LEGAL

Privacy Policy

Last updated: 25 June 2026  ·  Data controller: Sailwind Trading, IFZA, Dubai Silicon Oasis, Dubai, UAE  ·  Contact: [email protected]

1. Introduction

Sailwind Trading ("Sailwind Trading", "we", "us", or "our") is committed to protecting the personal data of everyone who visits our website or engages with us. This Privacy Policy describes how we collect, use, store, and disclose personal data in connection with our website at sailwindtrading.com and our business communications.

This policy applies to personal data we collect directly from you via the Website. It does not cover data collected through commercial contracts or trade transactions with counterparties, which are governed by separate agreements.

2. Data Controller

The data controller for personal data collected through this Website is:

3. Personal Data We Collect

We collect personal data only to the extent necessary for the purposes described in this policy. The data we may collect includes:

Data you provide to us

  • Contact enquiries: If you contact us by email or phone, we receive your name, email address, phone number, company name, and the content of your message.

Data collected automatically

  • Usage data: Standard server log data such as your IP address, browser type, pages visited, and timestamps, collected for security and operational purposes.
  • Cookies: We use limited cookies as described in Section 9 below.

We do not knowingly collect personal data from individuals under 18 years of age.

4. How We Use Your Data

We use the personal data we collect for the following purposes:

  • To respond to your enquiries and communicate with you about potential business opportunities;
  • To manage and improve the Website and our online presence;
  • To comply with applicable legal and regulatory obligations;
  • To protect the security and integrity of our systems;
  • To conduct KYC (Know Your Customer) and due diligence checks where we enter into or consider a commercial relationship with you.

We do not use your personal data for automated decision-making or profiling, and we do not sell or rent your data to third parties.

5. Legal Basis for Processing

Where applicable data protection laws require us to identify a legal basis for processing your personal data, we rely on:

  • Legitimate interests: To respond to business enquiries, maintain Website security, and conduct basic analytics — where these interests are not overridden by your rights.
  • Legal obligation: Where we are required to process data to comply with applicable laws and regulations, including AML, sanctions, and trade compliance requirements.
  • Consent: Where you have expressly consented to specific processing activities (e.g., optional communications).
  • Contractual necessity: Where processing is necessary to perform a contract with you or to take pre-contractual steps at your request.

6. Sharing of Data

We do not sell, trade, or rent your personal data to third parties. We may share data in the following limited circumstances:

  • Service providers: Trusted third-party service providers (such as website hosting, IT support, or email services) who process data on our behalf and are contractually required to keep it confidential.
  • Legal requirements: Where we are required by law, court order, or regulatory authority to disclose your data.
  • Compliance screening: Where required by applicable sanctions, anti-money laundering, or trade compliance regulations, we may need to verify your identity with authorised screening services.
  • Business transfer: In the event of a merger, acquisition, or sale of all or a portion of our business, your data may be transferred as part of that transaction.

7. Data Retention

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by law. In practice:

  • Contact enquiry data is retained for up to 3 years from the date of last contact, unless a business relationship ensues, in which case longer retention may apply.
  • Server log data is typically retained for up to 90 days.
  • Data held for compliance and regulatory purposes may be retained for up to 6 years in accordance with UAE AML regulations.

When data is no longer needed, it is securely deleted or anonymised.

8. Your Rights

Depending on your location and applicable laws (including the UAE Personal Data Protection Law and, where applicable, the EU GDPR), you may have the following rights regarding your personal data:

  • Access: The right to request a copy of the personal data we hold about you.
  • Rectification: The right to request correction of inaccurate or incomplete data.
  • Erasure: The right to request deletion of your data, subject to legal retention obligations.
  • Restriction: The right to request that we restrict processing of your data in certain circumstances.
  • Objection: The right to object to processing based on legitimate interests.
  • Portability: The right to receive your data in a structured, commonly used format where technically feasible.

To exercise any of these rights, please contact us at [email protected]. We will respond within 30 days. We may need to verify your identity before processing your request.

9. Cookies & Analytics

This Website uses minimal cookies. Cookies are small text files stored on your device that help the Website function and improve user experience.

Strictly necessary cookies

These are essential for the Website to function and cannot be switched off. They do not store personally identifiable information.

Third-party services

We embed Google Maps on our contact page. Google may set cookies or collect data about your visit as a result. Please refer to Google's Privacy Policy for details. We use Google Fonts and Font Awesome via CDN, which may log requests but do not place tracking cookies.

We currently do not use any analytics or advertising tracking tools beyond server-level access logs.

10. Data Security

We implement appropriate technical and organisational measures to protect personal data against unauthorised access, loss, disclosure, or destruction. These measures include secure hosting, access controls, and encrypted communications where applicable.

While we take data security seriously, no method of transmission over the internet or electronic storage is completely secure. We cannot guarantee absolute security, but we commit to notifying affected individuals and authorities in the event of a data breach where required by law.

11. International Data Transfers

As an international commodity trading company based in Dubai, UAE, data we collect may be accessed by team members or service providers in other countries. When we transfer data internationally, we ensure appropriate safeguards are in place in accordance with applicable data protection laws.

12. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. When we do, we will update the "Last updated" date at the top of this page. We encourage you to review this policy periodically.

Continued use of the Website following any changes constitutes your acceptance of the updated policy.

13. Contact Us

If you have questions about this Privacy Policy or wish to exercise your data rights, please contact us:

You also have the right to lodge a complaint with the relevant data protection supervisory authority in your jurisdiction.