Last updated: 10 April 2026
Contrarian Advisory & Trading FZCO ("the Firm," "we," "us," or "our") is the data controller responsible for your personal data. We are registered in the Dubai Multi Commodities Centre (DMCC) Free Zone, United Arab Emirates, under DMCC Licence No. 964020. Our registered address is Unit No. 3989, DMCC Business Centre, Level No. 1, Jewellery & Gemplex 3, Dubai, UAE.
This Privacy Policy is drafted in compliance with the UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (the "PDPL"), which came into effect on 2 January 2022. Where we process personal data of individuals located in the European Economic Area, we also comply with the General Data Protection Regulation (EU) 2016/679 ("GDPR"). In the event of any conflict between the PDPL and GDPR, the more protective standard shall apply.
We collect personal data that you voluntarily provide to us through the following channels:
| Data Category | Examples | Purpose |
|---|---|---|
| Identity data | Full name, company name | Newsletter delivery, client identification |
| Contact data | Email address, location | Communications, service delivery |
| Preference data | Language preference, advisory interest | Personalisation of services |
| Technical data | IP address, browser type, device information | Website functionality, security, analytics |
We process your personal data on the following legal bases: (a) your explicit consent, which you provide when subscribing to our newsletter or submitting a contact enquiry; (b) the performance of a contract or pre-contractual measures, where processing is necessary to deliver services you have requested; (c) our legitimate interests, including the operation and improvement of our website, provided these interests do not override your fundamental rights and freedoms; and (d) compliance with legal obligations under UAE law.
We use your personal data to deliver the daily crisis briefing newsletter in your preferred language; to respond to enquiries submitted through our contact form; to provide geopolitical advisory services where engaged; to analyse website usage for the purpose of improving our services; and to comply with applicable legal and regulatory requirements. We do not use your personal data for automated decision-making or profiling.
We do not sell, rent, or trade your personal data to third parties. We may share your data with trusted service providers who assist us in operating our website and delivering our services (such as email delivery platforms and hosting providers), subject to appropriate data processing agreements. Where personal data is transferred outside the UAE, we ensure that adequate safeguards are in place in accordance with Article 22 of the PDPL and, where applicable, Chapter V of the GDPR.
We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected. Newsletter subscriber data is retained for the duration of your subscription and for a period of twelve months following unsubscription for record-keeping purposes. Contact enquiry data is retained for twenty-four months. Upon expiry of the retention period, your data is securely deleted or anonymised.
Under the PDPL and, where applicable, the GDPR, you have the right to: access the personal data we hold about you; request correction of inaccurate or incomplete data; request deletion of your data (subject to legal retention obligations); restrict or object to the processing of your data; request portability of your data in a structured, commonly used format; and withdraw your consent at any time without affecting the lawfulness of processing carried out prior to withdrawal. To exercise any of these rights, please contact us at the address below.
Our website uses essential cookies that are strictly necessary for the operation of the site (such as session management and authentication). We also use analytics tools to understand how visitors interact with our website. These analytics tools collect anonymised data including pages visited, time spent on pages, and referral sources. You may control cookie preferences through your browser settings or through the cookie consent mechanism on our website. For detailed information about the cookies we use, please refer to our cookie consent banner.
We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These measures include encryption of data in transit (TLS/SSL), access controls, and regular security reviews. However, no method of transmission over the internet is entirely secure, and we cannot guarantee absolute security.
Our services are not directed at individuals under the age of 18. We do not knowingly collect personal data from minors. If we become aware that we have inadvertently collected data from a minor, we will take steps to delete it promptly.
We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. The "Last updated" date at the top of this page indicates when the policy was last revised. We encourage you to review this page periodically.
For any questions regarding this Privacy Policy or to exercise your data protection rights, please contact:
Contrarian Advisory & Trading FZCO
Unit No. 3989, DMCC Business Centre
Level No. 1, Jewellery & Gemplex 3
Dubai, United Arab Emirates
DMCC Licence No. 964020