Privacy Policy
Our privacy policy governs our privacy practices when you are using this website, any subdomains, and our mobile application(s), hereinafter and collectively referred to as the Platform.
We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint.
This Privacy Policy applies to all users of our Platform regardless of their location and is designed to comply with the Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data in the United Arab Emirates (UAE PPD), the UK General Data Protection Regulation (UK GDPR), the UK Data Protection Act of 2018, the EU General Data Protection Regulation (EU GDPR) and other applicable global privacy laws. These regulations govern how we process, store, and protect your personal data, ensuring compliance with international privacy standards.
Key terms
It would be helpful to start by explaining some key terms used in this policy:
| Term | Meaning |
|---|---|
| We, us, our, Kobray | Kobray Portal and our group companies |
| Data Controller | Kobray Portal, a company registered in Dubai, United Arab Emirates under Trade Licence number 1156632. |
| Personal data | Any information relating to an identified or identifiable individual collected directly from users through our Platform |
| Special category personal data | Personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership Genetic data Biometric data (where used for identification purposes) Data concerning health, sex life or sexual orientation |
| Data subject, you, your, user | The individual who the personal data relates to |
| Member | Any User who has registered an account with us and has purchased or subscribed to a Kobray subscription plan |
| Buyer | Any Member or User that purchases or intends to purchase Products through the Platform |
| Seller | Any Member that lists, advertises, or offers Products through the Platform |
| User, you, your | Any person or entity accessing or using our Platform |
Capitalised terms used but not defined in this Privacy Policy have the meaning given to them in our Terms and Conditions.
Personal data we collect about you
We will collect and use the following personal data about you:
- your name, complete address, contact information, including email address and telephone number and company details
- information to check and verify your identity, eg your date of birth
- your gender, if you choose to give this to us
- location data, if you choose to give this to us
- your billing information, transaction and payment card information
- your personal or professional interests
- your professional online presence, eg LinkedIn profile
- information from accounts you link to us, eg Facebook, Gmail
- information to enable us to undertake credit or other financial checks on you
- information about how you use our Platform, IT, communication and other systems
- data relating to and/or derived from the operation of our products and services
- IP address, browser type, operating system, device identifiers, and other usage data
- your responses to surveys, competitions and promotions
- your testimonials, social media posts, comments, feedback, etc
Personal Data We Collect — Sellers
In addition to the general data listed above, where you register as a Seller we may collect:
- your business registration documents and trade licence details;
- your bank account or payment details for the purpose of remitting funds;
- details of the Products you list on the Platform, including descriptions, pricing, and images;
- KYC documentation where required for compliance purposes;
- your subscription plan details and billing history.
Personal Data We Collect — Buyers
In addition to the general data listed above, where you register as a Buyer we may collect:
- your order history and transaction records;
- your delivery or shipping address details;
- your payment information for the purpose of processing purchases through the Platform.
We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below. If you do not provide personal data we ask for, it may delay or prevent us from providing products and services to you.
How your personal data is collected
We collect personal data from you, in person, by telephone, text or email and/or via our Platform. However, we may also collect information regarding you:
- from a third party with your consent, eg your bank, or social media platforms;
- from cookies on our Platform, for more information on our use of cookies, please see below our cookie policy;
- via our IT systems, eg through automated monitoring of our Platforms and other technical systems, such as our computer networks and connections, communications systems, email and instant messaging systems.
Use and Sharing of Google User Data
If you use our services through a Google-integrated feature, we only access, use, or share your Google user data to provide or improve the functionality of our application. We do not use Google user data for advertising or marketing purposes, nor do we transfer such data to third parties for reasons other than supporting the core functionality of our application.
Our Use of Cookies
Our Platform uses cookies. A cookie is a small piece of data or a text file that is downloaded to your computer or mobile device when you access certain websites. Cookies may contain text that can be read by the web server that delivered the cookie to you. The text contained in the cookie consists of a sequence of letters and numbers that uniquely identifies your device; it may contain other information as well.
By agreeing to accept our use of cookies you are giving us and the third parties with which we partner permission to place, store, and access some or all the cookies described below on your device.
- Strictly Necessary Cookies — These cookies are necessary for the proper functioning of the Platform.
- Performance Cookies — These cookies collect information about the use of the Platform.
- Functional Cookies — These cookies enable the Platform to remember users’ choices.
- Media Cookies — These cookies can be used to improve a website’s performance and provide special features and content. They can be placed by us or third parties who provide services to us.
- Advertising or Targeting Cookies — These cookies are usually placed and used by advertising companies to develop a profile of your browsing interests.
- Session Cookies — These cookies allow websites to link the actions of a user during a browser session.
- Persistent Cookies — These cookies are stored on a user’s device between browser sessions and may be used for remembering users’ choices and preferences.
We may also use cookies for:
- identifying the areas of our Platform that you have visited;
- personalising the content that you see on our Platform;
- our Platform analytics;
- remarketing our products or services to you;
- remembering your preferences, settings, and log-in details;
- targeted advertising and serving ads relevant to your interests;
- allowing you to share content with social networks.
Most web browsers can be set to disable the use of cookies. However, if you disable cookies, you may not be able to access features on our Platform correctly or at all.
Collecting Information About Your Physical Location
When you use our services, we may collect and process information about your actual physical location. We use several technologies such as GPS and IP tracking to determine your location. These technologies may also give us information about nearby cell towers, Wi-Fi access points, and other devices.
Third-Party
We use third-party services to enhance your experience and provide seamless services on our Platform. These third-party service providers may assist us with, including but not limited to:
- website and cloud hosting;
- payment processing and payment gateway services;
- email delivery, messaging, and communication services;
- customer support tools, live chat, and contact forms;
- analytics and performance monitoring;
- advertising, remarketing, and marketing services;
- fraud prevention, security monitoring, and identity verification;
- currency conversion and exchange rate services;
- document management, storage, and backup services; and
- other technology infrastructure necessary for the operation of the Platform.
Where third-party service providers process personal data on our behalf, they do so only for the purposes of providing their services to us and are required to maintain appropriate technical and organisational measures to protect such data in accordance with applicable data protection laws and our contractual requirements.
Some third-party providers may collect information directly through cookies, pixels, software development kits (SDKs), APIs, or similar technologies. The collection and processing of such information are governed by the respective third party's privacy policy. Where required by applicable law, we will obtain your consent before enabling non-essential cookies or similar technologies.
Where the Platform integrates with third-party accounts or services at your request, we will access and process only the data necessary to provide the requested functionality. Such data will be used solely for the purpose for which access was granted.
We do not sell your personal data to third parties. We do not disclose your personal data except as described in this Privacy Policy, where necessary to provide the Platform, to comply with applicable law, protect our legal rights, or with your consent.
You may choose to disable certain cookies or tracking technologies through your browser settings or other available preference management tools. However, doing so may affect the availability or functionality of certain features of the Platform.
Where personal data is transferred to third-party service providers located outside your jurisdiction, we will take appropriate measures to ensure that such transfers comply with applicable data protection laws and are subject to appropriate safeguards.
No Prohibited Transfer or Use of Google User Data
We confirm that Google user data is not used for advertising, profiling, or analytics, and is not transferred to third parties beyond essential service integrations necessary for the app’s core email functionality.
Payment Processing
We facilitate payments between Buyers and Sellers through the Platform. When a Buyer makes a payment, funds are processed through the Platform’s designated payment gateway. We may temporarily hold funds pending order confirmation before remitting the applicable amount to the relevant Seller, net of any subscription fees or applicable deductions.
All payment transactions are processed through certified, industry-standard payment gateways. We do not store full payment card details. Your billing and payment information is handled in accordance with applicable payment security standards.
Your payment data will be shared with our payment processing providers solely to the extent necessary to facilitate and complete your transaction.
What happens if you don’t give us your personal data
If you do not provide us with enough personal data, we may not be able to provide you with all our products and services.
Account and Data Management
Users have control over their account settings, including the ability to access their data, modify their data, and request deletion of their data. These actions are in compliance with applicable data protection regulations.
Backup & Restore
To prevent data loss and provide recovery options in case of accidental deletion or system failure, we utilise backup and restore services, ensuring data integrity and security.
Local Storage
We store certain data in the local storage of the end user’s browser to improve ease of access and time efficiency. This data includes personal information such as the user’s name and email, as well as our information, including user activation status, organisation reference number, role and permissions for the specific user, and an encrypted session token. This information is not stored as cookies but is copied from our database and retained in the browser’s local storage for seamless user experience.
Data Security
We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, disclosure, alteration, loss, or destruction. While we take reasonable steps to safeguard your information, no method of electronic transmission or storage is completely secure, and we cannot guarantee absolute security.
How and why we use your personal data
Under data protection law, we can only use your personal data if we have a proper reason, eg:
- where you have given consent;
- to comply with our legal and regulatory obligations;
- for the performance of a contract with you or to take steps at your request before entering into a contract; or
- for our legitimate interests or those of a third party.
A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests.
The table below explains what we use your personal data for and why.
| What we use your personal data for | Our reasons |
|---|---|
| Providing products and services to you | To perform our contract with you or to take steps at your request before entering into a contract |
| Processing payments and subscriptions | To execute financial transactions as per our contractual agreements |
| Preventing and detecting fraud against you or us | For our legitimate interest, ie to minimise fraud that could be damaging for you and/or us |
| Conducting checks to identify our customers and verify their identity Screening for financial and other sanctions or embargoes Other activities necessary to comply with professional, legal and regulatory obligations that apply to our business, eg rules issued by our professional regulator |
Depending on the circumstances: — to comply with our legal and regulatory obligations — for our legitimate interests |
| To enforce legal rights or defend or undertake legal proceedings | Depending on the circumstances: — to comply with our legal and regulatory obligations; — in other cases, for our legitimate interests, ie to protect our business, interests and rights |
| Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies | To comply with our legal and regulatory obligations |
| Ensuring business policies are adhered to, eg policies covering security and internet use | For our legitimate interests, ie to make sure we are following our own internal procedures |
| Operational reasons, such as improving efficiency, training and quality control | For our legitimate interests, ie to be as efficient as we can so we can deliver the best service to you at the best price |
| Ensuring the confidentiality of commercially sensitive information | Depending on the circumstances: — for our legitimate interests, ie to protect trade secrets and other commercially valuable information; — to comply with our legal and regulatory obligations |
| Statistical analysis to help us manage our business, eg in relation to our financial performance, customer base, product range or other efficiency measures | For our legitimate interests, ie to be as efficient as we can so we can deliver the best service to you at the best price |
| Preventing unauthorised access and modifications to systems | Depending on the circumstances: — for our legitimate interests, ie to prevent and detect criminal activity that could be damaging for you and/or us; — to comply with our legal and regulatory obligations |
| Protecting the security of systems and data used to provide the products and services | To comply with our legal and regulatory obligations We may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests, ie to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us |
| Updating and enhancing customer records | Depending on the circumstances: — to perform our contract with you or to take steps at your request before entering into a contract; — to comply with our legal and regulatory obligations; — for our legitimate interests, eg making sure that we can keep in touch with our customers about existing orders and new products |
| Statutory returns | To comply with our legal and regulatory obligations |
| Ensuring safe working practices, staff administration and assessments | Depending on the circumstances: — to comply with our legal and regulatory obligations; — for our legitimate interests, eg to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you |
| Marketing our services and those of selected third parties to: — existing and former customers; — third parties who have previously expressed an interest in our services; — third parties with whom we have had no previous dealings. |
For our legitimate interests, ie to promote our business to existing and former customers |
| External audits and quality checks, eg for ISO or Investors in People accreditation and the audit of our accounts | Depending on the circumstances: — for our legitimate interests, ie to maintain our accreditations so we can demonstrate we operate at the highest standards; — to comply with our legal and regulatory obligations |
| To share your personal data with members of our group companies, if any, and third parties that will or may take control or ownership of some or all of our business (and professional advisors acting on our or their behalf) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency In such cases information will be anonymised where possible and only shared where necessary |
Depending on the circumstances: — to comply with our legal and regulatory obligations; — in other cases, for our legitimate interests, ie to protect, realise or grow the value in our business and assets |
How and why we use your personal data — in more detail
More details about how we use your personal data and why are set out in the table below.
| Purpose | Processing operation | Relevant categories of personal data |
|---|---|---|
| Communications with you not related to marketing, including about changes to our terms or policies or changes to the products or other important notices (other than those addressed above) | Addressing and sending communications to you as required by data protection laws, ie: — the UK GDPR or the EU GDPR or the UAE PPD | — your name, address and contact information, including email address and telephone number and company details; — your account details (username) |
| Addressing and sending communications to you as required by applicable law | — your name, address and contact information, including email address and telephone number and company details; — your account details (username) |
|
| Addressing and sending communications to you about changes to our terms or policies or changes to the products or other important notices | — your name, address and contact information, including email address and telephone number and company details; — your account details (username) |
How and why we use your personal data — Special category personal data
Certain personal data we collect is treated as a special category to which additional protections apply under data protection law:
- personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership;
- genetic data;
- data concerning health, sex life or sexual orientation.
We do not knowingly collect or process special category personal data unless it is necessary for a lawful purpose and permitted under applicable data protection laws.
Where we process special category personal data, we will do so only where:
- you have provided your explicit consent;
- the processing is necessary to protect your or another person's vital interests where you are physically or legally incapable of giving consent;
- the processing is necessary to establish, exercise, or defend legal claims; or
- another lawful basis applies under applicable data protection laws.
How and why we use your personal data — sharing
We may share your personal data with third parties only where it is necessary to provide and improve our Platform’s functionality or to comply with legal obligations.
See ‘Who we share your personal data with’ for further information on the steps we will take to protect your personal data where we need to share it with others.
Marketing
We will use your personal data to send you updates (by email, text message, telephone or post) about our products and services, including exclusive offers, promotions or new products and services.
We have a legitimate interest in using your personal data for marketing purposes (see above ‘How and why we use your personal data’). This means we do not usually need your consent to send you marketing information. If we change our marketing approach in the future so that consent is needed, we will ask for this separately and clearly.
You do, however, have the right to opt out of receiving marketing communications at any time by:
- contacting us at [email protected]; or
- using the ‘unsubscribe’ link in emails.
In the event you choose to opt out of receiving marketing communications, you will continue to receive essential service-related communications, including, but not limited to, account notifications (such as password changes and renewal reminders), security alerts (including notifications of security incidents and privacy updates), and transactional or payment-related correspondence. These communications are necessary for the administration and operation of your account, compliance with applicable legal and regulatory obligations, and the maintenance of the security and integrity of our services.
We may ask you to confirm or update your marketing preferences if you ask us to provide further products and services in the future, or if there are changes in the law, regulation, or the structure of our business.
We will always treat your personal data with the utmost respect and never sell or share it with other organisations outside our group companies, if any, for marketing purposes.
Who we share your personal data with
We routinely share personal data collected directly from users through our Platform with:
- companies within the group, if any;
- third parties we use to help deliver our products and services to you, eg payment service providers;
- other third parties we use to help us run our business, eg marketing agencies or website hosts;
- third parties approved by you, eg social media sites you choose to link your account to or third party payment providers;
- credit reference agencies;
- our banks.
We or the third parties mentioned above occasionally also share personal data with:
- our and their external auditors, eg in relation to the audit of our or their accounts, in which case the recipient of the information will be bound by confidentiality obligations;
- our and their professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations;
- law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations.
If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).
How long your personal data will be kept
We will not keep your personal data for longer than we need it for the purpose for which it is used.
We only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including to satisfy any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data. When your information is no longer needed, we will destroy, delete, or erase it.
If you no longer have an account with us or we are no longer providing products or services to you, we will retain your data for the maximum period permitted by applicable law or for as long as necessary to fulfil our legal, regulatory, and business obligations, after which it will be deleted or anonymised.
Transferring your personal data to other countries
It is sometimes necessary for us to transfer your personal data among countries in which we operate. In those cases, we will comply with applicable laws designed to ensure the privacy of your personal data. Wherever we transfer, process, or store your personal data, we will try to apply reasonable safeguards to protect it. We will use the information we collect from you by following the practices described in our privacy policy. Also, we enter into data processing agreements and standard contractual clauses when appropriate. By using our Platform, services, or products, you agree to the transfers of your personal data described within this section.
Your rights
You have the following rights, which you can exercise free of charge:
| Right | What it means |
|---|---|
| Access | The right to be provided with a copy of your personal data |
| Rectification | The right to require us to correct any mistakes in your personal data |
| Erasure (also known as the right to be forgotten) | The right to require us to delete your personal data — in certain situations |
| Restriction of processing | The right to require us to restrict processing of your personal data in certain circumstances, eg if you contest the accuracy of the data |
| To object | The right to object: — at any time to your personal data being processed for direct marketing (including profiling); — in certain other situations to our continued processing of your personal data, eg processing carried out for the purpose of our legitimate interests unless there are compelling legitimate grounds for the processing to continue or the processing is required for the establishment, exercise or defence of legal claims |
| The right to withdraw consent | If you have provided us with a consent to use your personal data you have a right to withdraw that consent easily at any time You may withdraw consent by contacting us (see ‘How to contact us’ below) Withdrawing consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn |
For more information on each of those rights, including the circumstances in which they apply, please contact us (see ‘How to contact us’ below).
If you would like to exercise any of those rights, please:
- email us — see below: ‘How to contact us’; and
- provide enough information to identify yourself (eg your full name, address and customer or matter reference number) and any additional identity information we may reasonably request from you;
- let us know what right you want to exercise and the information to which your request relates.
Keeping your personal data secure
We have appropriate security measures to prevent personal data from being lost accidentally, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your personal data will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
Links to other websites
Our Platform may contain links to other websites. These websites are not under our control and are not subject to our privacy policy. We have no responsibility for these websites, and we provide links to these websites solely for your convenience. You accept that your use of and access to these websites are solely at your risk.
Use of your credit/debit card
You may have to provide a credit or debit card to buy products and services from our Platform. We use third-party billing services and have no control over them. We use commercially reasonable efforts to ensure that your credit card number is kept strictly confidential by using only third-party billing services that use industry-standard encryption technology to protect your credit card number from unauthorised use. However, you understand and agree that we are in no way responsible for any misuse of your credit card number.
How to complain
Please contact us if you have any queries or concerns about our use of your personal data (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.
Changes to this privacy policy
This privacy policy was published on 24.07.2026 and last updated on 24.07.2026.
We may change this privacy policy from time to time, when we do we will inform you via our Platform or other means of contact such as email.
Updating your personal data
We take reasonable steps to ensure your personal data remains accurate and up to date. To help us with this, please let us know if any of the personal data you have provided to us has changed, eg your surname or address — see below ‘How to contact us’.
How to contact us
You can contact us by email if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.
Our contact details: [email protected]