Privacy Policy

1. General

A N E R MANAGEMENT CONSULTANCIES L.L.C (hereinafter the “Company”, “we”, “us” or “our”), registered with the Department of Economy and Tourism of Dubai (Licence No. 1344205, Commercial Register No. 2282847, Dubai Chamber of Commerce membership No. 530737), respects your privacy and is committed to protecting the personal data you provide when visiting or interacting with the website www.aner.ae (hereinafter the “Website”).

This Privacy Policy (hereinafter the “Policy”) explains what personal data we collect, how and on what legal basis we process it, to whom we disclose it, how we protect it, and what rights you have as a data subject. This Policy has been prepared in accordance with the applicable laws of the United Arab Emirates, including Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (PDPL) and its implementing regulations.

2. Personal Data We Collect

We collect personal data in two categories.

2.1. Data you provide directly

When you complete a contact form on the Website or reach out to us by email, we collect:

your name;
your email address;
your telephone number.

Any other data (such as a company name or the content of your enquiry) is processed only where you choose to provide it to us on your own initiative.

2.2. Data collected automatically

When you visit the Website, and subject to your consent, we may automatically collect technical and usage data through cookies and web analytics services:

IP address;
browser type and version, operating system, device type and screen settings;
cookie identifiers and device identifiers;
pages visited, referral source and activity on the Website.

Please note: these technical identifiers (including IP address and cookie identifiers) qualify as personal data under applicable law, as they allow a specific user to be singled out and re-identified even where the user’s name is not known to us.

2.3. Payment data

The Website does not process online payments and does not collect payment card data. Payment for our services is made off the Website (for example, by bank transfer) on the basis of separately issued documents.

3. Legal Basis for Processing

We process your personal data where at least one of the following legal bases applies:

your consent — in particular, for the use of cookies, web analytics services and cross-border transfers of data;
the need to respond to your enquiry — handling requests submitted through the Website forms or by email;
the Company’s legitimate interests — ensuring the functionality and security of the Website and analysing and improving its performance;
compliance with legal obligations — meeting obligations imposed by the laws of the UAE.

4. Cookies and Web Analytics

We use cookies and similar technologies to operate the Website and to analyse its traffic. Cookies fall into the following categories:

strictly necessary — required for the basic functioning of the Website; used without consent;
analytics — used to measure traffic and user behaviour; used only after your consent has been obtained.

Analytics and other non-essential cookies, as well as the web analytics services connected to the Website, are activated only after you have given consent through the cookie management banner on your first visit. You may change or withdraw your consent at any time through the banner settings or your browser settings.

4.1. Web analytics services

To analyse Website traffic we use the following third-party services:

Google Analytics— a service provided by Google LLC (United States). The service collects data on interaction with the Website using cookies and transfers it to Google servers located outside the UAE. For more information: policies.google.com/privacy.
Yandex Metrica— a service provided by YANDEX LLC (Russian Federation). The service collects data on interaction with the Website and transfers it to servers located outside the UAE. Where the session recording feature is used, it operates with form-field masking, so the content entered into forms is not recorded. For more information: yandex.com/legal/confidential.

Use of these services involves the transfer of data outside the UAE (see Section 6). You may decline consent to analytics cookies, in which case these services will not be activated on the Website.

5. Purposes of Processing

We use the collected data for the following purposes:

providing our services and responding to your enquiries and requests;
informing you about services, offers and consultations (where you have given consent);
analysing Website traffic and performance and improving its content and usability;
ensuring the security of the Website and preventing fraud;
complying with obligations imposed by the laws of the UAE.

6. Cross-Border Transfer of Data

As a result of using web analytics services, your personal data (including technical identifiers) is transferred to and processed outside the United Arab Emirates, namely:

to the United States — when Google Analytics is used;
to the Russian Federation — when Yandex Metrica is used.

Such cross-border transfers are carried out in accordance with Articles 22–23 of Federal Decree-Law No. 45 of 2021. The legal basis for the transfer is your explicit consent, given through the cookie management banner. We take reasonable steps to ensure that recipients of the data provide an adequate level of protection for it. If you do not consent to analytics cookies, no cross-border transfer of data on these grounds takes place.

7. Disclosure of Data to Third Parties

We do not sell or rent your personal data. We may disclose data only to the following categories of recipients:

service providers acting on our behalf (hosting, web analytics, IT support), with whom appropriate confidentiality and data protection agreements are in place;
government authorities — in the cases and to the extent required by the laws of the UAE;
legal and other professional advisers — in the event of disputes or investigations.

8. Data Retention

We retain personal data for no longer than is necessary for the purposes set out in this Policy, or for the period required by applicable legal, tax or regulatory requirements. In particular:

contact data received through forms or by email — for 24 months from the last interaction, unless a longer period is required by law;
web analytics data — for the period set by the relevant service’s settings, but no longer than 26 months.

Upon expiry of the retention period, the data is deleted or anonymised.

9. Your Rights

In accordance with the laws of the UAE, you have the right to:

access your personal data and obtain information about its processing;
request the correction or updating of inaccurate or incomplete data;
request the deletion of your personal data, subject to the limitations provided by law;
withdraw consent previously given, including consent to the use of cookies and cross-border transfers;
object to the processing of your data or request that it be restricted;
lodge a complaint with the competent UAE data protection authority.

To exercise these rights, please send a request to info@aner.ae. We will address your request within the time limits provided by law.

10. Security Measures

We apply reasonable technical and organisational measures to protect personal data against unauthorised access, disclosure, alteration or destruction, including restricting access to data and using secure transmission channels. However, no method of transmitting data over the internet is entirely secure, and we cannot guarantee the absolute security of the data.

11. Children’s Data

The Website and our services are intended for individuals aged 18 and over. We do not knowingly collect the personal data of minors. If we become aware that data relating to a minor has been obtained without appropriate consent, such data will be deleted.

12. Changes to This Policy

We may update this Policy from time to time. The current version is published on this page with the new effective date indicated. We recommend that you review this Policy periodically.

13. Contact Information

For any questions regarding this Policy or the processing of your personal data, please contact:

A N E R MANAGEMENT CONSULTANCIES L.L.C

Office 9-2802, Al Thanya First, Dubai, United Arab Emirates

Email: info@aner.ae

Phone: +971 56 2439591

Website: www.aner.ae