Privacy Policy

Last updated: 26 August 2026

1. CONTROLLER

1.1. This Privacy Policy explains how DIGITAL AZBA MARKETPLACE FZCO, a free zone company incorporated in the Dubai Airport Free Zone, Dubai, United Arab Emirates, trading under the brand “AZBA” (“AZBA”, “we”, “us”, “our”), collects, uses, stores, discloses and protects personal data of users of the AZBA platform (the azba.ae website and the AZBA mobile applications, together the “Platform”). 1.2. DIGITAL AZBA MARKETPLACE FZCO is the data controller within the meaning of UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (the “PDPL”). Registered address: Premises 137 9WC 524, Fifth Floor, Building 9WC, Dubai Airport Free Zone, Dubai, United Arab Emirates. Full registration and licence details are set out in Section 13. 1.3. This Policy applies together with the AZBA Terms of Use. It does not apply to any third-party website, application or service you reach from the Platform, nor to the processing carried out by any Seller in respect of your data once you contact them directly. 1.4. Contact for all data protection matters: privacy@azba.ae

2. DATA WE COLLECT

2.1. Data you provide: • Account data: name, mobile number, e-mail address, profile photo, interface language, password credentials in hashed form. • Listing data: photographs, descriptions, prices, item and vehicle specifications, location at emirate or area level, contact details you choose to display. • Communications: in-Platform chat messages, including machine translations of them; support requests and correspondence; reviews and ratings you submit. • Verification data, where a function requires it: identity or licence documents you upload at our request, such as Emirates ID, passport, trade licence or vehicle ownership documents. 2.2. Data generated by your use: • Technical data: device type and model, operating system and version, application version, IP address, push-notification identifiers, crash and diagnostic reports, access and usage logs, timestamps. • Activity data: views, searches, filters, favourites, listing interactions, session data. • Service Balance data: top-ups, charges and transaction records on your internal service account. These records relate solely to payments made to AZBA for its own Paid Services. AZBA holds no record of any payment between a Buyer and a Seller, because it does not receive or process such payments. 2.3. Data from third parties: confirmation of payment status from our payment service providers; information contained in complaints or reports submitted about you by other users or by rights holders; information received from competent authorities. 2.4. AZBA does not collect or store payment card numbers or bank account details. Card payments are processed by third-party payment service providers under their own terms. 2.5. AZBA does not collect precise geolocation from your device. Location is recorded at emirate or area level from what you enter. 2.6. AZBA does not seek sensitive personal data within the meaning of the PDPL, and you must not submit it. Do not include health, religious, political, biometric or similar information in listings, chats, reviews or support requests. Where such data nonetheless reaches us because a User has submitted it, we process it only where a lawful basis under the PDPL exists, restrict access to it, and delete it where it is not required for a lawful purpose.

3. PURPOSES AND LEGAL BASES

We process personal data on the following bases under the PDPL: (a) Performance of our contract with you (Terms of Use): creating and administering your account; publishing, displaying and searching listings; operating the chat function; providing Paid Services and maintaining the Service Balance; providing support. (b) Compliance with legal obligations under UAE law: tax and accounting record-keeping; responding to lawful requests from competent authorities; retention required by law; obligations applicable to platforms under UAE legislation on trading by modern technological means and consumer protection. (c) Our legitimate interests, and the interests of our users, in a safe and functioning platform: fraud detection and prevention; identification and blocking of prohibited, counterfeit, stolen or unlawful listings; abuse, spam and bot detection; account security; investigation of complaints; establishment, exercise and defence of legal claims; service improvement, aggregated analytics and capacity planning; protection of our rights and property. We balance these interests against your rights and you may object as set out in Section 7. (d) Your consent, where required: push notifications; marketing and promotional communications; any optional processing identified as consent-based at the point of collection. Consent may be withdrawn at any time in the application settings or by writing to privacy@azba.ae. Withdrawal does not affect the lawfulness of processing before withdrawal.

4. PERSONALISATION AND AUTOMATED PROCESSING

4.1. We use activity data to rank, sort and personalise search results and recommendations, and to select which listings and notifications are shown to you. This is an automated process based on your interactions with the Platform. 4.2. We use automated rules and filters to detect suspicious activity, fraud indicators, duplicate accounts and prohibited content. Automated detection may result in a listing or account being flagged, restricted or temporarily suspended. 4.3. Decisions with a legal effect on you or which seriously affect you are not taken solely by automated means. Where an automated process results in restriction or suspension of your account, you may request human review by writing to privacy@azba.ae, and a member of our team will review the decision. 4.4. You may object to personalisation of results as set out in Section 7. Objection does not affect processing necessary for security and fraud prevention.

5. DISCLOSURE TO THIRD PARTIES

5.1. We do not sell personal data and do not share it for third-party advertising purposes. 5.2. Data may be disclosed to: (a) Processors acting on our documented instructions under written data processing agreements: cloud hosting and database providers; content delivery networks; our software development and technical maintenance partner; push-notification and messaging providers; crash reporting and product analytics providers; payment service providers; e-mail and SMS delivery providers; machine translation providers used for the chat function. (b) Other users, to the extent you publish it yourself. Listing content is public by nature. Your seller name, the contact details you display, your listing content and your reviews are visible to any visitor and may be indexed by search engines and copied or cached by third parties beyond our control. (b1) Separate controllers. Where you contact a Seller or service provider through the Platform, or submit an enquiry to one, that Seller or service provider may act as an independent data controller in respect of the data you provide to them and its own purposes. Their processing is governed by their own policies and is outside AZBA’s control and responsibility. The same applies to any data you exchange with another User outside the Platform. (c) Competent UAE authorities, courts and regulators, where there is a lawful request or where disclosure is necessary to comply with a legal obligation, to prevent or investigate crime or fraud, or to protect the rights, property or safety of AZBA, our users or the public. (d) Professional advisers, including lawyers, auditors and insurers, under duties of confidentiality. (e) An acquirer or successor, in connection with any merger, acquisition, restructuring, financing or sale of business or assets, subject to equivalent protection. 5.3. We require every processor to apply appropriate technical and organisational safeguards, to process only on our instructions, to maintain confidentiality, and to delete or return data at the end of the engagement.

6. INTERNATIONAL TRANSFERS

6.1. Some of our infrastructure and service providers process data on servers located outside the United Arab Emirates. 6.2. Such transfers are made in accordance with Articles 22 and 23 of the PDPL: to jurisdictions recognised as providing an adequate level of protection, or, where no such recognition applies, subject to contractual safeguards imposing protection equivalent to that required under UAE law, or on another basis permitted by the PDPL. 6.3. You may request information on the safeguards applied by writing to privacy@azba.ae.

7. YOUR RIGHTS

7.1. Subject to the conditions and exceptions in the PDPL, you have the right to: • obtain information about our processing of your data and access to that data, and to receive a copy; • request rectification of inaccurate or incomplete data; • request erasure of your data; • request restriction of processing, or object to processing carried out on the basis of legitimate interests, including personalisation; • withdraw consent where processing is based on consent; • receive data you provided to us in a structured, commonly used, machine-readable format, and to have it transmitted to another controller where technically feasible; • request human review of a decision reached by automated means as described in Section 4; • object to the use of your data for direct marketing. 7.2. To exercise any right, write to privacy@azba.ae, or use the request form in the application settings. You may also raise the matter through the “AZBA Support” chat, but a request sent to privacy@azba.ae will always be treated as formally received. 7.3. We may ask you to verify your identity before acting, in order to prevent unauthorised disclosure. We respond without undue delay and within the timeframes required by applicable UAE law. 7.4. Certain rights are qualified. We may decline or limit a request where the data is required for the performance of a contract, for compliance with a legal obligation, for the establishment or defence of legal claims, for fraud prevention, or where the request would adversely affect the rights of others. Where we decline, we will explain why. 7.5. Deletion of your account does not delete published listing content that has been copied, cached or indexed by third parties, and does not delete records we are required to retain under Section 8. 7.6. You have the right to lodge a complaint with the UAE Data Office. We ask that you contact us first at privacy@azba.ae so that we can address the matter directly.

8. RETENTION

8.1. We retain personal data only as long as necessary for the purposes for which it was collected: • Account data: while the account is active, and for a limited period after closure to permit reactivation, resolve outstanding matters and prevent re-registration for the purpose of evading a ban. • Listing data: while published, and thereafter in archive for the purpose of handling complaints and legal claims. • Chat messages: for the period necessary to handle disputes, complaints and fraud investigations, after which they are deleted or anonymised. • Transaction and Service Balance records: for the period required by UAE tax and accounting law. • Verification documents: for the period required to satisfy the legal obligation that prompted their collection, and no longer. • Technical and usage logs: for a limited period in identifiable form, after which they are aggregated or anonymised. • Records relating to complaints, bans, fraud and unlawful conduct: for as long as necessary for the establishment, exercise or defence of legal claims and for platform security. 8.2. After the applicable period, data is deleted or irreversibly anonymised.

9. SECURITY

9.1. We apply technical and organisational measures appropriate to the risk, including encryption of data in transit, access control at row level in the database, role-based access limitation for staff and contractors, authentication controls, logging and monitoring, and regular infrastructure updates. 9.2. Access to personal data by our personnel and contractors is limited to those who require it for their function and is subject to confidentiality obligations. 9.3. No system can guarantee absolute security. You are responsible for keeping your credentials and device secure and for the information you choose to publish or share with other users. 9.4. In the event of a personal data breach that would prejudice your privacy, confidentiality or security, we will notify the UAE Data Office and, where required, affected users, in accordance with the PDPL and within the timeframes it requires.

10. MINORS AND CHILD DIGITAL SAFETY

10.1. The Platform is intended exclusively for persons aged 18 and over. It is not directed at children, is not designed to appeal to children, and offers no content, feature or functionality intended for them. 10.2. We do not knowingly collect, process, publish or share the personal data of persons under 18. We apply age-declaration and, where appropriate, further age-assurance measures proportionate to the risk profile of the Platform, and we keep those measures under review. 10.3. Where we have reasonable grounds to believe that an account belongs to a person under 18, we may restrict or close the account and delete the associated data, to the extent permitted by law. 10.4. We do not profile persons under 18, do not direct marketing at them, and do not use design features intended to encourage prolonged or compulsive use by children. 10.5. If you become aware that a person under 18 has provided us with data, or that any content on the Platform poses a risk to a child, contact privacy@azba.ae and we will act without undue delay. 10.6. This Section is applied having regard to Federal Decree-Law No. 26 of 2025 on Child Digital Safety and any implementing decisions issued under it.

11. COOKIES, STORAGE AND SIMILAR TECHNOLOGIES

11.1. The web version uses cookies and local storage that are strictly necessary for the service — session and authentication, language and interface settings, security, and caching — and cookies used for aggregated product analytics. 11.2. The mobile applications use on-device storage for caching and preferences, push-notification identifiers, and software development kits for crash reporting and product analytics. 11.3. We do not use third-party advertising or ad-retargeting trackers. If this changes, we will update this Policy and, where required, obtain your consent before any such technology is activated. 11.4. You may restrict cookies through your browser and disable push notifications and analytics permissions through your device settings. Restricting strictly necessary cookies may prevent the Platform from functioning.

12. CHANGES TO THIS POLICY

12.1. We may update this Policy. The date of the current version appears at the top. Material changes will be notified through the Platform or by e-mail before they take effect. Continued use after the effective date constitutes acknowledgement of the updated Policy. Where a change requires consent under the PDPL, we will obtain it.

13. CONTACT

DIGITAL AZBA MARKETPLACE FZCO Premises 137 9WC 524, Fifth Floor, Building 9WC Dubai Airport Free Zone, Dubai, United Arab Emirates Registration No. RNo-03280 | Licence No. 07519 Data protection: privacy@azba.ae General support: support@azba.ae Legal and complaints: legal@azba.ae © DIGITAL AZBA MARKETPLACE FZCO. “AZBA” is a brand of DIGITAL AZBA MARKETPLACE FZCO. All rights reserved.