PRIVACY POLICY
Effective Date: 15 September 2026
1. Introduction
Foxtrane Energy FZE LLC (“Foxtrane”, “we”, “us” or “our”) respects the privacy and confidentiality of individuals who interact with our business, website and digital services.
Foxtrane Energy FZE LLC is a Free Zone Entity incorporated in Ajman, United Arab Emirates, under Licence and Registration No. 2626817367888, with its registered address at:
CWS-2V-227767
26th Floor, Amber Gem Tower
Ajman, United Arab Emirates
Where Foxtrane determines the purposes and means of processing personal information collected through this website or related Foxtrane business channels, Foxtrane Energy FZE LLC acts as the data controller.
This Privacy Policy explains the personal information we may collect, how and why it may be processed, how it may be disclosed and retained, and the rights available to individuals under applicable law.
Foxtrane processes personal information in accordance with applicable data-protection and privacy laws.
2. Scope
This Privacy Policy applies to personal information processed in connection with:
• the Foxtrane website;
• contact and enquiry forms;
• requests for quotation (“RFQs”);
• client, supplier and vendor communications;
• procurement and project-support activities;
• supplier and counterparty verification;
• business-development communications;
• documents and files submitted to Foxtrane;
• authorised Foxtrane email and digital communication channels; and
• other business interactions where Foxtrane determines the purposes and means of processing personal information.
Separate contractual privacy, confidentiality or data-protection provisions may apply to specific clients, suppliers, projects or transactions.
3. Personal Information We May Collect
Depending on the nature of your interaction with Foxtrane, we may collect the following categories of information.
Identity and contact information may include names, business contact details, email addresses, telephone numbers, job titles, company information and, where required for an appropriate business, contractual, compliance or legal purpose, nationality or identification information.
Business and professional information may include employer information, professional roles, correspondence, RFQs, quotations, purchase-order information, supplier records and other business documentation.
Procurement and project information may include technical requirements, product specifications, delivery information, project documentation and information provided in connection with proposed or existing transactions.
Supplier and counterparty information may include corporate-registration records, ownership information, beneficial-ownership information, authorised-representative information, identification documents, business credentials and information relevant to sanctions or restricted-party verification.
Where necessary and permitted by applicable law, compliance or due-diligence activities may involve information receiving additional legal protection, including information relating to alleged or actual offences or criminal records.
Technical and website information may include IP addresses, browser and device information, operating-system information, security information, website activity, referral information and cookie or similar technology identifiers.
Submitted documents may include documents and files voluntarily provided through the website or other authorised Foxtrane business channels.
Foxtrane seeks to limit the collection of personal information to information reasonably relevant to the purpose for which it is collected.
4. How We May Use Personal Information
Foxtrane may process personal information to:
• respond to enquiries and RFQs;
• prepare quotations and commercial proposals;
• communicate with clients, suppliers and business partners;
• evaluate prospective suppliers and counterparties;
• undertake verification, compliance or due-diligence activities where appropriate;
• perform sanctions or restricted-party verification where appropriate;
• procure and supply equipment, materials and services;
• manage projects, logistics and deliveries;
• establish and administer commercial relationships;
• maintain procurement and transaction records;
• protect against fraud, impersonation and cybersecurity threats;
• operate, maintain and improve the website and related digital systems;
• comply with applicable legal, regulatory, tax, accounting and contractual requirements;
• establish, exercise or defend legal claims; and
• maintain appropriate corporate and business records.
Foxtrane does not materially repurpose personal information in a manner incompatible with the purpose for which it was collected unless permitted by applicable law.
5. Basis for Processing
Where applicable law requires a lawful basis for processing personal information, Foxtrane relies on a processing ground available under that law.
Depending on the circumstances, this may include:
• consent;
• taking steps at an individual’s request before entering into a contract;
• entering into or performing a contract;
• compliance with applicable legal or regulatory obligations;
• protection of interests or fulfilment of purposes expressly recognised by applicable law; or
• another processing ground permitted under applicable law.
Where processing relies upon consent, consent may be withdrawn in accordance with applicable law. Withdrawal does not affect processing lawfully undertaken before withdrawal.
6. Supplier and Counterparty Verification
In connection with certain procurement, sourcing and project-support activities, Foxtrane may collect and process information for supplier, contractor, client and counterparty verification and due-diligence purposes.
Depending on the nature of the proposed relationship and applicable requirements, this information may include:
• corporate-registration information;
• ownership and beneficial-ownership information;
• authorised-representative information;
• business credentials;
• identification information;
• sanctions or restricted-party information; and
• other information relevant to the proposed transaction or applicable compliance requirements.
Such information is processed only for appropriate business, contractual, compliance, risk-management or legal purposes and subject to applicable law.
7. Sharing Personal Information
Where reasonably necessary for the relevant purpose, Foxtrane may disclose personal information to:
• related entities involved in the relevant activity;
• clients, manufacturers, suppliers and subcontractors;
• logistics, freight, customs and project-support providers;
• banks, insurers and financial institutions;
• technology, cloud, cybersecurity, hosting and communications providers;
• compliance and due-diligence providers;
• auditors, accountants, lawyers and other professional advisers; and
• courts, regulators, government authorities or law-enforcement bodies where required or permitted by law.
Foxtrane does not sell personal information.
Foxtrane may use third-party service providers in connection with its website, communications and business operations. Where those providers process personal information, their handling of that information is subject to applicable contractual arrangements and legal requirements.
8. International Data Transfers
Foxtrane operates within international supply chains and may interact with clients, manufacturers, suppliers and service providers across multiple jurisdictions.
Personal information may therefore be transferred to, accessed from or processed in jurisdictions outside the country in which it was originally collected.
Where applicable law imposes requirements relating to international transfers of personal information, Foxtrane handles such transfers in accordance with those requirements.
9. Information Security
Foxtrane takes reasonable measures designed to protect personal information against unauthorised access, disclosure, alteration, misuse, loss or destruction.
Security measures are applied having regard to the nature of the information, the systems involved and applicable legal requirements.
No internet transmission, electronic communication or electronic-storage system can be guaranteed to be completely secure.
10. Data Retention
Foxtrane retains personal information only for as long as reasonably necessary for the purpose for which it was collected and for applicable legal, regulatory, contractual, accounting, tax, compliance or dispute-resolution requirements.
Different categories of information may therefore be retained for different periods.
Where personal information is no longer required, Foxtrane takes reasonable steps to delete, anonymise or securely dispose of it, subject to applicable requirements.
11. Cookies and Similar Technologies
The Foxtrane website may use cookies and similar technologies for website functionality, security and performance.
Information concerning cookies or similar technologies actually deployed on the website, together with any choices required by applicable law, is presented through relevant website controls where applicable.
Users may also manage certain cookie settings through their browser.
12. Marketing Communications
Where permitted by applicable law, Foxtrane may send business updates or information concerning its services to relevant business contacts.
Recipients may opt out of marketing communications at any time by using an unsubscribe mechanism provided in the communication, where available, or by contacting Foxtrane.
Opting out of marketing communications does not prevent Foxtrane from sending necessary transactional, contractual, procurement, security or service-related communications.
13. Your Rights
Depending on applicable law and the circumstances of processing, individuals may have rights to:
• obtain information concerning the processing of their personal information;
• request access to personal information held about them;
• request correction of inaccurate or incomplete information;
• request deletion where legally available;
• request restriction or cessation of certain processing where applicable;
• object to particular processing where applicable;
• request transfer or portability of information where applicable;
• withdraw consent where processing depends upon consent; and
• submit a complaint to the competent data-protection or regulatory authority where such a right is available.
These rights may be subject to limitations, exemptions and identity-verification requirements under applicable law.
14. Third-Party Websites
The Foxtrane website may contain links to websites operated by manufacturers, suppliers, clients or other third parties.
Foxtrane does not control third-party websites and is not responsible for their content, security, privacy practices or processing of personal information.
15. Changes to This Privacy Policy
Foxtrane may update this Privacy Policy to reflect changes in applicable law, technology, website functionality or business operations.
The current version will be published on the Foxtrane website with its effective or revision date.
16. Contact
Data Controller
Foxtrane Energy FZE LLC
Licence/Registration No. 2626817367888
CWS-2V-227767
26th Floor, Amber Gem Tower
Ajman, United Arab Emirates
Privacy enquiries: privacy@foxtrane.com