PRIVACY & COOKIE POLICY


BORA FINANCE FZCO

1. Introduction
BORA FINANCE FZCO (“BORA FINANCE”, “we”, “us” or “our”) respects the privacy of individuals who visit our website, contact us, represent customers, manufacturers, suppliers or business partners, or otherwise interact with us in a professional or business context.
This Privacy & Cookie Policy explains how we may collect, use, store, disclose and protect Personal Data, as well as how cookies and similar technologies may be used on bora-finance.com.
BORA FINANCE is based in Dubai, United Arab Emirates and conducts international business activities, including engagement with manufacturers, customers, suppliers and business partners in the United Arab Emirates, the European Union, the European Economic Area and other international markets.
This Policy is intended to address applicable requirements under:

  • UAE Federal Decree-Law No. 45 of 2021 concerning the Protection of Personal Data (“UAE PDPL”); and
  • Regulation (EU) 2016/679, the General Data Protection Regulation (“GDPR”), where the GDPR applies to the relevant processing activity.

Other applicable data-protection, privacy and electronic-communications laws may also apply depending on the location and nature of the relevant activity.

2. Data Controller
For the purposes of applicable data-protection law, the controller responsible for the processing described in this Policy is:
BORA FINANCE FZCO
Dubai, United Arab Emirates
Website: bora-finance.com
Email: info@bora-finance.com

3. Definitions
For the purposes of this Policy:
“Personal Data” means information relating to an identified or identifiable natural person.
Personal Data may include professional or business information where it identifies an individual, including a person's name, individual business email address, telephone number, job title or other information connected to that individual.
“Processing” includes activities such as collecting, recording, organising, storing, using, consulting, transmitting, disclosing, restricting or deleting Personal Data.
“Controller” means the person or organisation that determines the purposes and means of processing Personal Data.
“Cookies” are small data files or similar technologies that may be stored on or accessed from a visitor's browser or device.


4. Personal Data We May Collect
The categories of Personal Data we process depend on how an individual interacts with BORA FINANCE.
4.1 Contact and Identity Information
We may process:

  • First name and surname
  • Business email address
  • Telephone or mobile number
  • Job title or professional role
  • Employer, company or organisation
  • Business location or country
  • Preferred communication details

4.2 Enquiry and Business Relationship Information
Where an individual contacts us or represents an organisation dealing with us, we may process:

  • Area of business interest
  • Enquiry details
  • Correspondence and messages
  • Meeting information
  • Requested services
  • Manufacturer, supplier or customer relationship information
  • Commercial or project-related discussions
  • Records of professional communications
  • Information voluntarily provided to us

4.3 Website and Technical Information
When our website is accessed, certain technical information may be processed automatically by our website infrastructure or service providers.
This may include:

  • IP address
  • Browser type and version
  • Device type
  • Operating system
  • Date and time of access
  • Pages requested or visited
  • Referring page
  • Technical diagnostic information
  • Server and security logs
  • Cookie or consent preferences

Such information may be required for technical operation, website security, troubleshooting or, where enabled and legally permitted, website analytics.
4.4 Professional and B2B Contact Information
As part of our international business activities, we may process professional contact information relating to employees, representatives or other personnel of:

  • Manufacturers
  • Laboratory equipment companies
  • Customers
  • Suppliers
  • Distributors
  • Commercial partners
  • Professional advisers
  • Prospective business partners
  • Other organisations relevant to our business activities

We seek to limit such processing to information reasonably relevant to the professional relationship.
4.5 Sensitive Personal Data
Our general website and ordinary B2B communications are not intended for the collection of special categories or other sensitive Personal Data.
Please do not submit sensitive Personal Data through the general website contact form unless it is specifically necessary and an appropriate communication method has been agreed.

5. Sources of Personal Data
We may obtain Personal Data:
Directly from the Individual
For example through:

  • Our contact form
  • Email
  • Telephone
  • Business meetings
  • Trade fairs and exhibitions
  • Business cards
  • Video conferences
  • Other direct professional communication

From the Individual's Organisation
Professional contact information may be provided by an employer, colleague, distributor, manufacturer, customer, supplier or other organisation involved in a business relationship.
From Publicly Available Professional Sources
For legitimate B2B purposes, professional contact information may also be obtained from sources such as:

  • Official company websites
  • Manufacturer websites
  • Professional directories
  • Trade-fair exhibitor information
  • Public business listings
  • Professional networking platforms
  • Published corporate contact information
  • Industry associations or directories

Where the GDPR applies and Personal Data has not been obtained directly from the individual, BORA FINANCE will provide the information required by applicable law within the applicable period or at the appropriate point of communication, subject to any lawful exceptions.
Through Website Technology
Technical information may be generated automatically when a visitor accesses our website or interacts with website functionality.

6. Why We Process Personal Data
We may process Personal Data for purposes including:
Responding to Enquiries
To receive, assess and respond to enquiries concerning:

  • Scientific and laboratory solutions
  • Laboratory projects
  • Laboratory equipment
  • Manufacturer representation
  • Market development
  • Precious metals and gold consulting
  • Commercial brokerage
  • General business opportunities

Manufacturer and Supplier Relationships
To identify, establish and manage professional relationships with manufacturers and suppliers, including:

  • Manufacturer representation discussions
  • Distribution opportunities
  • Market development
  • Technical-commercial coordination
  • Product and project enquiries
  • Customer development
  • Commercial cooperation

Customer and Business Development
To communicate with prospective or existing customers and business partners concerning relevant business opportunities, products, projects or services.
Business Relationship Management
To maintain communications, records and information reasonably necessary for existing or prospective business relationships.
Pre-Contractual and Contractual Activities
To:

  • Assess proposed business relationships
  • Prepare quotations or commercial proposals
  • Take requested pre-contractual steps
  • Enter into agreements
  • Perform contractual obligations
  • Manage ongoing commercial relationships

Website Operation and Security
To:

  • Operate and maintain the website
  • Deliver website content
  • Protect against unauthorised access or misuse
  • Detect and investigate technical or security incidents
  • Diagnose website problems
  • Maintain technical and information security

Legal and Regulatory Compliance
To comply with applicable:

  • Laws
  • Regulations
  • Regulatory requirements
  • Court orders
  • Government requirements
  • Record-keeping obligations

and to establish, exercise or defend legal rights.

7. Legal Bases for Processing under the GDPR
Where the GDPR applies, BORA FINANCE processes Personal Data only where an appropriate legal basis exists.
Depending on the circumstances, this may include:
Consent
Processing may be based on consent where an individual has freely given specific, informed and unambiguous consent.
Where processing is based on consent, the individual may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.
Contract and Pre-Contractual Steps
Processing may be necessary to perform a contract with an individual or to take steps requested by an individual before entering into a contract.
Legal Obligation
Processing may be necessary for compliance with a legal obligation applicable to BORA FINANCE.
Legitimate Interests
BORA FINANCE may process professional Personal Data where this is necessary for legitimate business interests, provided those interests are not overridden by the rights and freedoms of the individual.
Such legitimate interests may include:

  • Developing legitimate B2B relationships
  • Communicating with manufacturers, suppliers and customers
  • Responding to professional enquiries
  • Developing new business relationships
  • Managing existing business relationships
  • Maintaining business records
  • Protecting our website and systems
  • Preventing misuse or security incidents
  • Establishing, exercising or defending legal claims

Before relying on legitimate interests, the nature of the processing, reasonable expectations of the individual and potential impact on the individual's rights should be considered.

8. Processing under UAE Data Protection Law
Where the UAE PDPL applies, Personal Data will be processed with consent where consent is required or on another basis permitted by applicable UAE law.
BORA FINANCE seeks to process Personal Data in accordance with principles including:

  • Fair and transparent processing
  • Processing for specific and legitimate purposes
  • Data minimisation
  • Accuracy
  • Appropriate retention
  • Confidentiality
  • Security
  • Accountability

We seek to collect only the Personal Data reasonably necessary for the relevant purpose.

9. B2B Communications and Direct Marketing
BORA FINANCE operates primarily in a professional and business-to-business environment.
We may contact existing or prospective professional contacts concerning services, products, manufacturer representation, commercial opportunities or other matters reasonably relevant to their professional role.
Where the GDPR applies, such communications may be based on legitimate interests where permitted.
Where consent is required under applicable data-protection, electronic-communications or direct-marketing law, communications will only be made on the appropriate basis.
Right to Object
Individuals have the right to object at any time to the use of their Personal Data for direct marketing where applicable.
If an individual objects to direct marketing, BORA FINANCE will cease using that individual's Personal Data for that purpose as required by applicable law.
Requests can be sent to:
info@bora-finance.com

10. Data Minimisation
BORA FINANCE seeks to process only Personal Data that is adequate, relevant and reasonably necessary for the relevant purpose.
We do not seek to collect excessive Personal Data through our general website or ordinary B2B communications.

11. Sharing of Personal Data
BORA FINANCE does not sell Personal Data.
Personal Data may be disclosed where reasonably necessary to:

  • Website and hosting providers
  • IT and technical service providers
  • Email and communication providers
  • Professional advisers
  • Accounting, legal or compliance service providers
  • Business partners involved in a matter requested by the individual or their organisation
  • Government, regulatory, judicial or law-enforcement authorities where legally required
  • Other recipients where disclosure is required for the establishment, exercise or defence of legal rights

Where appropriate, service providers acting on our behalf are expected to process Personal Data only for the relevant services and subject to appropriate confidentiality and data-protection obligations.
Corporate Transactions
Personal Data may also be transferred where reasonably necessary in connection with a restructuring, merger, acquisition, financing, sale or transfer of all or part of a business or its assets, subject to applicable data-protection requirements.

12. International Data Transfers
BORA FINANCE is established in the United Arab Emirates and conducts business internationally.
Accordingly, Personal Data relating to individuals or business contacts in the EU or EEA may be processed or accessed in the United Arab Emirates.
Personal Data may also be processed by service providers located in other countries.
EU/EEA Personal Data
Where the GDPR applies to a transfer of Personal Data to a country outside the European Economic Area, BORA FINANCE will seek to ensure that an appropriate transfer mechanism or lawful basis is used where required.
Depending on the circumstances, this may include:

  • An adequacy decision
  • Standard Contractual Clauses
  • Appropriate contractual safeguards
  • Another transfer mechanism permitted by applicable law
  • A specific statutory derogation where legally available

UAE Personal Data
Cross-border transfers subject to the UAE PDPL will be handled in accordance with applicable UAE requirements concerning international transfers and appropriate protection of Personal Data.

13. Data Retention
BORA FINANCE retains Personal Data only for as long as reasonably necessary for the purpose for which it was collected.
Retention periods may depend on:

  • The nature of the business relationship
  • Whether discussions remain active
  • Contractual requirements
  • Legal or regulatory obligations
  • Accounting or record-keeping requirements
  • Potential disputes
  • The need to establish, exercise or defend legal claims

Where Personal Data is no longer reasonably required, it should be deleted, anonymised or otherwise securely disposed of where appropriate.

14. Information Security
BORA FINANCE seeks to implement appropriate technical and organisational measures to protect Personal Data against:

  • Unauthorised access
  • Unlawful processing
  • Accidental disclosure
  • Loss
  • Alteration
  • Destruction
  • Misuse

Access to Personal Data should be limited to persons who reasonably require access for legitimate business purposes.
However, no method of transmission over the internet or electronic storage system can be guaranteed to provide absolute security.


COOKIES AND WEBSITE TECHNOLOGIES

15. What Are Cookies?
Cookies are small data files or similar technologies that may be stored on or accessed from a visitor's browser or device when visiting a website.
Cookies can be used for purposes including:

  • Website functionality
  • Security
  • Session management
  • Remembering preferences
  • Consent management
  • Website analytics, where enabled


16. Strictly Necessary Cookies
Some cookies or similar technologies may be necessary for the website to function correctly.
These may support:

  • Basic navigation
  • Website security
  • Session functionality
  • Technical website operation
  • Consent and privacy preferences

Where such technologies are strictly necessary to provide the website or a function requested by the visitor, they may be used without optional analytics or marketing consent where permitted by applicable law.

17. Functional Cookies
Functional cookies may, where enabled, remember certain choices or settings in order to improve website functionality.
Where such cookies are not strictly necessary, they will be subject to applicable consent requirements.

18. Analytics Technologies
Where website analytics are enabled, cookies or similar technologies may be used to obtain information concerning general website usage, for example:

  • Visits
  • Pages viewed
  • General navigation patterns
  • Device categories
  • Browser categories
  • General technical performance

Where applicable law requires consent, non-essential analytics technologies should not be activated until the visitor has made the required choice through the available consent mechanism.

19. Advertising and Behavioural Tracking
BORA FINANCE does not treat advertising, behavioural advertising or remarketing technologies as strictly necessary website functionality.
If such technologies are introduced in the future, their use will be reviewed against applicable consent and transparency requirements and this Policy will be updated where necessary.

20. Managing Cookie Preferences
Where a cookie consent or preference mechanism is available, visitors can use it to accept, reject or manage non-essential cookie categories.
Consent for optional cookies can be withdrawn or changed through the available cookie settings where supported.
Visitors can also control cookies through their browser settings.
Depending on the browser, users may be able to:

  • Review stored cookies
  • Delete cookies
  • Block individual cookies
  • Block categories of cookies
  • Block all cookies
  • Receive notifications concerning cookies

Blocking strictly necessary cookies may affect the operation of certain website functions.

DATA PROTECTION RIGHTS


21. Rights under UAE Data Protection Law
Subject to the UAE PDPL, applicable implementing requirements and any lawful exceptions, individuals may have rights relating to their Personal Data, including rights concerning:

  • Information about the processing of their Personal Data
  • Access to relevant information
  • Correction of inaccurate or outdated Personal Data
  • Deletion where applicable
  • Restriction of processing where applicable
  • Objection to or stopping certain processing
  • Objection to direct marketing
  • Certain automated processing activities
  • Other rights provided by applicable UAE law

The exercise of a right may be subject to legal conditions or exceptions.

22. Rights under the GDPR
Where the GDPR applies, individuals may have the following rights, subject to applicable conditions and exceptions:
Right of Access
To request confirmation as to whether BORA FINANCE processes Personal Data concerning them and to obtain access to relevant Personal Data and processing information.
Right to Rectification
To request correction of inaccurate Personal Data and completion of incomplete information.
Right to Erasure
To request deletion of Personal Data where the applicable legal conditions are satisfied.
Right to Restriction
To request restriction of processing in circumstances provided by the GDPR.
Right to Data Portability
Where applicable, to receive certain Personal Data in a structured, commonly used and machine-readable format and to request transmission to another controller where legally and technically applicable.
Right to Object
To object to certain processing based on legitimate interests.
Where Personal Data is processed for direct marketing, individuals may object to such processing at any time.
Right to Withdraw Consent
Where processing is based on consent, consent may be withdrawn at any time without affecting processing carried out lawfully before withdrawal.
Rights Relating to Automated Decision-Making
Where applicable, individuals may have rights concerning decisions based solely on automated processing that produce legal or similarly significant effects.

23. Exercising Data Protection Rights
Requests relating to Personal Data may be submitted to:
info@bora-finance.com
BORA FINANCE may request reasonable information to verify the identity of the person making the request before providing, changing or deleting Personal Data.
Where the GDPR applies, requests will be handled without undue delay and within the periods required by the GDPR, generally within one month unless a legally permitted extension applies.
Certain rights are not absolute and may be restricted where continued processing is permitted or required by law.


24. Complaints
Individuals are encouraged to contact BORA FINANCE first if they have concerns regarding the processing of their Personal Data.
Where UAE data-protection law applies, individuals may have the right to raise a matter with the competent UAE data-protection authority in accordance with applicable law.
Where the GDPR applies, individuals also have the right to lodge a complaint with a competent supervisory authority in the European Union or European Economic Area, including, where applicable, the supervisory authority in the country of their habitual residence, place of work or the place of the alleged infringement.

25. EU/EEA Representation
BORA FINANCE is established in the United Arab Emirates.
Where applicable law requires BORA FINANCE to appoint a representative in the European Union or European Economic Area in connection with processing subject to Article 27 GDPR, BORA FINANCE will comply with the applicable requirement and make the representative's contact information available as required.

26. Children's Privacy
The BORA FINANCE website and its services are intended for professional and business users and are not directed at children under the age of 18.
We do not knowingly seek to collect Personal Data from children through this website.
If we become aware that Personal Data relating to a child has been submitted through the website without an appropriate legal basis, reasonable steps will be taken to delete or otherwise appropriately handle that information.


27. Third-Party Websites
Our website may contain links to websites or services operated by third parties.
BORA FINANCE does not control the privacy, security or data-processing practices of independent third-party websites.
Visitors should review the privacy information provided by the relevant third party when leaving our website.


28. Changes to This Policy
BORA FINANCE may update this Privacy & Cookie Policy where necessary to reflect changes to:

  • Applicable law
  • Our website
  • Website functionality
  • Business operations
  • Service providers
  • Data-processing activities
  • International business activities

The current version will be made available on bora-finance.com.
The “Last updated” date at the beginning of this Policy indicates when the document was most recently revised.

29. Contact
For privacy, data-protection or cookie-related questions or requests, please contact:
BORA FINANCE FZCO
Dubai, United Arab Emirates
Email: info@bora-finance.com
Website: bora-finance.com

Last updated: 24 September 2026