Privacy Policy

Effective Date: 30 July 2026
Last Updated: 30 July 2026

1. Introduction

Nova Eliteo International Trading – FZCO («Nova Eliteo», «Eliteo», «we», «our» or «us») is committed to protecting the privacy and personal data of every individual with whom we conduct business.

This Privacy Policy explains how we collect, use, disclose, store, transfer and otherwise process personal data when you visit our websites, contact us, use our services, respond to our communications, or otherwise interact with Nova Eliteo International Trading – FZCO and the Eliteo Group brand.

Our primary place of establishment is the United Arab Emirates («UAE»). Accordingly, our data processing activities are primarily governed by the UAE Federal Decree-Law No. 45 of 2021 concerning the Protection of Personal Data («UAE PDPL»).

Where applicable, we also comply with the European Union General Data Protection Regulation («EU GDPR»), the UK General Data Protection Regulation («UK GDPR»), and any other mandatory privacy legislation applicable to our international business activities.

We are committed to processing personal data lawfully, fairly, transparently and securely while maintaining the highest standards of confidentiality and professional integrity.

2. Data Controller

Unless expressly stated otherwise, the controller responsible for processing personal data is:

Nova Eliteo International Trading – FZCO
Commercial License No. 16848
DSO – IFZA
Dubai Silicon Oasis
Dubai
United Arab Emirates

Email: info@eliteogroup.com

Website: www.eliteogroup.com

Throughout this Privacy Policy, references to «Eliteo Group» refer exclusively to the international brand identity under which Nova Eliteo International Trading – FZCO operates.

Eliteo Group is a commercial brand and not a separate legal entity.

Unless explicitly agreed otherwise in writing, all contractual relationships, commercial obligations and legal responsibilities are undertaken solely by Nova Eliteo International Trading – FZCO.

3. Scope of this Privacy Policy

This Privacy Policy applies to all personal data processed by Nova Eliteo International Trading – FZCO in connection with:

• our corporate websites;
• contact forms;
• email communications;
• telephone communications;
• messaging applications;
• video conferences;
• social media interactions;
• newsletters;
• commercial mailings;
• marketing campaigns;
• dealer acquisition activities;
• supplier relationships;
• customer enquiries;
• vehicle sourcing requests;
• procurement activities;
• commercial negotiations;
• logistics coordination;
• export documentation;
• compliance procedures;
• customer relationship management (CRM);
• future online dealer portals;
• future marketplace services;
• future customer accounts;
• future supplier accounts; and
• any other business activities operated by Nova Eliteo International Trading – FZCO.

This Privacy Policy applies whether personal data is obtained directly from the individual, through authorised business partners, through publicly available business sources or through other lawful means.

4. Our Business Activities

Nova Eliteo International Trading – FZCO operates internationally under the Eliteo Group brand.

Depending on the nature of a particular transaction, we may act as:

• purchaser;
• seller;
• sourcing partner;
• exporter;
• importer;
• intermediary;
• commercial representative;
• coordinator;
• service provider;
• consultant;
• project manager; or
• business facilitator.

Our current and planned business activities include, without limitation:

• international vehicle sourcing;
• international vehicle trading;
• dealer acquisition;
• business development;
• office technology solutions;
• procurement services;
• export coordination;
• logistics coordination;
• supplier management;
• consulting services;
• business networking;
• investment-related business services;
• marketplace development;
• customer relationship management;
• commercial communications; and
• additional business services introduced in the future.

The future expansion of our services does not automatically change the purposes for which personal data is processed. Where legally required, this Privacy Policy will be updated accordingly.

5. Who this Privacy Policy Applies To

This Privacy Policy applies to all identifiable natural persons whose personal data is processed by Nova Eliteo International Trading – FZCO, including:

• website visitors;
• prospective customers;
• existing customers;
• vehicle buyers;
• vehicle sellers;
• authorised dealer representatives;
• suppliers;
• manufacturers;
• logistics providers;
• shipping companies;
• customs brokers;
• business partners;
• consultants;
• contractors;
• referral partners;
• investors;
• service providers;
• marketing recipients;
• newsletter subscribers;
• applicants;
• users of future online platforms; and
• any other individual whose personal data is processed during the course of our legitimate business activities.

This Privacy Policy does not apply exclusively to information relating to legal entities where no identifiable natural person is concerned.

6. Our Privacy Principles

We process personal data in accordance with the following principles:

• lawfulness;
• fairness;
• transparency;
• purpose limitation;
• data minimisation;
• accuracy;
• storage limitation;
• integrity;
• confidentiality;
• accountability; and
• appropriate technical and organisational security.

Personal data is processed only for legitimate business purposes and only to the extent necessary for those purposes.

We do not sell personal data.

We do not engage in the commercial sale of customer databases.

We do not disclose personal data to unrelated third parties except where required for our business operations, where legally required or where authorised by the data subject.

7. International Nature of Our Business

Nova Eliteo International Trading – FZCO conducts business internationally.

Our customers, suppliers, dealers, manufacturers and commercial partners may be located in different jurisdictions, including but not limited to:

• United Arab Emirates;
• European Union;
• United Kingdom;
• Switzerland;
• Japan;
• North America;
• Asia;
• Middle East; and
• other international markets.

Consequently, personal data may be processed across multiple jurisdictions in accordance with applicable legal requirements and appropriate safeguards described in this Privacy Policy.

8. Categories of Personal Data We Collect

Depending on the nature of our relationship with you and the services provided, we may collect and process the following categories of personal data.

8.1 Identification Data

We may collect:

• full name;
• title;
• company name;
• position or job title;
• nationality, where required;
• business registration details;
• signature;
• identification documents where legally required;
• passport information where necessary for compliance purposes;
• Emirates ID or equivalent identification where legally required;
• VAT or tax identification numbers where applicable; and
• other information required to identify you in the context of our business relationship.

8.2 Business Contact Information

We may process:

• business email addresses;
• telephone numbers;
• mobile numbers;
• business addresses;
• company websites;
• LinkedIn profiles;
• other professional networking profiles;
• preferred language;
• preferred communication method; and
• communication preferences.

8.3 Company Information

Where you represent a business, we may process information relating to your organisation, including:

• company name;
• registered address;
• registration number;
• commercial licence details;
• VAT registration;
• ownership structure where relevant;
• authorised representatives;
• business sector;
• company size;
• countries of operation;
• banking information required for commercial transactions; and
• publicly available corporate information.

8.4 Communication Data

We may process information contained in communications between you and Nova Eliteo International Trading – FZCO, including:

• emails;
• letters;
• telephone conversations;
• video conferences;
• online meetings;
• messaging applications;
• social media messages;
• website enquiries;
• contact forms;
• meeting notes;
• internal communication records;
• quotations;
• commercial proposals;
• purchase enquiries;
• sourcing requests; and
• follow-up correspondence.

Communications may be retained where necessary for contractual, operational, legal or evidential purposes.

8.5 Website Usage Information

When you visit our website, certain technical information may be collected automatically, including:

• IP address;
• browser type;
• browser version;
• operating system;
• device type;
• preferred language;
• referring website;
• pages visited;
• date and time of access;
• session duration;
• click behaviour;
• technical error logs;
• security logs; and
• other technical information necessary for the operation, security and optimisation of our websites.

Such information does not necessarily identify you directly but may constitute personal data under applicable legislation.

8.6 Vehicle and Transaction Information

Where you enquire about, purchase, sell or source vehicles through us, we may process information relating to:

• requested vehicles;
• purchased vehicles;
• sourced vehicles;
• vehicle specifications;
• Vehicle Identification Numbers (VIN);
• chassis numbers;
• registration details;
• mileage;
• photographs;
• inspection reports;
• maintenance history;
• valuation reports;
• pricing information;
• quotations;
• purchase orders;
• invoices;
• shipping documentation;
• customs documentation;
• certificates of conformity;
• export documentation;
• logistics information;
• delivery information; and
• transaction history.

8.7 Payment Information

Where commercial transactions take place, we may process:

• bank account details;
• payment references;
• invoice information;
• payment confirmations;
• transaction values;
• currencies;
• financial correspondence;
• credit information where appropriate;
• refund information; and
• accounting records.

Nova Eliteo International Trading – FZCO does not intentionally store complete payment card details unless this is strictly necessary and permitted by applicable law.

8.8 Dealer, Supplier and Partner Information

In the course of our international business activities, we maintain information relating to dealers, suppliers and business partners, including:

• dealership information;
• supplier information;
• procurement history;
• sourcing history;
• transaction history;
• commercial preferences;
• areas of expertise;
• vehicle interests;
• business references;
• communication history;
• contractual information;
• commercial performance;
• delivery history; and
• relationship management information.

8.9 Compliance Information

Where required by law or reasonably necessary to protect our legitimate business interests, we may process information relating to:

• Know Your Customer (KYC);
• Know Your Business (KYB);
• sanctions screening;
• anti-money laundering (AML) requirements;
• export control compliance;
• fraud prevention;
• identity verification;
• ownership verification;
• politically exposed person (PEP) screening where applicable;
• adverse media screening where appropriate; and
• other legally required compliance procedures.

Such processing is performed only where necessary and proportionate.

8.10 Marketing Information

Where permitted by applicable law, we may process:

• newsletter subscriptions;
• mailing preferences;
• campaign interactions;
• event registrations;
• webinar registrations;
• download history;
• marketing permissions;
• communication preferences;
• responses to commercial communications; and
• requests to unsubscribe.

You may withdraw your marketing consent or object to marketing communications at any time.

8.11 Information Obtained from Public Sources

To develop legitimate business relationships, we may obtain business contact information from publicly available sources, including:

• official commercial registers;
• corporate websites;
• professional networking platforms;
• trade fairs;
• industry publications;
• business directories;
• public procurement databases;
• publicly accessible company announcements;
• referrals from existing business partners; and
• other lawful public sources.

Where required by applicable law, we will provide appropriate privacy information regarding such processing.

8.12 Future Platform Data

As our business develops, we may introduce additional online services, including dealer portals, sourcing platforms or marketplace solutions.

Where such services become available, we may process additional categories of personal data, including:

• account registration information;
• login credentials;
• authentication records;
• dealer verification information;
• profile information;
• marketplace activity;
• listing information;
• transaction history;
• communication history;
• reputation indicators;
• user preferences; and
• platform security information.

Should additional categories of personal data become necessary, this Privacy Policy will be updated before or when such processing begins.

9. Special Categories of Personal Data

Nova Eliteo International Trading – FZCO does not intentionally collect or process special categories of personal data, such as information relating to racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data processed for the purpose of uniquely identifying an individual, health information or information concerning a person’s sex life or sexual orientation, unless such processing is explicitly required by law or is necessary for the establishment, exercise or defence of legal claims.

Where the processing of such data becomes necessary, appropriate legal safeguards and security measures will be implemented in accordance with applicable legislation.

10. How We Collect Personal Data

We collect personal data through a variety of lawful sources depending on the nature of our business relationship.

Personal data may be collected directly from you when you:

• visit our websites;
• contact us by email or telephone;
• submit an enquiry;
• request a quotation;
• request vehicle sourcing services;
• purchase or sell vehicles through us;
• subscribe to newsletters;
• register for future online services;
• participate in meetings or video conferences;
• attend business events; or
• otherwise communicate with us.

We may also receive personal data from third parties, including:

• authorised representatives;
• employers;
• business partners;
• dealers;
• suppliers;
• logistics providers;
• manufacturers;
• referral partners;
• publicly available business sources;
• commercial registers;
• professional networking platforms;
• government authorities where legally permitted; and
• service providers acting on our behalf.

We only collect personal data that is relevant and reasonably necessary for legitimate business purposes.

11. Purposes of Processing

Nova Eliteo International Trading – FZCO processes personal data only where there is a legitimate business purpose or another lawful basis for doing so.

Depending on the circumstances, personal data may be processed for the following purposes:

Business Communication

• responding to enquiries;
• communicating with customers;
• communicating with suppliers;
• communicating with dealers;
• managing business relationships;
• scheduling meetings;
• providing customer support;
• maintaining commercial correspondence.

Vehicle Sourcing and Trading

• identifying suitable vehicles;
• processing sourcing requests;
• preparing quotations;
• negotiating transactions;
• arranging purchases;
• arranging sales;
• coordinating exports;
• organising transportation;
• managing logistics;
• preparing commercial documentation;
• issuing invoices;
• processing payments.

Supplier and Dealer Management

• onboarding business partners;
• verifying business credentials;
• evaluating suppliers;
• managing commercial relationships;
• maintaining supplier records;
• maintaining dealer databases;
• improving sourcing efficiency.

Customer Relationship Management

We maintain a professional CRM system to manage ongoing business relationships.

The CRM may contain information relating to:

• previous enquiries;
• business interests;
• preferred vehicle brands;
• communication history;
• completed transactions;
• sourcing requests;
• commercial opportunities;
• meeting history;
• follow-up activities; and
• other information relevant to maintaining a professional business relationship.

Marketing and Commercial Communications

Subject to applicable law, we may process personal data to:

• send newsletters;
• distribute vehicle offers;
• distribute sourcing opportunities;
• invite individuals to events;
• announce new services;
• provide market updates;
• maintain professional business relationships.

Recipients may unsubscribe or object to marketing communications at any time.

Website Administration

We process technical information in order to:

• operate our websites;
• improve website performance;
• analyse website usage;
• detect technical issues;
• prevent abuse;
• protect against cyber threats;
• maintain system security.

Compliance

We may process personal data in order to:

• comply with applicable laws;
• comply with accounting obligations;
• comply with customs regulations;
• comply with export control regulations;
• comply with sanctions requirements;
• comply with anti-money laundering obligations;
• comply with court orders;
• comply with requests from competent authorities.

Fraud Prevention

Personal data may be processed to:

• prevent fraud;
• prevent identity theft;
• verify business partners;
• protect our business;
• investigate suspicious activities;
• enforce contractual rights.

Future Platform Services

If future online dealer platforms or marketplace services are introduced, personal data may additionally be processed to:

• create user accounts;
• verify dealers;
• authenticate users;
• facilitate transactions;
• manage listings;
• improve platform security;
• resolve disputes;
• prevent fraudulent activities.

12. Legal Basis for Processing

Where required by applicable law, we process personal data on one or more of the following legal bases.

Performance of a Contract

Processing may be necessary to:

• prepare quotations;
• negotiate transactions;
• fulfil contractual obligations;
• provide requested services;
• process payments;
• arrange deliveries;
• complete vehicle transactions.

Pre-Contractual Measures

Before entering into a contract, we may process personal data to:

• evaluate enquiries;
• identify suitable vehicles;
• assess sourcing opportunities;
• prepare commercial proposals;
• communicate with prospective business partners.

Legal Obligations

Processing may be required to comply with:

• accounting legislation;
• tax legislation;
• customs regulations;
• export control laws;
• sanctions legislation;
• anti-money laundering regulations;
• court orders;
• governmental requests;
• other applicable legal obligations.

Legitimate Interests

Where permitted by applicable law, we may process personal data for our legitimate business interests, including:

• developing business relationships;
• maintaining our CRM;
• protecting our legal rights;
• improving our services;
• ensuring network security;
• preventing fraud;
• verifying business partners;
• maintaining supplier relationships;
• maintaining dealer relationships;
• conducting internal business analysis;
• improving operational efficiency.

Before relying on legitimate interests, we carefully assess whether those interests are outweighed by the rights and freedoms of the individual concerned.

Consent

Where required by law, we will request your consent before processing personal data.

Consent may be used for purposes including:

• newsletter subscriptions;
• marketing communications where required;
• optional cookies;
• optional analytics;
• optional marketing technologies;
• any other processing requiring consent under applicable law.

You may withdraw your consent at any time without affecting the lawfulness of processing carried out before the withdrawal.

13. Dealer Verification and Compliance

To protect our business, customers and commercial partners, Nova Eliteo International Trading – FZCO may conduct reasonable business verification procedures before entering into commercial relationships.

Such verification may include:

• confirmation of business registrations;
• verification of commercial licences;
• verification of VAT registrations;
• verification of authorised representatives;
• confirmation of company ownership where appropriate;
• sanctions screening;
• export control screening;
• fraud prevention checks;
• publicly available business information.

These verification procedures are performed solely for legitimate business, legal and compliance purposes and are proportionate to the nature of the proposed commercial relationship.

14. Disclosure of Personal Data

Nova Eliteo International Trading – FZCO treats all personal data as confidential. We do not sell personal data and do not disclose personal data to unrelated third parties for their own marketing purposes.

Personal data may be disclosed only where necessary for legitimate business purposes, contractual obligations, legal compliance or with the consent of the data subject.

Depending on the nature of the business relationship, personal data may be shared with:

• customers;
• authorised dealers;
• suppliers;
• manufacturers;
• logistics providers;
• shipping companies;
• customs brokers;
• inspection companies;
• financial institutions;
• payment service providers;
• professional advisers;
• auditors;
• insurers;
• IT service providers;
• hosting providers;
• cloud service providers;
• CRM providers;
• marketing service providers;
• governmental authorities;
• regulatory authorities;
• courts; and
• other parties where disclosure is required or permitted by applicable law.

All third parties receiving personal data are expected to process such data in accordance with applicable legal requirements and appropriate confidentiality obligations.

15. International Data Transfers

As an international trading company headquartered in the United Arab Emirates, Nova Eliteo International Trading – FZCO regularly cooperates with customers, suppliers and business partners located in multiple jurisdictions.

Accordingly, personal data may be transferred to, stored in or accessed from countries outside the jurisdiction in which it was originally collected.

Such countries may include, without limitation:

• United Arab Emirates;
• Member States of the European Union;
• United Kingdom;
• Switzerland;
• Japan;
• United States;
• Canada;
• Singapore;
• other countries within the Middle East;
• and other jurisdictions where our business partners operate.

Where applicable data protection legislation requires additional safeguards for international transfers, we implement appropriate legal, technical and organisational measures before such transfers take place.

Depending on the circumstances, these safeguards may include:

• Standard Contractual Clauses approved by the European Commission;
• the UK International Data Transfer Agreement (IDTA);
• the UK Addendum to the EU Standard Contractual Clauses;
• contractual confidentiality obligations;
• technical security measures;
• organisational safeguards;
• transfer risk assessments; and
• other legally recognised transfer mechanisms.

Where a transfer is necessary for the performance of a contract, the establishment or defence of legal claims, compliance with legal obligations or another lawful exception recognised by applicable law, personal data may be transferred accordingly.

16. Data Retention

Nova Eliteo International Trading – FZCO retains personal data only for as long as necessary to fulfil the purposes described in this Privacy Policy or as required by applicable law.

Retention periods depend upon the nature of the data, the business relationship and applicable legal obligations.

As a general principle:

• general enquiries are retained only for as long as reasonably necessary to respond and conduct follow-up communications;
• customer and supplier information is retained for the duration of the business relationship and an appropriate period thereafter;
• contractual documentation is retained in accordance with applicable commercial and legal requirements;
• accounting and tax records are retained for the legally prescribed retention periods;
• compliance documentation may be retained for longer periods where required by anti-money laundering, sanctions or export control legislation;
• litigation-related information may be retained until the final resolution of legal proceedings and any applicable limitation periods;
• website security logs are retained only for operational and security purposes; and
• marketing data is retained until consent is withdrawn or a valid objection is received, unless another lawful basis justifies continued processing.

Upon expiry of the applicable retention period, personal data will be securely deleted, anonymised or otherwise rendered permanently inaccessible unless continued retention is required by law.

17. Information Security

Nova Eliteo International Trading – FZCO implements appropriate technical and organisational measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or unauthorised access.

Our security measures may include:

• encrypted communications where appropriate;
• secure hosting infrastructure;
• access control mechanisms;
• authentication procedures;
• role-based access management;
• password protection;
• firewall protection;
• malware detection;
• network monitoring;
• system logging;
• regular software updates;
• data backup procedures;
• employee confidentiality obligations;
• supplier security requirements; and
• internal security policies.

Despite our efforts, no method of electronic transmission or storage can guarantee absolute security. Accordingly, while we strive to protect personal data using commercially reasonable measures, we cannot guarantee absolute protection against every possible security risk.

In the event of a personal data breach, Nova Eliteo International Trading – FZCO will take appropriate measures in accordance with applicable law, including investigation, containment, remediation and notification where legally required.

18. Your Privacy Rights

Depending on the laws applicable to your personal data, you may have one or more of the following rights.

Subject to legal limitations and verification of identity, you may request:

• access to your personal data;
• confirmation that your personal data is being processed;
• correction of inaccurate information;
• completion of incomplete information;
• deletion of personal data;
• restriction of processing;
• objection to certain processing activities;
• withdrawal of consent where processing is based on consent;
• data portability where applicable;
• information regarding international data transfers;
• information regarding recipients of your personal data; and
• information regarding the legal basis for processing.

The availability of individual rights may vary depending on the applicable legal framework and the specific circumstances of the processing.

Requests relating to personal data should be submitted to:

Email: info@eliteogroup.com

To protect personal data, we may request additional information necessary to verify the identity of the requesting individual before responding to a request.

Where permitted by law, requests that are manifestly unfounded, repetitive or excessive may be refused or subject to reasonable administrative measures.

19. Marketing Communications

Where permitted by applicable law, Nova Eliteo International Trading – FZCO may send commercial communications relating to:

• vehicle sourcing opportunities;
• available vehicles;
• business services;
• market insights;
• industry updates;
• events;
• newsletters; and
• other information relevant to our professional business activities.

Every marketing communication sent electronically will include an appropriate mechanism enabling recipients to unsubscribe or object to future communications.

Withdrawal of marketing consent or objection to marketing communications will not affect communications that are necessary for existing contractual relationships or legal obligations.

20. Cookies and Similar Technologies

Our websites use cookies and comparable technologies to ensure the proper operation, security and performance of our online services.

Depending on your preferences and applicable law, these technologies may also be used for:

• website functionality;
• user preferences;
• security;
• analytics;
• performance measurement;
• fraud prevention;
• embedded content; and
• marketing.

Where required by applicable law, non-essential cookies and similar technologies will only be activated after obtaining your valid consent.

You may change or withdraw your cookie preferences at any time through our Cookie Settings or the consent management tool available on our website.

Further information regarding the cookies and similar technologies we use is available in our separate Cookie Policy.

21. Third-Party Services

Our websites and business operations may include services provided by independent third parties.

These may include:

• cloud hosting providers;
• website security providers;
• content delivery networks (CDNs);
• analytics providers;
• mapping services;
• video hosting platforms;
• payment providers;
• communication platforms;
• email service providers;
• customer relationship management systems;
• document management systems;
• logistics platforms; and
• other business service providers.

Where personal data is processed by third-party providers on our behalf, appropriate contractual and technical safeguards are implemented where required by applicable law.

Independent third-party providers remain responsible for their own privacy practices.

We encourage users to review the privacy policies of third-party services before providing personal information through those services.

22. Third-Party Websites

Our websites may contain links to websites operated by third parties.

Such links are provided solely for informational or business purposes.

Nova Eliteo International Trading – FZCO does not control the content, security, availability or privacy practices of third-party websites.

Accessing third-party websites is entirely at your own discretion and subject to the terms and privacy policies of the respective website operators.

We accept no responsibility or liability for the processing of personal data by third-party websites that are not operated by Nova Eliteo International Trading – FZCO.

23. Children’s Privacy

Our services are intended exclusively for business users and individuals who are at least eighteen (18) years of age.

We do not knowingly collect personal data from children.

If we become aware that personal data relating to a child has been collected without appropriate legal authorisation, we will take reasonable steps to delete such information without undue delay.

Parents or legal guardians who believe that a child has provided personal data to Nova Eliteo International Trading – FZCO are encouraged to contact us immediately.

24. Automated Decision-Making

Nova Eliteo International Trading – FZCO does not currently make decisions based solely on automated processing where such decisions produce legal effects or similarly significant effects on individuals.

As our business develops, we may introduce automated systems designed to improve operational efficiency, including:

• dealer verification;
• fraud detection;
• sanctions screening;
• marketplace security;
• customer relationship management;
• recommendation systems;
• vehicle matching;
• sourcing optimisation; and
• business analytics.

Where applicable law requires additional transparency, human intervention or specific safeguards for automated processing, such requirements will be implemented before the relevant systems become operational.

25. Data Accuracy

We take reasonable steps to ensure that personal data remains accurate, complete and up to date.

However, the accuracy of certain information depends on the cooperation of the individual concerned.

We encourage you to notify us promptly whenever your contact details or other relevant information changes.

Where inaccurate or incomplete information is identified, we will take reasonable steps to correct or update it without undue delay.

26. Business Transfers

In the event of a merger, acquisition, corporate restructuring, sale of assets, investment transaction or similar business event involving Nova Eliteo International Trading – FZCO, personal data may be transferred to the acquiring or succeeding entity where legally permitted.

Any such transfer will remain subject to appropriate confidentiality obligations and applicable data protection laws.

The new controller, where applicable, will continue to process personal data only for lawful purposes and in accordance with applicable legal requirements.

27. Changes to this Privacy Policy

Nova Eliteo International Trading – FZCO may update this Privacy Policy from time to time to reflect:

• changes in applicable legislation;
• changes in regulatory guidance;
• changes to our business operations;
• new services;
• new technologies;
• changes to our websites;
• security improvements; or
• other operational developments.

The current version will always be published on our website together with its effective date.

Where required by applicable law, we will provide appropriate notice before material changes become effective.

Continued use of our services after the effective date of an updated Privacy Policy constitutes acknowledgement of the revised version where permitted by applicable law.

28. Contact Us

If you have any questions regarding this Privacy Policy or the processing of your personal data, please contact:

Nova Eliteo International Trading – FZCO
Commercial License No. 16848
DSO – IFZA
Dubai Silicon Oasis
Dubai
United Arab Emirates

Email: info@eliteogroup.com

Website: www.eliteogroup.com

We will make reasonable efforts to respond to legitimate privacy enquiries within the timeframes required by applicable law.

29. Complaints

If you believe that your personal data has been processed in violation of applicable data protection laws, you may contact us first so that we have the opportunity to investigate and resolve your concerns.

Where applicable law grants such rights, you may also lodge a complaint with the competent supervisory authority or other regulatory body responsible for data protection in the relevant jurisdiction.

Nothing in this Privacy Policy limits any statutory rights or legal remedies available under applicable law.

30. Governing Law

This Privacy Policy shall be interpreted in accordance with the laws applicable to Nova Eliteo International Trading – FZCO.

Where mandatory data protection legislation of another jurisdiction applies to a particular processing activity, the relevant provisions of that legislation shall prevail to the extent required by law.

Any matters not governed by mandatory data protection legislation shall be interpreted in accordance with the applicable laws of the United Arab Emirates.