PETROLODEX

1. Who We Are

Petrolodex operates as a business-to-business (B2B) petroleum trade facilitation platform. Our clients and counterparties are predominantly commercial entities, institutional buyers, licensed traders, and industry professionals. We do not knowingly collect personal information from minors or members of the general public who are unrelated to commercial petroleum trade.

2. Information We Collect

We collect information necessary to operate our Website, provide our Services, evaluate trade inquiries, and comply with applicable legal and regulatory obligations. The categories of information we collect include:

2.1 Information You Provide Directly

• Full legal name and job title
• Company name and registered business address
• Business email address and telephone number
• Nature of the trade inquiry (product type, quantity, delivery terms, destination)
• Country of operation and regulatory jurisdiction
• Any documentation submitted as part of a buyer verification or trade facilitation process, including Irrevocable Corporate Purchase Orders (ICPOs), Letters of Intent (LOIs), and related trade instruments
• Communications submitted through our contact forms, email, or inquiry portals

2.2 Information Collected Automatically

When you visit or interact with our Website, we and our third-party service providers may automatically collect:

• IP address and approximate geographic location
• Browser type, version, and device operating system
• Pages viewed, links clicked, and time spent on each page
• Referring URL or source
• Session identifiers and cookies (see Section 7 for full details)
• Technical performance data related to page load times and errors

2.3 Information from Third Parties

In the course of trade facilitation and counterparty due diligence, we may receive information about you or your organization from:

• Business partners, intermediaries, and brokers who introduce you to Petrolodex
• Publicly available corporate registries, trade directories, and regulatory databases
• Sanctions screening and compliance service providers
• Credit and trade reference agencies

3. How We Use Your Information

We use the information we collect for the following purposes:

3.1 Service Delivery and Trade Facilitation

• To evaluate, process, and respond to trade inquiries, purchase orders, and requests for proposals
• To verify the identity, authority, and eligibility of potential buyers, sellers, and intermediaries
• To coordinate transaction workflows including ICPO processing, SPA execution, PPOP documentation, NCNDA/IMFPA execution, physical inspection arrangements, and MT103 payment coordination
• To deliver procedural documents, offer sheets, and product specifications to qualified counterparties

3.2 Legal and Regulatory Compliance

• To comply with anti-money laundering (AML) and know-your-customer (KYC) obligations under applicable UAE law and international standards
• To screen against sanctions lists maintained by OFAC, the United Nations, the European Union, OFSI, and other relevant regulatory authorities
• To comply with applicable export control regulations, trade sanctions, and commodity trade laws
• To fulfill reporting obligations to regulatory and governmental authorities as required by law
• To maintain records required under UAE commercial and financial regulations

3.3 Website Operation and Improvement

• To operate, maintain, and improve the Website and its features
• To diagnose technical issues and ensure Website security and performance
• To analyze usage trends and understand how visitors interact with the Website
• To prevent fraudulent, abusive, or unauthorized activity

3.4 Communications

• To respond to your inquiries, questions, and communications
• To send you trade procedure updates, product availability notices, and relevant market information where you have expressed interest or given consent
• To notify you of material changes to this Privacy Policy or our Terms of Use

3.5 Legal Defense and Dispute Resolution

• To establish, exercise, or defend legal claims arising in connection with trade transactions or Website use

4. Legal Basis for Processing Personal Data

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

• Contractual necessity: Processing required to enter into or perform a contract with you or your organization, including the execution of trade agreements and facilitation services.
• Legal obligation: Processing required to comply with applicable UAE law, international trade regulations, AML and KYC requirements, and sanctions screening obligations.
• Legitimate interests: Processing necessary for our legitimate business interests, including Website security, fraud prevention, improving our Services, and maintaining business records, provided such interests are not overridden by your rights.
• Consent: Where we rely on consent (such as for certain marketing communications), you may withdraw consent at any time by contacting us at info@petrolodex.com.

5. Disclosure and Sharing of Information

We do not sell, rent, or trade your personal information to third parties for marketing or commercial purposes. We may share your information in the following circumstances:

5.1 Trade Counterparties and Intermediaries

In the course of facilitating a petroleum transaction, we may share relevant information with counterparties, licensed brokers, mandates, or intermediaries who are party to the same transaction. Such sharing is subject to appropriate confidentiality obligations, including Non-Circumvention, Non-Disclosure, and Fee Protection Agreements (NCNDAs) where applicable.

5.2 Service Providers and Processors

We engage third-party service providers who process information on our behalf to support our operations, including:

• Website hosting and cloud infrastructure providers
• Email communication and CRM platforms
• Compliance, KYC, and sanctions screening service providers
• Legal and professional advisors bound by confidentiality obligations

All third-party processors are subject to data processing agreements and are required to implement appropriate security measures.

5.3 Legal and Regulatory Disclosure

We may disclose information where required or permitted by law, including:

• To comply with a valid legal process, subpoena, court order, or government request
• To comply with sanctions screening obligations and report to relevant regulatory authorities
• To prevent or investigate fraud, security breaches, or violations of our Terms of Use
• To protect the rights, property, or safety of Petrolodex, its personnel, counterparties, or the public

5.4 Corporate Transactions

If Petrolodex undergoes a merger, acquisition, restructuring, or sale of assets, your information may be transferred as part of such a transaction. We will notify you via the email address on record or through a prominent notice on our Website in the event of such a transaction.

6. International Data Transfers

Petrolodex operates globally, and your information may be transferred to, stored in, or accessed from jurisdictions outside your country of residence, including the United Arab Emirates and other countries where our service providers operate. These jurisdictions may have data protection laws that differ from those in your country.

Where we transfer personal data internationally, we take appropriate steps to ensure that such transfers are conducted in compliance with applicable legal requirements and that adequate protections are in place, including standard contractual clauses, binding corporate rules, or equivalent safeguards as appropriate.

7. Cookies and Tracking Technologies

Our Website uses cookies and similar technologies to support functionality, analyze usage, and improve your experience. A cookie is a small data file placed on your device when you visit a website.

7.1 Types of Cookies We Use

• Strictly Necessary Cookies: Required for the Website to function properly, including session management and security. These cannot be disabled.
• Analytics and Performance Cookies: Used to understand how visitors interact with the Website, including pages visited and time spent. Data collected is aggregated and anonymous.
• Functional Cookies: Enable enhanced functionality, such as remembering preferences and form data between sessions.

7.2 Managing Cookies

You may control or disable non-essential cookies through your browser settings or any cookie preference center available on the Website. Please note that disabling certain cookies may limit the functionality of the Website. For more information about cookies and how to manage them, visit www.allaboutcookies.org.

8. Data Retention

We retain personal information for as long as necessary to fulfill the purposes for which it was collected, including to satisfy legal, regulatory, accounting, and reporting obligations. Specific retention periods include:

• Trade inquiry and transaction records: Retained for a minimum of seven (7) years following the conclusion of the transaction or inquiry, consistent with UAE commercial and regulatory record-keeping requirements.
• KYC and compliance documentation: Retained for the period required by applicable AML and regulatory obligations, typically a minimum of five (5) years following the end of the business relationship.
• Website usage and analytics data: Retained for up to twenty-four (24) months in aggregated or anonymized form.
• General correspondence: Retained for up to three (3) years unless a longer period is required for legal purposes.

When information is no longer required, we securely delete or anonymize it in accordance with applicable laws and our internal data governance procedures.

9. Data Security

We implement administrative, technical, and physical safeguards designed to protect personal information from unauthorized access, use, disclosure, alteration, or destruction. These measures include:

• Encryption of data in transit using industry-standard TLS protocols
• Access controls limiting information access to authorized personnel on a need-to-know basis
• Secure document handling procedures for trade instruments and KYC documentation
• Regular review of our information security practices and controls

While we take reasonable steps to protect your information, no method of electronic transmission or storage is completely secure. We cannot guarantee absolute security. If you have reason to believe that a security incident has occurred, please contact us immediately at info@petrolodex.com.

10. Your Privacy Rights

Depending on your country or jurisdiction of residence, you may have the following rights with respect to your personal information:

• Right of Access: The right to request a copy of the personal information we hold about you.
• Right to Rectification: The right to request correction of inaccurate or incomplete personal information.
• Right to Erasure: The right to request deletion of your personal information, subject to our legal retention obligations and legitimate business interests.
• Right to Restriction: The right to request that we limit the processing of your personal information in certain circumstances.
• Right to Data Portability: The right to receive your personal information in a structured, machine-readable format where technically feasible.
• Right to Object: The right to object to processing based on our legitimate interests, including for direct marketing purposes.
• Right to Withdraw Consent: Where processing is based on consent, the right to withdraw consent at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, please submit a written request to info@petrolodex.com. We will respond to your request within a reasonable period and in accordance with applicable law. We may ask you to verify your identity before processing your request. Please note that some rights may be limited where we have overriding legitimate interests or legal obligations that require us to retain or continue processing information.

11. Third-Party Links and External Services

Our Website may contain links to third-party websites, platforms, and resources. These links are provided for your convenience and do not constitute an endorsement of the content or practices of those third parties. Petrolodex is not responsible for the privacy practices or content of any third-party website. We encourage you to review the privacy policies of any third-party sites you visit.

12. Business Contact Information and B2B Context

Because Petrolodex operates exclusively in the business-to-business context, much of the information we process relates to individuals acting in their capacity as business representatives rather than as private consumers. We process this information to carry out legitimate commercial petroleum trade facilitation activities. Where business contact information is obtained from publicly available sources or through legitimate industry channels, we treat such information with the same standards of care described in this Privacy Policy.

13. Human Rights Commitment

Petrolodex is committed to responsible and ethical business practices. We acknowledge that responsible information handling is an element of our broader commitment to human rights, dignity, and transparency in international trade. We do not use personal information in ways that would facilitate unlawful discrimination, surveillance, or harm to individuals. Our Human Rights Assessment Responses, available on our Website, provide additional detail regarding our approach to responsible trade practices.

14. Changes to This Privacy Policy

We reserve the right to update or modify this Privacy Policy at any time. When we make material changes, we will revise the "Last Updated" date at the top of this document and, where appropriate, notify affected parties via email or a prominent notice on the Website. Your continued use of the Website or Services following the posting of changes constitutes your acceptance of the revised Privacy Policy. We encourage you to review this Privacy Policy periodically.

15. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

We aim to respond to all privacy-related inquiries within ten (10) business days. If you believe your privacy rights have been violated and you are located in a jurisdiction with a data protection supervisory authority, you have the right to lodge a complaint with that authority.