1. Data Controller
The party responsible for processing personal data in connection with this website (“Swapa”, “we”, “us”) is:
SWAPA , No.501, Empire Heights Tower A, Business Bay, Dubai . Trade licence no.: [number]
Email: [privacy@swapa.ae]
Phone / WhatsApp: +971 58 580 6890
2. General
We take the protection of your personal data seriously and process it in accordance with UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (“PDPL”) and any other applicable Dubai/UAE regulations.
3. Data We Collect
Because our website does not operate an online shop with checkout, we do not process online payment-card data through the website itself. In connection with your use of the website and any purchase enquiry, we may process:
- Contact details: name, email address, phone/WhatsApp number
- Enquiry and order data: vehicle model(s) you are interested in, quote and invoice details, order history
- Delivery and community data: delivery/residential address within the relevant community, community/development name, access information needed for delivery or for registering the vehicle with community security
- Payment-related data: payment method chosen and transaction reference (bank transfer, payment link, financing partner, or in-person payment) — we do not store full card numbers
- Identification data: where required for ownership transfer, warranty registration, or legal record-keeping (e.g. Emirates ID details)
- Communication data: messages sent via our contact form, email, phone or WhatsApp
- Technical data: IP address, device/browser information, website usage data (see our separate Cookie Policy)
4. Purposes of Processing
- Responding to enquiries and preparing quotes
- Concluding and fulfilling the purchase agreement, including delivery and community registration support
- Customer service and after-sales support (maintenance, warranty claims)
- Compliance with legal obligations (e.g. bookkeeping, regulatory record-keeping)
- Fraud and misuse prevention
- Marketing and newsletters — only with your prior consent, which you may withdraw at any time
- Improving our website (e.g. via analytics cookies, where you have consented — see Cookie Policy)
5. Legal Basis for Processing
- Performance of a contract or steps taken at your request prior to entering into a contract
- Your consent (e.g. marketing, certain cookies)
- Our legitimate business interests (e.g. IT security, fraud prevention)
- Compliance with a legal obligation under UAE law
6. Disclosure to Third Parties
We only share your data where necessary, with:
- Payment or financing partners involved in processing your payment
- Logistics/delivery partners for vehicle delivery
- The management or security team of the relevant residential community or master developer (e.g. Emaar, Nakheel, Damac or similar), where required for vehicle registration or site access
- IT and website hosting providers, contractually bound to data-protection obligations
- Authorities, where we are legally required to do so
We do not sell or share your data with third parties for their own marketing purposes without your consent.
7. International Data Transfers
Where data is transferred to service providers outside the UAE (e.g. cloud hosting), we ensure an adequate level of protection through appropriate contractual and technical safeguards consistent with PDPL requirements.
8. Retention Period
We retain personal data only for as long as necessary for the purposes described above or as required by applicable UAE statutory retention obligations (e.g. commercial or tax record-keeping), after which it is deleted or anonymised.
9. Your Rights
Under the PDPL, you generally have the right to:
- Request access to the personal data we hold about you
- Request correction of inaccurate data
- Request deletion of your data (“right to be forgotten”), subject to certain conditions
- Request restriction of processing
- Object to certain processing, in particular direct marketing
- Withdraw consent at any time, with effect for the future
- Request data portability, where applicable
To exercise these rights, contact us at [privacy@swapa.ae].
10. Data Security
We apply appropriate technical and organisational measures to protect your data against loss, misuse and unauthorised access (e.g. encryption, access controls, regular security reviews).
11. Cookies
For details of the cookies used on our website, please see our separate Cookie Policy.
12. Changes to this Policy
We apply appropriate technical and organisational measures to protect your data against loss, misuse and unauthorised access (e.g. encryption, access controls, regular security reviews).
11. Cookies
For details of the cookies used on our website, please see our separate Cookie Policy.
12. Changes to this Policy
We may update this Privacy Policy from time to time, for example if our services or applicable law change. The current version is always available on our website.
13. Contact
For any privacy-related questions, please contact: [privacy@swapa.ae]