Privacy Policy
This Privacy Policy explains how SG TRADING L.L.C-FZ collects, uses, stores, shares and protects Personal Data when you use sgtrading.biz, submit an RFQ, contact us, communicate with us, or otherwise interact with our business.
1. Controller and scope
SG TRADING L.L.C-FZ ("SGTRADING", "we", "us" or "our") is a company registered in Dubai, United Arab Emirates under Trade Licence No. 2540641.01, with its registered office at Meydan Grandstand, 6th Floor, Meydan Road, Nad Al Sheba, Dubai, United Arab Emirates.
For Personal Data processed through this website and our related commercial communications, SGTRADING acts as the Controller where it determines the purposes and means of Processing. A supplier, logistics provider, technical partner or other third party may act as an independent Controller for Personal Data it receives and processes for its own purposes.
This Policy applies to visitors to sgtrading.biz, representatives of actual and prospective customers, suppliers and partners, persons submitting RFQs, and persons who communicate with us by website form, email, telephone, WhatsApp or other business channels.
2. Applicable data protection framework
We process Personal Data in accordance with applicable laws of the United Arab Emirates, including Federal Decree-Law No. 45 of 2021 Concerning the Protection of Personal Data ("UAE PDPL"), together with applicable regulations, decisions and binding requirements issued under it.
Under the UAE PDPL, Personal Data must be processed fairly, transparently and lawfully, for clear and specific purposes, in a manner that is adequate and limited to what is necessary, kept accurate where relevant, protected using appropriate technical and organisational measures, and retained only for as long as required for the relevant purpose or applicable legal obligations.
3. Personal Data we may collect
3.1 Identity and contact information
This may include your name, job title, company name, business email address, telephone number, WhatsApp number, country, city and other contact details that you provide to us.
3.2 RFQ, commercial and technical information
When you submit a request, we may process information about the requested gas or service, purity or grade, target quantity, packaging, delivery location, Incoterms, required timeline, documentation requirements, application, operating conditions, technical specifications and other information included in the RFQ.
3.3 Documents and communications
We may process files, specifications, certificates, drawings, photographs, correspondence and other documents that you choose to upload or send to us. We also process the content of business communications and records of our follow-up with you.
3.4 Technical and website information
When you access the website, our systems and service providers may process limited technical information such as IP address, browser type, device information, operating system, referring page, requested pages, timestamps, error logs, security events and session or attribution information generated by cookies or similar technologies.
3.5 Information from third parties or public sources
In a B2B context, we may receive business contact details and company-related information from your employer, colleagues, authorised representatives, suppliers, technical partners, public company records, professional directories or other lawful public sources.
3.6 Sensitive Personal Data
The website is not designed to collect health, biometric, genetic, religious, political or other Sensitive Personal Data. Please do not include Sensitive Personal Data in an RFQ or attachment unless it is genuinely necessary and you are authorised to provide it. We may remove or restrict access to unnecessary Sensitive Personal Data that is submitted to us.
4. Why we process Personal Data and the applicable basis
We process Personal Data only for specified business purposes. Depending on the circumstances, we rely on your consent or on a specific case in which the UAE PDPL permits Processing without consent.
| Purpose | Examples of data | Basis under the UAE PDPL |
|---|---|---|
| Responding to enquiries and RFQs | Contact details, product, packaging, destination, technical requirements | Consent where relied upon, and/or Processing necessary to take steps requested by you in connection with a potential contract |
| Negotiating, entering into and performing commercial arrangements | Commercial correspondence, specifications, delivery requirements, contract-related records | Processing necessary for the conclusion, amendment, performance or termination of a contract where the statutory conditions apply |
| Coordinating with relevant suppliers, packaging providers, logistics or technical partners | Information reasonably necessary to assess feasibility and respond to the request | Consent where required and/or a permitted contract-related basis under Article 4 |
| Maintaining business records and complying with applicable law | Correspondence, transactional records, company and contact information | Processing necessary to comply with obligations imposed by applicable UAE law |
| Protecting the website, systems, users and our legal rights | Security logs, IP address, device and access information, evidence relating to misuse | Applicable legal obligations and, where relevant, Processing necessary to establish, exercise or defend legal claims |
| Sending optional promotional or marketing communications | Name, business email, communication preferences | Consent where required. Marketing consent is separate from the processing necessary to handle an RFQ |
| Operating optional third-party website features | Technical identifiers and data transmitted to the relevant provider | Consent where required, or another basis specifically permitted by applicable UAE law |
4.1 If you do not provide requested information
You are not required to provide Personal Data merely to browse public pages. However, if information is necessary to assess an RFQ, respond to an enquiry, verify a request, comply with law, or take steps toward a commercial arrangement, we may be unable to proceed if that information is not provided.
4.2 Marketing
We do not treat submission of an RFQ as blanket consent to unrelated marketing. Where we send optional marketing communications on the basis of consent, you may withdraw that consent or opt out at any time using the instructions in the communication or by contacting us.
5. Who we may share Personal Data with
We do not sell Personal Data. We may disclose Personal Data only where reasonably necessary for the purposes described in this Policy, including to:
- relevant gas suppliers, packaging providers, regional distributors, engineering or technical partners where necessary to review or respond to your request
- hosting, email, website, IT, cybersecurity, file storage and other service providers acting for us
- logistics providers, inspection providers, laboratories, advisers or other parties involved in evaluating a proposed transaction where relevant
- professional advisers such as lawyers, auditors, accountants and insurers where necessary
- banks, payment service providers or financial institutions where a separate commercial transaction later requires them
- government authorities, regulators, courts, law enforcement agencies or other competent bodies where disclosure is required or permitted by law
- a prospective buyer, investor, successor or adviser in connection with a genuine corporate transaction, subject to appropriate confidentiality and legal safeguards
We seek to limit disclosures to information reasonably necessary for the relevant purpose. Where a third party processes Personal Data on our behalf, we use appropriate contractual and organisational controls as required by applicable law.
6. International transfers
SGTRADING handles cross-border B2B requests and may work with service providers, suppliers or technical partners located outside the United Arab Emirates. As a result, Personal Data may be transferred to or accessed from another country where this is necessary for the relevant purpose.
We carry out cross-border transfers only where permitted by the UAE PDPL. Depending on the destination and circumstances, this may include transfer to a jurisdiction providing an adequate level of protection, use of contractual safeguards that require the recipient to protect Personal Data in accordance with UAE requirements, a permitted contract-related transfer, explicit consent where applicable, or another lawful transfer mechanism available under Articles 22 and 23 of the UAE PDPL.
7. Retention and deletion
We retain Personal Data only for as long as reasonably necessary for the purpose for which it was collected and for any additional period required or permitted by applicable law.
Our retention decisions take into account the status and duration of an RFQ or commercial relationship, the nature and sensitivity of the data, legal, tax, accounting, compliance and record-keeping obligations, applicable limitation periods, the need to establish or defend legal claims, security requirements and any valid request by the Data Subject.
When Personal Data is no longer required, we take reasonable steps to delete, destroy or irreversibly anonymise it, unless continued retention is required or permitted by law.
8. Security and Personal Data breaches
We use reasonable and appropriate technical and organisational measures designed to protect Personal Data against unauthorised access, unlawful Processing, accidental loss, destruction, alteration or disclosure. Measures may include access controls, authentication, software updates, backups, security monitoring, restricted administrative access and contractual confidentiality obligations.
No website, email system or transmission method can be guaranteed to be completely secure. If a Personal Data breach occurs, we will assess it and take the notification and corrective steps required by applicable UAE law, including notification to the competent authority and affected Data Subjects where the legal threshold is met.
9. Your rights
Subject to the conditions, limitations and exceptions in the UAE PDPL, you may have the right to:
- obtain information about the Personal Data we process, the purposes of Processing, recipients, retention controls and cross-border safeguards
- receive certain Personal Data that you provided to us in a structured and machine-readable format and request transfer to another Controller where the statutory conditions and technical feasibility requirements are met
- request correction or completion of inaccurate or incomplete Personal Data
- request erasure of Personal Data in circumstances provided by law
- request restriction of Processing in circumstances provided by law
- object to or request the stopping of certain Processing, including direct marketing, where the statutory conditions apply
- request human review of a decision based solely on automated Processing where such a decision is subject to the relevant UAE PDPL provisions
- withdraw consent at any time where Processing is based on consent
- submit a complaint to the UAE Data Office or other competent authority where applicable
We may need to verify your identity before acting on a request. We may refuse or limit a request where permitted by law, including where it conflicts with legal proceedings, the rights and privacy of others, information-security requirements, mandatory retention duties, or another applicable statutory exception.
9.1 Automated decision-making
The website is not intended to make decisions that produce legal or similarly significant effects concerning you solely through automated Processing. Automated tools may be used for routine technical, security or administrative functions, but commercial RFQs are subject to human review.
10. Cookies, Google Maps and third-party services
The website may use cookies and similar technologies for website operation, security, session management and limited attribution functionality. Details are provided in our Cookies Policy.
Pages may also contain third-party services or links, including Google Maps and WhatsApp. Loading an embedded third-party service or following an external link may cause the third party to receive technical data such as your IP address, browser or device information and may cause that third party to use cookies or similar technologies under its own privacy terms. Third-party services are not controlled by SGTRADING.
11. Children
This website is intended for business and professional users and is not directed to children. We do not knowingly solicit Personal Data from children through the RFQ process. If you believe a child has provided Personal Data to us inappropriately, please contact us so that we can assess and take appropriate action.
12. Third-party websites
The website may link to websites operated by other organisations. We are not responsible for the privacy practices, content or security of third-party websites. You should review the privacy information provided by the relevant third party before submitting Personal Data to it.
13. Changes to this Privacy Policy
We may update this Policy to reflect changes in law, regulatory guidance, our website, technologies, suppliers, services or Processing practices. The latest version will be posted on this page and identified by the "Last updated" date. Where a change materially affects how we use Personal Data, we will take additional notice or consent steps where required by law.
14. Contact and complaints
To ask a privacy question, exercise a data protection right, withdraw consent where applicable, or raise a complaint, contact:
SG TRADING L.L.C-FZ
Meydan Grandstand, 6th Floor, Meydan Road, Nad Al Sheba,
Dubai, United Arab Emirates
Email: info@sgtrading.biz
Telephone: +971 50 260 2765
You may also have the right to raise a complaint with the UAE Data Office or another competent UAE authority in accordance with applicable law.