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PRIVACY POLICY

Effective date: 1 October 2026

This Privacy Policy explains how Ale Pietrocola FZE collects, uses, stores and shares personal data when you visit booking.alepietrocola.com, contact us, book a consultation or private meeting, or otherwise interact with our services.

1. Data Controller

The controller responsible for your personal data is:
Ale Pietrocola FZE
Trade License No. 4422663.01
Business Centre, Sharjah Publishing City Free Zone,Sharjah, United Arab Emirates
References to “we”, “us” or “our” mean Ale Pietrocola FZE.

2. Scope of This Policy

This Policy applies to personal data collected through:
  • this Website;
  • booking and scheduling forms;
  • online and in-person consultations;
  • email, telephone and messaging applications;
  • payment and invoicing processes;
  • enquiries and customer-support communications; and
  • related interactions with Ale Pietrocola FZE.
A separate privacy notice or engagement agreement may apply if you proceed with corporate, legal, tax, immigration, accounting, compliance or other services through Ale Pietrocola FZE or an affiliated company.

3. Personal Data We Collect

Depending on how you interact with us, we may collect the following categories of personal data.

3.1 Identity and contact information

This may include:
  • full name;
  • email address;
  • telephone or WhatsApp number;
  • country of residence;
  • nationality;
  • company name and job title; and
  • preferred language and communication method.

3.2 Booking information
This may include:
  • selected consultation or meeting package;
  • booking date, time and time zone;
  • answers submitted through the booking form;
  • meeting preferences;
  • rescheduling or cancellation history; and
  • correspondence concerning the booking.

3.3 Payment and transaction information

This may include:
  • amount and currency paid;
  • payment date and status;
  • billing name and address;
  • invoice and transaction references; and
  • limited payment-method information provided by the payment processor.
Payments may be handled by an independent payment provider. We do not normally receive or store your complete payment-card number or card security code.

3.4 Consultation information

You may voluntarily provide information about:
  • your business and professional activities;
  • corporate ownership or management;
  • personal or family relocation plans;
  • assets, income, investments or source of funds;
  • tax residence and immigration status;
  • banking or financial objectives;
  • legal, regulatory or commercial issues; and
  • other information relevant to your requested consultation.
Please do not provide more personal or sensitive information than reasonably necessary.

3.5 Compliance information

If you proceed with services requiring client due diligence, we or the relevant service provider may request:
  • passport or other identity documents;
  • proof of residential address;
  • date and place of birth;
  • citizenship and residency information;
  • corporate documents and ownership information;
  • source-of-funds or source-of-wealth information;
  • politically exposed person or sanctions information; and
  • other information required by applicable anti-money laundering, sanctions or regulatory rules.
Where another entity becomes responsible for providing the requested service, you will be informed of that entity’s role and applicable terms.

3.6 Technical and Website information

When you use the Website, certain information may be collected automatically, including:
  • IP address;
  • browser and device type;
  • operating system;
  • approximate location based on IP address;
  • pages visited and time spent on the Website;
  • referring website;
  • cookie identifiers; and
  • diagnostic, security and error information.

3.7 Communications

We may retain copies of emails, WhatsApp messages, contact-form submissions, complaints, feedback and other communications.
Consultations are not recorded unless participants are informed in advance and any consent required by law has been obtained.

4. How We Collect Personal Data

We collect personal data:
  • directly from you;
  • from a person booking on your behalf;
  • through booking, payment and communication platforms;
  • from affiliated companies involved in your enquiry;
  • from publicly available sources where relevant and lawful;
  • from professional advisers or service providers authorised by you; and
  • automatically through cookies and similar technologies.
If you provide personal data concerning another person, you confirm that you are authorised to provide it and, where required, that you have informed them about this Policy.

5. Purposes and Legal Bases

We process personal data for the following purposes.

5.1 To manage bookings and provide services

We use personal data to:
  • schedule and confirm consultations;
  • process payments;
  • communicate before and after a meeting;
  • understand your objectives;
  • conduct research;
  • provide recommendations and reports;
  • issue vouchers or service credits; and
  • manage cancellations, rescheduling and complaints.
This processing is necessary to perform our contract with you or to take steps requested by you before entering into a contract.

5.2 To administer our business

We process information for invoicing, accounting, internal administration, service improvement, fraud prevention, dispute management and recordkeeping.
This processing is based on contractual necessity, legal obligations and our legitimate interests in operating and protecting our business.

5.3 To meet legal and compliance obligations

We may process personal data to comply with:
  • tax and accounting requirements;
  • anti-money laundering and sanctions obligations;
  • lawful requests from authorities;
  • court orders;
  • regulatory requirements; and
  • obligations to establish, exercise or defend legal claims.

5.4 To communicate and market our services

With your consent where required, we may send information about relevant services, events, content or offers.
You may unsubscribe at any time by using the unsubscribe option in the message or contacting us. Withdrawing consent does not affect processing that occurred before withdrawal.
We do not sell personal data to third parties.

5.5 To operate and secure the Website

We may process technical information to:
  • deliver Website content;
  • remember preferences;
  • detect and prevent fraud or misuse;
  • maintain security;
  • diagnose technical problems;
  • understand Website performance; and
  • improve navigation and user experience.
Necessary processing is based on our legitimate interests and the operation of the Website. Non-essential cookies or advertising technologies will be used with consent where required.

5.6 With your consent

Where processing depends on consent, you may withdraw your consent at any time. Withdrawal does not affect the lawfulness of processing completed before consent was withdrawn.

6. Sensitive Personal Data

Information provided during a consultation may reveal financial circumstances, identity-document information or other sensitive matters.
We process sensitive information only where:
  • it is necessary to provide a service requested by you;
  • you have provided the required consent;
  • processing is required or permitted by law;
  • it is necessary for compliance or legal claims; or
  • another valid legal basis applies.
We ask that you do not send sensitive documents through unsecured channels unless requested.

7. Cookies and Similar Technologies

The Website and integrated third-party services may use cookies or similar technologies.

7.1 Necessary cookies

These cookies are required for essential functions such as security, booking functionality, payment processing and remembering privacy choices.

7.2 Analytics cookies

Where used, analytics cookies help us understand how visitors use the Website and improve its performance.

7.3 Third-party and embedded-service cookies

Booking, video, payment, map, social-media or other embedded services may place their own cookies when you interact with them.
Where legally required, non-essential cookies will not be activated until you provide consent. You may withdraw or change your consent through the Website’s cookie settings.
You can also restrict cookies through your browser, although doing so may affect Website or booking functionality.

8. Recipients of Personal Data

We may share personal data, where reasonably necessary, with:
  • employees and authorised consultants;
  • companies affiliated with Ale Pietrocola FZE;
  • booking and scheduling providers, including Calendly;
  • Website hosting and website-building providers;
  • payment processors and banks;
  • email, cloud-storage, video-conferencing and messaging providers;
  • accountants, auditors, lawyers and compliance advisers;
  • identity-verification and due-diligence providers;
  • travel or venue providers where necessary for an in-person meeting;
  • government, regulatory, judicial or law-enforcement authorities where legally required; and
  • a purchaser or successor in connection with a lawful business restructuring or transfer.
Service providers are authorised to process personal data only for the relevant service or as otherwise permitted by their own lawful role and applicable terms.
If you proceed with services from an affiliated company, relevant information may be shared with that company so it can assess or perform the proposed engagement.

9. International Transfers

Because we serve international clients and use international technology providers, personal data may be transferred to or accessed from countries outside the UAE or your country of residence.
Where required, we use appropriate measures for international transfers, which may include:
  • contractual data-protection obligations;
  • transfers to jurisdictions recognised as providing adequate protection;
  • obtaining consent where appropriate;
  • limiting access to information;
  • encryption and other security measures; or
  • another transfer mechanism permitted by applicable law.

10. Data Retention

We retain personal data only for as long as reasonably necessary for the purposes for which it was collected and to satisfy legal, accounting, compliance and dispute-resolution requirements.
Ordinarily:
  • booking and transaction records may be retained for up to seven years;
  • consultation correspondence and deliverables may be retained for up to seven years after the last substantive interaction;
  • unsuccessful or general enquiries may be retained for up to two years;
  • compliance and due-diligence records may be retained for the period required by applicable law;
  • marketing information is retained until you unsubscribe or the information is no longer required; and
  • cookie data is retained according to the duration stated in the relevant cookie settings.
Information may be retained longer where required by law, a regulatory authority, an ongoing dispute or the establishment, exercise or defence of legal claims.
When no longer required, personal data will be deleted, anonymised or securely destroyed.

11. Data Security

We use reasonable technical and organisational measures intended to protect personal data against accidental or unlawful loss, alteration, disclosure, destruction or unauthorised access.
These measures may include:
  • access restrictions;
  • authentication controls;
  • secure cloud systems;
  • encryption where appropriate;
  • confidentiality obligations;
  • staff and contractor access controls; and
  • periodic review of service providers and security practices.
No internet transmission or electronic storage system is completely secure. You should use caution when sending sensitive information electronically.

12. Your Rights

Subject to applicable law and relevant exceptions, you may have the right to:
  • obtain information about how your personal data is processed;
  • request access to your personal data;
  • request correction of inaccurate or incomplete information;
  • request deletion of personal data;
  • request restriction or suspension of processing;
  • object to certain processing;
  • withdraw consent;
  • object to direct marketing;
  • receive or transfer certain personal data in a structured and machine-readable format;
  • object to decisions based solely on automated processing where they have legal or similarly significant effects; and
  • submit a complaint to the competent data-protection authority.
These rights may be restricted where processing is necessary to comply with law, protect another person’s rights, preserve legal privilege, fulfil regulatory obligations or establish, exercise or defend legal claims.

13. Exercising Your Rights

You may submit a request to exercise your privacy rights through our Notices and Complaints page by selecting “Privacy Request” as the reason for submission.
Please provide your name, contact details, the nature of your request and sufficient information for us to identify the relevant personal data.
We may request additional information reasonably necessary to verify your identity and protect personal data from unauthorised access or disclosure. We will respond within the period required by applicable law.
We will not ordinarily charge a fee, but may charge a reasonable fee or refuse a request where legally permitted and the request is manifestly unfounded, repetitive or excessive.

14. Marketing Communications

We may send marketing communications where you have consented or where otherwise permitted by law.
You may opt out at any time by:
  • selecting the unsubscribe option in an email;
  • replying “STOP” or using the available opt-out method in a message; or
  • submitting a request through our Notices and Complaints page.
You may continue to receive non-marketing communications concerning an active booking, payment, service or legal obligation.

15. Automated Decision-Making

We do not ordinarily make decisions producing legal or similarly significant effects based solely on automated processing.
If this changes, we will provide the information and safeguards required by applicable law.

16. Children

The Website and services are intended for adults. We do not knowingly collect personal data directly from children under 18 through the Website.
Information about children may sometimes be relevant to family relocation, residency or citizenship services. Such information should be provided only by a parent, guardian or other properly authorised adult and only where necessary.
If you believe a child has provided personal information without appropriate authorisation, please contact us.

17. Third-Party Websites and Platforms

The Website may link to third-party websites and services, including booking, payment, video-conferencing and social-media platforms.
Those providers may act as independent controllers of personal data and maintain their own privacy policies. We recommend reviewing their policies before providing personal data.
We are not responsible for the privacy practices of independent third parties.

18. Complaints

If you have a concern about how we process personal data, please contact us first so that we can investigate and respond.
You may also have the right to complain to the UAE Data Office or another competent supervisory authority in your country, where applicable.

19. Changes to This Policy

We may update this Privacy Policy to reflect changes in our services, technology or legal obligations.
The updated version will be published on the Website with a revised effective date. Material changes may also be communicated through an additional notice where appropriate.

20. Contact Us

For privacy questions, requests or complaints, please use our Notices and Complaints page and select “Privacy Request” as the reason for submission.

Please do not submit identity documents or other sensitive personal data unless specifically requested by us through an appropriate secure channel.

Ale Pietrocola FZE
Trade Licence No. 4422663.01
Business Centre, Sharjah Publishing City Free Zone
Sharjah, United Arab Emirates