Privacy Notice

Responsibility

This Privacy Notice is provided by Upfront Trading LLC, a company incorporated under the laws of Dubai, United Arab Emirates, with license number 1103731; "Upfront", "we", "us", "our"). This Data Protection Notice has been prepared according to the terms of the UAE's Data Protection Law (UAE Federal Law No. 45 of 2021 and its executive regulations) and will be augmented by jurisdictional specific addendums from time to time.

We are committed to safeguarding the privacy of the personal information that we process in the course of our business, including the personal information we receive from you ("you" or "your"). This Privacy Notice describes how and why we collect, store, and use personal information, and provides information about the rights of the individuals to whom such personal information relates.

For applicable data protection law, Upfront is typically the "data controller" of any personal information provided to us. A component of our services is to facilitate your recovery of payments due to you from third parties, and in such cases, we process personal data only in accordance with the directions of a data controller, or as otherwise permitted by law.

Please read the following information carefully to understand our views and practices regarding how we handle personal information. If you have any queries about our approach to data protection not already addressed in this Privacy Notice, please contact us as per the contact details set out at the end of this Privacy Notice.

Collection of Personal Information

We may collect personal information from you in the course of our business, when you contact us, engage with our website (www.getupfront.io), our software platform via app.getupfront.io, or when you request services from us when you utilize our services and/or software platforms, or as a result of your relationship with any of our personnel.

The personal information that we process includes:

Basic details, such as your name, role/title, employer/s, your relationship to a person, and your contact information (such as your email address, physical address, contact numbers);
Identification information to enable us to check and verify your identity (e.g. your birthdate; your passport details), and information collected from publicly available resources to verify the same;
Information relating to how you wish to utilize our services;
Bank account or other financial information, if relevant to the services that shall be rendered to you;
Technical information (including your location, IP address, browser details, traffic data, and location data), such as information from your visits to our website or mobile app (page interaction information, length of visits, etc.), or concerning marketing emails we send to you;
Personal information provided to us by or on behalf of our customers, or generated by us in the course of providing services to them;
Any other information relating to you which you may provide to us.

We may collect your personal information:

As part of our new know-your-business (KYB) procedures and client onboarding, client maintenance activities, or when you seek services from us;
When you seek employment from us, as part of our new employee on-boarding and maintenance of the employment relationship, or when you engage with our alumni group;
When you provide (or offer to provide) services to us, either yourself or on behalf of your employer;
When you interact with our website or mobile app, or use any of our online services;
When you interact with us in respect of any of our marketing communications or events.

We collect most of this information directly from you, or through your use of our website. However, we may also collect data about you from a third-party source, such as your employer, other third-parties, platform operators for technology used in our business, other organisations that you have dealings with, regulators or other government authorities, credit reporting agencies, information service providers, or from publicly available records.

The information you provide may be confidential, and we will maintain such confidentiality and protect your information per any contractual arrangement that we have with you, and applicable law. We have arrangements in place with personnel and service providers who may process your personal information, to ensure that confidentiality is maintained.

Purposes

Whether we receive your personal data directly from you or a third party, we will only use your personal information if:

We have obtained your consent (where necessary), or if we have another lawful basis upon which to do so (e.g. for the performance of a contract to which you are a party, or to take steps at your request before entering into such contract);
For compliance with a legal obligation on us;
To protect your vital interests or those of another natural person; or for our legitimate interests, or those of a third party, except where such interests are overridden by your rights or interests.

The purposes for which we process your personal information are as follows:

Providing our services to you;
Communicating with you in respect of developments, enhancements, or other changes to our software, or regulatory developments related to our services, or the promotion of our business;
Managing our business relationship with you (or your organisation), whether in connection with the provision of our services, the procurement of your goods and services, or as your employer (or potential or former employer), including processing payments, accounting, auditing, billing and collection, and related support services;
Complying with our legal obligations, including concerning legal and regulatory considerations (e.g. anti-money laundering and sanctions checks, audits, enquiries by regulatory authorities);
Managing and securing access to our premises and information technology systems, and monitoring the technology side of our operations;
Keeping your contact details accurate and current using information provided by you, or information publicly available;
For any purpose related and/or ancillary to any of the above or any other purposes for which your personal data was provided to us.

Cookies and Tracking Technologies

Cookies are small files sent to your device's storage by a web server, enabling a website to remember your preferences, activities, or other information related to your visit. Information collected by cookies may include details about your use of our website or app, information about your device (such as IP address, browser type, and operating system), and demographic data. We use cookies to enhance your experience on our website, provide personalized content, and improve functionality and performance.

In addition to cookies, we may use other tracking technologies such as web beacons, pixel tags, device fingerprinting, or local storage to collect similar information. These technologies help us understand user behavior, track interactions with our website or app, and measure the effectiveness of our content or advertising campaigns.

We may also employ analytics tools and similar products to:

Track unique visitors by storing identifiers (e.g., unique visitor IDs, timestamps of first and subsequent visits, and visit frequency).
Record session details to attribute visit information — such as conversions, transactions, and traffic sources — to specific activities.
Recognize when a session ends or a browser is closed to ensure proper attribution and functionality.

Most modern internet browsers provide mechanisms to notify you when you receive a new cookie and offer options to reject or manage cookies. You can also disable cookies altogether through your browser settings. Please note that disabling cookies or other tracking technologies may limit some functionalities of our website or app and impact your overall experience.

Sharing your Personal Information

We may disclose your personal information to a recipient:

to outsource one or more of the purposes-related functions described above;
to confirm or update information provided by you;
to inform you of events, information about our services, and other important information, or
for other purposes disclosed at or before the time the information is collected. If we re-organise our business, we may need to transfer your personal information to other group entities or third parties.

If you tell us you wish to attend an event, your name and organisation may appear on a list which we provide to other delegates at the event. We also take photographs and video of our events, and this may result in your image being captured and used in the course of reporting on the event (e.g. via social media or other means); we will draw this to your attention in materials relating to the specific events.

Concerning any other disclosures to third parties as necessary to provide the services as effectively as we can (for example, but not limited to any third parties who are utilized to deliver the services to you, our professional advisors such as lawyers and accountants, government or regulatory authorities, insurers, tax authorities, document processing and transaction services, third party postal and courier services), we will only do so where you have given your consent, where we are required to do so by law, or where it is necessary for or in connection with legal proceedings or to exercise or defend legal rights. We do not sell, rent, distribute, or otherwise make, personal information commercially available to any third party.

In addition, we make use of third-party technology services including, amongst other things, cloud security systems. The use of these services may require your personal information to be held in the cloud on infrastructure managed by the relevant service provider.

Cross-Border Transfers of Information

It may sometimes be necessary for us to share your personal information with other Upfront offices or with employees or consultants to Upfront who work outside of the UAE. It may also be necessary for us to share your personal information with third-party service providers who are either a component of Upfront delivering its services or are necessary to a contract between you and Upfront (including data storage facilities or online storage located within or outside the United Arab Emirates, which may be operated by independent service contractors). This will entail a transfer of personal information from the UAE to recipients outside the UAE, and vice versa.

The level of personal information protection in the various jurisdictions in which we operate varies, and in some instances may not provide an adequate level of protection from an international 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. (For further information, please contact legal@getupfront.io.) When we transfer your information to other countries, we will use, share, and safeguard that information as described in this Privacy Notice.

Retention of Personal Information

We will retain your personal information for the length of time needed to fulfil the purposes for which it was collected, unless we specifically agree a longer retention period with you, or a longer retention period is required or permitted by law.

Your Rights

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:

Withdraw consent: When personal information is processed on the basis of consent, you may withdraw consent at any time, although such withdrawal will not affect the lawfulness of processing occurring prior to such withdrawal. You can also change your preferences for receiving our marketing emails and legal updates from us at any time, and you can unsubscribe by following the instructions specified in our marketing emails or via the websites;
Access and rectification, etc.: You may request access to and rectification or erasure of personal information, or restriction of processing concerning the Data Subject or to object to processing as well as the right to data portability;
Objecting and restricting: You may object, on legitimate grounds, to the processing of your personal information, or request that processing be restricted; and
Complaints: If you believe that your data protection rights may have been breached, you may lodge a complaint with the relevant data protection authority.

If you would like to exercise any of the above rights, or any other rights available to you pursuant to applicable law, please contact us using the contact details set out below.

Information Security

We have implemented reasonable administrative, technical, and physical measures to protect your personal information against loss, misuse, and alteration.

Changes to this Privacy Notice

We may from time to time make changes to this Privacy Notice. Where these are likely to be material, we will communicate these in advance. Otherwise, these will become effective once the amended Privacy Notice is posted on our website. Please check back regularly to keep informed of updates to this Privacy Notice.

Contact Details

If you have any questions about this Privacy Notice or our processing of your personal data, please contact us using the contact details set out below:

Email: legal@getupfront.io