Privacy Policy

Monday, 06 May 2024, 06:30

Introduction and Scope
1.1 This Privacy Policy (“Privacy Policy”) describes the types of personal data which Dubai Trade Fze (“Dubai Trade” or “us” or “we” or “our”), a company incorporated under, and governed by, the laws of the United Arab Emirates (“UAE”) collects, the purposes for which we collect such personal data, the other parties with whom we may share it and the measures we take to protect the security of the said personal data when you avail the services and products on the website, www.dubaitrade.ae. It also tells you about your rights and choices with respect to your personal data, and how you can contact us about our privacy practices.
1.2 By applying or signing up for services offered through Dubai Trade, you consent to our direct or indirect collection, processing, and disclosing to third parties any personal data about you as described in this Privacy Policy (including Annex A) or as may otherwise be allowed or required by applicable law. You are not under a legal obligation to provide us with any of your personal information but please note that if you elect not to provide us with your personal data, we may be unable to provide our products or services to you.
1.3 You can read, print, and save this whole policy. We use sub-headings to help you find specific information that you may be looking for more easily.

Data Controller
2.1 Dubai Trade is the data controller for the purposes of this Privacy Policy.
2.2 As a data controller, we collect personal data and process it in accordance with relevant data protection principles, including lawfulness, fairness, and transparency; purpose limitation; collection limitation; data minimization; accuracy; rectification measures; storage limitation; integrity and confidentiality (security); with all relevant laws and regulations considered; and however applicable.

Further Information

For any further information regarding this Privacy Policy, advice, or guidance, please email This email address is being protected from spambots. You need JavaScript enabled to view it..

Information We Collect From Or About You, Why We Use It And Where We Get It From
4.1 We collect and process different types of personal data, which we set out in the table below together with the lawful basis for our use of your information and the source of such information. Please read the below table in conjunction with the respective annexes of this Privacy Policy.

Information we use	Purpose / activity	Lawful basis / condition	Source of information
Personal identifiers/details Name, address, employer, job title, contact details, appointments, nationality, languages and qualifications and experience.	Register for our services. Fulfil any requests you make (e. g., submitting a query on our website, subscribing to a communications service, fulfilling requests for information, entering into a competition, promotion, survey etc.). Allow you to participate in any interactive features of our service, when you choose to do so.	Performance of a contract with you. Necessary to comply with a legal obligation.	Our registration, enquiry or contact forms, our direct interactions with you, or our email correspondence with you. Our business units.
Marketing data Preferences regarding communications methods and areas of interest relating to: · group companies and our products or services; and · receiving marketing communications from us.	Promote and market group companies’ products and services. Promote and market third party products.	Consent.	Our registration, enquiry or contact forms, our direct interactions with you, or our email correspondence with you. Our business units.
Feedback and opinions	Allow us to answer queries and complaints you may have. Help us evaluate the quality and consistency of our services.	Your consent. Performance of our contract with you.	Our enquiry or contact forms, and our correspondence with you.
Website and communication usage data Your IP address, details of visits to our website, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, the full Uniform Resource Locators (“URL”), clickstream to, through and from our website and the date and time of the clickstream, products or services you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (scrolling, clicks, and mouse-overs), methods used to browse away from the page and any phone number used to call our customer service number.	Enable us to: · monitor the performance and relevance of our website and our ad words campaigns; · ensure that content from our website is presented in the most effective manner for you and for your computer; · tailor the content of our website for you; and · keep our website, our other IT systems, and facilities safe and secure.	Your consent. Performance of our contract with you.	As you interact with our website, we will automatically collect website and communication usage data about your equipment, browsing actions and patterns. We collect this personal data through the operation of your browser on your device, by using cookies and other similar technologies. Please see our cookie policy in section 2 of Annex A for further details. Third party analytics providers such as Google Analytics and Hotjar.
Email interaction The number of times you open each email we have sent you, whether they have been delivered to you, and which sections you clicked on, and information contained within our correspondence with you.	Fulfil any requests you make (e.g., submitting a query on our website, subscribing to a communications service, fulfilling requests for information, entering into a competition, promotion, survey etc.). Measure the effectiveness of our email correspondence with you, including marketing campaigns. Plan marketing campaigns. Segment our database.	Your consent. Performance of our contract with you.	Our correspondence with you.
Banking data Your transactional information, such as bank account number, the merchant’s name and location, the date and the total amount of the transaction, masked payment card numbers, bank statements BIC and, where applicable, your tax reference, sales tax, or VAT number, as well as your purchase/sales history (as applicable) and other information provided by financial institutions or merchants when we act on their behalf.	Perform the agreements we have with you or your employer and to manage our relationship in this respect. Monitor our activities (measuring and compiling statistics on sales, purchases, payments, number of customers). Improve the quality of our products and services. Safeguard our economic interests.	Your consent.	Our registration forms, order forms or correspondence with you. Any transactions conducted by you on our website.

Information we use

Purpose / activity

Lawful basis / condition

Source of information

Personal identifiers/details

Name, address, employer, job title, contact details, appointments, nationality, languages and qualifications and experience.

Fulfil any requests you make (e. g., submitting a query on our website, subscribing to a communications service, fulfilling requests for information, entering into a competition, promotion, survey etc.).

Allow you to participate in any interactive features of our service, when you choose to do so.

Performance of a contract with you.

Necessary to comply with a legal obligation.

Our registration, enquiry or contact forms, our direct interactions with you, or our email correspondence with you.

Our business units.

Marketing data

Preferences regarding communications methods and areas of interest relating to:

· group companies and our products or services; and

· receiving marketing communications from us.

Promote and market group companies’ products and services.

Promote and market third party products.

Consent.

Our registration, enquiry or contact forms, our direct interactions with you, or our email correspondence with you.

Our business units.

Feedback and opinions

Allow us to answer queries and complaints you may have.

Help us evaluate the quality and consistency of our services.

Your consent.

Performance of our contract with you.

Our enquiry or contact forms, and our correspondence with you.

Website and communication usage data

Your IP address, details of visits to our website, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, the full Uniform Resource Locators (“URL”), clickstream to, through and from our website and the date and time of the clickstream, products or services you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (scrolling, clicks, and mouse-overs), methods used to browse away from the page and any phone number used to call our customer service number.

Enable us to:

· monitor the performance and relevance of our website and our ad words campaigns;

· ensure that content from our website is presented in the most effective manner for you and for your computer;

· tailor the content of our website for you; and

· keep our website, our other IT systems, and facilities safe and secure.

Your consent.

Performance of our contract with you.

As you interact with our website, we will automatically collect website and communication usage data about your equipment, browsing actions and patterns. We collect this personal data through the operation of your browser on your device, by using cookies and other similar technologies. Please see our cookie policy in section 2 of Annex A for further details.

Third party analytics providers such as Google Analytics and Hotjar.

Email interaction

The number of times you open each email we have sent you, whether they have been delivered to you, and which sections you clicked on, and information contained within our correspondence with you.

Fulfil any requests you make (e.g., submitting a query on our website, subscribing to a communications service, fulfilling requests for information, entering into a competition, promotion, survey etc.).

Measure the effectiveness of our email correspondence with you, including marketing campaigns.

Plan marketing campaigns.

Segment our database.

Your consent.

Performance of our contract with you.

Our correspondence with you.

Banking data

Your transactional information, such as bank account number, the merchant’s name and location, the date and the total amount of the transaction, masked payment card numbers, bank statements BIC and, where applicable, your tax reference, sales tax, or VAT number, as well as your purchase/sales history (as applicable) and other information provided by financial institutions or merchants when we act on their behalf.

Perform the agreements we have with you or your employer and to manage our relationship in this respect.

Monitor our activities (measuring and compiling statistics on sales, purchases, payments, number of customers).

Improve the quality of our products and services.

Safeguard our economic interests.

Your consent.

Our registration forms, order forms or correspondence with you.

Any transactions conducted by you on our website.

You are not under a legal obligation to provide us with any of your personal information but please note that if you elect not to provide us with your personal data, we may be unable to provide our products or services to you.

4.2 Our products and services use cookies to distinguish you from other users. This helps us to provide you with a good experience when you browse. Our products and services and also allows us to improve it. For detailed information on the cookies, we use and the purposes for which we use them see our Cookie policy in section 2 of Annex A.

Related Websites and Third-Party Websites
5.1 We operate several other websites through which you can access our products and services, all of which are governed by this Privacy Policy unless a dedicated privacy policy is available on that website.
5.2 It is important that you read this Privacy Policy together with any other privacy notice (including any Acceptable Use Policy) or fair processing notice we provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your personal data. This Privacy Policy supplements the other notices and is not intended to override them.
5.3 Our products and services include links to third party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. We strongly advise you to review the privacy policy of every website you visit.
5.4 This Privacy Policy does not apply to, and we are not responsible for the privacy policies of these third-party websites regardless of whether they were accessed while using links from our website or communications. These third parties are typically used for the following:

5.4.1 Advertising, direct marketing, lead generation and other marketing service providers;
5.4.2 SMS and email notification service providers;
5.4.3 Foreign and domestic financial and credit institutions; and
5.4.4 Auditors.

Disclosing, Sharing and Transferring Personal Data
6.1 We use third party service providers in connection with providing our services to you. We have contracts in place with all third-party service providers we use that strictly govern how they use the personal data we disclose to them.
6.2 The table below indicates categories of organisations to whom we may disclose information about you, the reason we disclose this information, what information is shared with them, and where these organisations are located.

Categories of Organisation	Purpose / Activity	Lawful basis	Information shared
Marketing agencies, database hosting companies, data cleansing companies	To provide marketing services and fulfil our CRM and email program.	Your Consent.	Personal identifiers, marketing data, email interaction, website, and communication usage data.
Third-party product and service providers	To provide you promotional offers for products and services offered by third party service providers. Please refer to section 5 “Related Websites and Third-Party Websites” for additional information regarding your access of such third-party service provider’s websites.	Your Consent.	Personal identifiers, marketing data, email interaction, website, and communication usage data.
Email mailing houses	To fulfil our CRM and email program.	Your Consent.	Personal identifiers, marketing data, email interaction, website, and communication usage data.
Microsoft Azure	Information management.	Performance of our contract with you.	All data types listed in the ‘Information We Collect From Or About You, Why We Use It And Where We Get It From’ section above.
Analytics and search engine providers	To assist us in the improvement and optimisation of our website.	Performance of our contract with you.	Personal Identifiers, website, and communication usage data.
Public authorities, regulators, or government bodies	Administration of justice, regulatory and compliance.	Compliance with our legal obligations.	All data types listed in the ‘Information We Collect From Or About You, Why We Use It And Where We Get It From’ section above.
IT Service providers	To support and maintain the IT software and infrastructure we use including (WIPRO, Oracle, and Accenture).	Performance of our contract with you.	All data types listed in the ‘Information We Collect From or About You’ section above.
Professional advisers	Legal and compliance advice. Audits.	Compliance with our legal obligations.	All data types listed in the ‘Information We Collect From or About You’ section above.

6.3 We may also disclose your personal data to other third parties from time to time:

6.3.1 if we are under a duty to disclose or share your personal data to comply with any legal obligation or if we sell or buy any business or assets, in which case we will
disclose your personal data to the prospective seller or buyer of such business or assets;

6.3.2 to enforce or apply our terms of use and other agreements; and

6.3.3 to protect the rights, property, or safety of our company, our customers, or others including exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

6.4 Where we transfer your personal data to third parties outside of the UAE we shall do so only where there are adequate provisions to ensure your privacy. For more information regarding the measures, we take for international transfer of personal data, please refer to section 3 of Annex A.

Marketing Communications
7.1 You can ask us to only send you marketing communications by particular methods (email, telephone, text message or post), about specific subjects or you can us not to send you any marketing communications at all.
7.2 We will ask you to indicate your marketing preferences when you first register an account on our websites and/or app (as applicable), which you can change by emailing This email address is being protected from spambots. You need JavaScript enabled to view it..

Data Retention
8.1 We will retain and process your personal data for as long as you continue to use or express an interest in our services, log into our websites or use our interactive services. We may retain your personal data for a longer period of time to comply with legal, accounting, reporting, government, regulatory or law enforcement requirements. You may email us at This email address is being protected from spambots. You need JavaScript enabled to view it. for more information on our data retention practices.
8.2 We will hold information about how you interact with our electronic communications for 6 months in order to help us analyse the performance of our digital marketing activities or customers and prospects.
8.3 We will only keep your information for a longer period where necessary in order to comply with our legal obligations.
Your Rights
9.1 Data protection law grants you certain rights which we summarise in the table below. Please note that these rights are not absolute, and they may not always apply in your particular circumstances. To exercise your rights, please email us at This email address is being protected from spambots. You need JavaScript enabled to view it.. We may need to request specific information from you to help us confirm your identity and ensure your entitlement to such rights. This security measure is to ensure that your personal data is not disclosed to any person who has no right to receive it.

Right of access and data portability	You have the right of access to information we hold about you and/or to have it transferred to another data controller in some circumstances.
Right of rectification or erasure	If you feel that any data that we hold about you is inaccurate you have the right to ask us to correct or rectify it. You also have a right to ask us to erase information about you where you can demonstrate that the data, we hold is no longer needed by us, if you withdraw the consent upon which our processing is based, or if you feel that we are unlawfully processing your data. Your right of rectification and erasure extends to anyone we have disclosed your personal data to, and we will take all reasonable steps to inform those with whom we have shared your data about your request for erasure.
Right to restriction of processing	You have a right to request that we refrain from processing your data where you contest its accuracy, the processing is unlawful and you have opposed its erasure, where we do not need to hold your data anymore, but you need us to in order to establish, exercise or defend any legal claims, or we are in dispute about the legality of our processing your personal data.
Right to object	You have a right to object to our processing of your personal data. This includes the right to object to the use of your information for direct marketing and profiling purposes.
Right to withdraw consent	You have the right to withdraw your consent for the processing of your personal data where the processing is based on consent.
Right of complaint	If you are unhappy with the way we have used or are handling your personal data you have the right to lodge a complaint with the supervisory authority for data protection issues in the country where you usually live, work or where the relevant issue arose. We would, however, appreciate the chance to deal with your concerns before you approach the supervisory authority, so please contact us in the first instance at the email set out above.

Data Security
10.1 We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties as detailed in ‘Disclosing, Sharing and Transferring Personal Data’ above. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
10.2 We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
10.3 Please remember that you are responsible for keeping your passwords secure. If we have given you (or you have chosen) a password which enables you to access certain parts of products and services (as applicable), you are responsible for keeping this password confidential. Please do not to share your passwords with anyone.
10.4 Please note that no transmission over the internet or any method of electronic storage can be guaranteed to be absolutely 100% secure, however, our best endeavours will be made to secure data and the ability to access your personal data.
10.5 Without prejudice to our efforts on protection of your data, nothing contained in this Policy constitutes a warranty of security of the facilities, and you agree to transmit data at your own risk.
10.6 Please note, that we do not guarantee that your data may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. Please, always check that any website on which you are asked for financial or payment information in relation to our services is in fact legitimately owned or operated by us.
10.7 If you do receive any suspicious communication of any kind or request, do not provide your information and report it us by contacting our offices immediately at This email address is being protected from spambots. You need JavaScript enabled to view it.. Please also immediately notify us at This email address is being protected from spambots. You need JavaScript enabled to view it. if you become aware of any unauthorized access to or use of your account.
10.8 Furthermore, we cannot ensure and do not warrant the security or confidentiality of data transmitted to us or sent and received from us by internet or wireless connection, including email, phone, instant messaging service or SMS, since we have no way of protecting that information once it leaves and until it reaches us. If you have reason to believe that your data is no longer secure, please contact us This email address is being protected from spambots. You need JavaScript enabled to view it..
10.9 We also aim to conduct all applicable security risk assessments to ensure the availability of risk mitigation controls, to better safeguard the integrity of your data.

How We Keep This Policy Up to Date
11.1 This Privacy Policy was last updated on 01/05/2024. From time to time, we may revise, amend, or supplement this Policy to reflect necessary changes in law, our personal data collection and usage practices, the features of our offerings, or advances in technology. If any material changes are made to this Policy, the changes may be prominently posted on our websites and applications. However, the onus is also on you to occasionally familiarize yourself with the contents of this Policy, for your own information. Changes to this Policy are effective when they are published.

Annex A: Dubai Trade FZE

Preliminary

1.1. This Annex A (“Annex A”) supplements the above Privacy Policy and lists the nature of information collected, received, processed, and shared by Dubai Trade.

1.2. In case of any conflict between the contents of this Annex A and the main body of this Privacy Policy, this Annex A shall prevail insofar as the personal data processing activities of Dubai Trade are concerned. For any disclosure not made, or information not specifically provided in this Annex A in relation to Dubai Trade’s personal data processing activities, the contents of the main body of this Privacy Policy shall apply.

Cookies Policy

This section explains what cookies are, what information we collect using cookies and how we use cookies in respect of Dubai Trade.

2.1. What is a cookie?

2.1.1. A ‘cookie’ is a small piece of encrypted text saved on the browser or hard drive in your computer or mobile device when you visit a website. Cookies are selected pieces of information that sent to your device or computer’s hard drive, while you are viewing or using Dubai Trade, as permissioned. It allows us to recognise you and make your next visit easier and the experience of our services more useful to you. cookies can be stored for varying lengths of time on your browser or device.

2.1.2. We use both session / transient cookies (which expire once you close your device web browser) and persistent cookies (which stay on your device until you delete them) to collect information to provide you with a more personalized and interactive experience in using Dubai Trade and services. This type of data is collected to make our services more useful to you and to tailor your experience with us to meet your special interests and needs.

2.2. How we use cookies

2.2.1. When you use and access Dubai Trade, we may place a number of cookie files on your device’s web browser. We use cookies to enable certain functions of Dubai Trade, i.e., to provide analytics, to prevent fraudulent or illegal activity, to store your preferences, to enable advertisements delivery, including behavioural advertising. We also use cookies to enhance your browsing experience by:

Recognizing when you log in and any preferred settings.
Giving you a browsing experience that is unique to you and to serve you content which we believe improves your sites experience.
Analysing how you use our sites which helps us to troubleshoot any problems and to monitor our own performance.

2.2.2. In addition to our own cookies, we may also use various third parties’ cookies to report usage statistics of our sites, deliver advertisements on and through Dubai Trade, and so on.

2.3. Types of cookies we use

2.3.1. We use the following four type of cookies:

Essential cookies: These cookies are essential to let you move around Dubai Trade and use its features. These cookies allow Dubai Trade to provide services at your request. We use essential cookies to authenticate users and prevent fraudulent use of user accounts.
Performance cookies: These cookies may be used to collect information about how you use Dubai Trade e.g., which pages you visit most often, and if you experience any error messages. They also allow us to update Dubai Trade to improve performance and tailor it to your preferences. These cookies do not collect any information that could identify you - all the information collected is anonymous.
Functionality cookies: These cookies are used to remember the choices you make, e.g., your username, log in details and language preferences. They also remember any customizations you make to give you enhanced, more personal features of your digital experience.

2.4. Cookies preferences

Please note, that if you delete cookies or refuse to accept them, you might not be able to use all of the features we offer on Dubai Trade. You may not be able to store your preferences, and some of our pages might not display properly. Dubai Trade is not responsible and will not be held liable for any loss resulting from your decision or inability to use cookies.

International Transfer of Personal Data

3.1. Dubai Trade ensures that your personal data is stored and transferred in compliance with the applicable legislation or regulations of the UAE.

3.2. You should be aware that certain third-party service providers, such as payment transaction processors, may be located in, or have facilities that are located in, outside UAE, in a different jurisdiction than either you or us.

3.3. As mentioned in section 3.2 ,we may transfer of personal data outside the UAE, and we shall do so only when the country or territory to which the personal data is to be transferred (i) has a bilateral or multilateral agreements related to personal data protection with the UAE or (ii) has special legislation on personal data protection therein, including the most important provisions, measures, controls, requirements and rules for protecting the privacy and confidentiality of the your personal data and their ability to exercise their rights, and provisions related to imposing appropriate measures on the controller or processor through a supervisory or judicial authority.

3.4. However, some of the international organizations and countries to which your personal data may be transferred do not benefit from an appropriate data protection regulatory framework. For such international organizations and countries, we shall transfer your personal data, only upon ensuring that a suitable degree of protection is afforded to it through the implementation of the necessary safeguards, such as an adequacy decision by the relevant authority, adequate binding corporate rules or through the inclusion of standard contractual clauses in our agreements with such organizations and countries. We may also transfer your personal data to recipients outside the UAE based on your express consent; or if such transfer is necessary for judicial processes; or if such transfer is necessary for entering into or performing a contract between Dubai Trade and you or between Dubai Trade and a third party for your interests, or if such transfer is necessary for an act relating to international judicial cooperation; or if the transfer is necessary for protection of public interest. We shall notify you with regards to the specific safeguard we shall adopt in transferring your personal data to such an international organization and/or country if you require such data. You provide your consent, through the acceptance of the Privacy Policy and Annex A for such transfer.

3.5. If you wish to procure specific information about the third-party service providers with whom your personal data has been shared, please contact us at This email address is being protected from spambots. You need JavaScript enabled to view it.. If you choose to proceed with a service that requires the involvement of a third-party service provider, then your personal data may become subject to the laws of the jurisdiction(s) in which that service provider or its facilities are located. For these providers, we recommend that you read their privacy policies, so you can understand the manner in which your personal data will be handled by these providers.

Additional Security Precautions and Measures for Banking Data

4.1. Data breaches

4.1.1. Should your personal data be breached, and your banking data be at risk, we shall promptly and immediately communicate to you the nature of the breach which has taken place, the likely consequences of such a breach and shall describe thoroughly the measures we have implemented to address the breach and to mitigate any and all adverse effects to you and your rights. We will also notify the CBUAE of the breach in accordance with applicable regulations. In the unlikely event of a breach occurring, please reach out to us at This email address is being protected from spambots. You need JavaScript enabled to view it. for further information and for further advise on how to mitigate the potential adverse effects of such a breach.