, rented or leased to any person.
7. Storage and transfers outside the United Arab Emirates
7.1 Certain personal data of the User is processed outside the United Arab Emirates, in India, by service providers acting upon the Company's instructions.
7.2 Where the Company transfers personal data outside the United Arab Emirates, it does so only where the destination affords an adequate level of protection recognised for that purpose, or under a contract requiring the recipient to apply the protections required by the personal data protection law of the United Arab Emirates, or with the User's express consent, or where the transfer is necessary for the performance of the Company's contract with the User.
8. Security measures
The Company applies technical and organisational measures appropriate to the risk, including encryption of data in transit and at rest, pseudonymisation where practicable, access control on a need-to-know basis, logging, secure development and change control, backup and recovery, and periodic testing and review of those measures. No system can be guaranteed to be entirely secure; the Company treats the security of the User's data with due seriousness and reviews it regularly.
9. Personal data breaches
Where personal data is lost, disclosed or accessed without authorisation in a manner that would prejudice its privacy, confidentiality or security, the Company shall investigate immediately, take corrective action, report the breach to the UAE Data Office, and notify the User where the breach affects the User's data in that manner, stating what has occurred and what the Company has done.
10. Rights of the User
10.1 The User has the right:
(a) to be informed of the categories of personal data processed, the purposes and legal bases of processing, the recipients, the retention periods, the manner in which automated decisions are made, the protections applicable to any transfer outside the United Arab Emirates, the consequences of a breach, and the manner of complaining;
(b) to obtain a copy of the User's personal data, free of charge;
(c) to receive that data in a structured, machine-readable format and to request its transfer to another controller where technically feasible;
(d) to have inaccurate data corrected;
(e) to have the data erased, subject to periods for which the Company is required by law to retain it;
(f) to restrict processing in the cases permitted by law;
(g) to object to and stop processing, including, at any time and without stating a reason, processing for the purposes of direct marketing;
(h) to withdraw any consent given, at any time, such withdrawal not affecting processing carried out before it;
(i) to object to a decision taken by automated processing having legal effects for the User or seriously affecting the User, and to request review by a natural person; and
(j) to complain, to the Company and to the UAE Data Office.
10.2 Exercise of rights. The User shall contact the Company through the App, in the Support section, or at help@kit-rent.com. The Company shall respond within 3 working days, that being the period the Company applies to every complaint, dispute and request addressed to it. The Company may require the User to confirm the User's identity. The Company may refuse a request only in the limited cases permitted by law, such as where the request is excessively repetitive, conflicts with a judicial investigation, would compromise information security or would affect the privacy of another person, and shall in such case state its reasons.
11. Children
The Service is intended for persons aged 18 years and over. The Company does not knowingly collect data concerning children. Any person who believes that the Company holds data concerning a child shall notify the Company through the Support section of the App or at help@kit-rent.com, and the Company shall delete that data.
12. Contact and complaints
12.1 The Company: in the App, Support section; help@kit-rent.com; +971 4 576 0715; Arenco Offices DIP, Building 3, Office 116, Dubai Investments Park, Dubai, United Arab Emirates.
12.2 The UAE Data Office: the User may file a complaint with the UAE Data Office where the User believes that the Company has processed the User's personal data in breach of the law.
12.3 Consumer complaints concerning charges, refunds or the Service are to be addressed to the Company in the first instance and thereafter to the Dubai Corporation for Consumer Protection and Fair Trade, in accordance with clause 15 of the User Agreement.
13. Amendment of this Policy
The Company reviews this Policy regularly. Where the Company amends it, the Company shall publish the amended version at the address stated above bearing a new version number and effective date and, where the amendment is significant, shall notify the User in the App and by e-mail before it takes effect. Previous versions are available upon request.
KEEP IN TOUCH SELLING PRODUCTS & SERVICES BY AUTOMATIC VENDING MACHINES L.L.C. · Trade Licence No. 1144640 · Arenco Offices DIP, Building 3, Office 116, Dubai Investments Park, Dubai, United Arab Emirates · Data controller
Version 3.0 — Effective 9 August 2026. Supersedes the Privacy Policy dated 5 March 2025 and the Personal Data Policy dated 5 March 2025. Governing law and jurisdiction: clauses 18.10 and 15.5 of the User Agreement.
Dubai, Arenco Offices DIP, bld. 3, off. 116
Dubai, Arenco Offices DIP, bld. 3, off. 116
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