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ZOLARE HOLDINGS

PRIVACY POLICY

Effective Date: 06th May 2026

Document Version: 1.0

Jurisdiction: Abu Dhabi, United Arab Emirates

 

Zolare Holdings LLC ("Zolare," "we," "us," or "our"), a company registered and operating in Abu Dhabi, United Arab Emirates, is committed to protecting the privacy and personal data of all individuals who interact with our website at www.zolareholdings.com (the "Site").

 

This Privacy Policy is issued in compliance with UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data ("UAE PDPL") and describes how we collect, use, store, disclose, and protect your personal information. It also sets out your rights as a data subject.

 

By accessing or using our Site, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with its terms, please discontinue use of the Site.

1. Identity and Contact Details of the Data Controller

The Data Controller responsible for your personal information is:

Legal Entity Name: Zolare Holdings LLC
Registered Address: Level 15, Al Khatem Tower, Al Maryah Island, Abu Dhabi, United Arab Emirates

Primary Contact Email: hq@zolareholdings.com

Phone: +971 50 327 4989

Website: www.zolareholdings.com

 

For all privacy-related enquiries, data subject requests, or complaints, please contact us at hq@zolareholdings.com with the subject line "Privacy Request."

2. Information We Collect

2.1 Personal Information You Provide

When you contact us, submit an enquiry, or register interest through our Site, we may collect:

 

  • Full name

  • Email address

  • Phone number

  • Company name and job title

  • Any other information you voluntarily provide through contact forms or direct correspondence

2.2 Automatically Collected Technical Data

When you visit our Site, we automatically collect non-personal technical information including:

 

  • IP address and approximate geolocation (country/city level)

  • Browser type, version, and language settings

  • Operating system and device type

  • Pages visited, time on page, and navigation paths

  • Referral source (how you arrived at our Site)

  • Date and time of access

This data is collected via cookies, web server logs, and third-party analytics tools (see Section 4).

3. Legal Basis for Processing

Under the UAE PDPL, we process your personal data on the following legal grounds:

Consent (Article 4, UAE PDPL):

Where you have provided explicit consent - for example, by opting into marketing communications or agreeing to cookies - we process your data on that basis. You may withdraw consent at any time.

Legitimate Interests:

We may process your personal data where it is necessary for our legitimate business interests, such as improving our website, responding to unsolicited enquiries, and maintaining the security of our systems, provided those interests are not overridden by your rights and freedoms.

Contractual Necessity:

Where you engage with us as a prospective or current investor or business partner, we may process your personal data to the extent necessary to fulfil pre-contractual or contractual obligations.

Legal Obligation:

We may process personal data to comply with applicable UAE laws, regulations, or lawful orders from competent authorities.

4. How We Use Your Information

We use the personal data we collect for the following purposes:

  • To respond to your enquiries and provide information about our services

  • To schedule and manage investor consultations or business meetings

  • To improve the functionality, performance, and content of our Site

  • To send periodic updates or marketing communications (only if you have opted in)

  • To comply with our legal and regulatory obligations under UAE law

  • To detect, prevent, and address technical issues or fraudulent activity


We do not sell, rent, or trade your personal information to any third party for their own commercial purposes.

5. Cookies and Tracking Technologies

5.1 What Are Cookies

Cookies are small data files placed on your device when you visit our Site. They help us understand how users interact with our Site, remember your preferences, and improve your browsing experience.

5.2 Types of Cookies We Use

  • Strictly Necessary Cookies: Essential to the operation of the Site. These cannot be disabled.

  • Analytics Cookies: Used to collect aggregated, anonymised information about Site usage (e.g., Google Analytics). These are only set with your consent.

  • Preference Cookies: Used to remember your settings and preferences.
     

5.3 Your Cookie Choices

On your first visit to our Site, you will be presented with a cookie consent notice. You may accept or decline non-essential cookies at that time. You may also update your preferences at any time via your browser settings or our cookie settings panel.

 

Please note that disabling certain cookies may impact the functionality of our Site.

6. Third-Party Services and Data Processors

We engage the following third-party service providers who may process personal data on our behalf:

Wix.com (Website Platform):

Our Site is hosted and built on Wix.com, Inc. (USA). Wix processes technical data including IP addresses and browsing behaviour as part of hosting our Site. Wix acts as a data processor on our behalf. More information is available at: www.wix.com/about/privacy

Google Analytics (Google LLC, USA):

We use Google Analytics to collect anonymised statistical information about Site traffic and usage. Google may transfer data to servers in the United States. Google operates under standard contractual clauses and its own Privacy Shield-equivalent mechanisms. You may opt out of Google Analytics tracking by installing the Google Analytics Opt-out Browser Add-on at: tools.google.com/dlpage/gaoptout

All third-party processors are bound by contractual obligations to process data only on our instructions and in accordance with applicable data protection law. We do not authorise any third party to use your personal data for their own independent purposes.

7. International Data Transfers

As our Site is hosted by Wix.com (United States) and uses Google Analytics (United States), personal data collected through our Site may be transferred to and processed in countries outside the UAE, including the United States.

Where such transfers occur, we ensure that appropriate safeguards are in place, including:

  • Standard contractual clauses or equivalent contractual protections

  • Reliance on the data processor's own certified compliance mechanisms (e.g., Google's EU-U.S. Data Privacy Framework participation)

  • Ensuring the recipient country provides an adequate level of protection as determined by the UAE Data Office
     

By using our Site, you acknowledge and consent to such transfers as described above.

8. Data Retention

We retain personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable UAE law. Our standard retention periods are:

  • Enquiry and contact form data: Up to 3 years from last contact, unless an ongoing business relationship is established

  • Investor relations correspondence: Up to 7 years in accordance with UAE commercial record-keeping requirements

  • Website analytics data: Up to 26 months (as per Google Analytics default settings)

  • Marketing opt-in records: Until consent is withdrawn, then deleted within 30 days

When personal data is no longer required, it is securely deleted or anonymised in accordance with our internal data destruction procedures.

9. Data Security

We implement appropriate technical and organisational measures to protect your personal information against unauthorised access, accidental loss, alteration, disclosure, or destruction. These measures include:

  • Encrypted data transmission via HTTPS/TLS protocols

  • Access controls limiting data access to authorised personnel only

  • Regular review of security practices and third-party processor agreements

  • Use of reputable, security-certified cloud service providers

 

However, no method of transmission over the internet or electronic storage is completely secure. While we strive to protect your personal data, we cannot guarantee absolute security. In the event of a data breach that poses a risk to your rights and freedoms, we will notify the UAE Data Office and affected individuals in accordance with our obligations under the UAE PDPL.

10. Your Rights as a Data Subject

Under the UAE Federal Decree-Law No. 45 of 2021 (UAE PDPL), you have the following rights in relation to your personal data:

Right of Access:
You may request a copy of the personal data we hold about you, along with information about how it is processed.

Right to Rectification:​

You may request that we correct inaccurate or incomplete personal data.

Right to Erasure:
You may request the deletion of your personal data where it is no longer necessary for the purpose for which it was collected, or where you have withdrawn consent.

Right to Restriction of Processing:
You may request that we restrict how we process your personal data in certain circumstances.

Right to Data Portability:
Where technically feasible, you may request your personal data in a structured, commonly used, machine-readable format.

Right to Withdraw Consent:
Where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of prior processing.

Right to Object:
You may object to processing based on legitimate interests, including direct marketing.

To exercise any of these rights, please submit a written request to hq@zolareholdings.com with the subject line "Data Subject Request." We will respond within 30 days of receipt. We may request proof of identity before processing your request.

11. Right to Lodge a Complaint

If you believe we have not handled your personal data in accordance with applicable law, you have the right to lodge a complaint with the UAE Data Office, the supervisory authority responsible for data protection in the UAE.

UAE Data Office contact information:

We would, however, appreciate the opportunity to address your concerns directly before you contact the authority. Please reach out to us first at hq@zolareholdings.com.

12. Marketing Communications

We will only send you marketing emails, newsletters, or updates if you have explicitly opted in to receive them. Each marketing communication will include a clear and easy unsubscribe mechanism. You may opt out at any time by:

  • Clicking the "Unsubscribe" link in any marketing email

  • Sending a written request to hq@zolareholdings.com with the subject line "Unsubscribe"

Opting out of marketing does not affect our ability to send you service-related communications (e.g., responses to your direct enquiries).

13. Links to Third-Party Websites

Our Site may contain links to external websites operated by third parties. These links are provided for your convenience only. We have no control over the content or privacy practices of those sites and are not responsible for them. We encourage you to review the privacy policy of any third-party site you visit.

14. Children's Privacy

Our Site is not directed at individuals under the age of 18. We do not knowingly collect personal data from children. If we become aware that we have inadvertently collected personal data from a minor, we will take immediate steps to delete it. If you believe a minor has submitted personal data to us, please contact us at hq@zolareholdings.com.

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal obligations, or operational requirements. Any updated version will be posted on this page with a revised effective date. We encourage you to review this Policy periodically.

Where changes are material, we will endeavour to notify you by prominent notice on our Site or by direct communication where we hold your contact details.

16. Contact Us

For any questions, concerns, or requests relating to this Privacy Policy or the handling of your personal data, please contact us:

Zolare Holdings LLC

Level 15, Al Khatem Tower

Al Maryah Island, Abu Dhabi

United Arab Emirates

Email: hq@zolareholdings.com

Phone: +971 50 327 4989

© 2026 Zolare Holdings LLC. All rights reserved.

Abu Dhabi, UAE  |  www.zolareholdings.com

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