The Site www.neutralfuels.com (the “Site”) is owned and operated by Neutral Fuels LLC (“Neutral Fuels”, “we”, “us”, or “our”). This privacy policy (the “Privacy Policy”) sets out the basis on which we collect and use any personal data we collect from customers, visitors, and users of the Site (“you” or “your”), or that you provide to us.

Please read this Privacy Policy carefully. By accessing and continuing to use this Site, you confirm that you have read, understood, and agree to be bound by this Privacy Policy in its entirety and that you give us your consent to collect and process your personal data as set out in this Privacy Policy. If you do not accept the terms of this Privacy Policy, then you must stop using or accessing this Site.

For the purposes of applicable data protection law (including the UAE Federal Decree-law No 45 of 2021 on Personal Data Protection), “personal data” is any information that relates to you, and which, alone or in combination with other information, could reasonably be used to identify you such as your name, voice, picture, identification number, electronic identifier, geographical location, or physical, physiological, economic, cultural, or social characteristics. Neutral Fuels is the data “controller” of any personal data provided to us. Specifically, your data will be controlled by Neutral Fuels.

The Privacy Policy describes how we use and process your personal data. It also tells you how you can contact us if you have questions about your personal data. Neutral Fuels may amend the Privacy Policy from time to time, so you should check this page from time to time to ensure that you are aware of any changes that have been made.

Neutral Fuels respects your right to privacy and are committed to responsible information handling practices. We value your trust, and we are committed to protecting and safeguarding any personal information you give us.

What Kind of Data Does the Site Use?

‍When you fill out our form online, you’ll be asked for your name, email address and telephone number. By accessing the Site, you consent to the collection, use and storage of this personal data as set out herein.

When you visit our website, Neutral Fuels may also collect certain information, like your IP address, or browser, and information about your computer’s operating system, application version, language settings and pages that have been shown to you. As typical of other websites, Neutral Fuels may passively collect information regarding country and time of access through use of Google Analytics. This information is not stored, and no personal data (such as your name) is collected. The service providers that administer these services use technologies such as cookies to help analyse how visitors use our site. The information collected through these means (including IP address) is disclosed to or collected directly by these service providers, who use the information to evaluate the use of the website or to provide interest-based advertising to you. This Privacy Policy should be read in conjunction with our Cookies Policy.

If you’re using a mobile device, Neutral Fuels might also collect data that identifies your mobile device, device-specific settings and characteristics and latitude/longitude details. Neutral Fuels treats this data as non-personal information, except where Neutral Fuels are compelled to do otherwise by law or legal authority.

Neutral Fuels may also receive information about you when you use certain social media services.

Neutral Fuels may link to other websites which are not within our control. Once you have left the Site, Neutral Fuels are not responsible for the protection and privacy of any data which you provide. You should exercise caution and look at the privacy statement applicable to the third party’s website in question.

Processing Your Personal Data

Neutral Fuels uses your personal data to provide you with a better service, and in particular for the following reasons:
    · to provide you with services you have requested and notify you about important changes or developments to these services;
    · to respond to your inquiries and/or complaints or process your requests in relation to your data;
    · to follow up as part of our customer care procedures;
    · to update our records about you;
    · for internal record keeping;
    · to contact you for market research purposes and/or administer offers to you;
    · to improve our products and services;
    · for fraud prevention and detection, and to comply with applicable laws and regulations;
    · in relation to competitions and other promotions;
    · to evaluate the effectiveness of our marketing and for research, training, and statistical analysis with the aim of improving our services; and
    · to make our Site easier for you to use and to provide you with access to certain parts of the Site.                                                                                  

Neutral Fuels processes your personal data for the purposes outlined above where:
    · The processing of your personal data is necessary to perform a contract or enter into a contract with you;
    · The processing of your personal data is necessary for us to comply with legal and regulatory obligations;or
    · The processing is necessary to support our legitimate interests in managing our business (or those of a third party) provided such interests are not overridden by your interests and rights.

Where required by applicable law, where Neutral Fuels sends you direct marketing, we will obtain your consent for this, which you may withdraw at any time.

Sharing Your Personal Data

‍Neutral Fuels may disclose your personal data to the following third parties:
    · Other companies in our group of companies;
    · Selected third parties to provide us with services, including companies that provide us with technical support and assistance in respect of the Site, companies that provide back-office services, companies that provide hosting services, or that track the Site’s activities and analytics, and companies engaged to market and distribute our products and/or services;
    · Professional advisers, judicial, regulatory and law enforcement bodies; and
    · In any other case with your consent.

We may also share your personal data with third parties if we sell or buy any business or assets, in which case we may disclose personal data to the prospective seller or buyer of such business or assets, along with its professional advisers. If Neutral Fuels, or substantially all of its assets, are acquired by a third party, personal data held by us about customers will be one of the transferred assets.

Otherwise, no third parties will have access to your personal data unless there is a legal obligation, or you give us permission to do so.

‍Cross-Border Transfer of Your Data

‍We may instruct service providers, domestically or in a foreign country, to process your personal data on our behalf and in accordance with our instructions. We will retain control over your personal data and will remain fully responsible to you when engaging service providers.

The level of personal data protection in the other jurisdictions may not provide an adequate level of protection from a UAE perspective. To address this, we have procedures and safeguards in place to ensure the protection of personal information. These procedures include contractual obligations to ensure that all such entities safeguard your personal information and use it only for the purposes that we have specified and communicated to you. When we transfer your information to other countries, we will use, share, and safeguard that information as described in this Privacy Policy.

‍Data Security and Retention

‍Neutral Fuels are required to ensure that your personal data is accurate and maintained in a secure environment for a period of time no longer than necessary for the purposes for which we are processing your personal data. We will take all steps that are reasonably necessary to ensure that your personal data is treated securely and in accordance with this Privacy Policy and applicable data protection laws.

Neutral Fuels generally keep personal data collected via the Site in accordance with the timeframes set out in any relevant legislation which applies to the personal data provided to us. However, in some cases Neutral Fuels may need to keep personal data for longer (e.g., where Neutral Fuels are required to do so in accordance with legal, regulatory, tax or accounting requirements, or dealing with complaints, legal challenges, or prospective litigation).

Accessing Your Personal Information

‍Various rights may be available to you, depending on the circumstances and the applicable law. We summarise key rights likely to be available to most data subjects:
‍
    · You may request information on the personal data held by us relating to you and the manner in which we have been processing your personal data, including information such as the categories of the data held, the purpose of the processing, controls and standards of the storage/archiving of the data, the safeguards put in place for cross-border processing and any actions taken regarding a breach that is a threat to the privacy and confidentiality of your personal data.

    · You have the right to request inaccurate personal data is corrected.  

    · You have the right to restrict or stop processing of personal data if you contest the accuracy of the data, or where the processing is contrary to the purposes for which the data was given, or it contravenes the law.

    · You have the right to request that personal data is erased if it is no longer necessary for the purposes it was collected, you have withdrawn your consent to the processing, there are no legitimate grounds to continue processing, or the processing does not comply with the law. This is subject to any rights Neutral Fuels may have to retain the information under the law.

    · You can request that we cease processing personal data where it has been processed for direct marketing purposes, statistical survey purposes or been processed in contravention of the provisions of the law. This is subject to any rights Neutral Fuels Group may have to retain the information under the law.

For Neutral Fuels Group to proceed with a request to amend, correct, erase, restrict or stop the processing of personal data (“Subject Access Request”), you will need to provide proof of your identity, unless we already hold the same. Proof of identity should be an official document containing your photograph such as a driving license, passport, or residency card. Proof of Identity Information will not be retained and will be used for the sole purpose of identity identification.

Your Subject Access Request will be processed within 30 calendar days upon receipt your request and a proof of identity, where necessary. Copies of the personal data held by Neutral Fuels will be provided on an encrypted (password protected) file sent securely. To make a Subject Access Request please email subjectaccessrequest@neutralfuels.com with the following information:
‍
    · First and last name as per your passport
    · Email address
    · Your relationship to Neutral Fuels (for example, customer, supplier, or other relationship)
    · Your reason for accessing the personal data (for example, access, rectification, or deletion)

‍If you are not satisfied with our response or believe we are processing your personal data not in accordance with the law, you can complain to the competent data protection supervisory authority in UAE.

‍Confidentiality

‍The information you provide may be confidential, and we will maintain such confidentiality and protect your information in accordance with this Privacy Policy, our professional obligations and applicable law. We do not sell, rent, distribute, or otherwise make, personal data commercially available to any third party. We may share information with our service providers for the purpose set out in this Privacy Policy.

For any questions, please email us at info@neutralfuels.com. Updated 2023.