PRIVACY

Privacy Policy

UCT Consulting and Trading FZCO

Last updated: 25 August 2026

This Privacy Policy explains how UCT Consulting and Trading FZCO (“UCT”, “we”, “us” or “our”) processes personal data when you visit uct.solutions, contact us through the website or otherwise communicate with us in connection with our business-development services.

This Privacy Policy is intended to reflect the requirements of applicable data-protection laws, including the United Arab Emirates Federal Decree-Law No. 45 of 2021 concerning the Protection of Personal Data and, where applicable, the General Data Protection Regulation (EU) 2016/679 (“GDPR”).

1. Data Controller

The controller responsible for the processing described in this Privacy Policy is:

UCT Consulting and Trading FZCO
IFZA Properties
Dubai Silicon Oasis
Dubai, United Arab Emirates

Trade Licence No.: 20190

Managing Director: Ernst Ullmann

Email: info@uct.solutions
Phone: +971 52 195 7991

2. EU Representative

UCT Consulting and Trading FZCO is established in the United Arab Emirates and actively addresses business opportunities in European markets, including Germany.

Where Article 27 GDPR requires the appointment of a representative in the European Union, that representative must be established in an EU Member State in which relevant data subjects are located.

EU Representative:

Eugen Ullmann, Betzgerstr 4, 73733 Esslingen, Germany

info@uct.solutions

The representative must be formally appointed in writing and must be available to data subjects and supervisory authorities regarding processing covered by the GDPR.

3. Personal Data We Process

Depending on how you use the website, we may process the following categories of personal data.

3.1 Information submitted through the contact form

  • The current contact form may collect:

    • Name
    • Company
    • Email address
    • Phone number
    • Target region
    • Product / Technology information
    • Message content
    • Any other information you voluntarily include in your message

    You are not required to provide information beyond what is reasonably necessary for us to handle your enquiry.

3.2 Technical website and server data

When you access the website, technical information may be processed automatically, including:

  • IP address
  • Date and time of access
  • Requested page or file
  • Referring URL
  • Browser type and version
  • Operating system
  • Device and technical connection information
  • HTTP status and error information
  • Amount of transmitted data

This information is required in part to deliver and secure the website.

3.3 Consent information

Our consent-management system may store information concerning your privacy choices, such as whether you have accepted or rejected Analytics or Marketing technologies.

This information is used to remember and respect your consent choices.

3.4 Analytics data

If you consent to Analytics technologies, Google Analytics may process information concerning your use of the website, such as:

  • Pages viewed
  • Approximate location information derived from technical information
  • Device and browser information
  • Referral information
  • Interaction and event information
  • Session and usage information
  • Consent and technical identifiers

Google states that IP addresses are not logged or stored in Google Analytics 4.

3.5 LinkedIn marketing and measurement data

If you consent to Marketing technologies, the LinkedIn Insight Tag may process information including:

  • Page URL
  • Referrer URL
  • IP address
  • Device and browser characteristics
  • User Agent
  • Timestamp
  • Cookie and pseudonymous identifier information
  • Information relating to website interactions and campaign measurement

We do not intend to enable LinkedIn Enhanced Matching or transmit contact-form email addresses to LinkedIn unless this Privacy Policy and the technical configuration are expressly updated beforehand.

4. Purposes and Legal Bases

We process personal data only where there is an appropriate purpose and legal basis.

4.1 Responding to business enquiries

We process contact-form and email information to:

  • respond to enquiries;
  • provide requested information;
  • assess possible cooperation;
  • communicate about potential projects;
  • prepare possible contractual relationships; and
  • maintain necessary business correspondence.

For persons covered by the GDPR, the legal basis is:

  • Article 6(1)(b) GDPR where processing is necessary to take steps at your request before entering into a contract or for an existing contractual relationship; or
  • Article 6(1)(f) GDPR where processing is necessary for our legitimate interests in responding to professional enquiries, maintaining business communications and developing business relationships.

Under UAE law, processing may also be permitted where necessary to take steps requested by the data subject to enter into, amend or perform a contract.

4.2 Website operation and security

Technical data is processed to:

  • provide the website;
  • maintain technical stability;
  • prevent misuse and attacks;
  • diagnose errors;
  • secure our systems; and
  • maintain appropriate technical records.

For processing subject to the GDPR, the legal basis is Article 6(1)(f) GDPR. Our legitimate interest is the secure, reliable and efficient operation of our website.

4.3 Analytics

Google Analytics is used only where the visitor has consented to the Analytics category through our consent banner.

The purposes are to:

  • understand website usage;
  • measure website performance;
  • understand which content is useful to visitors; and
  • improve our website and communication.

For processing subject to the GDPR, the legal basis is Article 6(1)(a) GDPR — consent.

Where access to or storage of information on the visitor’s device requires consent under applicable electronic-communications or cookie law, such processing takes place only after the required consent has been obtained.

Consent can be withdrawn at any time through Manage consent / Cookie preferences.

4.4 LinkedIn Insight Tag

The LinkedIn Insight Tag is used only where the visitor has consented to the Marketing category.

The purposes may include:

  • measuring the effectiveness of LinkedIn campaigns;
  • conversion measurement;
  • understanding interactions with our campaigns;
  • website audience measurement;
  • aggregated audience insights; and
  • retargeting where enabled.

For processing subject to the GDPR, the legal basis is Article 6(1)(a) GDPR — consent.

The LinkedIn Insight Tag must remain blocked until Marketing consent has been provided.

Consent may be withdrawn at any time through the website’s consent-management controls.

5. Contact Form – Fluent Forms

The website uses Fluent Forms as its WordPress contact-form system.

When you submit the form, the information you provide is processed for the purpose of transmitting your enquiry to UCT.

Our current configuration is set to:

Delete entry data after form submission.

Accordingly, the submitted contact-form entry is not intended to remain stored in the Fluent Forms submission database after the form has been successfully processed.

The enquiry is transmitted to UCT by email.

This means that the content may continue to exist in the resulting business email correspondence even though the Fluent Forms database entry has been deleted.

6. Email Processing

Website enquiries are delivered to and handled through our email account hosted by:

ALL-INKL.COM – Neue Medien Münnich

We process emails for the purposes of answering enquiries, managing business communications, documenting relevant discussions and, where applicable, preparing or performing business relationships.

We currently use the WordPress/PHP default mail mechanism for transmission from the website.

WP Mail SMTP email logging is not currently enabled.

7. Hosting

The website and email infrastructure are hosted by:

ALL-INKL.COM – Neue Medien Münnich
Germany

ALL-INKL processes technical data as part of hosting, security and email services.

According to ALL-INKL’s published privacy information, web-server logs may include IP address, request date and time, requested content, access status, transferred data volume, referring website, browser, operating system and related technical information.

ALL-INKL states that server log files are generally deleted after seven days at the latest, although longer retention may occur in individual cases such as the investigation of attacks or security incidents.

8. Consent Management – Complianz

We use Complianz to manage cookie and technology consent.

Complianz is configured to distinguish between:

  • Functional (required)
  • Analytics
  • Marketing

Functional technologies required for the secure and proper operation of the website may operate without optional consent where permitted by applicable law.

Analytics and Marketing technologies are intended to remain inactive until the relevant consent has been provided.

Your consent choices can be changed at any time using the Manage consent function available on the website.

Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

For further information about individual cookies and technologies, please see our Cookie Policy.

9. Google Fonts

Fonts used on this website are configured to be self-hosted.

Accordingly, the website is not intended to contact Google merely for the purpose of downloading Google Fonts when a visitor opens a page.

10. Google Analytics 4

Subject to your consent, we intend to use Google Analytics 4.

For visitors in the EEA, relevant Google services may involve:

Google Ireland Limited
Gordon House
Barrow Street
Dublin 4
Ireland

and, depending on the processing, Google group companies including Google LLC in the United States.

Google Analytics is used to measure and analyse website usage.

Google states that IP addresses are not logged or stored in Google Analytics 4.

Google Analytics data-retention settings allow retention of user-level and event-level data for periods including 2 months or 14 months. We will configure and document the retention period actually selected in the Analytics property.

Google Analytics will be activated only after Analytics consent where such consent is required.

11. LinkedIn Insight Tag

Subject to your consent, we intend to use the LinkedIn Insight Tag.

For visitors in the EU/EEA and Switzerland, the relevant LinkedIn controller is:

LinkedIn Ireland Unlimited Company
Wilton Place
Dublin 2
Ireland

LinkedIn states that the Insight Tag can collect:

  • URL
  • referrer URL
  • IP address
  • device and browser characteristics
  • User Agent
  • timestamps

LinkedIn states that direct member identifiers are removed within seven days for pseudonymisation and remaining pseudonymised Insight Tag data is deleted within 180 days.

LinkedIn also states that Insight Tag data may be stored on servers in the United States.

The Insight Tag will be activated only after Marketing consent.

12. Cookies and Similar Technologies

This website uses cookies and similar technologies.

Necessary technologies may be used where required for website security, functionality or the storage of privacy choices.

Non-essential Analytics and Marketing technologies are activated only after the relevant consent has been given.

For detailed information regarding:

  • individual cookies;
  • providers;
  • purposes;
  • categories; and
  • storage durations,

please see the separately maintained Cookie Policy.

13. International Data Transfers

UCT is established in the United Arab Emirates.

The website is hosted in Germany, and some services used by the website may process information in the European Economic Area, the United States and other jurisdictions.

This means personal data may be transferred between jurisdictions, including:

  • from the EEA to the United Arab Emirates;
  • from the UAE to service providers in Germany or elsewhere; and
  • where Google or LinkedIn services are used, potentially to the United States or other locations used by those providers.

Where the GDPR requires safeguards for transfers from the EEA to a country that is not covered by an applicable adequacy decision, we will rely on an appropriate transfer mechanism where required, such as applicable Standard Contractual Clauses or another legally recognised transfer mechanism.

Google describes its use of mechanisms including the EU-U.S. Data Privacy Framework and Standard Contractual Clauses for relevant transfers.

LinkedIn states that it participates in the EU-U.S. Data Privacy Framework for relevant transfers.

Cross-border transfers from the UAE are handled in accordance with the applicable requirements of the UAE Personal Data Protection Law.

14. Data Retention

We retain personal data only for as long as necessary for the relevant purpose and applicable legal obligations.

Contact-form database entries

Fluent Forms is configured to delete the form entry after submission.

Email correspondence

Business correspondence may be retained for as long as necessary to:

  • handle the enquiry;
  • manage an existing or potential business relationship;
  • establish, exercise or defend legal claims;
  • meet applicable accounting, tax, commercial or other legal retention obligations; or
  • maintain necessary business records.

Server logs

ALL-INKL states that ordinary web-server log files are generally deleted after seven days at the latest, subject to exceptions such as security incidents.

Analytics

Google Analytics retention will follow the retention setting configured in the relevant GA4 property and will be documented accordingly.

LinkedIn Insight Tag

LinkedIn states that direct member identifiers are removed within seven days and remaining pseudonymised Insight Tag data is deleted within 180 days.

Consent information may be retained for as long as necessary to remember, demonstrate and respect your privacy choices.

15. Data Recipients

Depending on the processing concerned, personal data may be accessible to:

  • authorised persons within UCT;
  • ALL-INKL.COM as website and email hosting provider;
  • technical service providers acting on our behalf;
  • Google in connection with Google Analytics, where consent has been given;
  • LinkedIn in connection with the LinkedIn Insight Tag, where consent has been given;
  • professional advisers where necessary; and
  • public authorities or courts where disclosure is legally required.

We do not sell personal data submitted through the UCT website.

16. Your Rights

Depending on the law applicable to you, you may have rights concerning your personal data.

These may include the right to:

  • obtain information about the processing of your personal data;
  • request access to your personal data;
  • request correction of inaccurate or incomplete data;
  • request deletion where the applicable requirements are met;
  • request restriction of processing;
  • object to certain processing;
  • withdraw consent at any time for future processing;
  • request data portability where applicable; and
  • object to or obtain safeguards in relation to certain automated decisions where applicable.

Under the UAE Personal Data Protection Law, data subjects are provided with rights including information, correction or deletion and restriction of processing, subject to the conditions and exceptions provided by law.

To exercise your rights, contact:

info@uct.solutions

We may need to verify your identity before responding to a request.

17. Right to Withdraw Consent

Where processing is based on consent, you can withdraw your consent at any time.

For website Analytics and Marketing technologies, use the Manage consent function.

You may also contact:

info@uct.solutions

Withdrawal does not affect the lawfulness of processing that took place before consent was withdrawn.

18. Right to Lodge a Complaint

If the GDPR applies to the processing of your personal data, you have the right to lodge a complaint with a competent data-protection supervisory authority.

In particular, you may contact the supervisory authority in the EU/EEA country of your habitual residence, place of work or the place where you believe an infringement occurred.

Where UAE data-protection law applies, you may also have rights to raise matters with the competent UAE data-protection authority in accordance with applicable law.

19. Automated Decision-Making

UCT does not currently use the website to make decisions producing legal or similarly significant effects about individuals solely through automated processing.

If this changes, this Privacy Policy will be updated as required.

20. Children

The UCT website is a business-to-business website and is not intended for children.

We do not knowingly use the website to solicit personal data from children for commercial business-development purposes.

21. Data Security

We use appropriate technical and organisational measures designed to protect personal data against:

  • unauthorised access;
  • accidental or unlawful loss;
  • alteration;
  • disclosure;
  • destruction; and
  • misuse

These measures include appropriate website, hosting, access-control and data-minimisation practices.

No internet-based system can be guaranteed to be completely secure.

22. Third-Party Links

The website may contain links to external websites.

When you leave our website, the privacy practices of the respective external provider apply.

UCT is not responsible for the privacy practices of independent third-party websites.

23. Changes to This Privacy Policy

Last updated: 25 August 2026