Last updated: 2024-01-15T10:00:00Z • Draft — not legal advice.

Privacy Policy

1. Data Controller

Controller: Car-Vault UAE FZ-LLC

Contact: [email protected]

Data Protection Officer: [email protected]

2. Categories of Personal Data

We collect the following categories of personal data:

• Identity information (name, Emirates ID, passport)
• Contact details (phone, email, address)
• Vehicle information (make, model, year, VIN, condition)
• KYC documentation (ID copies, proof of ownership)
• Financial information (bank account details for transfers)

3. Purposes and Legal Bases

3.1 Contract Performance

Service provision and payment processing

3.2 Legitimate Interests

Business operations and customer service

3.3 Legal Obligation

AML/CFT compliance and regulatory reporting

4. Your Data Subject Rights (UAE PDPL)

Under the UAE Personal Data Protection Law, you have the following rights:

• Right of access to personal data
• Right to correction of inaccurate data
• Right to erasure (subject to legal obligations)
• Right to restrict processing
• Right to object to processing
• Right to data portability

To exercise these rights, contact us at [email protected]. We will respond within 30 days of receiving your request.

5. Data Sharing

5.1 Service Providers

We share data with the following processors:

• Hosting providers (AWS, Vercel)
• Analytics services (Google Analytics)
• Telecom providers for SMS/email
• CRM systems for customer management

5.2 Law Enforcement

When required by UAE law or court order

6. Cross-Border Data Transfers

Cross-border transfers only to adequate jurisdictions or with appropriate safeguards

6.1 Safeguards

We implement appropriate safeguards including:

• Standard contractual clauses
• Explicit consent where required

7. Data Retention

7.1 KYC Documentation

5 years post-transaction as required by UAE AML/CFT

7.2 General Data

3 years post-service completion

7.3 Marketing Data

Until consent withdrawn

8. Children's Privacy

Not targeted at children; 18+ only

No intentional collection of children's data

9. Complaints

If you have concerns about our data processing, you can:

• Contact our DPO at [email protected]
• File a complaint with the UAE Data Office

We aim to respond to complaints within 30 days for initial response.

10. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be communicated via email or website notice. The "Last updated" date indicates when this policy was last revised.

11. Contact Information

For privacy-related questions:

• Email: [email protected]
• Phone: +971 4 123 4567
• Address: Business Bay, Dubai, UAE