Privacy Policy

1. Who We Are

WHL Logistics Marketplace LLC is a company registered in the United Arab Emirates, operating a digital marketplace that connects businesses requiring warehouse space (Kind A users) with businesses that have surplus warehouse capacity to rent (Kind B users).

Data Controller: WHL Logistics Marketplace LLC
Registered Address: Building 12, Floor 4, Dubai Internet City, Dubai, UAE
Contact: privacy@whl.ae

2. Data We Collect

We collect information you provide directly, data generated through your use of the platform, and information from third parties where permitted by law.

2.1 Information You Provide

• Account data: Full name, email address, mobile number, company name, trade license number, Emirates ID (for verification)
• Listing data (Kind B): Warehouse address, size, photos, certifications, pricing, availability, and facility features
• Requirement data (Kind A): Storage needs, preferred location, duration, cargo type, and budget range
• Payment data: Billing details processed through our PCI-DSS compliant payment processor (we do not store full card numbers)
• Communications: Messages exchanged between users via our platform messaging system, support tickets, and emails sent to WHL

2.2 Data Collected Automatically

• IP address, browser type, device identifiers, and operating system
• Pages visited, time spent on pages, search queries, and click patterns
• Session logs and platform interaction data
• Cookie and similar tracking technology data (see Section 7)

2.3 Data from Third Parties

• Verification data from identity verification partners
• Business registration data from UAE government databases (with your consent)
• Fraud prevention signals from our security partners

3. How We Use Your Data

We use the data we collect for the following purposes:

• Providing the platform: Creating and managing your account, facilitating matches between Kind A and Kind B users, processing bookings and payments
• Verification: Confirming business identity, validating warehouse listings for accuracy and legitimacy
• Communications: Sending booking confirmations, payment receipts, important service updates, and responding to your support inquiries
• Safety and security: Detecting and preventing fraudulent activity, enforcing our Terms of Service, resolving disputes
• Improving our service: Analysing usage patterns to improve features, fix bugs, and develop new functionality
• Marketing (with consent): Sending promotional emails, product updates, and market insights where you have opted in
• Legal compliance: Meeting our obligations under UAE law, including anti-money laundering (AML) requirements and tax regulations

4. Legal Basis for Processing

We process your personal data under the following legal bases as provided under UAE Federal Decree-Law No. 45 of 2021 on Personal Data Protection:

• Contractual necessity: Processing required to provide the services you have signed up for
• Legitimate interests: Fraud prevention, platform security, and service improvement where your rights do not override our interests
• Legal obligation: Compliance with applicable UAE laws and regulations
• Consent: Marketing communications and non-essential cookies, where we have obtained your explicit consent

5. Data Storage & Security

All personal data is stored on secure servers located within the United Arab Emirates or in jurisdictions that provide an adequate level of data protection as recognised under UAE law.

We implement the following technical and organisational measures to protect your data:

• AES-256 encryption for data at rest
• TLS 1.3 encryption for all data in transit
• Multi-factor authentication for staff access to production systems
• Role-based access controls — staff only access data necessary for their role
• Annual third-party penetration testing
• Automatic backups with 30-day retention
• ISO 27001-aligned information security management policies

6. Third-Party Services

We share data with carefully selected third parties only to the extent necessary to operate our platform. These partners are contractually bound to protect your data and may not use it for their own purposes.

6.1 Categories of Third-Party Recipients

• Payment processors: For processing AED transactions (e.g., payment gateway providers licensed by the UAE Central Bank)
• Identity verification providers: For KYC and business verification services
• Cloud infrastructure providers: For hosting, storage, and computing services
• Analytics providers: For aggregated, anonymised usage analytics (e.g., page performance, crash reporting)
• Email service providers: For transactional and marketing email delivery
• Legal and compliance: Lawyers, auditors, and UAE regulatory authorities where required by law

6.2 Cross-Border Transfers

Where data is transferred outside the UAE, we ensure adequate protections are in place through standard contractual clauses or confirmed adequacy status of the recipient country under UAE data protection law.

7. Cookies

We use cookies and similar technologies on our platform. Please refer to our Cookie Policy for full details on what cookies we use, why, and how to manage your preferences.

In summary, we use:

• Essential cookies: Required for the platform to function (cannot be disabled)
• Analytics cookies: Help us understand how users interact with our platform
• Preference cookies: Remember your settings and preferences
• Marketing cookies: Used only with your explicit consent

8. UAE Data Protection Compliance

WHL operates in full compliance with UAE Federal Decree-Law No. 45 of 2021 on Personal Data Protection ("PDPL") and its implementing regulations. Where applicable, we also comply with the Dubai International Financial Centre (DIFC) Data Protection Law and the Abu Dhabi Global Market (ADGM) Data Protection Regulations.

Our data protection practices include:

• Appointment of a Data Protection Officer (DPO) responsible for privacy compliance
• Maintaining a record of all data processing activities
• Conducting Data Protection Impact Assessments (DPIAs) for high-risk processing
• Providing transparent information about data processing at the point of collection
• Ensuring data subject rights are upheld within statutory timeframes

To contact our DPO: dpo@whl.ae

9. Your Rights

Under the UAE PDPL, you have the following rights with respect to your personal data:

• Right to access: Request a copy of the personal data we hold about you
• Right to correction: Request correction of inaccurate or incomplete data
• Right to erasure: Request deletion of your data where we no longer have a lawful basis to hold it
• Right to restriction: Request that we restrict processing of your data in certain circumstances
• Right to data portability: Receive your data in a structured, machine-readable format
• Right to object: Object to processing based on legitimate interests or for direct marketing
• Right to withdraw consent: Where processing is based on consent, withdraw it at any time without affecting prior processing

If you are dissatisfied with our response, you have the right to lodge a complaint with the UAE Data Office or the relevant supervisory authority.

10. Data Retention

We retain personal data for as long as necessary to fulfil the purposes for which it was collected, comply with legal obligations, and resolve disputes. Our default retention periods are:

• Active account data: Retained for the lifetime of your account plus 7 years after closure (as required by UAE commercial law)
• Transaction records: 7 years from the date of transaction (UAE tax and commercial law requirement)
• Marketing data: Until you withdraw consent or request erasure
• Support correspondence: 3 years from last interaction
• Analytics data: 26 months in identifiable form; thereafter in aggregated/anonymised form indefinitely

11. Children's Privacy

Our platform is intended for business use and is not directed at individuals under the age of 18. We do not knowingly collect personal data from minors. If we become aware that a minor has provided us with personal data without appropriate parental consent, we will delete such information promptly. If you believe a minor has submitted data to us, contact us at privacy@whl.ae.

12. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or for other operational reasons. When we make material changes, we will:

• Update the "Last Updated" date at the top of this page
• Send a notification to your registered email address
• Display a prominent notice on the platform for at least 30 days

Your continued use of WHL after changes take effect constitutes your acceptance of the updated policy.

13. Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or your personal data, please contact us through any of the following channels:

• Email: privacy@whl.ae
• DPO: dpo@whl.ae
• Contact Form: whl.ae/contact
• Post: Data Protection Officer, WHL Logistics Marketplace LLC, Building 12, Floor 4, Dubai Internet City, Dubai, UAE