Privacy Policy
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Privacy Policy
Used German Machines FZE (“Company”, “we”, “us” or “our”) is committed to protecting your privacy. This Privacy Policy explains how we collect, use, and safeguard your personal data when you use our website UGM.ae or engage with our services, in compliance with applicable laws of the United Arab Emirates (UAE). We adhere to the UAE Personal Data Protection Law which ensures confidentiality and privacy of personal information (Data protection laws | The Official Portal of the UAE Government). By using our site, you agree to the practices described in this Privacy Policy.
Personal Data We Collect and How We Use It
We only collect personal data that is necessary for specified purposes. The types of personal data we may collect include:
- Contact Information: Such as your name, email address, phone number, and company name. We collect this when you fill out our contact forms, request a quote, subscribe to our newsletter, or communicate with us. We use this information to respond to your inquiries, provide quotes or information about our machines and services, process orders or service requests, and keep you updated (with your consent) on our products and offers.
- Transaction and Order Information: If you purchase a product or service from us, we will collect information related to the purchase. This may include billing address, delivery address, details of the product or service requested, and payment information (note: for online payments, your payment details may be processed directly by a secure payment gateway and not stored on our servers). We use this data to process and fulfill your order or service contract, arrange delivery, provide customer support, and for internal accounting/tax records.
- Usage Data: When you visit our website, our systems may automatically collect technical data such as your IP address, browser type, device information, and browsing actions (e.g. pages viewed, time spent). We collect this through cookies or similar technologies to understand how our website is used, to improve its performance and user experience, and to tailor our communications. For more details, please refer to our Cookie Policy (if applicable). You can adjust your browser settings to refuse cookies, but some site features may not function properly.
- Newsletter and Marketing Data: If you subscribe to our newsletter or explicitly consent to receive marketing communications, we will collect your email (and optionally name) to send you news, updates, promotional offers or other information about our products and services. You can opt out of these communications at any time by clicking the unsubscribe link in the email or contacting us. We will not send you marketing communications without the legally required consent (Data protection laws | The Official Portal of the UAE Government) (Consumer protection law | The Official Portal of the UAE Government).
- Other Information: Any other personal data you voluntarily provide to us. For example, if you participate in a survey, provide feedback, or apply for a job via our site, we will collect the information you submit for that specific purpose only.
We will use your personal data only for the purposes for which it was collected, and such data will not be further processed in a manner incompatible with those purposes. If we intend to use your data for a new purpose, we will seek your consent or ensure it is permitted by law.
Legal Basis for Data Processing
Our processing of your personal data is always based on a lawful basis as required under UAE law. We will only process your information when one of the following legal bases applies:
- Consent: In most cases, we rely on your consent to process personal data. For instance, we obtain your consent to collect and use your email for newsletter subscriptions or for optional marketing communications. You have the right to withdraw your consent at any time. Withdrawing consent will not affect the lawfulness of processing done prior to withdrawal (Overview of UAE’s Federal Decree-Law No. (45) of 2021 on PDPL – Securiti) (Overview of UAE’s Federal Decree-Law No. (45) of 2021 on PDPL – Securiti).
- Contractual Necessity: When you request a service or purchase a product from us, we process your personal data as needed to enter into or perform the contract. For example, using your contact and payment details to process an order, or your address to deliver a machine, is necessary for us to fulfill our contractual obligations to you (Overview of UAE’s Federal Decree-Law No. (45) of 2021 on PDPL – Securiti).
- Legal Obligation: We may process certain data to comply with our legal obligations under UAE laws. For example, we retain transaction records and invoices as required by accounting and tax regulations, or we may disclose information if required by a court order or government authority.
- Legitimate Interests or Other Lawful Grounds: In some cases, we may process your data to pursue our legitimate business interests, such as improving our website’s functionality, preventing fraud, securing our IT systems, or exercising or defending legal claims – but only where such interests are not overridden by your data protection rights. Additionally, the UAE Personal Data Protection Law permits processing of personal data without consent in specific circumstances, such as when necessary to protect the public interest, to exercise legal rights or proceedings, to protect your vital interests, or other circumstances defined by law (Data protection laws | The Official Portal of the UAE Government) (Overview of UAE’s Federal Decree-Law No. (45) of 2021 on PDPL – Securiti). We will only rely on these alternative legal grounds in strict accordance with the applicable law.
Data Sharing and Third-Party Disclosure
We treat your personal data with care and confidentiality. We do not sell or rent your personal information to third parties. We only share your data with third parties in the following situations and only to the extent necessary:
- Within Our Company and Affiliates: Your information may be shared within our organization, including with our parent or affiliate companies, in order to provide you with our services. For example, if our affiliate (such as our team in Germany) is involved in sourcing a machine or providing support, we may share relevant details with them. All such intra-group sharing is done on a need-to-know basis and under strict confidentiality.
- Service Providers: We may share personal data with trusted third-party service providers who perform functions on our behalf. These include logistics and shipping partners (to deliver machines or parts to you), payment processors or banks (to handle payment transactions securely), IT and hosting providers (who host our website or databases), customer support tools, email service providers (to send out newsletters or transaction emails), and analytics or marketing service providers. When we use third-party processors, we ensure they are bound by contracts that require them to only use your data for our specified purposes and to protect it with appropriate security measures in line with UAE data protection requirements (Overview of UAE’s Federal Decree-Law No. (45) of 2021 on PDPL – Securiti).
- Business Transfers: If our company undergoes a business transaction such as a merger, acquisition, or asset sale, your personal data may be transferred to the new owner or partner as part of that transaction. In such cases, we will ensure the confidentiality of your personal information is maintained and that you are informed of any significant changes.
- Legal Compliance and Protection: We may disclose personal data to courts, law enforcement, regulatory authorities, or other competent bodies when we believe disclosure is required by applicable law or legal process. For example, if we receive a legitimate legal request, or to enforce our Terms & Conditions, or to protect the rights, property, or safety of our company, our customers, or others. This may include exchanging information with other companies and organizations for fraud protection and credit risk reduction, in compliance with the law.
- With Your Consent: In situations where you explicitly consent to or request that we share your information with a third party, we will do so according to the terms of your consent. For instance, if you ask us to refer you to a partner company or service, or agree that we can share your testimonial on our website.
Any third parties with whom we share data are obligated to keep your information confidential and to use it only for the purposes we specify. If we ever need to share your data for any other purpose, we will obtain your consent or ensure it is allowed by law.
Cross-Border Data Transfers: Used German Machines FZE is based in the UAE, but our affiliate company and some of our service providers are located in other countries (for example, our parent office in Germany or cloud service providers in various regions). If your personal data is transferred outside of the UAE, we take steps to ensure it remains protected. The UAE’s data protection law sets requirements for cross-border transfer and sharing of personal data (Data protection laws | The Official Portal of the UAE Government). In compliance with these requirements, we will only transfer data to jurisdictions that ensure an adequate level of data protection, or implement appropriate safeguards such as contractual data protection clauses, or obtain your consent where required. We will inform you of any significant cross-border transfer of your personal data and the measures taken to protect it (Overview of UAE’s Federal Decree-Law No. (45) of 2021 on PDPL – Securiti).
Data Security Measures
We employ robust technical and organizational security measures to safeguard your personal data against unauthorized access, disclosure, alteration, or destruction. In accordance with UAE law and international best practices, we strive to ensure a high level of information security appropriate to the sensitivity of the data (Overview of UAE’s Federal Decree-Law No. (45) of 2021 on PDPL – Securiti). Our security measures include, but are not limited to:
- Encryption: Our website is secured via SSL/TLS encryption. This means that when you submit information through our site (for example, filling out forms or making a payment), the data is encrypted in transit to protect it from eavesdropping (Overview of UAE’s Federal Decree-Law No. (45) of 2021 on PDPL – Securiti). We also implement encryption and/or pseudonymization for stored personal data where appropriate, so that even if data is accessed without authorization, it remains protected.
- Secure Infrastructure: Personal data is stored on secure servers, and we use firewalls, anti-malware, and intrusion detection systems to prevent and monitor for unauthorized access. Our hosting providers maintain high security standards and are regularly audited. Access to our databases and systems is restricted to authorized personnel only on a need-to-know basis, and these individuals are bound by confidentiality obligations.
- Organizational Measures: We have implemented internal policies and training to ensure our staff handle personal data safely and in accordance with this Privacy Policy. We limit the personnel who can access personal information, and we regularly review our practices. Physical security measures are in place for any facilities where personal data might be stored (such as locked server rooms).
- Payment Security: For any online payments, we partner with reputable payment processors that are compliant with security standards (such as PCI-DSS for card payments). We do not store full payment card details on our systems to minimize risk.
- Monitoring and Testing: We periodically evaluate our security measures and update them in response to emerging threats. This includes applying security patches, using up-to-date encryption protocols, and conducting vulnerability assessments or penetration testing on our systems. We also maintain data backup routines and have processes to ensure we can restore access to personal data in the event of a technical incident, adding to the resilience and availability of our systems (Overview of UAE’s Federal Decree-Law No. (45) of 2021 on PDPL – Securiti).
While we take all reasonable measures to protect your data, please note that no method of transmission over the internet or electronic storage is 100% secure. Therefore, we cannot guarantee absolute security. However, we continually strive to protect your information and regularly enhance our security measures.
Data Breach Notification: In the unlikely event of a data breach that compromises your personal data, we will act promptly in accordance with UAE laws. We have a breach response plan in place. If a personal data breach occurs and poses a risk to your privacy or personal information, we will notify the UAE Data Office and/or other relevant authorities as required, and we will inform affected individuals without undue delay, consistent with legal requirements (Overview of UAE’s Federal Decree-Law No. (45) of 2021 on PDPL – Securiti). We will also take all necessary steps to contain and remedy the breach.
Data Retention (Storage Duration)
We retain personal data only for as long as necessary to fulfill the purposes for which it was collected, or to comply with applicable legal and business requirements. We do not keep personal data indefinitely and will securely delete or anonymize it when it is no longer needed.
The exact duration for which we keep your data may vary depending on the type of data and the purpose of processing. Generally:
- Customer and Transaction Data: If you purchase a machine or service from us, we will retain your personal data for as long as you remain a customer and as needed to fulfill our contract with you (e.g. until your order is completed and for any applicable warranty or support period). After that, we may retain certain information for a further period required by law – for example, financial records and invoices are kept for the minimum period mandated by UAE commercial, tax, and accounting laws. This is typically up to 5 years (or as required) from the end of the financial year when the transaction occurred, to comply with audit and tax regulations. We may also retain contract-related data until any legal claims under the contract expire (statute of limitations).
- Contact Inquiries (no purchase): If you contact us with an inquiry but do not ultimately purchase a product or service, we will retain your correspondence and contact details for a reasonable period to assist you with any follow-up questions. Typically, such inquiry data is kept for up to 1–2 years, unless you request its deletion earlier. This allows us to refer to previous communications if you contact us again.
- Marketing Subscription: If you have subscribed to our newsletter or agreed to receive marketing emails, we will retain your email address and related preferences until you unsubscribe or withdraw your consent. Upon opting out, we will promptly remove you from our mailing list (though we may keep a record of your unsubscribe request to ensure we honor it going forward).
- Website Usage Data: Usage data (analytics logs, cookies) is retained only for as long as necessary for the purposes collected. For example, analytics data may be retained for internal analysis and trend purposes typically for a few months up to a couple of years. Where possible, we aggregate or anonymize usage data after a short retention period so it no longer identifies individual users.
- Legal Obligations & Disputes: In certain cases, we may need to retain your data for longer if required to meet other legal obligations or to resolve disputes. For instance, if we are involved in a legal dispute or investigation, we will retain relevant data until the issue is resolved and no further action is needed. Also, if deletion of your data is technically not immediately feasible (for example, stored in secure backups), we will ensure it is isolated from any active use and deleted as soon as possible.
Once the retention period expires or the purpose of processing has been fulfilled, we will either delete your personal data in a secure manner or anonymize it (so that it can no longer be associated with you). If anonymized, we may retain that data for statistical purposes without further notice to you, since it no longer constitutes personal information.
Your Rights as a Data Subject
We respect your rights to your personal data. Under UAE data protection laws, and in line with international best practices, you have the following rights regarding the personal data we hold about you:
- Right of Access: You have the right to request confirmation of whether we are processing your personal data, and to request a copy of the personal data we hold about you, as well as to obtain information about how we process it (Overview of UAE’s Federal Decree-Law No. (45) of 2021 on PDPL – Securiti). This means you can ask us to explain what data we have about you, the purposes for which we use it, the categories of data, the third parties with whom it is shared (if any), and how long we plan to keep it. We will provide this information, subject to some exceptions (for example, we may not be able to provide data that includes someone else’s personal information unless we can anonymize or separate it).
- Right to Rectification: If any of your personal data that we have is inaccurate or incomplete, you have the right to request that we correct or update it so that it is accurate (Data protection laws | The Official Portal of the UAE Government). We encourage you to keep your information with us up-to-date and will promptly make corrections when you request them. This includes the ability to update, for instance, your contact details or any account information if you have an account with us.
- Right to Erasure (Deletion): You have the right to request that we delete your personal data in certain circumstances (Overview of UAE’s Federal Decree-Law No. (45) of 2021 on PDPL – Securiti). This is sometimes referred to as the “right to be forgotten.” You can request erasure, for example, if the data is no longer necessary for the purposes it was collected, if you have withdrawn your consent and no other legal basis for processing applies, or if you believe we are processing your data unlawfully. We will honor valid deletion requests and will also ensure any processors or third parties we’ve shared your data with do the same, insofar as required by law. Please note there are exceptions to this right – for instance, we might retain data if required for legal obligations or establishment of legal claims, but we will inform you of such reasons if applicable.
- Right to Restrict Processing: You have the right to request that we limit or suspend the processing of your personal data under certain conditions (Data protection laws | The Official Portal of the UAE Government). You might exercise this right if you contest the accuracy of your data (for a period enabling us to verify it), or if you object to our processing and we are evaluating your request, or if processing is unlawful and you prefer restriction instead of deletion. When processing is restricted, your data will remain stored but not used (other than to secure it and as necessary to honor your request). We will inform you before lifting any restriction.
- Right to Object: You have the right to object to certain types of processing. In particular, you can object to any direct marketing uses of your data at any time, and we will stop using your data for that purpose. You may also object if we ever process your data based on a public interest or our legitimate interests (as allowed by law) and you believe your fundamental rights and freedoms outweigh our interests. In such cases, we will re-evaluate our reasoning and unless we have a compelling legitimate ground, we will cease the processing in question.
- Right to Withdraw Consent: Where we rely on your consent to process your personal data, you are free to withdraw that consent at any time. Once you withdraw consent, we will stop the processing that was based on it. For example, if you consented to receive our newsletter, you can unsubscribe and we will stop sending it. Withdrawal of consent will not affect the legality of any processing we carried out before you withdrew, and it will not affect processing of your data under other legal bases (if any apply).
- Right to Data Portability: To the extent provided by UAE law, you may have the right to receive certain personal data that you have provided to us in a structured, commonly used, and machine-readable format, and the right to transmit that data to another controller. This typically applies to data processed by automated means on the basis of your consent or a contract. If you require such data portability, we will assist with providing your data in a suitable format.
- Right to Lodge a Complaint: We are regulated under UAE data protection laws. If you believe your rights have been violated or you have a concern about how we handle your personal data, we encourage you to contact us first so we can try to resolve the issue. However, you also have the right to lodge a complaint with the UAE Data Office (once it is fully operational as the data protection supervisory authority) or the appropriate regulatory authority in UAE. We will provide you with the contact information for the relevant authority upon request. (For instance, the UAE Data Office is the agency tasked with overseeing personal data protection compliance in the UAE.)
To exercise any of your rights, please contact us using the contact details provided in the “Contact Us” section below. We will respond to your request as soon as possible and within any timeframe required by law. Please note that to protect your privacy, we may need to verify your identity before fulfilling certain requests (for example, by asking you to provide information that matches our records). If we cannot fulfill a request, we will explain the reason in our response (such as if an exemption applies or if we cannot verify your identity).
We provide these rights to you free of charge. However, if a request is manifestly unfounded or excessive (for example, repetitive requests without justification), we may charge a reasonable fee or refuse to act on it, as permitted by law.
Third-Party Websites and Services
Our website may contain links to third-party websites or integrate third-party services (such as embedded videos, social media widgets, or a link to our partner’s spare parts store). Please note that this Privacy Policy does not apply to those external sites or services that are not operated by us. We are not responsible for the privacy practices of third-party sites. We encourage you to review the privacy policies of any third-party websites or services before providing any personal information to them.
Updates to this Privacy Policy
We may update or revise this Privacy Policy from time to time to reflect changes in our practices or to ensure compliance with legal requirements. If we make material changes, we will notify users via a prominent notice on our website or by other appropriate means. The “Last Updated” date at the top of this Policy will indicate when the latest changes were made. We encourage you to review this Policy periodically to stay informed about how we are protecting your information.
If we update the Policy, in some cases we may seek your re-consent if required (for example, if the changes affect how we process data based on your consent). In all other cases, continued use of our website or services after the updated Policy is in effect will signify your acceptance of the revised terms.
Contact Us
If you have any questions, concerns, or requests regarding this Privacy Policy or the personal data we hold about you, please do not hesitate to contact us:
Used German Machines FZE
Email: sales@ugm.ae
Phone: +971 50 314 1369
Mailing Address: Hamriyah Free Zone, Warehouse LV02-B, Sharjah – United Arab Emirates
When you contact us, please provide sufficient information for us to identify you (if you are an existing customer) and to understand your request. We will treat requests and complaints confidentially. Our team will investigate any issue and get back to you as soon as possible, and in any event within the timeframe provided by law.
Thank you for trusting Used German Machines FZE. We value your privacy and will continue to safeguard your personal data in compliance with UAE regulations and in line with global best practices.