Privacy Policy

1. Who we are

The controller responsible for the personal data described in this policy is THE FENEK FZCO, a Private Freezone Limited Liability Company registered in Dubai Airport Freezone (DAFZA), Dubai, United Arab Emirates, under Trading License No. 07562 issued by the Dubai Integrated Economic Zones Authority. Registered office: Building 1 West, Third Floor, Office W310, Dubai Airport Freezone (DAFZA), Dubai, United Arab Emirates.

For any question about this policy or about your personal data, contact us at office@thefenek.com. Our telephone numbers are +971 58 207 1872 (UAE — Dubai) and +39 351 565 6095 (Italy).

2. Applicable data protection laws

We process personal data in accordance with the data protection laws that apply to us and to you. Depending on the circumstances, these may include the UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data and, for individuals in the European Union or the European Economic Area, Regulation (EU) 2016/679 (General Data Protection Regulation, “GDPR”).

3. Personal data we process

When you contact us by email or telephone

If you write to office@thefenek.com, we process the information you choose to include, such as your name, company, job title, email address, telephone number, the content of your message and any attachments.

If you call one of our telephone numbers, we process your telephone number and the information you share during the call, in order to handle your request.

Inquiry and partnership forms

Our wholesale inquiry form asks for your company name, contact name, business email address and country and, optionally, a telephone number and a message. Buyers also indicate the products, phone models, variants and quantities they need and the accepted condition of the goods; suppliers indicate the categories they supply, available quantities, their offer and whether a price list is available.

Our retail and franchise interest form asks for your name, email address, country, city, the type of partnership you are interested in and a message and, optionally, your company and your experience.

Online submission is not currently enabled. When you submit one of these forms, the website does not send the form data to our servers: your own email application opens with a pre-filled message addressed to office@thefenek.com, and you decide whether to send it. We receive your data only if you send that email. Before online submission is enabled, this policy will be updated to name the service used to deliver inquiries to us.

Orders, supply and business relationships

When an inquiry leads to an order, a supply agreement or a partnership, we also process the information needed to carry it out, such as the names and contact details of the people we deal with, delivery, customs and billing details, order, invoice and payment records and the related correspondence. We keep these records in our email service and in our online accounting, invoicing and customer and order management systems.

Quotation list

Products you add to a quotation list are stored only in your browser, for the current tab (session storage). They are not sent to us unless you include them in an inquiry, and they are deleted when you close the tab or clear the list.

Product assistant

When you use the product assistant, the text you type and the context you select (product, phone model, colour or variant, quantity and language) are sent to our website's server to generate the answer. The assistant follows predefined rules and approved company information; it does not use an artificial intelligence service. Your messages are processed only to produce the reply and are not stored by the website. Please do not include sensitive personal data in your messages.

Technical data

When you visit the website, your browser automatically sends technical information, such as your IP address, browser type and version, language preferences, the page requested, the referring page and the date and time of the request. We use this information to deliver the website in the right language, to keep it secure and to prevent abuse. To limit excessive requests to our forms and assistant, the server keeps a short-lived count of requests per IP address in memory, for about one minute; the website does not store it in a database or in its own logs.

Our hosting provider processes technical data to deliver and protect the website. The server logs available to us — technical records of the requests handled by the website's server functions, such as the time, the page requested, the response status and the browser type — are kept for 1 day under our current hosting plan, and we do not forward them to any other service. Our hosting provider, Vercel, may also use usage data and metadata generated through its services as an independent controller, as described in its privacy notice (vercel.com/legal/privacy-policy).

4. Cookies and similar technologies

We do not use advertising, analytics or tracking cookies, tracking pixels or social media plugins, and no third-party cookies are set when you browse our public pages. We use only:

• NEXT_LOCALE (first-party cookie) — set only when you choose a language in the language menu. It stores your language choice, for example “en”, for 12 months, so that the website opens in your language on your next visit.
• Quotation list (session storage in your browser) — holds the products you add to a quotation until you close the tab. It is never sent to us automatically.

Both are strictly necessary to provide functions that you explicitly request, so they do not require your consent. If we introduce analytics or other non-essential technologies, we will ask for your consent where required and update this policy before doing so. We do not currently embed third-party content such as videos or maps.

5. Why we use personal data and on what legal basis

Under the GDPR, we rely on the following legal bases:

• To answer your inquiries, to prepare and send the quotations, offers and price lists you request and to conduct supply or partnership discussions — to take steps at your request before entering into a contract (Article 6(1)(b) GDPR) and our legitimate interest in communicating with business customers, suppliers and partners (Article 6(1)(f) GDPR).
• To carry out orders, supply agreements and partnerships, including delivery, customs clearance, invoicing and payments — the performance of a contract (Article 6(1)(b) GDPR) or, when the contract is with the company you work for, our legitimate interest in carrying it out (Article 6(1)(f) GDPR).
• To meet our legal obligations, for example accounting, tax and customs obligations (Article 6(1)(c) GDPR).
• To send you promotional communications that you have not specifically requested — only with your consent (Article 6(1)(a) GDPR).
• To operate the product assistant — our legitimate interest in helping visitors find products and prepare quotation requests (Article 6(1)(f) GDPR).
• To deliver the website, remember your language choice, keep the website secure and prevent abuse — our legitimate interest in operating a secure and functional website (Article 6(1)(f) GDPR).

Where UAE law applies, we rely on the corresponding grounds it provides, such as processing that is necessary to take steps at your request before entering into a contract, to perform a contract or to comply with our legal obligations, and on your consent for promotional communications.

We do not sell personal data, and we do not use it for automated decision-making or profiling.

6. Quotations, price lists and promotional communications

This website does not offer newsletters or marketing subscriptions.

When you ask us for a quotation, an offer or a price list, we send it to you as part of handling your request. This is not a promotional communication.

We send other commercial offers, price lists and promotional communications — by email, by SMS, through messaging apps such as WhatsApp or by telephone — only to people who have specifically asked to receive them or have given us their consent. We do not send unsolicited promotional campaigns.

You can withdraw your consent or ask us to stop at any time, free of charge, by replying to our email or by writing to office@thefenek.com. Withdrawing your consent does not affect communications sent before, nor our replies to your requests and messages about your orders. For any other question, you can contact us as described in the Contact section.

7. Who receives personal data

• Website hosting — Vercel Inc., which runs the website's server functions in Frankfurt, Germany, and delivers pages through its global network.
• Email — Google, which provides our email service (Google Workspace) for office@thefenek.com.
• Business software — the providers of our online accounting and invoicing services and of our online customer and order management (CRM/ERP) system, which store the data of customers, suppliers and other business contacts on our behalf.
• Messaging and telephone services — the messaging apps, such as WhatsApp, and the telephone and SMS services we use to communicate with you. Messaging apps also process data under their own terms and privacy policies.
• Only after a confirmed commercial order — logistics and freight-forwarding companies, customs brokers, banks and payment service providers, and our external accountants and auditors, to the extent necessary to carry out the order and to meet our legal obligations.

Vercel and Google process personal data on our behalf under their data processing terms — Vercel's Data Processing Addendum and Google's Cloud Data Processing Addendum — and use their own sub-processors, which they publish: Vercel at security.vercel.com and Google at workspace.google.com/terms/subprocessors.

We may also disclose personal data where required by law or by a competent authority, or where necessary to establish, exercise or defend legal claims.

8. International transfers

THE FENEK is based in the United Arab Emirates and our service providers operate internationally: Vercel Inc. is based in the United States, runs our server functions in Frankfurt, Germany, and may deliver pages from a location close to you; Google may process our email data in any country where it or its sub-processors maintain facilities. Personal data may therefore be processed outside your country.

For personal data subject to the GDPR, Vercel's Data Processing Addendum incorporates the EU Standard Contractual Clauses, with the corresponding terms for the United Kingdom and Switzerland, and Google's Cloud Data Processing Addendum provides for the EU Standard Contractual Clauses or another transfer mechanism recognised under European data protection law. You can ask us for more information about these safeguards at office@thefenek.com.

The providers of our business software and the messaging services we use may also process personal data outside your country. You can ask us at office@thefenek.com for more information about these providers and the transfers involved.

9. How long we keep personal data

• Inquiries, quotations and related correspondence: 12 months after the last contact when no business relationship follows; when one follows, for its duration and afterwards for as long as applicable commercial, accounting and tax laws require.
• Supplier and partnership proposals: 12 months after the last contact when the proposal is not pursued; when a supply or partnership relationship follows, for its duration and afterwards for as long as applicable law requires.
• Contact details used for promotional communications: until you withdraw your consent or ask us to stop.
• Product assistant messages: not stored by the website after the reply is generated.
• Request-rate counters: about one minute, in server memory only.
• Language cookie: 12 months, or until you delete it.
• Quotation list: until you close the browser tab or clear the list.
• Server logs available to us at our hosting provider: 1 day under our current hosting plan.

Every three months, we review our mailbox and business systems and delete the inquiries, quotations, proposals and contact details whose retention period has ended.

10. Security

We protect personal data with technical measures that include encrypted connections (HTTPS), validation and size limits for data sent to the website, protection of our forms against automated abuse and limits on the rate of requests. The website does not keep copies of inquiry data.

11. Your rights

Subject to the conditions of applicable law, you may have the right to:

• access the personal data we hold about you;
• have inaccurate data corrected;
• have your data erased;
• restrict the processing of your data;
• object to processing, in particular processing based on our legitimate interests, and object at any time to direct marketing;
• receive your data in a portable format;
• withdraw your consent at any time, where processing is based on consent.

To exercise your rights, write to office@thefenek.com. We may need to verify your identity before responding, and we will reply within the time limits set by applicable law.

You may also lodge a complaint with a data protection supervisory authority — for individuals in the EU or EEA, in particular in the member state of your habitual residence, place of work or place of the alleged infringement. In the United Arab Emirates, complaints can be submitted to the UAE Data Office.

12. Children

Our website and services are intended for businesses and are not directed to children. We do not knowingly collect personal data from children.

13. Changes to this policy

We may update this policy, for example when we introduce new website functions or services. The date at the top of this page shows when it was last updated.

14. Contact

THE FENEK FZCO, Building 1 West, Third Floor, Office W310, Dubai Airport Freezone (DAFZA), Dubai, United Arab Emirates — office@thefenek.com — telephone +971 58 207 1872 (UAE — Dubai) and +39 351 565 6095 (Italy). Written correspondence can also be sent to this address.