1. INTRODUCTION

This Privacy Policy explains how Taraf, a company incorporated in the United Arab Emirates (“Taraf”, “we”, “us”, or “our”), collects, uses, stores, shares, and protects Personal Data when you access or use our website www.tarafholding.com (the “Website” or “Service”).

By accessing or using the Service, you acknowledge that your Personal Data will be processed in accordance with this Privacy Policy and Federal Decree-Law No. (45) of 2021 on the Protection of Personal Data (the “PDPL”). If you do not agree, you should refrain from using the Service.
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2. APPLICABLE LAW

This Privacy Policy is governed by and interpreted in accordance with:

• Federal Decree-Law No. (45) of 2021 on the Protection of Personal Data;
• its implementing regulations and decisions issued by the UAE Data Office; and
• other applicable UAE federal laws, including consumer protection and cybercrime legislation.

This Policy applies to all Personal Data processed by Taraf in its capacity as Data Controller on the UAE mainland.
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3. DEFINITIONS

For the purposes of this Privacy Policy:

• Personal Data: Any information relating to an identified or identifiable natural person, whether directly or indirectly.
• Sensitive Personal Data: Personal Data revealing health, biometric data, religious beliefs, criminal records, or other categories designated as sensitive under the PDPL.
• Processing: Any operation performed on Personal Data, including collection, recording, storage, use, disclosure, transfer, or deletion.
• Data Subject: The natural person to whom the Personal Data relates.
• Controller: Taraf, which determines the purposes and means of processing Personal Data.
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4. PERSONAL DATA WE COLLECT

We may collect the following categories of Personal Data:

4.1 Data You Provide Voluntarily

• Name, email address, phone number
• Company name and job title
• Enquiries, correspondence, and information submitted through forms or email
• Marketing preferences
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4.2 Data Collected Automatically

When you use the Website, we may automatically collect:

• IP address
• Browser type and version
• Operating system
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4.3 Third-Party Data

Where permitted by law, we may receive limited data from analytics or technical service providers supporting the operation and security of the Website.
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5. PURPOSES OF PROCESSING

We process Personal Data strictly for legitimate and lawful purposes, including:

• Website administration and operation
• Responding to enquiries and communications
• Customer service and relationship management
• Website security, fraud prevention, and system integrity
• Marketing and promotional communications (subject to consent)
• Compliance with legal and regulatory obligations
• Protection and exercise of legal rights

If we intend to process Personal Data for a new purpose, we will provide appropriate notice and obtain consent where required by law.
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6. LAWFUL BASIS FOR PROCESSING

Personal Data is processed only where permitted under the PDPL, including where:

• the Data Subject has provided valid consent;
• processing is necessary for the performance of a contract;
• processing is required to comply with a legal obligation;
• processing is necessary to protect public interest or legal rights; or
• another lawful ground applies under the PDPL.

Consent may be withdrawn at any time without affecting prior lawful processing.
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7. DATA SHARING AND DISCLOSURE

We may disclose Personal Data, strictly on a need-to-know basis, to:

• Affiliated companies of Taraf
• Service providers and processors (e.g., IT, hosting, cybersecurity, analytics), acting under contractual obligations
• Professional advisers (legal, audit, compliance)
• Government authorities or regulators where required by UAE law
• Successors or transferees in the event of a corporate transaction

We do not sell Personal Data.
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8. DATA RETENTION

Personal Data is retained only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by UAE law. Data may be retained for backup, audit, and business continuity purposes for a limited period thereafter.

Requests for deletion may be submitted as set out in Section 14.
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9. COOKIES

We use cookies and similar technologies to:

• enable core website functionality;
• enhance security;
• remember user preferences;
• analyze website performance and usage.

Cookies are small text files stored on your device. You may control cookie settings through your browser. Disabling cookies may affect website functionality.
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10. GOOGLE ANALYTICS

We use Google Analytics, a web analytics service provided by Google, to monitor and analyze website usage. Google may process usage data in accordance with its own privacy policies. You may opt out of Google Analytics tracking using available tools provided by Google.
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11. MARKETING COMMUNICATIONS

Where permitted by law, we may send marketing communications. You may opt out at any time by:

• clicking the unsubscribe link in our emails; or
• contacting us at info@tarafholding.com.

Withdrawal of marketing consent will not affect non-marketing communications.
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12. SECURITY MEASURES

We implement appropriate technical and organizational security measures in accordance with our internal Information Security Policy to protect Personal Data against loss, misuse, unauthorized access, disclosure, or alteration. While we take reasonable steps to safeguard data, no system can be guaranteed to be completely secure.
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13. YOUR RIGHTS

Subject to UAE law, you may have the right to:

• request correction or erasure;
• restrict or object to processing;
• withdraw consent;
• request transfer of data where applicable;
• lodge a complaint with the competent UAE authority.

To exercise your rights, please contact info@tarafholding.com. Identity verification may be required.

Please note that withdrawal of consent or refusal to provide required data may limit your ability to access certain services.
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14. THIRD-PARTY WEBSITES

The Website may contain links to third-party websites not operated by Taraf. We are not responsible for the privacy practices or content of such third-party sites. You should review their privacy policies separately.
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15. CHANGES TO THIS PRIVACY POLICY

We may amend this Privacy Policy at any time. The updated version will be posted on the Website and will take effect upon publication. Continued use of the Service constitutes acceptance of the revised Policy.
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16. CONTACT DETAILS

For any questions, requests, or complaints relating to this Privacy Policy or our data processing practices, please contact:

Taraf
Email: info@tarafholding.com
Attention: Taraf IT & InfoSec Team

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