Privacy Policy

1. Who we are

This website, awatera-services.ae, is operated by Awatera Businessmen Services LLC, a company registered in Dubai, United Arab Emirates.

In this Privacy Policy, “AWATERA”, “we”, “us” and “our” refer to Awatera Businessmen Services LLC.

For the personal data described in this Privacy Policy, AWATERA generally acts as the controller — meaning that we determine why and how that personal data is processed.

• Office UAE, Dubai, Al Mankhool, 4C Street, Alfa Hub Building, 5th floor, office 5E4
• E-mail [email protected]
• Phone +971 55 371 3659
• Privacy requests Please write to [email protected] with “Personal data” in the subject line.

We process personal data in accordance with Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (UAE PDPL) and other applicable UAE laws, regulations and decisions relating to personal data protection.

2. What this Policy covers — and what it does not

This Privacy Policy covers personal data that we receive when you:

• visit this website;
• submit an enquiry or request a quote;
• contact us by e-mail;
• call us;
• contact us through WhatsApp or Telegram using the details published by AWATERA; or
• otherwise communicate with us in relation to a prospective or existing business relationship.

It also covers technical information generated when your device communicates with this website.

Client and translation files

Documents provided to AWATERA for translation, certification, localisation, interpreting, legal translation or another professional service may contain personal data belonging to the client, its employees, customers, counterparties or other individuals.

The way AWATERA processes that data depends on the circumstances.

Where we process personal data solely on a client’s documented instructions for the purpose of delivering a service, AWATERA may act as a processor on behalf of that client.

For certain purposes — such as client administration, contracting, billing, regulatory compliance, information security, fraud prevention and the establishment or defence of legal claims — AWATERA may act as a controller.

The handling of client files may therefore also be governed by the applicable service agreement, confidentiality terms, data processing terms or other agreement entered into with the client.

Please contact us if you need more detailed information about how data contained in client files is processed.

3. What personal data we collect

Information you give us

When you submit an enquiry or contact us, we may receive:

• your name;
• e-mail address;
• telephone number;
• company name;
• job title or business role;
• the service you are interested in;
• the content of your enquiry or message; and
• any other information you choose to provide.

Please do not send passports, Emirates IDs, identity numbers, sensitive personal information or documents containing third-party personal data through a general website enquiry form unless we specifically ask you to do so.

Where such information is necessary to provide a service, we may arrange an appropriate channel for receiving it.

Information collected automatically

Our website, hosting provider and security provider may automatically process technical information including:

• IP address;
• browser type;
• device and user-agent information;
• pages and resources requested;
• date and time of requests;
• security events; and
• information needed to detect automated traffic, attacks, fraud or abuse.

This information is primarily used to operate and secure the website.

Website analytics

The website uses analytics services that collect technical and behavioural information about your visit: the pages you view, how you arrived at the site, the characteristics of your device and browser, and interactions with the page such as clicks and scrolling. One of the services also records the session so that we can see how pages are actually used.

The services, the cookies they set and how to refuse them are described in section 5.

What this website does not currently do

As of the effective date of this Privacy Policy, the public website:

• does not display advertising;
• does not use advertising pixels or third-party advertising trackers;
• does not make decisions about visitors using solely automated decision-making;
• does not require visitors to create an account; and
• does not process payments directly through the website.

If this changes, we will update this Privacy Policy where required.

4. Why we use personal data

We process personal data only where there is a lawful basis for doing so under applicable UAE law.

Depending on the circumstances, this may include:

• your consent, where consent is required;
• taking steps at your request before entering into a contract;
• performing a contract with you or your organisation;
• complying with obligations imposed by applicable law;
• establishing, exercising or defending legal claims; or
• another circumstance in which processing without consent is expressly permitted by applicable UAE law.

We may use personal data for the following purposes.

Answering enquiries

We use the information you provide to:

• understand what service you need;
• prepare a quotation;
• prepare a proposal;
• estimate timing or scope;
• answer your questions; and
• contact you about the enquiry.

Where applicable, this processing is carried out because you asked us to take steps in connection with a possible engagement and, where required, on the basis of your consent.

Providing services and managing client relationships

Where an engagement begins, we may process personal data to:

• provide the agreed services;
• communicate about the work;
• administer the client relationship;
• issue invoices and maintain accounting records;
• manage suppliers or specialists involved in the engagement; and
• maintain an appropriate record of instructions and work performed.

Security and prevention of misuse

We process technical and security information where necessary to operate the website, protect our systems, investigate misuse and respond to security incidents, to the extent permitted by applicable law.

Legal and regulatory requirements

We may retain or use information where necessary to:

• comply with applicable legal or regulatory obligations;
• respond to lawful requests from competent authorities; or
• establish, exercise or defend AWATERA’s legal rights.

Marketing

We do not sell personal data to advertisers.

We do not use an enquiry as permission to send unrelated marketing communications.

Where consent is required for marketing communications, we will obtain that consent separately. You may withdraw such consent at any time.

5. Cookies and similar technologies

A cookie is a small file that a website may store in your browser.

As of the effective date of this Privacy Policy, the public AWATERA website uses cookies and similar technologies for three purposes: website operation, security and network protection, and website analytics.

Cookies required for website operation and security are used without consent because the website cannot be provided safely without them. Analytics cookies are used only if you agree to them.

Website operation

A small number of cookies are set by the website itself so that it works as expected:

• color_theme — remembers the display theme shown to you;
• wp-wpml_current_language — remembers the language version of the website.

Cloudflare

Cloudflare provides network security and delivery services for the website and may place security cookies where necessary to distinguish legitimate visitors from automated or malicious traffic.

The duration of such cookies depends on the security function being performed and may range from a browser session to a limited security period.

Website analytics

We use two analytics services to understand how the website is used — which pages are visited, how visitors arrive and where they stop reading — so that we can improve it.

Yandex Metrica (counter 113052425), provided by Yandex. The counter is configured with click maps and session recording, which capture interactions with the page such as clicks, scrolling and mouse movement. It sets cookies including _ym_uid and _ym_d (visitor identification, up to one year), _ym_isad (detection of ad-blocking software, up to two days) and _ym_visorc (session recording, for the duration of the visit).

Google Analytics 4 (property G-SYEWG32DFQ), provided by Google. It sets cookies including _ga and _ga_SYEWG32DFQ (visitor and session identification, up to two years).

These services process technical and behavioural information such as IP address, device and browser characteristics, pages viewed and interactions with the page. Each provider processes that information under its own terms, and the information may be processed outside the UAE — see section 7.

We do not display advertising on this website, and analytics information is never combined with the content of documents sent to us for translation.

Your choice about analytics

When you first open the website, we ask whether you accept analytics cookies. Until you accept them, the analytics services described above are not loaded and set no cookies. If you decline, they are not loaded at all, and any analytics cookies previously stored in your browser by this website are deleted.

You can change your choice at any time through the Cookie settings link in the website footer.

Independently of that choice, you can delete or block cookies using your browser settings, and you can opt out of these services directly: Yandex provides an opt-out page for Yandex Metrica, and Google provides a browser add-on that disables Google Analytics. Blocking cookies or technologies required for security or website operation may cause parts of the website to stop working correctly.

6. Who may receive your personal data

We limit access to personal data to people and organisations that reasonably need it for the purposes described in this Policy.

AWATERA team

Enquiries are normally handled by members of our team in the UAE.

Where your enquiry requires expertise from another AWATERA group company or specialist, relevant information may be shared with that person or company where appropriate.

Access is limited to what is reasonably necessary for the relevant purpose.

Service providers

We use third-party service providers to operate our website and communications systems.

As of the effective date, these include:

• Hostinger Provides website hosting and infrastructure. The website and mail-relay infrastructure used for website submissions are hosted in a data centre in Mumbai, India.
• Cloudflare Provides network delivery, traffic routing, security and protection against attacks and automated abuse.
• Yandex Provides corporate e-mail infrastructure. Enquiries delivered by e-mail may be stored on Yandex mail infrastructure located in Russia.
• Yandex Metrica Provides website analytics, including click maps and session recording. Information collected by the counter may be processed on infrastructure located in Russia.
• Google Provides website analytics (Google Analytics 4). Information collected may be processed on Google infrastructure outside the UAE, including in the United States.

Where a provider processes personal data on our behalf, we require it to process the data for the relevant services and subject to applicable contractual and legal protections.

WhatsApp and Telegram

If you choose to contact us through WhatsApp or Telegram, information transmitted through those services will also be processed by the operator of the relevant platform in accordance with its own terms and privacy practices.

You should avoid using consumer messaging services to send sensitive documents unless AWATERA has confirmed that the channel is appropriate for the information concerned.

Professional specialists and contractors

Once a client engagement begins, information may also need to be provided to translators, interpreters, certified specialists, professional advisers, technology providers or other contractors involved in delivering the service.

The applicable service agreement, confidentiality obligations and data processing arrangements may provide additional rules governing such access.

Authorities and legal proceedings

We may disclose personal data where required by applicable law, a competent court or a UAE authority acting within its lawful powers.

We may also disclose information where reasonably necessary to establish, exercise or defend legal claims.

We do not disclose personal data in response to informal requests where there is no proper legal basis for doing so.

7. Transfers outside the UAE

Some of the systems used by AWATERA involve processing outside the United Arab Emirates.

At the effective date of this Policy, this includes:

• website and related hosting infrastructure in India;
• corporate e-mail infrastructure in Russia;
• website analytics infrastructure in Russia (Yandex Metrica) and outside the UAE, including the United States (Google Analytics); and
• potential access by AWATERA group personnel or service providers located outside the UAE where their involvement is necessary.

Network and security providers may also process technical information through infrastructure located in more than one jurisdiction.

Cross-border transfers of personal data are handled in accordance with the requirements of the UAE PDPL.

Where personal data is transferred to a country or recipient that does not benefit from an applicable recognised level of protection, AWATERA uses a transfer mechanism permitted by applicable UAE law. Depending on the circumstances, this may include appropriate contractual safeguards or another exception or mechanism expressly permitted by law.

Where consent is relied upon for an international transfer, we will obtain the form of consent required by applicable law.

If your organisation has contractual, regulatory or internal requirements restricting the countries in which its information may be processed, please tell us before sending the information, so that we can determine whether an appropriate alternative arrangement is available.

8. How long we keep personal data

The applicable retention period depends on why the data was collected.

Enquiries and prospective clients

Enquiries and related correspondence are retained while we are dealing with the request and afterwards, for as long as maintaining the correspondence remains relevant to the business relationship, to follow-up enquiries or to the protection of the parties’ legal rights. A returning client is often the same client, and the record of what was previously discussed is what keeps our terminology and our commitments consistent.

We will be straightforward about the consequence: enquiry correspondence is not deleted automatically after a fixed period. We do not operate a retention timer for it, and older records therefore remain available to us.

What this means for you is set out under Deletion requests below and in section 10: you can ask us to delete your personal data, and we will do so unless we are permitted or required by law to retain it.

Client and commercial records

Where an enquiry results in an engagement, relevant client, contractual, financial and commercial records may be retained for the duration of the relationship and afterwards for the period required by applicable UAE laws or reasonably necessary for accounting, regulatory, audit or legal-claims purposes.

Client files

Retention of translation files and other material received or created as part of a client engagement may be governed by the applicable service agreement, client instructions, data processing terms or legal retention requirements.

Website and security logs

Technical and security logs are generally kept for a short operational period, normally measured in weeks, unless a particular record needs to be retained for longer because of a security incident, investigation, legal requirement or dispute.

Deletion requests

You may request deletion where the UAE PDPL gives you that right.

We will delete the relevant personal data unless we are permitted or required to retain it, for example because it is needed to comply with another legal obligation or to establish, exercise or defend legal claims.

9. How we protect personal data

AWATERA uses technical and organisational measures intended to protect personal data against unauthorised access, loss, alteration, disclosure or misuse.

These measures include, where appropriate:

• encrypted website connections using HTTPS/TLS;
• access controls for website administration and corporate systems;
• authenticated corporate accounts;
• restriction of access according to business need;
• confidentiality obligations for personnel and contractors;
• security and network protection services; and
• procedures for responding to security incidents.

No internet-connected system can be guaranteed to be completely secure.

If a personal data breach occurs, we will investigate it and notify the competent authority and affected individuals where notification is required by applicable law.

10. Your rights

Subject to the conditions and exceptions in applicable UAE law, you may have the right to ask AWATERA to:

• tell you what categories of personal data we process about you and why;
• tell you who your personal data has been shared with, including relevant recipients outside the UAE;
• explain applicable retention and cross-border transfer safeguards;
• provide personal data you supplied to us in a structured and machine-readable format where the legal conditions for data portability are met;
• transfer eligible personal data to another controller where technically feasible;
• correct or complete inaccurate personal data;
• erase personal data where the legal conditions for erasure are met;
• restrict processing in the circumstances provided by law;
• stop processing in circumstances where the UAE PDPL gives you that right;
• withdraw consent where processing is based on consent; and
• object to qualifying solely automated decisions that have legal or similarly significant effects on you.

The public AWATERA website does not currently make such automated decisions about visitors.

Withdrawing consent does not affect processing that lawfully took place before consent was withdrawn.

How to exercise your rights

Write to [email protected]. Please put “Personal data” in the subject line and explain what you would like us to do.

We may ask for information reasonably necessary to confirm your identity before disclosing, changing or deleting personal data. This is to prevent information being released to the wrong person.

We will deal with your request without undue delay and within any period required by applicable law.

Where applicable law allows us to refuse or limit a request, we will explain the reason unless doing so would itself be prohibited by law.

Exercising rights under the UAE PDPL is not subject to a fee except where a charge is expressly permitted by applicable law.

If you believe your personal data has been processed in violation of applicable UAE data protection law, you may also lodge a complaint with the competent UAE data protection authority.

11. Children

AWATERA’s services are primarily intended for businesses and adults acting on their own behalf or on behalf of an organisation.

We do not knowingly use this website to collect personal data directly from children.

If you believe that a child has provided personal data to us through this website without appropriate authority, please contact us so that we can review the situation and take any action required by law.

12. Changes to this Privacy Policy

We may update this Privacy Policy where our services, systems, providers or legal obligations change.

For example, we may update it if we:

• introduce analytics or new website technologies;
• change hosting or communications providers;
• begin processing additional categories of information; or
• are affected by changes in applicable law.

The effective date at the top of this page identifies the version currently in force.

Where a change materially affects how personal data is processed, we will provide appropriate notice where required by applicable law.

13. How to contact us

For questions about this Privacy Policy or the personal data AWATERA holds about you, contact:

• Company Awatera Businessmen Services LLC
• Address UAE, Dubai, Al Mankhool, 4C Street, Alfa Hub Building, 5th floor, office 5E4
• E-mail [email protected]
• Phone +971 55 371 3659

For privacy requests, please use “Personal data” in the e-mail subject line.