PRIVACY POLICY
Miloni X Roc
Last Updated: 26.2.26
This Privacy Policy explains how Miloni X Roc collects, uses, stores, transfers, and protects personal data in accordance with:
• The UK General Data Protection Regulation (UK GDPR)
• The Data Protection Act 2018 (United Kingdom)
• The UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (PDPL)
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1. Company Information
United Kingdom Entity
Company Number: 17052784
Registered in England and Wales
United Arab Emirates Entity
Registration Number: *****
Free Zone Company
Miloni X Roc operates internationally and may manufacture products in the UK and, on occasion, within the UAE.
For data protection enquiries, contact:
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2. About Miloni X Roc
Miloni X Roc is a luxury personalised brand specialising in customisation of premium products, primarily shisha pipes, though not limited to such items. We provide bespoke design services tailored to individual client specifications.
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3. Personal Data We Collect
We may collect and process the following categories of personal data:
A. Identity Information
• Full name
• Billing and delivery address
• Contact telephone number
• Email address
• Social media usernames (if applicable)
B. Transaction Data
• Order details
• Custom design specifications
• Product selections (design, colour, branding)
• Payment records (deposit, instalments, full payments)
C. Financial Information
• Payment confirmations
(Note: Full card details are not stored by us where third-party payment processors are used.)
D. Technical Data
• IP address
• Device information
• Website usage data
• Cookies (if applicable)
E. Communications Data
• Emails, messages, WhatsApp conversations, social media communications
• Customer service interactions
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4. Lawful Basis for Processing (UK GDPR & UAE PDPL)
We process personal data under the following lawful bases:
• Contractual necessity (to fulfil custom orders)
• Legal obligations
• Legitimate business interests
• Consent (where required for marketing)
• Explicit consent for any sensitive data (if ever applicable)
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5. How We Use Personal Data
We use personal data to:
• Process and manufacture custom orders
• Manage staged payment structures (50% deposit / 50% completion payment)
• Arrange hand delivery logistics
• Provide customer service
• Comply with accounting and regulatory obligations
• Prevent fraud and misuse
• Improve product quality and durability standards
• Provide marketing communications (where consent is provided)
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6. Payment Terms & Data Handling
Orders require:
• 50% deposit upon order placement
• 50% upon completion prior to delivery
• Optional full payment upfront at customer discretion
Payment information is processed securely. Miloni X Roc does not accept liability for third-party payment platform breaches where reasonable due diligence has been undertaken.
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7. Shipping & Delivery
All items are hand delivered. Delivery costs vary depending on product weight and logistics requirements.
Customer data is shared only with necessary delivery personnel strictly for fulfilment purposes.
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8. Branding Transparency & Third-Party Products
Miloni X Roc may customise products manufactured by other established brands.
We:
• Clearly state original brand names used
• Do not claim ownership of third-party manufactured products
• Do not resell branded items in their original purchased condition
• Ensure customisation does not impact functionality
Any third-party brand warranties remain separate from Miloni X Roc’s labour warranty.
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9. Manufacturing Locations
Products are primarily manufactured in the United Kingdom.
On occasion, manufacturing may take place within the United Arab Emirates.
Where cross-border processing occurs, safeguards are implemented in accordance with UK GDPR and UAE PDPL requirements.
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10. Data Sharing
We may share personal data with:
• Payment processors
• Accountants and legal advisers
• Logistics and delivery personnel
• IT service providers
• Regulatory authorities where legally required
We do not sell personal data.
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11. International Transfers
Due to UK-UAE operations, personal data may be transferred internationally.
Such transfers are protected via:
• Contractual safeguards
• Data processing agreements
• Adequate security measures
• Compliance with UK GDPR transfer provisions
• Compliance with UAE PDPL cross-border requirements
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12. Data Retention
We retain data only as long as necessary for:
• Contract fulfilment
• Warranty obligations (1 year labour cover)
• Legal and accounting requirements
• Dispute resolution
Data is securely deleted when no longer required.
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13. Warranty, Refunds & Exchanges
• No refunds or exchanges after deposit payment
• Labour covered for 1 year
• Excludes accidental damage, misuse, improper cleaning, or wear and tear
Warranty claims may require retention of order records.
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14. Customer Responsibilities
Customers must:
• Provide accurate information
• Follow cleaning and maintenance instructions
• Acknowledge custom nature of products
• Confirm design approval prior to production
Failure to follow product guidance voids labour warranty coverage.
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15. Customer Rights (UK & UAE)
Under applicable laws, individuals have the right to:
• Access their data
• Request correction
• Request erasure (subject to legal obligations)
• Restrict processing
• Object to processing
• Data portability (where applicable)
• Withdraw consent (where processing is based on consent)
Requests must be submitted in writing.
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16. Security Measures
We implement appropriate technical and organisational measures including:
• Secure storage systems
• Limited access controls
• Encrypted communications where applicable
• Confidentiality obligations for staff
However, no digital system is completely immune from risk. We shall not be liable for breaches beyond reasonable control where appropriate safeguards were in place.
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17. Limitation of Liability
To the fullest extent permitted under applicable law:
• Miloni X Roc shall not be liable for indirect, incidental, consequential, or third-party damages.
• Liability is limited to the value of the order placed.
• Customers accept the bespoke nature of customised goods.
• Miloni X Roc is not responsible for third-party brand defects unrelated to customisation.
Nothing in this policy excludes liability where prohibited by UK or UAE law.
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18. Marketing Communications
Where consent is provided, we may send promotional material.
You may opt out at any time.
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19. Cookies
If operating via a website, cookies may be used to enhance user experience and track analytics.
A separate Cookie Policy may apply.
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20. Dispute Resolution & Governing Law
Where transactions occur via the UK entity, disputes shall be governed by the laws of England and Wales.
Where transactions occur via the UAE entity, disputes shall be governed by the laws of the relevant Free Zone jurisdiction.
Jurisdiction will be determined based on the contracting entity.
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21. Updates to This Policy
We reserve the right to amend this Privacy Policy at any time to reflect legal or operational changes.
The latest version will always be published online.