1. Introduction and Data Controller
BOGNA TRADE FZ-LLC ("Bogna Trade," "we," "us," or "our") is a company incorporated and registered in the Ras Al Khaimah Economic Zone (RAKEZ), United Arab Emirates, under License No. 5027817RIB-210A, with its registered office at RAK Insurance Building, RAKEZ Business Zone-FZ RAK, United Arab Emirates.
We are committed to protecting the privacy and security of personal data entrusted to us by our business partners, prospective clients, website visitors, and all other individuals who interact with us. This Privacy Policy explains how we collect, use, store, share, and protect your personal data in connection with our website bogna.ae (the "Website") and related business communications.
For the purposes of the UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data ("UAE PDPL"), Bogna Trade is the Data Controller responsible for your personal data.
2. Scope and Applicability
This Privacy Policy applies to all personal data processed by Bogna Trade in connection with the operation of our Website, business-to-business (B2B) trading activities, and communications through any channel including email, WhatsApp, telephone, and web-based forms.
This Policy is designed to comply with UAE Federal Decree-Law No. 45 of 2021 (UAE PDPL) and takes into account international best practices including the EU General Data Protection Regulation (GDPR), the Kingdom of Saudi Arabia's Personal Data Protection Law (KSA PDPL), and the Bahrain Personal Data Protection Law (PDPL), to the extent that these laws may apply to our processing activities due to the international nature of our business.
If you are accessing this Website from a jurisdiction with specific data protection legislation, we will process your personal data in accordance with the applicable legal requirements of that jurisdiction, in addition to the requirements of UAE law.
3. Key Definitions
In this Policy, the following terms have the meanings set out below, consistent with Article 1 of the UAE PDPL:
"Personal Data" means any data relating to an identified natural person, or a natural person who can be identified, directly or indirectly, through the linking of data, by reference to an identifier such as their name, voice, image, identification number, online identifier, geographical location, or one or more physical, physiological, economic, cultural, or social characteristics.
"Sensitive Personal Data" means personal data that reveals family background, ethnicity, political or religious beliefs, criminal record, biometric data, health information, genetic data, or sexual life.
"Processing" means any operation performed on personal data, whether by automated or non-automated means, including collection, recording, organisation, structuring, storage, adaptation, retrieval, consultation, use, disclosure, dissemination, alignment, combination, restriction, erasure, or destruction.
"Data Subject" means the identified or identifiable natural person to whom personal data relates.
"Data Controller" means the entity that determines the purposes and means of processing personal data.
4. Personal Data We Collect
We collect and process the following categories of personal data, depending on the nature of your interaction with us:
4.1 Data You Provide Directly
| Category | Examples | Collection Point |
|---|---|---|
| Identity Data | Full name, job title, company name | Contact forms, email, WhatsApp |
| Contact Data | Email address, phone number, WhatsApp number, business address | Contact forms, direct correspondence |
| Business Data | Company registration details, trade licence number, import/export requirements, product preferences, order volumes | RFQ forms, negotiations, emails |
| Communication Data | Content of messages, enquiries, feedback | Email, WhatsApp, web forms |
4.2 Data Collected Automatically
| Category | Examples | Technology |
|---|---|---|
| Technical Data | IP address, browser type and version, operating system, device type, screen resolution | Web server logs, analytics |
| Usage Data | Pages visited, time on page, click patterns, referral source, exit pages | Analytics cookies |
| Location Data | Approximate geographic location derived from IP address (country/city level only) | Web server logs |
4.3 Data We Do Not Collect
Bogna Trade does not intentionally collect any Sensitive Personal Data as defined by the UAE PDPL, including data revealing ethnic origin, political opinions, religious or philosophical beliefs, criminal records, biometric data, health data, or data concerning sexual orientation. Our services are business-to-business in nature and do not require such information.
5. Legal Basis for Processing
In accordance with Article 5 of the UAE PDPL, we process your personal data on one or more of the following legal bases:
| Legal Basis | Description | Applicable Activities |
|---|---|---|
| Consent | You have given clear, informed, and unambiguous consent to the processing of your personal data for one or more specific purposes. | Newsletter subscription, marketing communications, non-essential cookies |
| Contractual Necessity | Processing is necessary for the performance or negotiation of a contract to which you are a party. | Processing RFQs, fulfilling orders, trade documentation, business correspondence |
| Legitimate Interest | Processing is necessary for the legitimate interests pursued by Bogna Trade, provided such interests are not overridden by your rights and freedoms. | Website analytics, fraud prevention, improving our services, business development |
| Legal Obligation | Processing is necessary for compliance with a legal obligation to which Bogna Trade is subject under UAE law. | Tax reporting, regulatory compliance, record-keeping requirements |
Where we rely on consent as the legal basis for processing, you have the right to withdraw your consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out prior to the withdrawal.
6. Purposes of Processing
We use your personal data exclusively for the following purposes:
Business Operations: To process and respond to your enquiries, requests for quotation (RFQs), and other business communications; to negotiate, conclude, and perform trade contracts; and to manage our ongoing business relationship with you.
Website Operation: To operate, maintain, and improve our Website; to provide you with relevant content; and to ensure the technical functionality and security of the Website.
Analytics and Improvement: To analyse usage patterns and trends on our Website in order to improve user experience, optimise content, and enhance our services. This processing is performed using aggregated or anonymised data wherever possible.
Compliance and Legal: To comply with applicable laws, regulations, and legal processes; to enforce our Terms of Service; to protect the rights, property, and safety of Bogna Trade, our business partners, and third parties; and to detect and prevent fraud or other unlawful activity.
Communications: To send you information directly related to our business relationship, including updates on products, pricing, logistics, and trade regulations relevant to your interests. Marketing communications will only be sent with your express prior consent, and you may opt out at any time.
7. WhatsApp and Messaging Channels
Bogna Trade uses WhatsApp Business as a primary communication channel with our B2B clients and prospective partners. When you initiate or respond to communication via WhatsApp, please be aware of the following:
Data Processed: Your WhatsApp phone number, display name, profile picture (if publicly visible), message content, and any attachments (documents, images, specifications) you share with us.
Third-Party Platform: WhatsApp is a service operated by Meta Platforms, Inc. Messages sent through WhatsApp are subject to WhatsApp's own Privacy Policy and Terms of Service, which are separate from and in addition to this Privacy Policy. We encourage you to review WhatsApp's privacy practices at whatsapp.com/legal/privacy-policy.
End-to-End Encryption: WhatsApp provides end-to-end encryption for messages. However, once we receive your messages, the information contained therein is processed and stored in accordance with this Privacy Policy.
Retention: Business communications via WhatsApp are retained for the duration of our active business relationship and for such additional period as may be required by UAE commercial law (see Section 12).
8. Email Communications
Email is a primary channel for our business communications, including enquiries, quotations, order confirmations, shipping documentation, and general correspondence. When you communicate with us via email, the following applies:
8.1 Data Processed
We process your email address, the name and signature block details you provide, the content and attachments of your messages, and associated technical metadata (date, time, IP headers). Where you send us commercial documents such as purchase orders, proforma invoices, or product specifications, the business information contained therein is also processed as part of our trade operations.
8.2 Legal Status of Email Correspondence
Unless a separate written agreement is executed between the parties, email correspondence with Bogna Trade does not constitute a binding offer, acceptance, or contractual commitment. Quotations, product descriptions, pricing indications, and availability information shared via email are provided for informational purposes only and are subject to formal confirmation through a signed contract or official purchase order. This provision does not affect any rights or obligations that may arise under applicable law regarding the formation of contracts through electronic communications.
8.3 Confidentiality and Interception
While we take reasonable measures to secure our email systems, email communication over the internet is inherently not fully secure and may be subject to interception, loss, or alteration. Bogna Trade cannot guarantee the confidentiality or integrity of information transmitted via unencrypted email. If you wish to share sensitive commercial information, we recommend using encrypted channels or arranging alternative secure methods of communication. Bogna Trade shall not be liable for any loss or damage arising from the interception, alteration, or misdelivery of email communications by third parties beyond our reasonable control.
8.4 Retention and Archiving
Business email correspondence is retained in accordance with the retention periods specified in Section 12 of this Policy. Email records may be preserved as evidence of business transactions and communications, in compliance with UAE Federal Law No. 46 of 2021 on Electronic Transactions and Trust Services and UAE commercial law requirements.
8.5 Email Confidentiality Notice
All emails sent from Bogna Trade are confidential and intended solely for the named recipient(s). If you receive an email from us in error, you are requested to notify us immediately and delete the message from your systems. Unauthorised use, disclosure, copying, or distribution of any email from Bogna Trade or its contents is prohibited and may be unlawful under UAE Federal Decree-Law No. 34 of 2021 on Combatting Rumours and Cybercrimes.
9. Cookies and Tracking Technologies
Our Website uses cookies and similar technologies. A detailed description of the cookies we use, their purposes, and your choices regarding cookies is provided in our separate Cookie Policy, which forms an integral part of this Privacy Policy.
In summary, we use: Strictly Necessary Cookies that are essential for the operation of the Website and cannot be disabled; Analytics Cookies that help us understand how visitors interact with our Website (deployed only with your consent); and Functional Cookies that enable enhanced functionality such as language preferences.
You may manage your cookie preferences at any time through our cookie consent mechanism or through your browser settings. For full details, please refer to our Cookie Policy.
10. Data Sharing and Disclosure
Bogna Trade does not sell, rent, or lease your personal data to third parties. We may share your personal data only in the following limited circumstances:
10.1 Service Providers
We engage trusted third-party service providers who process data on our behalf to support our business operations, including website hosting (Tilda Publishing), analytics services, email communication platforms, and cloud storage providers. All service providers are bound by data processing agreements and are contractually obligated to process your data only on our instructions and in accordance with applicable data protection laws.
10.2 Business Partners
Where necessary for the fulfilment of a trade transaction, we may share limited business contact data (name, company, email, phone) with logistics providers, customs brokers, shipping lines, and inspection agencies involved in the supply chain. This sharing is limited to the minimum data necessary for the specific transaction and is governed by appropriate contractual safeguards.
10.3 Legal Requirements
We may disclose your personal data where we are legally required to do so, including in response to valid requests by UAE governmental authorities, regulatory bodies, courts, or law enforcement agencies, or where disclosure is necessary to comply with applicable laws, regulations, or legal processes.
10.4 Protection of Rights
We may disclose personal data where we reasonably believe it is necessary to protect the rights, property, or safety of Bogna Trade, our business partners, or the public; to detect, prevent, or address fraud, security, or technical issues; or to enforce our Terms of Service.
10.5 Business Transfers
In the event of a merger, acquisition, reorganisation, or sale of all or a portion of our assets, personal data may be transferred to the acquiring entity, subject to this Privacy Policy and applicable data protection laws. We will provide notice of any such transfer and any choices you may have regarding your data.
11. International Data Transfers
Due to the international nature of our business, your personal data may be transferred to and processed in countries outside the United Arab Emirates, including but not limited to Vietnam (where our sourcing operations are based) and other countries where our service providers, logistics partners, or business associates operate.
When transferring personal data outside the UAE, we ensure that appropriate safeguards are in place in accordance with the UAE PDPL, including ensuring that the recipient country provides an adequate level of data protection; implementing contractual clauses requiring the recipient to protect personal data to standards no less stringent than those of the UAE PDPL; and obtaining your explicit consent where required by law.
For data subjects located in the European Economic Area (EEA), we will ensure that transfers are subject to appropriate safeguards as required under the GDPR, such as Standard Contractual Clauses (SCCs) approved by the European Commission.
For data subjects located in the Kingdom of Saudi Arabia, transfers will be conducted in compliance with the KSA PDPL and the Regulation on Personal Data Transfer Outside Saudi Arabia issued by SDAIA.
12. Data Retention
We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law. The specific retention periods are as follows:
| Data Category | Retention Period | Basis |
|---|---|---|
| Business correspondence and transaction records | 7 years from the end of the business relationship | UAE Commercial Transactions Law; tax and audit requirements |
| Contract and trade documentation | 10 years from contract completion | UAE Federal Law No. 50 of 2022 (Commercial Transactions Law); limitation periods |
| Website analytics data | 26 months from collection | Legitimate interest; industry standard |
| Marketing consent records | Duration of consent plus 3 years | Proof of consent obligation under UAE PDPL |
| Enquiries that do not result in a business relationship | 24 months from last interaction | Legitimate business interest |
Upon expiry of the applicable retention period, personal data will be securely deleted or anonymised such that it can no longer be associated with an identifiable individual. Where anonymisation is used, the resulting data may be retained indefinitely for statistical and analytical purposes.
13. Data Security Measures
Bogna Trade implements appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These measures include, but are not limited to:
Technical Measures: Encryption of data in transit using TLS/SSL protocols; secure access controls and authentication mechanisms; regular security updates and patches for all systems; access logging and monitoring; and secure backup procedures.
Organisational Measures: Access to personal data is restricted to authorised personnel on a need-to-know basis; service providers are bound by confidentiality obligations and data processing agreements; and we conduct periodic reviews of our data processing practices and security measures.
While we strive to use commercially reasonable means to protect your personal data, no method of electronic transmission or storage is completely secure. We cannot guarantee absolute security, but we commit to promptly addressing any data security incident in accordance with our obligations under the UAE PDPL, including notifying the UAE Data Office and affected individuals where required by law.
14. Your Rights as a Data Subject
Under the UAE PDPL and, where applicable, other data protection laws, you have the following rights in relation to your personal data:
Right of Access: You have the right to request confirmation of whether we process your personal data and, if so, to obtain a copy of such data along with information about the purposes of processing, categories of data concerned, and recipients or categories of recipients.
Right to Rectification: You have the right to request the correction of inaccurate personal data and to have incomplete personal data completed.
Right to Erasure: You have the right to request the deletion of your personal data where it is no longer necessary for the purposes for which it was collected, where you have withdrawn your consent (and no other legal basis exists), or where the data has been unlawfully processed.
Right to Restriction of Processing: You have the right to request that we restrict the processing of your personal data in certain circumstances, such as when you contest the accuracy of the data or when processing is unlawful but you do not want erasure.
Right to Data Portability: Where technically feasible and where processing is based on consent or contract and carried out by automated means, you have the right to receive your personal data in a structured, commonly used, and machine-readable format.
Right to Object: You have the right to object to the processing of your personal data where processing is based on legitimate interests, including profiling. We will cease processing unless we demonstrate compelling legitimate grounds that override your interests.
Right to Withdraw Consent: Where processing is based on consent, you may withdraw your consent at any time without affecting the lawfulness of processing carried out prior to the withdrawal.
Right to Object to Automated Decision-Making: You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
If you believe that our processing of your personal data violates applicable data protection laws, you have the right to lodge a complaint with the UAE Data Office or with the relevant supervisory authority in your jurisdiction.
15. Children's Privacy
Our Website and services are directed exclusively to businesses and business professionals. We do not knowingly collect personal data from individuals under the age of eighteen (18). If we become aware that we have inadvertently collected personal data from a child, we will take immediate steps to delete such data from our systems. If you believe that we have collected data from a minor, please contact us immediately using the details in Section 19.
16. Automated Decision-Making
Bogna Trade does not currently engage in automated decision-making or profiling that produces legal effects concerning you or similarly significantly affects you. Should this change in the future, this Privacy Policy will be updated accordingly and, where required by law, your explicit consent will be obtained before any such processing takes place.
17. Third-Party Links
Our Website may contain links to third-party websites, platforms, or services that are not operated by Bogna Trade. This includes links to WhatsApp, social media platforms, and external resources. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services. We strongly advise you to review the privacy policy of every third-party site you visit. The inclusion of any link on our Website does not imply endorsement by Bogna Trade.
18. Changes to This Policy
Bogna Trade reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data processing practices, legal requirements, or business operations. When we make material changes, we will update the "Last Updated" date at the top of this Policy and, where changes are significant, we will provide a prominent notice on our Website or, where appropriate and feasible, notify you directly.
We encourage you to review this Privacy Policy periodically. Your continued use of our Website and services after any modifications constitutes your acknowledgement of the updated Policy. Where required by law, we will obtain your consent to material changes that affect the processing of your personal data.
19. Contact Information
For any questions, concerns, or requests relating to this Privacy Policy or our data processing practices, or to exercise your rights under applicable data protection law, please contact us:
BOGNA TRADE FZ-LLC
Data Protection Enquiries
RAK Insurance Building, RAKEZ Business Zone-FZ RAK
Ras Al Khaimah, United Arab Emirates
License No.: 5027817RIB-210A
Email: eaREMOVE.anNULLgobFAKE@ofSPAMni
We aim to respond to all legitimate enquiries within thirty (30) calendar days. If your enquiry is particularly complex, we will notify you and may take up to ninety (90) calendar days to provide a complete response.
20. Governing Law and Dispute Resolution
This Privacy Policy shall be governed by and construed in accordance with the laws of the United Arab Emirates, including Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data and all applicable executive regulations and amendments thereto.
Any dispute arising out of or in connection with this Privacy Policy that cannot be resolved amicably shall be submitted to the exclusive jurisdiction of the competent courts of Ras Al Khaimah, United Arab Emirates, unless an alternative dispute resolution mechanism is mandated by applicable law. Notwithstanding the foregoing, nothing in this section shall limit your right to lodge a complaint with a competent data protection authority in your jurisdiction.