Privacy Policy

Introduction

THE BROTHERS GENERAL TRADING L.L.C ("we," "our," or "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website https://brothers.ae.org/ or engage with our services. We comply with applicable data protection laws, including the UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (PDPL).

Information We Collect

Personal Information

We may collect personal information that you voluntarily provide to us when you:

• Fill out contact forms on our website
• Apply for career opportunities and upload your CV
• Request information about our trading activities or portfolio companies
• Communicate with us via email or phone

This information may include: name, email address, phone number, company name, job title, preferred location, CV/resume file, and any other information you choose to provide in your message.

Automatically Collected Information

When you visit our website, we may automatically collect certain information about your device and browsing activity, including:

• IP address (anonymized in Google Analytics)
• Browser type and version
• Operating system and device type
• Pages visited, time spent, and scroll depth
• Referring website addresses
• Approximate geographic location (country/region level)
• Interaction events (button clicks, form submissions, outbound link clicks)

How We Use Your Information

We use the information we collect for the following purposes:

• To respond to your inquiries and provide customer support
• To process career applications and recruitment activities
• To send you information about our services, updates, and news (only with your consent)
• To improve our website, user experience, and content
• To analyze website usage, trends, and performance using Google Analytics 4
• To track conversions and measure the effectiveness of our marketing efforts
• To prevent fraud and protect our rights
• To comply with legal obligations under UAE law

Cookies and Tracking Technologies

We use cookies and similar tracking technologies to enhance your experience on our website. Cookies are small data files stored on your device. We use the following categories:

• Essential Cookies: Required for core website functionality (session management, CSRF protection). These cannot be disabled.
• Analytics Cookies (Google Analytics 4): Help us understand how visitors use our website — page views, scroll depth, session duration, traffic source, and interaction events. IP addresses are anonymized.
• Preference Cookies: Remember your settings and preferences (e.g., light/dark theme selection). Stored locally in your browser.
• Security Cookies (Google reCAPTCHA v2): Used to protect our contact and career application forms from spam and automated abuse.

You can control cookies through your browser settings. However, disabling essential cookies may affect website functionality. We do not use advertising cookies or cross-site tracking pixels.

Google Analytics 4

We use Google Analytics 4 (GA4) to collect and analyze website usage data. GA4 helps us understand how visitors find and use our website so we can improve content and user experience. Key details:

• Data controller: THE BROTHERS GENERAL TRADING L.L.C
• Processor: Google LLC (acting as data processor under Google's Terms of Service)
• IP anonymization: IP addresses are anonymized at the collection point before being stored
• Data shared with Google: Anonymized page views, events, session data, and engagement metrics
• Google Signals: Disabled — we do not use cross-device tracking
• Advertising features: Disabled — we do not use GA4 for personalized advertising
• Consent mode v2: Implemented — ad-related storage is denied by default

For more information about how Google handles data, please review Google's Privacy Policy and Data Retention and Anonymization documentation.

Google reCAPTCHA v2

We use Google reCAPTCHA v2 on our contact and career application forms to protect against spam and automated submissions. reCAPTCHA may collect information about your device and browsing behavior to determine whether you are a human user. This data is sent to Google and subject to Google's Privacy Policy and Terms of Service.

Information Sharing and Disclosure

We do not sell, trade, or rent your personal information to third parties. We may share your information in the following circumstances:

• Service Providers: With trusted third-party service providers (Google Analytics, Google reCAPTCHA, email delivery services) who assist us in operating our website and conducting our business
• Legal Requirements: When required by UAE law, court order, or government authority, or to protect our rights
• Business Transfers: In connection with a merger, acquisition, or sale of assets
• With Your Consent: When you have given us explicit permission

Data Retention

We retain personal information only as long as necessary to fulfill the purposes for which it was collected:

• Contact form submissions: Retained for up to 12 months after the inquiry is resolved
• Career applications (including CVs): Retained for up to 12 months for consideration against future openings, unless you request earlier deletion
• Google Analytics data: Retained for 14 months (GA4 default), then automatically aggregated and anonymized
• Server logs: Retained for up to 90 days for security and troubleshooting

Data Security

We implement appropriate technical and organizational security measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include SSL/TLS encryption for data in transit, CSRF tokens on all forms, server-side input sanitization, and restricted access to personal data. However, no method of transmission over the internet or electronic storage is 100% secure, and we cannot guarantee absolute security.

Your Rights Under UAE PDPL

Under the UAE Personal Data Protection Law (PDPL), you have the following rights regarding your personal information:

• Right of Access: Request a copy of the personal information we hold about you
• Right to Correction: Request correction of inaccurate or incomplete information
• Right to Deletion: Request deletion of your personal information (subject to legal retention requirements)
• Right to Restrict Processing: Request that we limit the processing of your data
• Right to Object: Object to processing of your personal information for specific purposes
• Right to Withdraw Consent: Withdraw consent for data processing at any time
• Right to Data Portability: Request your data in a structured, machine-readable format

To exercise any of these rights, please contact us using the details provided below. We will respond to your request within 30 days.

Third-Party Links

Our website contains links to third-party websites, including our portfolio company websites. We are not responsible for the privacy practices or content of these external sites. We encourage you to review their privacy policies before providing any personal information.

Children's Privacy

Our website is not intended for children under the age of 18. We do not knowingly collect personal information from children. If you believe we have collected information from a child, please contact us immediately so we can delete it.

International Data Transfers

Your information may be processed by our third-party service providers (Google Analytics, Google reCAPTCHA) in countries outside the UAE, including the United States. We rely on Google's standard contractual clauses and data transfer frameworks to ensure appropriate safeguards are in place for international data transfers.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, or legal requirements. We will notify you of any material changes by posting the updated Privacy Policy on this page and updating the "Last updated" date. We encourage you to review this Privacy Policy periodically.

Contact Us

If you have any questions about this Privacy Policy, our privacy practices, or wish to exercise your data protection rights, please contact us: