1. Introduction

This Privacy Policy explains how Group Vintage and its affiliated entities (collectively, the “Company”, “we”, “our”, or “us”) collect, use, disclose, and protect personal data when you visit or interact with our websites (the “Website”).

We are committed to protecting your privacy and processing personal data in accordance with applicable data protection laws of the United Arab Emirates, including Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (“PDPL”).

2. Scope

This Privacy Policy applies to:

• Visitors to our Website
• Individuals who contact us via forms, email, or other digital communication
• Business contacts and representatives interacting with us through the Website

It does not apply to third-party websites linked from our Website.

3. Personal Data We Collect

a) Information You Provide Voluntarily

• Name
• Company name
• Job title
• Email address
• Telephone number
• Any information submitted via contact forms or email correspondence

b) Automatically Collected Information

• IP address
• Browser type and device information
• Website usage data (pages visited, time spent, referring URLs)

This data is collected through cookies and similar technologies.

4. Purpose of Processing

• Responding to enquiries or requests
• Business communication and relationship management
• Improving Website functionality and user experience
• Compliance with legal and regulatory obligations
• Protecting the security and integrity of our Website

We do not use personal data for automated decision-making or profiling.

5. Legal Basis for Processing

Personal data is processed based on one or more of the following legal grounds:

• Your consent (where applicable)
• Performance of a contract or pre-contractual steps
• Compliance with legal or regulatory obligations
• Legitimate business interests, provided such interests do not override your rights

6. Cookies & Tracking Technologies

Our Website may use cookies and similar technologies to:

• Enable basic Website functionality
• Analyse Website traffic and performance

You may control or disable cookies through your browser settings. Disabling cookies may affect Website functionality.

7. Data Sharing & Disclosure

We do not sell or rent personal data.

We may share personal data with:

• Group companies and affiliates
• Service providers assisting with Website hosting, IT, or analytics
• Legal, regulatory, or governmental authorities where required by law

All third parties are required to process data securely and in accordance with applicable laws.

8. International Data Transfers

Personal data may be transferred to and processed outside the UAE where necessary. In such cases, appropriate safeguards are implemented in accordance with UAE data protection laws.

9. Data Retention

Personal data is retained only for as long as necessary to fulfil the purposes outlined in this Privacy Policy, or as required by applicable laws and regulations.

10. Data Security

We implement appropriate technical and organisational measures to protect personal data against:

• Unauthorised access
• Loss, misuse, or alteration

However, no method of transmission over the internet is completely secure.

11. Your Rights

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

• Access your personal data
• Request correction of inaccurate data
• Request deletion of personal data
• Withdraw consent where processing is based on consent
• Object to certain processing activities

Requests may be submitted using the contact details below.

12. Third-Party Websites

Our Website may contain links to third-party websites. We are not responsible for the privacy practices or content of such websites.

13. Updates to This Policy

We may update this Privacy Policy from time to time. Any changes will be posted on this page with an updated effective date. Continued use of the Website constitutes acceptance of the updated Privacy Policy.

14. Contact Information

For questions or requests regarding this Privacy Policy or your personal data, please contact us.