Privacy notice
This notice explains how BGI COMMERCIAL BROKERAGE SOLUTIONS - FZCO ("BGI") handles personal data it receives through this website, by email, and through the messaging and social channels listed on this website (WhatsApp, Telegram, LinkedIn and Instagram). BGI applies the UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (the "PDPL") as the framework for this notice.
Who is responsible for your data
BGI is the controller of the personal data described in this notice. BGI COMMERCIAL BROKERAGE SOLUTIONS - FZCO is a free zone company licensed by the Dubai Integrated Economic Zones Authority (IFZA) under Commercial Licence No. 91264, Registration No. 84491, registered at Premises No. DSO-IFZA, IFZA Properties, Dubai Silicon Oasis, Dubai, United Arab Emirates.
For any question about this notice or about your data, write to Admin@BGIBrokers.com.
What BGI collects
Through the enquiry form, the request builder and the supplier form: your name, company and email address, the enquiry type, product family and product, quantity, destination region, Incoterm, whether you are the end buyer or an intermediary, a reference number, your message, and the page language and address. The supplier form also asks for capacity, certificates, minimum order, target markets and KYC readiness. The forms also contain a hidden field used only to filter automated spam.
By email: your email address, your name and whatever you include in your message and any attachments.
Through WhatsApp, Telegram, LinkedIn or Instagram: your phone number or account name, your profile details as that service shows them to BGI, and whatever you include in your messages and any attachments.
WhatsApp links: a WhatsApp link on this website opens a draft message that may include the product and reference you chose. Nothing is sent until you press send.
When BGI screens and carries out KYC: if BGI takes an enquiry further, it may also obtain information about the company concerned and about individuals connected with it from public and official sources, such as company registries, sanctions lists and news reports.
When you visit the website: your browser sends the technical information that accompanies every web request, such as your IP address, browser type, the page requested and the time of the request. This is received by the service providers described under "Who receives it". BGI does not use it to identify you.
Please send only what is needed to describe your requirement. Do not send documents, pricing or other information you are not prepared to share before an NCNDA is in place, and do not send sensitive personal data (for example about health, religion or criminal records). BGI does not need it.
Providing information is voluntary. If you do not provide the details the form asks for, BGI cannot respond to your enquiry.
Why BGI uses it
BGI uses personal data for these purposes only:
- To respond to your enquiry and to discuss whether BGI can take it further.
- To screen before any introduction. Before BGI introduces anyone, it screens the counterparty (the company named in an enquiry and individuals connected with it, such as its directors and its owners as declared to BGI) against sanctions lists, and carries out KYC checks, as described on this website.
- To keep the records BGI must keep, including records of screening decisions, and to meet obligations imposed on BGI by the laws of the United Arab Emirates.
- To establish, exercise or defend legal claims.
BGI does not sell personal data, does not use it for advertising, and does not add you to any mailing list because you sent an enquiry.
BGI does not make decisions about you by solely automated means. Screening software looks for possible name matches on sanctions lists; any possible match is reviewed by a person.
The legal basis
BGI relies on the grounds the PDPL allows for processing personal data:
- taking the steps you ask for in sending an enquiry, before any agreement is entered into;
- complying with obligations imposed on BGI by the laws of the United Arab Emirates, including sanctions obligations where they apply to BGI;
- establishing, exercising or defending legal claims; and
- your consent, for processing not covered by the grounds above, including screening against sanctions lists that UAE law does not itself require BGI to check. You give that consent by sending the form or an email after this notice has been made available to you.
You may withdraw your consent at any time by writing to Admin@BGIBrokers.com. Withdrawal does not affect processing already carried out, and BGI cannot take an enquiry further without the screening described above.
Where the GDPR applies, BGI relies on Article 6(1)(b) to take steps you request before a contract, and on Article 6(1)(f) for its legitimate interests in answering business enquiries, screening counterparties and defending claims. Transfers to the United States rely on the safeguards the service providers offer, such as Standard Contractual Clauses. You may also complain to the data protection authority where you live or work.
Who receives it
BGI shares personal data only as follows:
- Website host. The website is hosted by Netlify, Inc. (United States), which receives the technical information described above when you visit.
- Contact form service. The contact form is processed by Formspree, Inc. (United States). Formspree receives what you submit, together with technical information such as your IP address, stores it in the Formspree account BGI uses for this website, and forwards it to BGI by email.
- Email. Enquiries and correspondence are held in BGI's mailbox by BGI's email service provider.
- Messaging and social channels. If you contact BGI through WhatsApp, Telegram, LinkedIn or Instagram, your messages are carried and stored by the company that operates that service (Meta for WhatsApp and Instagram, Telegram for Telegram, and LinkedIn for LinkedIn), under its own terms and privacy notice. Links to these services on this website are plain links: they load nothing from those services until you click them.
- BGI's team. Enquiries are read by BGI's Managing Director or by a member of BGI's team whom he authorises to handle them. Some members of BGI's team work outside the United Arab Emirates.
- Prospective counterparties: only after screening, only after an NCNDA has been executed, and only as far as the introduction requires. Nothing is disclosed to either side before an NCNDA is executed.
- Professional advisers such as lawyers, auditors and tax advisers, who are bound by a duty of confidentiality.
- Authorities: where BGI is required by law to disclose information, for example to a UAE regulator, court or financial intelligence authority. Where the law requires it, BGI may not be permitted to tell you that such a disclosure has been made.
Netlify, Formspree and the operators of the messaging and social channels each have their own privacy notices, which also apply to what they do.
Transfers outside the United Arab Emirates
Netlify and Formspree are based in the United States, and their services may process data in other countries. The messaging and social channels named above also process data outside the United Arab Emirates. Members of BGI's team may also handle enquiries from outside the United Arab Emirates. Your personal data is therefore transferred outside the United Arab Emirates, including to countries whose data-protection law is not equivalent to the UAE's.
BGI makes these transfers on the grounds the PDPL allows for cross-border transfers: the data-protection commitments the service providers give in their terms, the steps you ask BGI to take in answering your enquiry, and your consent given by sending it.
How long BGI keeps it
BGI's retention policy is:
- An enquiry that does not lead to an introduction or an agreement is deleted from BGI's mailbox, from the contact form service and from BGI's messaging accounts no later than 12 months after the last correspondence about it.
- An enquiry that leads to a relationship is kept while the relationship lasts, and afterwards for as long as BGI needs it to meet its legal, tax and accounting obligations or to deal with a claim.
- Screening and KYC records are kept for at least five years after the relationship ends or after BGI decides not to proceed, or for longer where the law requires. This applies even where the enquiry itself is deleted under the first rule.
- Technical logs kept by the website host, and messages held by the operators of the messaging and social channels, are kept under their own retention periods.
Your rights
Under the PDPL, and subject to the conditions and exceptions it sets out, you have the right:
- to be told what personal data BGI holds about you, why, and who receives it, and to receive a copy;
- to have inaccurate data corrected, and to have data erased when BGI no longer needs it;
- to have processing restricted, or to object to it and ask BGI to stop, in the cases the PDPL provides;
- to receive data you gave BGI in a structured, machine-readable form, and to have it sent to another controller where that is technically feasible;
- to withdraw your consent at any time; and
- to complain to the UAE Data Office.
To exercise any of these rights, write to Admin@BGIBrokers.com. BGI may need to confirm your identity before acting on a request, and will reply without undue delay and in any event within the period the law requires.
Some rights are limited where BGI must keep information to comply with the law (including sanctions and screening records), or where disclosing it would prejudice the prevention or detection of financial crime.
If the data-protection law of another country also applies to you, you may have rights under that law as well. Write to the same address.
Cookies and analytics
This website does not set cookies, uses no analytics or advertising tools and runs no third-party scripts. Its fonts are hosted on the website itself.
When you send a form, it goes directly from this page to Formspree. You stay on this website.
Site search runs in your browser and sends nothing.
If BGI adds cookies or analytics to this website, this notice will be updated before they are used.
Security
The website is served only over an encrypted connection (HTTPS), and BGI limits access to enquiries to the people who need it to handle them. No transmission over the internet and no electronic storage is completely secure, and BGI cannot guarantee the security of information sent to it.
If a breach of security affects your personal data in a way the PDPL requires BGI to report, BGI will notify the UAE Data Office and, where the law requires, you.
Children
This website is intended for businesses. It is not directed at children, and BGI does not knowingly collect personal data from anyone under 18.
Changes to this notice
BGI may update this notice, for example if it changes the service providers named above. The version published on this page is the one that applies.
This notice is effective from the date of its publication on this website.
If this notice is published in another language, the English version prevails.