1. Introduction

This Privacy Notice (“Notice”) outlines how Galadari Automobiles Co. Ltd. (L.L.C.), a subsidiary of Galadari Brothers Co. LLC, collects, uses, and protects your Personal Data whenever you interact with any brand, product, service, showroom, or website, whether online or offline, operated by Galadari Automobiles Co. Ltd. (L.L.C.).

Galadari Automobiles Co. Ltd. (L.L.C.) is the Data Controller for the purposes of applicable data protection laws and is committed to protecting and respecting your privacy rights. We may use your Personal Data for the purposes described in this Notice or for any additional purposes that we shall inform you at the time of collecting your data.

This Notice is governed by and interpreted in accordance with applicable data protection and privacy laws, together with any implementing regulations, as well as other applicable laws.

In this Privacy Notice, references to:

• “We,” “us,” or “our” refer to Galadari Automobiles Co. Ltd. (L.L.C.) as the legal entity responsible for processing your Personal Data. References to “you” or “your “refer to the individuals whose Personal Data is being processed.
• “Personal Data” means any information that identifies you or can be used to identify you, directly or indirectly for example: your name, date of birth, age, gender, nationality, passport or identification details, marital status, signature, and country of residence.
• “Processing” refers to any activity performed on your Personal Data, including collecting, recording, storing, using, sharing, or deleting it.

2. Scope of This Notice

This Notice applies whenever you interact with any brand, product, service, showroom, or website operated by Galadari Automobiles Co. Ltd. (L.L.C.), including, but not limited to:

• Our websites, online platforms and mobile applications.
• Our showrooms and service centres
• Customer service and support channels, including call centres
• Marketing activities

3. Personal Data We Collect

We may collect certain types of Personal Information about you in a variety of ways, depending on your interactions with us online and offline, as described further below.

• 1. Contact Details Information that enables us to communicate with you, including your physical address, email address, and telephone number.
• 2. Identification Data Information that verifies your identity, such as your full name, title, copies of identification documents (e.g., passport, Emirates ID, driver’s license), and utility bill proofs.
• 3. Sensitive Data Personal Data including family details, ethnic origin, political or philosophical opinions, religious beliefs, criminal records, biometric data, and information relating to an individual’s physical, psychological, mental, genetic, or sexual health. This also includes any data associated with the provision of healthcare services that reveals an individual’s health status.
• 4. Account Data Security-related information (e.g., usernames, passwords, authentication methods, roles), service-related details (e.g., purchase history, account profiles), and billing information (e.g., payment details, shipping addresses).
• 5. User-generated Content Information you provide when engaging in community forums or posting content accessible to others, including comments, usernames, and profile pictures.
• 6. Geolocation Data Geolocation data is Personal Data such as the location of your device.
• 7. Web Data Web data is Personal Data collected via our websites such as cookies, user activity records, IP addresses, social media profiles, device identifiers, and information about your interactions on our websites.
• 8. Financial Data Financial data is Personal Data related to your finances such as your bank and card information.

3.1 Why and How We Use Your Personal Data

Description of Processing	Category of Personal Data	Legal Basis
We process your Personal Data when we offer our products and services, such as sale of new and used cars, sale of motorcycles and powersports (including accessories and apparel), car rentals, car maintenance, body repair solutions and car detailing services, test drives, etc.	Contact Details, Identification Data, Account data, User-generated content, Geolocation Data, Web Data, and Financial Data	Consent, Performance of Contract
We process your Personal Data to complete and manage your vehicle purchase or related service agreement. This includes securely handling your payment details together with our authorised payment processors to facilitate transactions, prevent fraud, and update your payment information if a transaction fails.	Contact Details, Identification Data and Financial Data	Consent, Performance of Contract
We process your Personal Data so we can monitor the quality of our services to you, to conduct surveys, obtain feedback, manage and progress complaints as necessary and market to you.	Contact Details, Identification Data, Account data, User-generated content, Geolocation Data, Web Data	Consent
Managing our loyalty programs and customizing offers for you.	Contact Details, Identification Data, Web Data	Consent
We process your Personal Data to fulfil our legal obligations and to investigate or defend legal claims.	Contact Details, Identification Data, Web Data, and Financial Data	Legal obligation
We process your Personal Data for accounting, administration, and auditing purposes related to our business operations.	Contact Details, Identification Data, and Financial Data	Performance of Contract
We process your Personal Data to protect and secure our IT systems or for backup and archiving purposes or to prevent a potential data breach.	Web Data	Legitimate Interest
We use your Personal Data, including geolocation data when provided, to ensure the accurate delivery of your orders through our application or website.	Contact details, Identification data, Geolocation Data, Financial Data	Performance of Contract
We process your Personal Data (including CCTV footage) to safeguard the safety and security of all customers and employees in our buildings or properties either owned or rented.	Identification Data	Protection of the interest of the data subject

 

4. Legal Basis for Processing

We will only process your Personal Data when there is a clear and legitimate purpose, using one of the following legal bases:

• Consent
• Performance of a contract
• Compliance with legal obligations
• Protection of vital interests
• Legitimate interests, unless this is overridden by your rights

5. Sharing Your Personal Data

We may share your Personal Data internally and externally with third parties under the following circumstances:

a) Internally: Within Galadari Automobiles Co. Ltd (L.L.C.)

Any Personal Data collected may also be shared with and retained by Galadari Automobiles Co. Ltd (L.L.C.), Galadari Brothers Co. Ltd (L.L.C) and its affiliated entities.

b) Externally:

• 1. Our Affiliates/Partners/Vendors We may share Personal Data collected by our affiliates, vendors, or registered partners with other affiliates to fulfil the purposes outlined in this policy.
• 2. Service Providers We work with carefully selected service providers who perform certain functions on our behalf. These include companies that assist with technology services, data storage and integration. We only share the Personal Data necessary for our service providers to perform their duties.Some service providers manage online media channels, where they place ads for our products and services, as well as those of our suppliers and Retail Partners. For example, you might see an ad for our products and services on a social media site.
• 3. Advertisers We, along with our advertising partners, use cookies to collect personal information to deliver advertisements tailored to your interests. For more details on our advertising partners and how we share data, please refer to our Cookie Policy.
• 4. Marketing, Security & Analytics Partners We may share your Personal Data with third-party marketing, security, and analytics service providers to help us market, secure, and understand the use of our services and platforms.

 

5.1 Sharing Your Personal Data Under Special Circumstances

We may share your Personal Data with third parties, including regulatory or supervisory authorities, and government agencies, where necessary and lawful to do so, in the following situations:

• When required by law or a public authority, including to comply with legal obligations or respond to lawful requests from government or regulatory bodies.
• To establish, exercise, or defend our legal rights, including preventing fraud, reducing credit risk, or managing legal claims.
• If we sell, transfer, or are in negotiations to sell or transfer any part of our business, or our rights and obligations under an agreement with you. In such cases, the receiving organization may continue to use your Personal Data in accordance with this Privacy Notice, unless and until you are notified of updated terms.
• With any successors in title to our business.
• With any party to whom we transfer or may transfer our rights and responsibilities under our agreement with you.

5.2 Cross-Border Data Transfers

When processing your Personal Data, we may share it with third parties, including those located outside the United Arab Emirates (UAE), where such sharing is necessary to fulfil the purposes described in this Notice.

Your Personal Data may also be shared within Galadari Automobiles Co. Ltd. (L.L.C.), and with its group company Galadari Brothers Co. LLC, including its subsidiaries and affiliates, for purposes including but not limited to operational, administrative, governance, or support purposes.

Depending on the nature of the services being provided, transfers may occur to countries outside UAE.

Any international transfers of Personal Data are carried out in accordance with applicable data protection, and subject to appropriate safeguards to ensure an adequate level of protection.

For more information regarding cross-border data transfers, please contact us at dpo@galadaribrothers.com.

6. How We Secure Your Personal Data

We are committed to protecting the information you provide us. We have adopted appropriate technological and operational security measures to protect your Personal Data against accidental loss, misuse, alteration, or destruction (including data encryption and pseudonymization). Only authorized individuals have access to Personal Data (access control), and these individuals are contractually bound to maintain its confidentiality.

We also conduct thorough background checks and vetting processes on our suppliers and vendors to ensure they meet our security and privacy standards. Additionally, we require them to implement appropriate safeguards when accessing or using Personal Data that we share with them.

While we strive to ensure the security and protection of your Personal Data, its security also depends on the safety of the computer or mobile device you use to communicate with us, as well as the security measures you take to protect your user ID and passwords. To keep your Personal Data safe, please take appropriate steps to safeguard your user ID, passwords, and any other information needed to access our platforms.

 

7. Retention of Personal Data

We only retain your Personal Data for as long as necessary to carry out the purposes indicated in this Notice. After this period, we will securely delete your Personal Data, unless we are obligated to retain your Personal Data to comply with a legal or regulatory requirement or to deal with any potential disputes.

If we no longer need to keep your Personal Data, we will delete it from our systems and records and/or take steps to properly anonymize it so that you cannot be identified from it.

 

8. Your Privacy Rights

You have certain rights that you can exercise. If you would like to exercise your rights, please send an email to dpo@galadaribrothers.com .

The following rights may be applicable to you, depending on the jurisdiction where your Personal Data is processed:

Data Privacy Right	What Does It Mean?
Right to access your data	You may request a copy of the Personal Data we hold about you.
Right to have your data updated or deleted	You have the right to request the correction of inaccurate or incomplete Personal Data and to request the deletion of your Personal Data.
Right to limit or stop data processing	You can request that we limit or stop the processing of your Personal Data in specific situations.
Right to request transfer of Personal Data Personal Data or data portability	You may request to receive your Personal Data in a structured, commonly used, and machine-readable format.
Right to raise objections to data processing	You have the right to object to the processing of your Personal Data in certain circumstances.
Right to revoke consent	You have the right to withdraw your consent to the processing of your Personal Data.

It is important to note that the rights stated above are not absolute and that not every request can be fulfilled. In certain cases, for instance where we are required to retain your Personal Data by contracts or the law, we might not be able to delete it or limit its processing.

8.1 Marketing Communications

All marketing communications we direct at you we will provide you with a way to withdraw your consent to future marketing. If you no longer wish to receive promotional materials you may opt-out from receiving these communications or change your account settings, this will remove you from marketing lists.

Please note that if you unsubscribe from marketing communications you will still receive operational and service messages from us regarding the services or products you bought from us and responses to enquiries made to us.

8.2 Cookies and Similar Technologies

We use cookies and similar technologies to improve website functionality, enhance your browsing experience, and deliver advertising that is relevant to you. Cookies help us remember your preferences, understand how our websites are used, and measure the effectiveness of our marketing, including limiting how often you see an ad and tracking whether you have opened a marketing email.

For full details on the cookies, we use and how you can manage your preferences, please refer to our Cookie Policy.

 

9. Special Categories

9.1 Processing Sensitive Personal Data

Where Sensitive Personal Data is required, it is processed strictly for a legitimate purpose and subject to enhanced safeguards, confidentiality measures, and access controls.

Sensitive Personal Data may be processed only with the explicit consent of the data subject or where otherwise permitted or required by law or in the course of lawful news gathering and publishing activities.

In all cases, such data is handled in accordance with applicable laws and regulatory requirements.

9.2 Processing Personal Data from Minors

Our platforms are not directed towards children. We do not knowingly collect personal information from a child under the age of 18, such as name, email, telephone number, or any other information, without the consent of a parent or guardian. If parent or guardian consent is required, we will collect the email address of the parent or guardian so we can provide notice of our information and/or seek the parent’s or guardian’s consent.

10. Automated Decision Making/Profiling

Our artificial intelligence technologies may enable automated data processing in several fields. This is called “profiling”. If we make use of profiling, we will always obtain your explicit consent. We will also conduct privacy impact assessments to implement appropriate measures to protect your rights.

 

When we make use of profiling, you have the right to object against it. This right can be invoked by using the contact details provided in the “Contact Us” section below.

11. Contact Us

If you have any questions or concerns about this Notice, please contact us at dpo@galadaribrothers.com

 

12. Updates to The Notice

This Notice may be updated on a regular basis to reflect new developments. We reserve the right to update, add, or remove portions of this Notice at any time. You are also advised to revisit this Notice periodically for updates.