1. Overview
Twarx ("Twarx," "we," "us," or "our") is committed to protecting your personal information and your right to privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website at twarx.com (the "Site") or engage with our services.
Please read this policy carefully. If you disagree with its terms, please discontinue use of the Site. This policy was last updated on 1 January 2026 and applies to all information collected through our Site and related services.
2. Information We Collect
We collect information in the following ways:
Information you provide directly: When you contact us, subscribe to research updates, apply for a role, or enter into a commercial agreement with us, you may provide: name, email address, employer or organisation name, job title, and any other information you choose to include in your communication.
Information collected automatically: When you visit our Site, we automatically collect certain technical information including: IP address, browser type and version, operating system, referring URLs, pages viewed, time spent on pages, and device identifiers. This information is collected through cookies and similar tracking technologies.
Information from third parties: We may receive information about you from third parties such as LinkedIn (if you apply for a role via that platform) or our analytics providers. We handle such information in accordance with this policy.
3. How We Use Your Information
We use the information we collect for the following purposes:
(a) To respond to enquiries and provide requested information about our services;
(b) To send research updates and publications to subscribers who have opted in;
(c) To process and evaluate employment applications;
(d) To improve and optimise our Site and services based on analytics;
(e) To detect and prevent fraud, abuse, and security incidents;
(f) To comply with our legal obligations;
(g) To enforce our Terms of Service and other agreements.
We will only use your personal data for the purposes described above or for other purposes that are compatible with those purposes. We will inform you if we intend to use your data for a new purpose.
4. Legal Basis for Processing
We process personal data in accordance with UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (the PDPL) and other applicable UAE data protection law. For users in the United Kingdom and European Economic Area, we also rely on the following legal bases under the GDPR:
Legitimate interests: Site analytics, security monitoring, and improvements to our services — where such processing does not override your fundamental rights.
Consent: Sending research newsletters and marketing communications. You may withdraw consent at any time by clicking "unsubscribe" in any email or contacting us at [email protected].
Contract: Processing necessary to fulfil or prepare to enter into a contract with you (including employment applications and commercial engagements).
Legal obligation: Processing required to comply with applicable law.
5. Sharing Your Information
We do not sell your personal information. We may share your information with:
Service providers: Third parties that assist us in operating our Site and services (such as hosting providers, analytics tools, and email delivery platforms). These providers are contractually bound to process your data only on our instructions and to protect it appropriately.
Professional advisors: Legal, financial, and other professional advisors where necessary.
Law enforcement and legal proceedings: Where required by applicable law, court order, or government authority, or to protect the rights, property, or safety of Twarx, our users, or others.
Business transfers: If Twarx is involved in a merger, acquisition, or asset sale, your personal data may be transferred as part of that transaction. We will provide notice before your data is transferred and becomes subject to a different privacy policy.
6. Cookies and Tracking Technologies
We use cookies and similar tracking technologies to collect and store information about your interactions with our Site. Cookies are small text files stored on your device.
We use: (a) Essential cookies, required for the Site to function; (b) Analytics cookies, to understand how users interact with our Site (we use privacy-respecting analytics that do not share data with advertising networks); (c) Preference cookies, to remember your settings.
You can control cookies through your browser settings. Blocking essential cookies may affect Site functionality. Our analytics are designed to minimise personal data collection — we do not use advertising cookies or share analytics data with third parties for advertising purposes.
7. Data Retention
We retain personal data only as long as necessary for the purposes described in this policy, or as required by law. Specifically:
Contact enquiries and correspondence: 3 years from last contact.
Research newsletter subscriptions: Until you unsubscribe, plus 1 year.
Employment applications: 12 months from the date of decision.
Commercial engagement records: 7 years from the end of the engagement (to comply with financial reporting obligations).
After these periods, we securely delete or anonymise personal data.
8. Your Rights
Depending on your location, you may have the following rights regarding your personal data:
Right of access: To request a copy of the personal data we hold about you.
Right to rectification: To request correction of inaccurate or incomplete data.
Right to erasure: To request deletion of your personal data in certain circumstances.
Right to restriction: To request that we limit our processing of your data in certain circumstances.
Right to data portability: To receive your data in a structured, machine-readable format.
Right to object: To object to processing based on legitimate interests.
Right to withdraw consent: Where processing is based on consent, to withdraw that consent at any time.
Right to complain: To lodge a complaint with the UAE Data Office or your local supervisory authority.
To exercise any of these rights, contact us at [email protected]. We will respond within 30 days. We may need to verify your identity before processing your request.
9. International Transfers
Twarx Ventures FZ-LLC is based in Ras Al Khaimah, United Arab Emirates. If you access our Site from outside the UAE, your information may be transferred to, stored, and processed in the UAE or other countries where our service providers operate.
Where we transfer data internationally, we ensure appropriate safeguards are in place in accordance with applicable data protection law, such as contractual protections with our service providers, and we comply with any transfer restrictions under the UAE PDPL and, where applicable, the GDPR.
10. Security
We implement appropriate technical and organisational measures to protect your personal data against accidental or unlawful destruction, loss, alteration, and unauthorised access or disclosure. These measures include encrypted transmission (HTTPS), access controls, and regular security reviews.
However, no transmission over the internet is 100% secure. While we take reasonable steps to protect your data, we cannot guarantee absolute security. In the event of a data breach that poses a high risk to your rights and freedoms, we will notify you as required by applicable law.
11. Children
Our Site and services are not directed to children under 16 years of age. We do not knowingly collect personal data from children under 16. If you believe we have inadvertently collected such data, please contact us immediately at [email protected] and we will delete it promptly.
12. Changes to This Policy
We may update this Privacy Policy from time to time. We will notify you of material changes by posting the new policy on this page with a revised "last updated" date and, where appropriate, notifying you by email. We encourage you to review this policy periodically.
13. Contact Us
If you have questions, concerns, or requests relating to this Privacy Policy or our data practices, please contact us at:
Twarx
Data Protection Enquiries
[email protected]
If you are unsatisfied with our response to a privacy complaint, you may contact the UAE Data Office or, where applicable, your local supervisory authority.
Twarx Ventures FZ-LLC · RAKEZ, Ras Al Khaimah, UAE · [email protected]
Data Controller under UAE Federal Decree-Law No. 45 of 2021