Effective date: 18th Feb, 2024

This Privacy Notice applies to the Bruqe website available at https://bruqe.com/ and to personal data collected through or in connection with that website, including through communications, enquiries, and other interactions relating to Bruqe (together, the “Website”).

Bruqe is a strategy and systems-intelligence advisory operated by Dar Al Nuhas (“Dar Al Nuhas”, “Bruqe”, “we”, “us” or “our”). Bruqe is responsible for personal data processed under this Privacy Notice, unless we notify you otherwise at the point at which personal data is collected or in a separate written agreement.

This Privacy Notice explains how we may collect, use, disclose, retain, transfer, and otherwise process personal data in connection with the Website. It does not form part of any agreement for professional services and does not create a client, adviser, fiduciary, agency, employment, partnership, joint-venture, or other contractual relationship between you and Bruqe and/or parent entities and/or sister entities.

Scope

The Website is made available globally for general informational purposes.

Access to the Website from a particular location does not, by itself, create a presence, establishment, offer of services, contractual relationship, or submission by Bruqe and/or parent entities and/or sister entities to the laws, courts, regulators, or jurisdiction of that location.

Professional services are provided only under separate written engagement agreements entered into by the relevant contracting entity. Any such agreement may specify the applicable contracting party, place of performance, governing law, dispute forum, confidentiality requirements, data arrangements, and other terms applicable to that engagement.

This Privacy Notice describes our general approach to the processing of personal data in connection with the Website. It does not extend rights, create obligations, or constitute a voluntary election to be subject to any particular privacy, data-protection, consumer-protection, or other legal regime, except to the extent required by applicable law.

This Privacy Notice does not apply to:

• Personal data processed under a separate client engagement, employment relationship, supplier arrangement, recruitment process, or other written agreement, where separate terms or notices apply.
• Third-party websites, services, platforms, applications, or resources linked from the Website.
• Information that has been aggregated, anonymised, or otherwise processed so that it no longer identifies, or cannot reasonably be used to identify, an individual.

Personal data we may collect

We may collect personal data directly from you, automatically through your use of the Website, through communications with us, or from lawful third-party sources.

The categories of personal data we may process include:

• Identity and contact information, including your name, title, employer, business address, email address, telephone number, and other professional contact details.
• Professional and business information, including your role, organisation, sector, location, business interests, professional background, and information relevant to an enquiry, prospective relationship, or career opportunity.
• Correspondence and enquiry information, including the content of messages, requests, attachments, meeting details, feedback, and other communications you send to us.
• Technical and usage information, including IP address, device type, browser type and version, operating system, referring URLs, access times, pages viewed, approximate location derived from IP address, log data, and interactions with the Website.
• Cookie and similar-technology information, including information generated through cookies, pixels, tags, scripts, local storage, and comparable technologies.
• Recruitment information, where you apply for a role or otherwise express an interest in working with Bruqe and/or parent entities and/or sister entities, including your CV, employment history, education, qualifications, references, availability, and correspondence.
• Security, compliance, and legal information, including information relevant to fraud prevention, suspected misuse of the Website, security incidents, legal claims, investigations, sanctions compliance, and other legal or regulatory matters.

We do not require you to provide personal data simply to browse the Website. However, certain features, communications, or requests may not be available without relevant information.

Information you should not submit

Unless we expressly request it or agree otherwise in writing, you must not submit through the Website or to any email address published on the Website:

• Confidential, proprietary, commercially sensitive, privileged, regulated, classified, or security-sensitive information.
• Special-category or sensitive personal data, including health, biometric, genetic, racial or ethnic, political, religious, trade-union, sexual-orientation, or criminal-offence information.
• Personal data relating to another person, unless you are authorised to provide it and have provided any notices or obtained any consents required by applicable law.
• Information subject to a non-disclosure agreement, fiduciary duty, legal privilege, regulatory restriction, or other confidentiality obligation.

Unless we expressly agree otherwise in writing, information submitted to us through the Website or through a published general contact channel will not be treated as confidential and will not create a duty of confidence, fiduciary duty, or other obligation on the part of Bruqe and/or parent entities and/or sister entities.

This section does not limit any duty of confidentiality expressly agreed in a written agreement signed by authorised representatives of the relevant parties.

How we use personal data

We may process personal data where reasonably necessary for the following purposes:

• Operating, administering, maintaining, securing, and improving the Website and related systems.
• Responding to enquiries, requests, correspondence, and communications.
• Assessing and managing potential client, commercial, professional, supplier, recruitment, or other business relationships.
• Providing information, materials, communications, events, or updates that you request or that may be relevant to your professional interests, where permitted by applicable law.
• Managing recruitment processes and expressions of interest opportunities at Bruqe and/or parent entities and/or sister entities.
• Conducting internal business administration, planning, quality assurance, training, research, audit, management reporting, and operational improvement.
• Protecting the rights, property, reputation, systems, information, personnel, operations, and legitimate interests of Bruqe, and/or parent entities, and/or sister entities, and/or other persons.
• Detecting, investigating, preventing, and responding to suspected fraud, security incidents, misuse, unlawful conduct, breaches of contract, intellectual-property infringement, or other wrongdoing.
• Complying with legal, regulatory, professional, accounting, tax, audit, recordkeeping, sanctions, and risk-management obligations.
• Establishing, exercising, defending, settling, or managing actual or potential legal claims, disputes, investigations, or proceedings.
• Facilitating a corporate transaction, financing, restructuring, merger, acquisition, reorganisation, sale, transfer, or disposal involving all or part of Bruqe and/or parent entities and/or sister entities.

Where applicable law requires a lawful basis for processing, we may rely on consent, performance of a contract, steps taken at your request before entering into a contract, compliance with a legal obligation, protection of vital interests, or legitimate interests.

Our legitimate interests may include operating and developing our business; managing professional relationships; protecting confidential information, intellectual property, systems, and reputation; maintaining security; managing risk; and complying with governance and legal requirements.

Google Analytics and similar technologies

We use Google Analytics, a web analytics service provided by Google, to understand how visitors use the Website and to assist us in assessing and improving its performance, content, functionality, security, and user experience.

Google Analytics may collect technical and usage information, including information about your device, browser, operating system, pages viewed, interactions with the Website, referring URLs, date and time of access, approximate location derived from IP address, and identifiers generated through cookies or similar technologies.

We do not intentionally provide Google Analytics with direct identifiers such as names, email addresses, telephone numbers, client names, project names, transaction details, or other information that directly identifies an individual.

Information collected through Google Analytics is processed in accordance with Google’s applicable terms and privacy documentation, available at: https://policies.google.com/privacy

We may amend, restrict, suspend, or discontinue our use of Google Analytics or any other analytics technology at any time.

You may be able to manage or delete cookies through your browser settings. Disabling cookies may affect the functionality or availability of certain parts of the Website.

Google also provides a browser add-on that enables users to opt out of Google Analytics across websites, available at: https://tools.google.com/dlpage/gaoptout

Disclosure of personal data

We may disclose personal data where reasonably necessary for the purposes described in this Privacy Notice, including to:

• Service providers, contractors, advisers, and technology providers that support website hosting, cloud infrastructure, data storage, communications, security, analytics, recruitment, professional operations, and other business functions.
• Professional advisers, including lawyers, auditors, accountants, insurers, banks, financing sources, consultants, and other advisers subject to appropriate confidentiality or professional obligations.
• Courts, regulators, government bodies, law-enforcement authorities, tax authorities, public bodies, or other persons where disclosure is required or reasonably considered necessary by law, regulation, court order, investigation, or legal process.
• Any person where disclosure is necessary to protect the rights, property, safety, reputation, security, systems, information, personnel, or legitimate interests of Bruqe, and/or parent entities and/or sister entities, and/or another person.
• Actual or prospective purchasers, investors, financiers, successors, acquirers, counterparties, advisers, or other parties involved in a corporate transaction, subject to appropriate confidentiality arrangements where practicable.

We do not sell personal data in exchange for monetary consideration.

International processing

Personal data may be collected, accessed, stored, processed, or disclosed in the jurisdiction from which Bruqe (and/or parent entities and/or sister entities) operates and in other jurisdictions in which our service providers, professional advisers, technology providers, or other authorised recipients operate.

The laws of those jurisdictions may differ from the laws of the jurisdiction in which you are located.

Where applicable law requires specific conditions, safeguards, contractual protections, approvals, notices, or transfer mechanisms in relation to an international transfer of personal data, we will take such steps as we consider necessary or appropriate to comply with those requirements.

By accessing the Website or voluntarily providing personal data to us, you acknowledge that your personal data may be processed in jurisdictions outside your location of residence, subject always to applicable law.

Retention

We retain personal data for as long as we reasonably consider necessary for the purpose for which it was collected or received, including to meet legal, regulatory, tax, accounting, audit, security, recordkeeping, contractual, and reporting requirements.

The relevant retention period will depend on the nature of the information, the purpose of processing, the sensitivity of the information, applicable legal requirements, the existence of an actual or anticipated dispute, claim, investigation, or proceeding, and whether retention is necessary to protect the rights or legitimate interests of Bruqe and/or parent entities and/or sister entities.

We may retain personal data for longer periods where necessary or appropriate to establish, exercise, defend, or manage legal claims; investigate misconduct or security incidents; comply with legal obligations; enforce our rights; or preserve relevant records under a legal hold, investigation, or dispute process.

Security

We maintain technical, organisational, administrative, and contractual measures that we consider appropriate to protect personal data against accidental, unlawful, or unauthorised destruction, loss, alteration, access, disclosure, misuse, or other processing.

No website, network, electronic transmission, storage environment, or security control can be guaranteed to be entirely secure. You are responsible for using appropriate care when transmitting information electronically and should not provide information that you are not authorised to disclose.

Your rights and choices

Depending on your location and the requirements of applicable law, you may have rights in relation to your personal data. These may include rights to request access to, correction of, deletion of, restriction of, objection to, or transfer of personal data, and to withdraw consent where we rely on consent.

You may also have the right to object to the use of your personal data for direct-marketing purposes.

To submit a request, please contact us at legal@bruqe.com with the subject line “Privacy Request”. We may request information reasonably necessary to verify your identity, authority, and the scope of your request before responding.

We may decline, limit, or defer a request where permitted or required by applicable law, including where responding would adversely affect the rights and freedoms of others, compromise confidential or privileged information, prejudice an investigation, conflict with a legal obligation, or impair the establishment, exercise, or defence of legal claims.

Where applicable law provides a right to lodge a complaint with a relevant data-protection authority, you may exercise that right in the jurisdiction relevant to you.

Third-party websites

The Website may contain links to third-party websites, services, platforms, or resources. We do not control and are not responsible for their privacy practices, content, availability, security, or operations.

Your use of third-party websites is subject to the terms and privacy notices of those third parties.

Children

The Website is not directed at children. We do not knowingly collect personal data from individuals under the age of 18.

If you believe that a child has provided personal data to us without appropriate authority, please contact legal@bruqe.com.

Changes to this Privacy Notice

We may amend this Privacy Notice from time to time to reflect changes in our operations, processing activities, legal or regulatory requirements, security practices, or business arrangements.

Any revised Privacy Notice will be published on this page and will take effect on the date stated at the top of the revised notice, unless applicable law requires otherwise.

Contact

For legal, privacy, compliance, or personal-data enquiries, contact: legal@bruqe.com

For general enquiries, contact: info@bruqe.com

Please use “Privacy Notice” or “Privacy Request” as the subject line, as appropriate.