Bowarr Management LTD



Effective Date: October 10, 2021

Bowarr respects your right to privacy.  This Privacy Policy explains who we are, how we collect, share and use personal information about you, and how you can exercise your privacy rights.  It applies to all individuals who access our website at (“Website“), engage our services (“Services“), or who participate in our recruitment activities. We recommend that you read this Privacy Policy in full to ensure you are fully informed.

What does Bowarr do?

‘Bowarr’ is the trade name of Bowarr Management Ltd, registered in DIFC at the legal address Office 2004, Emirates Financial Tower, South, DIFC, Dubai, United Arab Emirates.

For more information about Bowarr and the services we provide, please see the “Services” section of our Website at

What personal information does Bowarr collect when you visit our Website and why?

The personal information that we may collect about you when you visit our website broadly falls into the following categories:

Information that you provide voluntarily

We collect personal information that you provide voluntarily through our Website, for example when completing online forms to contact us, form-application for our Services or register for events that we are organizing.  The information we collect about you may include some or all of the following:

  • Name and job title;
  • Company or organization;
  • Contact information, including email address and telephone number(s);
  • Demographic information such as address, preferences and interests;
  • Other information relevant to client surveys or similar research;
  • Information pertinent to fulfilling our Services to you, such as business assets value; corporate banking; audit of the business; and
  • Any other personal/corporate information that you voluntarily choose to provide to us.

If we ask you to provide any other personal information not described above, the personal information that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point that you are asked to provide your personal information.

Information that we collect automatically

When you visit our Website, we may collect certain personal information automatically from your device.

Specifically, the information we collect automatically may include information like your IP address, device type, unique device identification number, browser-type, broad geographic location (e.g. country or city-level location) and other technical information.  We may also collect information about how your device has interacted with our Website, including the pages accessed and links clicked. 

Collecting this information enables us to better understand the visitors who come to our Website, where they come from, and what content on our Website is of interest to them.  We use this information for our internal analytics purposes and to improve the quality and relevance of our Website to our visitors.

Some of this information may be collected using cookies and similar tracking technology, as explained further in our cookie notice below.

Cookie Notice

A cookie is a small piece of data (text file) that a website – when visited by a user – asks your browser to store on your device in order to remember information about you, such as your language preference or login information. Those cookies are set by us and called first-party cookies. We also use third-party cookies – which are cookies from a domain different than the domain of the website you are visiting – for our advertising and marketing efforts. More specifically, we use cookies and other tracking technologies to provide us with information on how the website is being used.

You can control cookies through the settings or preferences of your browser, as well as through dedicated browser extensions or add-ons.

However, some cooking are strictly necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms.    You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information.

What personal information does Bowarr collect when you engage our Services and why?

When you engage us to provide you with our Services, we collect and use personal information which is necessary for the performance of those Services. 

The majority of the personal information we collect and use to provide our Services is supplied voluntarily by (or collected by us from third party sources at the request of) our clients.  Because of this, if you are a client of Bowarr then it will generally be obvious to you what personal or corporate information we collect and use.  This information may include:    

  • Basic information such as your name, the company you work for, your position and your relationship to a person;
  • Contact information such as your postal address, email address and telephone number(s);
  • Financial information, such as payment related information, business assets value, corporate banking, audit of the business;
  • Identification and background information provided by you or collected as part of our business acceptance process;
  • Special categories of personal information, such as information about a person’s alleged criminal activities, or similar where this is necessary in connection with the Services we provide (for example, to advise on a sale of business in connection with a criminal prosecution); and
  • Any other personal information relating to you, your company or other third parties which you may provide to us for the purpose of receiving our Services.

We use this information to facilitate the provision of our Services to you, the client.  In addition, we will process identification and background information as part of our business acceptance, finance, administration and marketing processes, including anti-money laundering, conflict, reputational and financial checks, and to fulfil any other legal or regulatory requirements to which we may be subject. The information our clients provide may be disclosed to third parties to the extent that is reasonably necessary in connection with that work (for example, when seeking advice from external counsel or experts). As part of our processing of information for marketing purposes we may collect information from responses provided to marketing campaigns via email. This information would be used for internal analytics purposes and to improve the quality, relevance and compliance of our marketing.

What information does Bowarr collect when you engage in recruitment services?

Bowarr collects information from and about candidates in connection with available employment opportunities at Bowarr.  This information may include CVs, identification documents, academic records, work history, employment and references.

When and with whom might Bowarr share your personal information?

We may disclose your personal information to the following categories of recipients:

  • To our partnerships operating under the Bowarr brand, as well as third party services providers and partners who provide data processing services to us (for example, for Website visitors who subscribe to our blogs, our blog e-mail delivery provider; our website spam security service; or, if you are a candidate, from recruitment agencies we have engaged);
  • To any competent law enforcement body, regulator, government agency, court or other third party where we believe disclosure is necessary: (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person;
  • To a potential buyer (and its agents and advisers) in connection with any proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this Privacy Policy; and
  • To a person you have given us your consent to disclose to.

Legal basis for processing personal information

Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it. 

However, we will normally collect personal information from you only where we have your consent to do so, where we need the personal information to perform a contract with you (for example, when providing our Services), or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to process personal information about you, or may need to process personal information in order to exercise, establish or defend legal claims.

If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as the possible consequences, if any,  if you do not provide your personal information).

If you have questions about or need further information concerning the legal basis on which we collect and use your personal information (including any legitimate interests relied upon), please send an email to

How does Bowarr keep my personal information secure?

We use appropriate technical and organizational measures to protect the personal information that we collect and process about you.  The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information. 

International data transfers

Bowarr brand and third party service providers operate in the United Arab Emirates and around the world.  This means that when we collect your personal information it may be processed in countries that may have data protection laws that are different to the laws of your country. 

However, we have taken appropriate safeguards to require that the personal information we process will remain protected in accordance with this Privacy Policy when transferred internationally, including when processed internationally by our third party service providers and partners. The safeguards we have taken include implementing the DIFC Data Protection Law No.5 of 2020 for transfers of personal information to our non-DIFC members and internationally. 

We have also implemented similar appropriate safeguards with our third party service providers and partners. The transfer of personal data to third party service providers outside of the DIFC takes place on the basis of data protection adequacy decisions via the implementation of DIFC Data Protection Law No.5 of 2020 standard contractual clauses. 

If you have questions about or need further information concerning international data transfers, please send an email to

Data retention

We will retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements). 

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), we will securely store your personal information and isolate it from any further processing until deletion is possible.

If you have questions about, or need further information concerning, our data retention periods, please send an email to

Your data protection rights

You have the following data protection rights:

  • If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by sending an email to;
  • You can object to the processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. You can exercise these rights by contacting us by email at;
  • You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you.  To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please email;
  • Similarly, if we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent; and  
  • You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact DIFC data protection authority. (Contact details for DIFC data protection authority are available here.)

We respond to all requests received from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

Updates to this Privacy Policy

We may update this Privacy Policy from time to time in response to legal, technical or business developments. When we update our Privacy Policy, we will take appropriate measures to inform you, which will be consistent with the significance of the changes we make.  We will obtain your consent to any material Privacy Policy changes if and where this is required by applicable data protection laws.

You can see when this Privacy Policy was last updated by checking the “last updated” date displayed at the end of this Privacy Policy. 

How to contact us

If you have any questions or concerns about our use of your personal information, please email us at

If you are a visitor to our Website or a client of our Services or a candidate seeking employment at Bowarr, the data controller of your personal information is Bowarr Management Ltd. 

Copyright © 2022 Bowarr Management Ltd. All rights reserved.

Last update January 2022.