Legal

Privacy Policy

1. WHO WE ARE

HWY27 FZCO ("HWY27", "we", "us", "our") is a B2B procurement and sourcing consultancy registered under the International Free Zone Authority (IFZA) in Dubai Silicon Oasis, United Arab Emirates. We operate the website hwy27global.com and provide sourcing, vendor vetting, and trade finance facilitation services to clients across the GCC and MENA region, with supply-side operations spanning Canada, the United States, and international markets. As the Data Controller, HWY27 FZCO is responsible for determining how and why personal data is processed in connection with our website and business operations.

2. SCOPE OF THIS POLICY

This Privacy Policy applies to: all visitors to hwy27global.com; prospective clients, suppliers, and partners who submit inquiries or engage with our outreach; existing clients and vendors whose data we process in the course of delivering services; and all personal data processed via our digital stack: GA4, HubSpot CRM, Meta/Facebook Ads, Webflow, WhatsApp Business, Apollo.io, Clay, n8n, and LinkedIn.

3. APPLICABLE LAWS

HWY27 operates across multiple jurisdictions. The following legal frameworks govern our data processing activities: UAE Federal Decree-Law No. 45 of 2021 (Personal Data Protection Law - PDPL); EU General Data Protection Regulation (GDPR) - applicable to data subjects in the EU/EEA; Canada's Personal Information Protection and Electronic Documents Act (PIPEDA); Canada's Anti-Spam Legislation (CASL) - applicable to commercial electronic messages sent to Canadian recipients.

4. DATA WE COLLECT

4.1 Data You Provide Directly: When you interact with HWY27 via our website contact forms, email, WhatsApp Business, or LinkedIn, we may collect: full name and job title; business email address and phone number; company name and industry; procurement requirements, RFQ details, and sourcing specifications; any other information you voluntarily include in communications with us. 4.2 Data Collected Automatically: When you visit hwy27global.com, we automatically collect the following data through cookies and tracking technologies (subject to your consent where required): IP address (partially anonymized by GA4); browser type, device type, and operating system; pages visited, time on site, and navigation behavior; referral source; approximate geographic location (country/city level); session duration and interaction data. 4.3 Data From Third-Party Sources: For B2B business development purposes, we may obtain professional contact data from: Apollo.io, Clay, and LinkedIn. This data is limited to professional contact information (name, job title, company, business email) and is used solely for legitimate B2B outreach purposes.

Introduction

Welcome to Evermind. This Privacy Policy outlines our practices regarding the collection, use, and protection of your personal information when you use our website. Your privacy is a priority, and we are committed to safeguarding your data.

Introduction

5. LEGAL BASES FOR PROCESSING

We only process personal data where we have a valid legal basis. Processing activities are based on the following grounds under UAE PDPL, GDPR, and PIPEDA: Consent - for cookie-based tracking and marketing communications where required; Legitimate Interests - for B2B outreach to procurement professionals whose roles are directly relevant to our services; Contractual Necessity - for processing data required to deliver services to clients; Legal Obligation - for retaining records required by UAE law, tax authority requirements, and financial regulations.

6. HOW WE USE YOUR DATA

We use the personal data we collect for the following purposes: responding to inquiries submitted via our website contact form or direct communications; managing client and prospect relationships through HubSpot CRM; delivering procurement and sourcing services to clients; conducting B2B prospecting and outreach to relevant procurement decision-makers; analyzing website performance and user behavior to improve our digital presence; running targeted advertising campaigns on Meta and LinkedIn; maintaining records of business transactions for legal and compliance purposes; complying with applicable laws, regulations, and legal obligations; protecting the rights and interests of HWY27 FZCO and third parties.

Introduction

7. COOKIES AND TRACKING TECHNOLOGIES

Our website uses cookies and similar technologies. A cookie consent banner is presented to all visitors upon first visit. Non-essential cookies are only activated after you provide consent. You may withdraw consent for non-essential cookies at any time via our cookie settings, or opt out directly through: Google Analytics Opt-Out: tools.google.com/dlpage/gaoptout; Meta Ad Preferences: facebook.com/settings?tab=ads.

8. THIRD-PARTY DATA PROCESSORS

We share personal data with the following third-party processors who act on our behalf and are bound by data processing agreements or equivalent contractual protections: Google LLC (GA4 - website analytics); HubSpot Inc. (CRM and email communication); Meta Platforms Inc. (advertising); LinkedIn Corporation (advertising and outreach); Apollo.io (B2B contact data); Clay Technologies (data enrichment); Webflow Inc. (website hosting and CMS); n8n GmbH (workflow automation); WhatsApp LLC / Meta Platforms Inc. (business communication). We do not sell personal data to third parties for their own commercial purposes.

9. INTERNATIONAL DATA TRANSFERS

HWY27 is a UAE-based entity that operates with suppliers, clients, and digital platforms across multiple countries. Personal data may be transferred to and processed in: United States, Canada, Germany, and European Union. These transfers are conducted under contractual safeguards modelled on international data transfer standards; Standard Contractual Clauses (SCCs) where applicable under GDPR; reliance on processor certifications and data processing agreements where available. As the UAE Data Office has not yet published a formal adequacy list under the PDPL, we apply conservative international transfer standards consistent with Articles 22 and 23 of UAE Federal Decree-Law No. 45 of 2021.

14. WHATSAPP BUSINESS COMMUNICATIONS

HWY27 uses WhatsApp Business as a primary business communication channel. When you communicate with us via WhatsApp: your messages and associated metadata are retained for up to 5 years as business records; WhatsApp Business communications are facilitated by Meta Platforms, Inc.; we do not use WhatsApp message content for advertising targeting purposes; communications via WhatsApp may be referenced in dispute resolution proceedings.

10. DATA RETENTION

We retain personal data only for as long as necessary for the purpose for which it was collected, and in compliance with applicable legal retention requirements: website analytics data (GA4) - 14 months; CRM contact records (HubSpot) - duration of business relationship plus 3 years; client transaction records - 7 years (UAE commercial law requirement); B2B outreach contact data - until opt-out request received or 2 years from last interaction; WhatsApp Business communications - up to 5 years as business records; financial records - 7 years (UAE FTA and IFZA requirements).

11. YOUR DATA RIGHTS

Your Rights Under Applicable Law

Depending on your jurisdiction, you may have the following rights: Right of Access; Right to Rectification; Right to Erasure; Right to Restriction; Right to Data Portability (GDPR); Right to Object; Right to Withdraw Consent; Right to Lodge a Complaint. To exercise any of these rights, contact us at saidsaleh@hwy27global.com. We will respond within 30 days.

Data Security

HWY27 implements appropriate technical and organizational security measures to protect personal data against unauthorized access, loss, alteration, or disclosure. These measures include: SSL/TLS encryption on all web properties; role-based access controls for HubSpot CRM and connected platforms; use of enterprise-grade SaaS platforms with their own security certifications; two-factor authentication on all critical business accounts; secure, access-controlled business banking via WIO Bank PJSC and ADIB.

B2B Outreach and CASL Compliance

HWY27's core business development model involves direct B2B outreach to procurement professionals via email and LinkedIn. Legal basis: Legitimate interests (PDPL, GDPR). CASL compliance: Our email outreach to Canadian business contacts qualifies under the Business-to-Business exception under CASL. Source disclosure: Contact data sourced via Apollo.io and Clay is limited to professional information derived from publicly available sources. Opt-out: Every outreach communication includes a clear, simple opt-out mechanism. Opt-out requests are honoured within 10 business days. If you wish to opt out, reply with "UNSUBSCRIBE" or email saidsaleh@hwy27global.com with the subject line "OPT OUT".

HOW WE USE YOUR INFORMATION

To operate and maintain our website and services.
To send you relevant communications and administrative updates.
To analyze usage data to improve our website and offerings.

DISCLOSURE OF YOUR INFORMATION

Your data is accessible only by authorized Evermind personnel.

We do not sell, rent, or trade your personal information to third parties.

Third-party partners who assist in maintaining our site are bound by strict confidentiality and security agreements.

DATA RETENTION

We retain your data for as long as necessary to:

Fulfill the purposes for which it was collected,
Or to comply with your request for its removal, subject to legal obligations.

SECURITY OF YOUR INFORMATION

We employ administrative, technical, and physical security measures to protect your information. While we take reasonable precautions, no system is completely secure.

YOUR RIGHTS

You have the right to access, correct, or request the deletion of your personal data. Please contact us to exercise these rights.

If you have any questions or concerns about this Privacy Policy or our data practices, please contact us. Evermind is committed to protecting your privacy and ensuring our practices are transparent and fair. You can reach our data protection officer at privacy@evermind.com or by mail at: Evermind Corp., 789 Sustainability Ave., Greendale, WA 98052.

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