PRIVACY POLICY

Tabarak Trading FZCO
Dubai, United Arab Emirates
Last Updated: [Insert Date]

1. INTRODUCTION

Tabarak Trading FZCO (“Company”, “we”, “our”) operates as an international commodity sourcing and trade coordination platform.

This Privacy Policy governs how we collect, process, and protect data in the context of:

  • Business engagement
  • Transaction structuring
  • Compliance obligations

This is a B2B environment, not a consumer platform.

2. DATA CLASSIFICATION

We process the following categories of data:

2.1 Business Contact Data

  • Company name
  • Representative details
  • Email / phone / WhatsApp

2.2 Commercial & Transaction Data

  • Commodity requirements
  • Volume requests
  • Technical specifications
  • Pricing discussions

2.3 Compliance & KYC Data

  • Corporate documents
  • Shareholder / UBO information
  • Identification documents
  • Banking details
  • Source of funds / wealth

2.4 Technical Data

  • IP address
  • Browser and device data
  • Website interaction

3. PURPOSE OF PROCESSING

Data is processed strictly for:

  • Client onboarding and communication
  • Transaction structuring and execution
  • Logistics coordination
  • Compliance with AML / KYC obligations
  • Internal risk and credit assessment

We do not process data for consumer marketing purposes.

4. LEGAL BASIS

Processing is based on:

  • Legitimate business interest
  • Pre-contractual and contractual necessity
  • Legal and regulatory obligations

including UAE AML/CFT framework and international compliance standards.

5. KYC / AML / SANCTIONS COMPLIANCE

5.1 We apply compliance procedures aligned with:

  • UAE Federal Decree-Law No. (20) of 2018
  • International banking standards

5.2 Data may be used for:

  • Identity verification
  • Beneficial ownership checks
  • Sanctions screening (OFAC, EU, UN, UK)
  • Risk profiling

5.3 We reserve the right to:

  • Refuse engagement
  • Suspend transactions
  • Request additional documentation

6. DATA SHARING & DISCLOSURE

We may disclose data strictly where necessary to:

  • Banking partners (for payments / trade finance)
  • Compliance providers
  • Inspection agencies (e.g. SGS)
  • Logistics and operational partners
  • Legal and regulatory authorities

We do not sell or commercially exploit personal data.

7. INTERNATIONAL DATA TRANSFER

Due to the nature of cross-border trade, data may be processed in multiple jurisdictions.

By engaging with us, you consent to such transfers.

8. DATA RETENTION

Data is retained:

  • For the duration of business engagement
  • As required by regulatory obligations
  • For risk management and audit purposes

9. DATA SECURITY

We implement appropriate safeguards to protect data against:

  • Unauthorized access
  • Misuse
  • Disclosure

However, no system is fully risk-free.

10. WEBSITE DATA (COOKIES & TRACKING)

We use cookies to:

  • Ensure website functionality
  • Improve performance
  • Analyze usage

Users may disable cookies via browser settings.

11. EMBEDDED CONTENT & THIRD PARTIES

Embedded content may collect data independently under their own policies.

We are not responsible for third-party data practices.

12. DATA SUBJECT RIGHTS

Subject to applicable law, you may:

  • Request access
  • Request correction
  • Request deletion (where permissible)

Requests can be submitted via email.

13. BUSINESS USE DISCLAIMER

All data provided to the Company is supplied in a commercial and professional context.

The Company does not assume obligations applicable to consumer data environments.

14. POLICY UPDATES

We reserve the right to update this Policy at any time.

15. CONTACT

Tabarak Trading FZCO
Dubai, United Arab Emirates
Website: https://tabarak.trading/
Email: [Insert Email]