Published Date: 01/10/2025

Effective Date: 1^st September 2025

1. Introduction

Welcome to STEERX INDUSTRIAL SOLUTIONS TRADING LLC – FZ (www.steerx.ae). We are committed to protecting your privacy and personal data. This Privacy Policy explains how STEERX INDUSTRIAL SOLUTIONS TRADING LLC – FZ (“the Company,” “we,” “us,” or “our”), a company registered in Dubai emirate under Commercial License No. 2535542.01, collects, uses, discloses, and protects your personal data when you visit our website www.steerx.ae (the “Website”), interact with us, purchase our products (manual and electric material handling products, industrial equipment, and general trading items), or use our services.         

By using our Website, you agree to the collection and use of information in accordance with this Privacy Policy. This policy is designed to comply with the Federal Decree-Law No. 45 of 2021 on Personal Data Protection (PDPL) in the UAE and other relevant data privacy laws.

2. Personal Data We Collect

We collect various types of personal data for the purposes outlined in this policy. “Personal Data” refers to any data that can identify an individual.

2.1. Information You Provide Directly to Us:

• Contact Information: Name, job title, company name, email address, phone number, mailing address, country.
• Account Information: Username, password, and other registration details if you create an account on our Website.
• Order Information: Product preferences, purchase history, delivery address, billing information.
• Communication Data: Information you provide when you communicate with us via email, phone, chat, or contact forms, including inquiries, feedback, and support requests.
• Payment Information: While we do not directly store full payment card details (which are processed by secure payment gateways), we may collect billing addresses and transaction details.

2.2. Information We Collect Automatically (Website Usage Data):

• Device Information: IP address, browser type and version, operating system, device identifiers.
• Usage Data: Pages visited, time spent on pages, referral source, navigation paths, clicks, search queries, and other interaction data with our Website.
• Cookies and Tracking Technologies: We use cookies and similar tracking technologies to track activity on our Website and hold certain information. (See Section 6 for more details).

2.3. Information from Other Sources:

• We may receive information from third-party partners (e.g., analytics providers, marketing partners, business directories) to improve our services and marketing efforts, always in compliance with applicable data protection laws.

3. How We Use Your Personal Data

We use the personal data we collect for various purposes, primarily based on the necessity for our legitimate business interests, contractual obligations, or your consent, and in compliance with UAE PDPL.

3.1. To Provide and Manage Our Services:

• Processing your orders and delivering products.
• Managing your account and providing customer support.
• Sending order confirmations, invoices, and shipping notifications.
• Facilitating quotes, inquiries, and technical assistance.
• Providing maintenance, repair, and after-sales support for industrial equipment.

3.2. For Communication:

• Responding to your inquiries and feedback.
• Sending you administrative notices, security alerts, and service updates.
• With your consent, sending you marketing communications, newsletters, and promotional offers about our Products and Services.

3.3. For Website Improvement and Analytics:

• Monitoring and analysing Website usage and trends to improve user experience and functionality.
• Diagnosing and resolving technical issues.
• Conducting research and analysis to better understand our customer needs.

3.4. For Security and Legal Compliance:

• Protecting the security and integrity of our Website and business operations.
• Detecting and preventing fraud, unauthorized access, and other illegal activities.
• Complying with legal obligations, regulatory requirements, and requests from government authorities in the UAE.
• Enforcing our Terms and Conditions.

3.5. For Business Operations:

• Internal record keeping and administrative purposes.
• Business development, strategic planning, and performance analysis.

4. How We Share Your Personal Data

We may share your personal data with third parties in the following circumstances, always ensuring appropriate safeguards are in place and in compliance with UAE PDPL.

4.1. Service Providers:

• We engage trusted third-party service providers to perform functions on our behalf, such as:
  • Payment Processors: To securely handle online payments.
  • Shipping and Logistics Companies: To deliver your orders.
  • IT and Infrastructure Providers: For hosting, data storage, and technical support.
  • Marketing and Analytics Providers: To help us understand Website usage and improve our marketing campaigns.
• These service providers are contractually obligated to protect your data and only use it for the specific purposes we define.

4.2. Business Partners:

• We may share data with our business partners (e.g., manufacturers, distributors) when necessary to fulfil orders, provide joint services, or for co-marketing efforts, always with your consent where required.

4.3. Legal and Regulatory Requirements:

• We may disclose your personal data if required by law or in response to valid requests by public authorities (e.g., a court or government agency in the UAE).
• To protect our rights, property, or safety, or the rights, property, or safety of others.

4.4. Business Transfers:

• In the event of a merger, acquisition, or sale of all or a portion of our assets, your personal data may be transferred as part of that transaction. We will notify you via email and/or a prominent notice on our Website of any such change in ownership or control of your personal data.

4.5. With Your Consent:

• We may share your personal data with third parties when we have your explicit consent to do so.

5. International Data Transfers (Applicable to UAE PDPL)

Your personal data may be stored and processed in, and transferred to, countries outside the UAE where our service providers or partners are located. When we transfer your personal data outside the UAE, we will ensure that adequate safeguards are in place to protect your data, as required by Federal Decree-Law No. 45 of 2021 (PDPL). This includes using standard contractual clauses approved by the UAE data protection authority, or ensuring the recipient country has an adequate level of data protection recognized by the UAE.

6. Cookies and Tracking Technologies

Our Website uses “cookies” and similar tracking technologies (e.g., pixels, web beacons) to enhance your browsing experience and collect information about how you interact with our Website.

6.1. What are Cookies? Cookies are small data files placed on your device (computer, tablet, mobile) when you visit a website. They allow the website to remember your actions and preferences over time.

6.2. How We Use Cookies:

• Strictly Necessary Cookies: Essential for the Website to function correctly (e.g., enabling navigation, logging in, adding items to a cart).
• Analytical/Performance Cookies: Help us understand how visitors interact with our Website by collecting information about page visits, traffic sources, and errors. This helps us improve Website performance.
• Functionality Cookies: Allow the Website to remember choices you make (e.g., language preferences, region) and provide enhanced, more personal features.
• Targeting/Advertising Cookies: Used to deliver advertisements more relevant to you and your interests. They are also used to limit the number of times you see an advertisement and help measure the effectiveness of advertising campaigns.

6.3. Your Choices Regarding Cookies: You have the right to decide whether to accept or reject cookies. Most web browsers automatically accept cookies, but you can usually modify your browser settings to decline cookies if you prefer. However, disabling cookies may impact your experience on our Website, and some features may not function correctly. You can often find these settings in the “options” or “preferences” menu of your browser.

7. Data Security

We are committed to ensuring the security of your personal data. We implement appropriate technical and organizational measures designed to protect your data from unauthorized access, disclosure, alteration, and destruction, in line with UAE PDPL requirements. These measures include:

• Encryption of data during transmission (SSL/TLS).
• Secure storage solutions with access controls.
• Regular security assessments and updates.
• Employee training on data protection and privacy best practices.

Despite our efforts, no method of transmission over the internet or method of electronic storage is 100% secure. Therefore, we cannot guarantee its absolute security.

8. Data Retention

We will retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements. The retention period for specific types of data will be determined based on factors such as the nature of the data, the purpose of processing, and legal obligations under UAE law.

9. Your Data Protection Rights (Under UAE PDPL)

In accordance with Federal Decree-Law No. 45 of 2021 on Personal Data Protection (PDPL), you have the following rights regarding your personal data:

• Right to Access: You have the right to request access to your personal data that we hold, along with information about how we process it.
• Right to Rectification: You have the right to request that we correct any inaccurate or incomplete personal data we hold about you.
• Right to Erasure (Right to be Forgotten): You have the right to request the deletion of your personal data under certain circumstances (e.g., when the data is no longer necessary for the purposes for which it was collected, or if you withdraw consent and there is no other legal basis for processing).
• Right to Restriction of Processing: You have the right to request that we restrict the processing of your personal data under certain conditions (e.g., if you contest the accuracy of the data, or if the processing is unlawful).
• Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit that data to another controller, where technically feasible.
• Right to Object to Processing: You have the right to object to the processing of your personal data in certain situations (e.g., for direct marketing purposes).
• Right to Withdraw Consent: Where we rely on your consent to process your personal data, you have the right to withdraw that consent at any time. This will not affect the lawfulness of processing based on consent before its withdrawal.
• Right to Lodge a Complaint: You have the right to lodge a complaint with the relevant data protection authority in the UAE if you believe your rights under the PDPL have been violated.

To exercise any of these rights, please contact us using the details provided in Section 11. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.

10. Third-Party Websites

Our Website may contain links to other websites that are not operated by us. If you click on a third-party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

11. Contact Us

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

STEERX INDUSTRIAL SOLUTIONS TRADING L.L.C-FZ , Meydan Free Zone, 6th Floor, Nad Al Sheba 1, Dubai – U.A.E, info@steerx.ae, Mobile Number: +971 522844546.

12. Changes to This Privacy Policy

We may update our Privacy Policy from time to time to reflect changes in our practices, technology, or legal requirements (especially regarding new developments in UAE data protection laws). We will notify you of any changes by posting the new Privacy Policy on this page and updating the “Effective Date” at the top of this Privacy Policy. We encourage you to review this Privacy Policy periodically for any changes.

13. Children’s Privacy

Our Website and services are intended for individuals 18 years and older. We do not knowingly collect personal data from minors. If we become aware of any such collection, we will promptly delete it.

14. Data Breach Notification

In the event of a data breach that poses risks to your rights and freedoms, we will:

• Notify the UAE Data Protection Authority within 96 hours
• Inform affected individuals without undue delay
• Provide clear information about the breach and our response
• Take immediate steps to contain and remedy the breach

15. Governing Law

This Privacy Policy is governed by the laws of the United Arab Emirates, including UAE Federal Law No. 45 of 2021 on the Protection of Personal Data and other applicable UAE regulations.

Any disputes arising from this policy will be subject to the exclusive jurisdiction of the UAE courts.

Acknowledgment: By using our website or engaging with our services, you acknowledge that you have read, understood, and agree to this Privacy Policy and our data processing practices as described herein.