Privacy Policy

1. Introduction

Aurne Private Advisory ("Aurne", "we", "our", "us") is committed to protecting the privacy, confidentiality, and security of personal and corporate information entrusted to us.

This Privacy Policy explains:

• What information we collect
• How we use, store, and protect it
• Your rights regarding your information

This Policy is drafted in accordance with:

• UAE Federal Decree-Law No. 45 of 2021 on Personal Data Protection (PDPL)
• Executive Regulations of the PDPL
• Applicable regulatory requirements for Corporate Service Providers (CSP), Accounting, Tax, and Business Advisory firms in the UAE

By using our website, contacting us, or engaging our services, you agree to the practices described in this Privacy Policy.

2. Definitions

"Personal Data" means any information relating to an identified or identifiable natural person.

"Processing" means any operation performed on personal data, including collection, storage, use, disclosure, or deletion.

"Client" means any individual or entity using Aurne's services.

"Regulations" refers to UAE federal laws, free zone rules, and compliance obligations (AML, ESR, UBO, CT, VAT, etc.).

3. Information We Collect

We collect information necessary to provide our corporate, accounting, tax, compliance, and structuring services.

3.1 Personal Information

• Full name
• Passport, Emirates ID, residency information
• Contact details (email, phone, address)
• Information required for KYC/KYB verification
• Signatures, authorization documents

3.2 Corporate Information

• Trade license and incorporation documents
• Shareholder and UBO details
• Corporate structure charts
• Financial statements and bookkeeping records
• Contracts, agreements, resolutions

3.3 Compliance & Regulatory Information

Collected as required by law, including:

• AML/KYC documentation
• UBO identification
• ESR-related submissions
• Board or shareholder documents

3.4 Website & Technical Data

• IP address
• Device information
• Cookies and analytics data
• Website interaction details
• Advertising identifiers, such as the Google click identifier (gclid) appended to our paid advert links, and the campaign parameters (utm_source, utm_medium, utm_campaign) that tell us which advert or referral brought you to us

We do not intentionally collect data from minors.

4. How We Use Your Information

We use personal and corporate data strictly for lawful, legitimate purposes, including:

4.1 Service Delivery

• Company formation, structuring, and registration
• Accounting, bookkeeping, VAT, and corporate tax services
• Compliance filings and regulatory submissions
• Advisory and administrative support

4.2 Legal & Regulatory Obligations

• KYC, AML, CTF compliance
• ESR, UBO, and tax reporting
• Record-keeping obligations under UAE law
• Responding to lawful requests from authorities

4.3 Operational Purposes

• Client communication and engagement
• Billing and invoicing
• Internal quality control and auditing
• IT improvements and website optimization

4.4 No Unlawful or Unauthorised Use

We do not:

• Sell, rent, or trade personal data
• Use your information for marketing without consent
• Provide investment advisory or asset management services

5. Legal Basis for Processing

We process your data under the following lawful bases:

• Performance of a contract (service engagement)
• Compliance with legal obligations (AML/KYC/Tax/ESR/UBO)
• Legitimate business interest (service delivery, risk management)
• Consent (where applicable)

6. Sharing and Disclosure of Information

We may share your information with:

6.1 Government Authorities

• Ministry of Economy
• Federal Tax Authority (FTA)
• Ministry of Finance (MOF)
• UAE Free Zone Authorities (e.g., DMCC, IFZA, Meydan, RAKEZ, SHAMS)
• Banks for account opening support
• Law enforcement when required by law

6.2 Service Providers

Trusted third parties assisting us in:

• Compliance checks
• IT hosting and cybersecurity
• Accounting systems and software
• Document processing
• Website analytics and advertising measurement

Providers who process personal data on our behalf include Vercel (website hosting), Airtable (enquiry records), Cloudflare (Turnstile bot protection on our enquiry forms), Google (Tag Manager, Analytics 4, Google Ads) and Meta Platforms (Facebook and Instagram advertising).

6.2a Advertising Measurement

We advertise on Google and Meta. To measure which adverts produce genuine enquiries, we share a hashed version of the email address and phone number you submit with those platforms. The values are irreversibly hashed (SHA-256) in your browser before they are sent, so neither platform receives your email address or phone number from us in readable form. Google calls this Enhanced Conversions and Meta calls it Advanced Matching.

This is used solely to attribute an enquiry to the advert that produced it. We do not sell your personal data, and we do not use these platforms to build marketing profiles about you. Full detail, including the specific cookies involved, is in our Cookie Policy. To object, contact us using the details below.

6.3 Professional Advisors

• Legal consultants
• Auditors
• Tax advisors

We ensure all third parties maintain confidentiality and data protection standards.

7. International Data Transfers

Where cross-border data transfers are required (e.g., intercompany matters, international clients), such transfers are conducted in compliance with:

• UAE PDPL transfer rules
• Adequate safeguards (contracts, encryption, restricted access)

We only transfer data when necessary and lawful.

8. Data Security

We employ strict technical and organizational measures to protect personal data, including:

• Encrypted storage
• Access controls and authentication
• Secure cloud infrastructure
• Regular auditing and monitoring
• Compliance with UAE cybersecurity requirements

Despite this, no method of transmission is 100% secure, and we cannot guarantee absolute security.

9. Data Retention

We retain information only for as long as necessary and in accordance with:

• Statutory retention periods
• AML/CTF regulations
• Corporate and tax compliance laws

Typically, data is retained for 5–8 years, unless law requires otherwise.

After the retention period, data is securely destroyed.

10. Your Rights Under UAE Law

Depending on applicable regulations, you may request:

• Access to your personal data
• Correction of inaccurate information
• Deletion of data (where legally permissible)
• Restriction of processing
• Copy/portability of data (if applicable)
• Withdrawal of consent (if processing is based on consent)

We must comply unless restricted by legal or regulatory obligations (e.g., AML retention rules).

11. GDPR Compliance (For EEA & UK Residents)

If you are located in the European Economic Area (EEA) or United Kingdom, the EU General Data Protection Regulation (GDPR) and UK GDPR apply to our processing of your personal data.

11.1 Data Controller

AURNE PRIVATE ADVISORY L.L.C-FZ is the data controller for personal data processed under this Privacy Policy.

11.2 Your GDPR Rights

Under GDPR, you have the following rights:

• Right of Access: Request a copy of your personal data
• Right to Rectification: Correct inaccurate or incomplete data
• Right to Erasure: Request deletion of your data (subject to legal obligations)
• Right to Restriction: Request limitation of processing in certain circumstances
• Right to Data Portability: Receive your data in a structured, machine-readable format
• Right to Object: Object to processing based on legitimate interests
• Right to Withdraw Consent: Withdraw consent where processing is consent-based
• Right Not to be Subject to Automated Decision-Making: Including profiling

11.3 Legal Basis for Processing (GDPR)

We process your data based on:

• Consent: Where you have provided explicit consent
• Contract: To perform our contractual obligations
• Legal Obligations: To comply with UAE and international laws (AML, tax, etc.)
• Legitimate Interests: For business operations, security, and service improvement

11.4 International Transfers (GDPR)

When transferring personal data outside the EEA/UK, we use appropriate safeguards including:

• Standard Contractual Clauses (SCCs)
• Encryption and access controls
• Other approved transfer mechanisms under GDPR

11.5 Exercising Your GDPR Rights

To exercise any of your GDPR rights, please contact us at contact@aurne.org with:

• Your request details
• Identity verification information
• Specific data concerned

We will respond within statutory timelines (typically 30 days under GDPR).

11.6 Right to Complain

You have the right to lodge a complaint with a supervisory authority in your country. We encourage you to contact us first to resolve any concerns.

11.7 Data Protection Officer

For GDPR-related inquiries, contact our Data Protection Officer at contact@aurne.org.

12. Cookies and Tracking

We use cookies for functionality, analytics and advertising measurement. Analytics is Google Analytics 4, loaded through Google Tag Manager. Advertising measurement is Google Ads conversion tracking and the Meta Pixel, which record when an advert click results in an enquiry.

For the full list, including cookie names, the providers who set them and the legal basis for each category, please see our Cookie Policy.

Users may modify browser settings to limit or manage cookies. Advertising cookies are not placed for EU/EEA and UK visitors without consent.

13. Third-Party Links

Our website may contain links to third-party sites.

We are not responsible for:

• Their privacy practices
• Their content
• Their compliance standards

14. Changes to This Policy

We may update this Privacy Policy periodically to reflect:

• Regulatory changes
• Service scope updates
• Internal policy improvements

Updates will be posted on our website with an updated "Last Updated" date.

15. Contact Information

For privacy-related inquiries or requests, contact us at:

Aurne Private Advisory
Email: contact@aurne.org
Phone: +971 56 615 8490 (WhatsApp)
Address: Meydan Grandstand, 6th floor, Meydan Road, Nad Al Sheba, Dubai, U.A.E.