Privacy Policy

Effective Date: January, 2025
Last Updated: September, 2025

1. Introduction

This Privacy Policy explains how Essential Tobacco FZE (“Company,” “we,” “our,” “us”), manufacturer and distributor of the KOLDMARK brand, collects, processes, and safeguards personal data when you access or use our website (the “Site”), submit inquiries, or engage in partnerships.

We are committed to protecting your privacy and handling your personal data in compliance with:

• UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (PDPL),
• EU General Data Protection Regulation (GDPR), and
• Other applicable international data protection laws.

By using this Site, you consent to the collection and processing of your data in accordance with this Policy.

2. Data Controller

The data controller for your personal data is:

Essential Tobacco FZE
Building S10109, JAFZA South, Dubai, United Arab Emirates
Email: info@essentialtobacco.com

3. Information We Collect

We may collect the following types of information:

3.1 Personal Information

• Name, email address, company name, phone number, market/region, and message content when you contact us.

3.2 Technical Information

• IP address, browser type, device details, operating system, and browsing activity collected through cookies or similar technologies.

3.3 Business Information

• Partnership inquiries, contract manufacturing requests, and distributor details provided via contact forms or direct communications.

4. Legal Basis for Processing

We process personal data under the following legal bases:

• Consent: When you submit data through forms or inquiries.
• Legitimate Interest: For communication with partners, maintaining Site functionality, and ensuring lawful business operations.
• Legal Obligation: To comply with regulatory requirements in the UAE and international markets.

5. How We Use Data

Your personal data may be used for the following purposes:

• To respond to inquiries, partnership requests, and distribution opportunities.
• To manage and fulfill contractual relationships.
• To improve the Site, ensure security, and analyze usage.
• To comply with applicable tobacco, nicotine, trade, and regulatory laws.
• For internal record-keeping and audit purposes.

6. Sharing of Data

6.1 We may share personal data with:

• Service providers (IT, hosting, analytics, logistics) acting under confidentiality agreements.
• Regulatory authorities, where disclosure is required by law.
• Business partners, only where necessary for contract execution.

6.2 We do not sell, trade, or rent personal data to third parties.

7. International Data Transfers

Where personal data is transferred outside the UAE, we ensure compliance with applicable laws, including:

• Adequacy decisions for jurisdictions recognized under UAE PDPL or GDPR.
• Standard contractual clauses or explicit consent from the data subject.

8. Data Retention

We retain personal data only as long as necessary to fulfill its purpose:

• Inquiry and partnership data: up to 24 months unless legally required longer.
• Contractual and regulatory records: as required by UAE law.
• Technical data (cookies/analytics): per cookie retention policy (see Section 11).

9. Security Measures

We employ appropriate technical and organizational safeguards, including encryption, firewalls, secure hosting, and access controls. Regular audits are conducted to ensure compliance.

10. Your Rights

In accordance with UAE PDPL, GDPR, and other applicable laws, you have the right to:

• Access your personal data.
• Request correction or deletion of inaccurate data.
• Restrict or object to processing.
• Request data portability.
• Withdraw consent at any time, without affecting prior lawful processing.

Requests must be submitted to: info@essentialtobacco.com. We will respond within legally mandated timeframes.

11. Cookies

11.1 This Site uses cookies to:

• Enable essential website functionality.
• Improve user experience and analyze performance.

11.2 By continuing to browse, you consent to the use of cookies. Non-essential cookies can be disabled in browser settings.

12. Children’s Privacy

Our products and services are not intended for minors under 18. We do not knowingly collect data from children. Any information inadvertently collected will be deleted promptly.

13. Links to Third-Party Sites

The Site may contain links to external websites. We are not responsible for the privacy practices or content of such websites.

14. Updates to This Policy

We may update this Privacy Policy to reflect changes in law, technology, or business operations. Updates will be published on this page with the “Last Updated” date clearly indicated.

15. Contact Information

For questions or concerns about this Privacy Policy, please contact:

Data Protection Officer Essential Tobacco FZE Building S10109, JAFZA South, Dubai, United Arab Emirates

Email: info@essentialtobacco.com