Legal
Privacy Policy
Effective date: 19 February 2024
Last updated:
Sinocar Automotive and Brokerage LLC-FZ
Sinocar Automotive and Brokerage LLC-FZ ("we", "us", "our") is committed to protecting the privacy of all individuals who interact with us — whether by email or in the course of commercial transactions. This Privacy Policy explains what personal data we collect, why we collect it, how we use and protect it, and what rights you have in relation to it. Please read this policy carefully before providing us with any personal information.
Section 1
Data Controller
The data controller responsible for your personal data is:
Data Controller
Sinocar Automotive and Brokerage LLC-FZ
Ras Al Khaimah, United Arab Emirates
Email:
info@sinocar.com
Section 2
What Personal Data We Collect
We collect only the personal data that is necessary for legitimate business purposes. The categories of data we may collect include:
| Category | Examples | How Collected |
| Identity data | Full name, company name, job title, passport / Emirates ID number (where legally required) | Directly from you via forms, email, or contracts |
| Contact data | Email address, phone number, postal address, WhatsApp number | Directly from you |
| Transaction data | Purchase orders, invoices, payment records, shipping documents | Generated during the course of business |
| Communication data | Email correspondence, inquiry content, negotiation records | From direct communications with us |
| Technical data | IP address, browser type, pages visited, visit duration | Automatically via cookies and server logs (see Cookies Policy) |
| KYC / compliance data | Trade licence copies, bank details, company registration documents | Directly from you for compliance purposes |
We do not collect special categories of sensitive personal data (such as health, biometric, or political data) and do not intentionally collect data from individuals under the age of 18.
Section 3
Legal Basis & Purposes of Processing
We process personal data only where we have a lawful basis to do so under applicable UAE data protection law (UAE Federal Decree-Law No. 45 of 2021 on Personal Data Protection). The purposes and corresponding legal bases are:
- Performance of a contract: Processing necessary to fulfil purchase orders, issue invoices, arrange delivery, and provide brokerage services.
- Legitimate interests: Responding to enquiries, maintaining business records, preventing fraud, protecting our legal rights, and improving our services.
- Legal obligation: Compliance with UAE commercial law, anti-money laundering (AML) regulations, and tax obligations.
- Consent: Where you have explicitly consented — for example, to receive marketing communications or newsletters. You may withdraw consent at any time.
Section 4
How We Use Your Data
- Processing and fulfilling orders for auto spare parts and components;
- Issuing quotations, invoices, and commercial documents;
- Communicating with you about your enquiries, orders, or complaints;
- Conducting Know Your Customer (KYC) and anti-money laundering checks as required by applicable law;
- Managing our supplier and client relationships;
- Sending transactional communications (order confirmations, dispatch notices);
- Sending marketing communications where consent has been given and not withdrawn;
- Analysing website usage to improve functionality and user experience;
- Complying with regulatory obligations and responding to lawful requests from authorities.
We will not use your personal data for automated decision-making or profiling that produces legal or similarly significant effects.
Section 5
Sharing of Personal Data
We do not sell, rent, or trade your personal data. We may share your data only with:
- Logistics & freight partners: To arrange shipment, customs clearance, and delivery of goods, who require your address and contact details;
- Banking & payment providers: For processing payments and complying with financial regulations;
- Legal & compliance advisors: Lawyers, auditors, and accountants acting under professional confidentiality obligations;
- Regulatory authorities: UAE regulatory authorities, financial intelligence units, or other authorities where required by law;
- IT service providers: Cloud storage, email, and website hosting providers operating under data processing agreements.
All third parties with whom we share data are contractually required to handle your data in accordance with applicable law and this policy.
Section 6
International Data Transfers
As an international trading company, we may transfer personal data to recipients located outside the UAE, including to counterparties, logistics providers, or IT systems in other countries. Where such transfers occur, we take reasonable steps to ensure adequate protections are in place, including contractual safeguards consistent with applicable UAE data protection law.
Section 7
Data Retention
We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, including to comply with legal, accounting, and reporting obligations. Our general retention periods are:
- Commercial transaction records (invoices, contracts, shipping documents): 7 years from the date of the transaction, as required under UAE commercial law;
- KYC and compliance records: 5 years from the end of the business relationship;
- Enquiry and communication records: 2 years from last contact, unless converted to a transaction;
- Website analytics data: 13 months from collection (anonymised thereafter);
- Marketing consent records: retained until consent is withdrawn, plus 1 year.
When data is no longer required, it is securely deleted or anonymised.
Section 8
Security
We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures include encrypted email communications, access controls, secure cloud storage with reputable providers, and staff confidentiality obligations.
However, no method of transmission over the internet or electronic storage is 100% secure. While we strive to protect your data, we cannot guarantee absolute security.
Section 9
Your Rights
Under UAE Federal Decree-Law No. 45 of 2021 on Personal Data Protection, you have the following rights in relation to your personal data:
- Right of access: To request a copy of the personal data we hold about you;
- Right to rectification: To request correction of inaccurate or incomplete data;
- Right to erasure: To request deletion of your data where it is no longer necessary for the purposes for which it was collected, subject to legal retention obligations;
- Right to restriction: To request that we limit the processing of your data in certain circumstances;
- Right to data portability: To receive your data in a structured, commonly used format;
- Right to object: To object to processing based on legitimate interests, including direct marketing;
- Right to withdraw consent: To withdraw consent at any time where processing is based on consent, without affecting the lawfulness of prior processing.
To exercise any of these rights, please contact us at info@sinocar.com. We will respond within 30 calendar days. We may need to verify your identity before processing your request.
Section 10
Links to Third-Party Websites
Our website may contain links to third-party websites, platforms, or services. This Privacy Policy applies only to our website and our data processing activities. We are not responsible for the privacy practices of third-party sites, and we encourage you to review their privacy policies independently.
Section 11
Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or business operations. The updated policy will be published on this page with a revised effective date. We encourage you to review this page periodically. Material changes will be communicated to existing clients by email where appropriate.
Contact
Privacy Enquiries
If you have any questions, concerns, or requests relating to this Privacy Policy or our data processing activities, please contact us:
Sinocar Automotive and Brokerage LLC-FZ
Ras Al Khaimah, United Arab Emirates
Email:
info@sinocar.com