Spring Near East FZCO Last updated: 28 August 2026
Spring Near East FZCO ("we", "us", "our") is committed to protecting the personal data of individuals who interact with us in a business context. This Privacy Policy explains how we collect, use, store, and protect personal data in accordance with applicable data protection laws, including the UAE Federal Decree-Law No. 45 of 2021 on Personal Data Protection, the UK General Data Protection Regulation (UK GDPR), and the Turkish Law on the Protection of Personal Data (KVKK, Law No. 6698).
1. Data We Collect
We collect the following categories of personal data from business contacts and website visitors:
- Name, job title, and business contact information (email, phone, company address)
- Communication records (emails, meeting notes, inquiries submitted via our website)
- Technical data (IP address, browser type, pages visited — collected via cookies; see our Cookie Policy)
- Due diligence and compliance information required by law (e.g. KYC documentation)
We do not collect sensitive personal data (such as health, political, or religious data) in the ordinary course of our business.
2. Legal Basis for Processing
We process personal data on the following legal bases:
- Performance of a contract: to deliver services agreed with your organisation
- Legitimate interests: to manage our business relationships, improve our services, and conduct marketing to existing and prospective B2B clients
- Legal obligation: to comply with applicable laws, regulations, and regulatory requirements
- Consent: where we have obtained your explicit consent (e.g. for certain marketing communications)
3. How We Use Personal Data
We use collected data to:
- Communicate with you regarding our services, proposals, and ongoing projects
- Fulfil contractual obligations and manage supplier and client relationships
- Comply with legal and regulatory obligations
- Improve our website and service offerings
- Send relevant business communications and service updates
4. Data Sharing
We do not sell personal data. We may share data with:
- Service providers and subcontractors who assist in delivering our services (under appropriate data processing agreements)
- Regulatory and government authorities where required by law
- Professional advisers (lawyers, auditors, insurers) under confidentiality obligations
Where data is transferred outside the UAE, UK, or Turkey, we ensure appropriate safeguards are in place in accordance with applicable law.
5. Retention
We retain personal data for as long as necessary to fulfil the purposes described above, and in accordance with applicable legal retention requirements. In general, business contact data is retained for the duration of the business relationship plus five (5) years.
6. Your Rights
Depending on your jurisdiction, you may have the right to:
- Access the personal data we hold about you
- Request correction of inaccurate data
- Request erasure of your data (subject to legal retention obligations)
- Object to or restrict processing
- Data portability (where applicable)
- Lodge a complaint with the relevant supervisory authority
To exercise any of these rights, contact us at: [email protected]
7. Data Security
We implement appropriate technical and organisational measures to protect personal data against unauthorised access, loss, or disclosure. These include encrypted communications, access controls, and regular security assessments.
8. Changes to This Policy
We may update this Privacy Policy periodically. The current version will always be available on our website. We will notify active business contacts of material changes where required by law.
9. Contact and Data Controller
Spring Near East FZCO acts as the data controller for personal data collected through this website and our services.
Contact: [email protected]
