PRIVACY POLICY & COOKIE NOTICE
Last updated: 01 August 2026
Please read this Privacy Policy & Cookie Notice carefully before using our website.
1. INTRODUCTION
WELLENGI FZCO (“we”, “us”, “our”) operates the website at https://www.wellengi.com, which includes:
- the WELLENGI Global Oilfield Marketplace, a business-to-business marketplace connecting buyers and sellers of surplus drilling, oilfield, and industrial equipment, spare parts, and materials (the “Marketplace”); and
- our well engineering consultancy, advisory, sourcing, equipment selection, inspection, and other services, and related corporate pages.
This Privacy Policy & Cookie Notice (“Policy”) explains how we collect, use, disclose, and protect personal information across the whole website. Where a section applies only to the Marketplace, this is stated.
Use of the Marketplace is additionally governed by our Terms and Conditions. Consultancy, advisory, and direct trading engagements are governed by separate written agreements, which may contain their own confidentiality and data provisions.
2. WHO WE ARE
Data Controller: WELLENGI FZCO, Registration no. DSO-FZCO-45349, Trade License no. 47556 Office 308-J, Building A2, IFZA, Dubai Digital Park, Dubai Silicon Oasis, Dubai, United Arab Emirates
Privacy contact: privacy@wellengi.com
We are established in the United Arab Emirates and process personal data in accordance with UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (“PDPL”) and its implementing regulations, and — where applicable to you — the EU/UK General Data Protection Regulation (“GDPR”) and other applicable data protection laws.
3. SCOPE
Our website and the Marketplace are intended for business users only. Most of the personal data we handle is business contact data — names, job titles, corporate email addresses and phone numbers of individuals acting on behalf of companies.
You may interact with us in three broad capacities, and the data we hold differs accordingly:
- General visitor — browsing our corporate pages. We process only technical and analytics data (Section 4.2) and any details you volunteer through a contact form.
- Marketplace user — a registered Buyer or Seller. We additionally process account, listing, transaction, and verification data, and carry out compliance screening (Section 6).
- Consultancy or trading counterparty — engaging us under a separate written agreement. We process contact and contractual data for the performance of that engagement.
We do not knowingly collect special categories of personal data (such as health, biometric, or religious data), and you should not submit such data through the website or the Marketplace.
4. INFORMATION WE COLLECT
4.1 Information you provide
| Category | Examples |
|---|---|
| Identity & contact | Name, job title, company name, business email, phone number |
| Account data | Username, password (stored hashed), account preferences, communication settings |
| Listing data | Equipment descriptions, photographs, specifications, location, pricing, serial numbers |
| Transaction data | RFQs, quotations, inquiries, purchase orders, correspondence |
| Verification data | Trade licence, certificate of incorporation, passport or Emirates ID of authorised signatories and beneficial owners, proof of authority, end-user statements |
| Support data | Messages sent to our support channels |
We collect only information reasonably necessary to operate the marketplace. Verification data is not collected through the website itself — our team may request it directly from you in certain cases (for example, seller verification or compliance screening).
4.2 Information collected automatically
When you visit our website, we may automatically collect:
- IP address
- Browser type, version, and language
- Device type and operating system
- Pages visited, features used, and time spent
- Referring and exit URLs
- Approximate location derived from IP address
- Session identifiers and error logs
4.3 Information from third parties
We may receive information about you from:
- Compliance and screening providers — sanctions, restricted-party, PEP, and adverse media data (see Section 6);
- Payment and identity verification providers — verification status and outcomes;
- Publicly available sources — company registries, corporate websites, and professional networking platforms, for business development and verification purposes;
- Your colleagues — where a colleague registers your business contact details on behalf of your organisation.
5. HOW WE USE INFORMATION AND OUR LEGAL BASIS
| Purpose | Legal basis (GDPR) / PDPL basis |
|---|---|
| Create and manage your account | Performance of a contract |
| Publish listings and facilitate RFQs between users | Performance of a contract |
| Process transactions, invoices, and commissions | Performance of a contract |
| Provide customer support | Performance of a contract / legitimate interests |
| Conduct KYB, sanctions, and export-control screening | Legal obligation / legitimate interests |
| Prevent fraud, abuse, and circumvention; secure the platform | Legitimate interests |
| Analyse and improve website performance and usability | Legitimate interests / consent (analytics cookies) |
| Send transactional emails and service notices | Performance of a contract |
| Send marketing communications about new equipment and offers | Consent |
| Maintain accounting and tax records | Legal obligation |
| Establish, exercise, or defend legal claims | Legitimate interests |
Where we act as a direct seller under separate contractual documentation, personal information may also be processed for the performance of that sales contract.
We only send marketing communications to visitors who have explicitly opted in — via an optional consent checkbox presented when you submit an RFQ, send a message through our Contact form, or register an account. You can withdraw this consent at any time (Section 13).
We do not use personal information for automated decision-making producing legal or similarly significant effects, except that compliance screening (Section 6) may result in an account being declined or suspended. In such cases you may request human review by contacting privacy@wellengi.com.
We do not use personal information for unrelated purposes without notifying you.
6. COMPLIANCE SCREENING
Because we operate in a sector subject to export controls and sanctions, we may, in certain circumstances and where required, screen users, their officers, and their beneficial owners against sanctions lists, restricted-party lists, politically exposed person databases, and adverse media sources.
Where carried out, this screening may be performed by us or by specialist third-party compliance providers acting as our processors, and may be repeated periodically for the duration of your relationship with us.
Screening results are retained as part of our compliance records and may be disclosed to regulators, financial institutions, or law enforcement where required by law.
7. COOKIES AND SIMILAR TECHNOLOGIES
7.1 What cookies are
Cookies are small text files placed on your device when you visit a website. We also use similar technologies such as local storage, session storage, pixels, and software development kits.
7.2 Categories of cookies we use
| Category | Purpose | Consent required |
|---|---|---|
| Strictly necessary | Authentication, session management, load balancing, security, CSRF protection, cookie preference storage | No — required for the website to function |
| Functional | Remembering language, currency, units of measurement, saved filters and search preferences | Yes |
| Analytics / performance | Understanding traffic, page views, feature usage, and errors in aggregate | Yes |
| Marketing | Measuring campaign effectiveness and, where enabled, delivering relevant advertising | Yes |
7.3 Third-party technologies
We may use the following third-party technologies. The list is indicative and may change:
| Provider | Purpose | Privacy information |
|---|---|---|
| Vercel Inc. | Application hosting, edge delivery, performance monitoring | https://vercel.com/legal/privacy-policy |
| Cloudflare, Inc. | Content delivery, object storage, bot and DDoS protection | https://www.cloudflare.com/privacypolicy/ |
| (analytics provider — to be confirmed) | Website and usage analytics | — |
| (payment processor — to be confirmed) | Payment processing and fraud prevention | — |
7.4 Managing your preferences
Where required by law, we request your consent before placing non-essential cookies. You can accept, reject, or adjust your preferences at any time via the cookie banner or the Cookie Settings link in the site footer.
You may also control cookies through your browser settings. Disabling strictly necessary cookies may prevent parts of the website from functioning.
Most browsers support "Do Not Track" signals; we currently respond to Global Privacy Control (GPC) signals where legally required.
7.5 Cookie lifespan
Session cookies expire when you close your browser. Persistent cookies remain for the period stated in the cookie banner details, typically no longer than 12 months.
8. HOW INFORMATION IS SHARED
8.1 Marketplace sharing
This section applies to the Marketplace only. Because it operates as a marketplace:
- When you submit an RFQ or inquiry, your name, company, and business contact details may be shared with the relevant counterparty for the purpose of responding to your request or facilitating a transaction;
- Listing information published by sellers may be visible to other users and, where listings are public, to search engines and the general public;
- We may disclose the identity of a counterparty where necessary to complete a transaction or resolve a dispute.
8.2 Service providers
We share personal information with trusted third-party providers that support the operation of our website and the Marketplace, under contractual obligations restricting their use of the data:
- Cloud hosting, storage, and content delivery providers
- Database and application infrastructure providers
- Payment processors and financial services providers
- Identity verification and compliance screening providers
- Analytics providers
- Email delivery and customer support providers
- Professional advisers (legal, accounting, audit)
8.3 Corporate transactions
If we are involved in a merger, acquisition, restructuring, or sale of assets, personal information may be transferred as part of that transaction, subject to this Policy.
8.4 Legal requirements
We may disclose personal information where necessary to:
- Comply with applicable law, regulation, or court order;
- Respond to lawful requests by public authorities;
- Enforce our Terms and Conditions;
- Protect the rights, property, and safety of us, our users, or others;
- Investigate fraud, sanctions breaches, or misuse of our website or the Marketplace.
9. WE DO NOT SELL PERSONAL INFORMATION
We do not sell personal information, and we do not share personal information for cross-context behavioural advertising.
10. INTERNATIONAL TRANSFERS
We operate from the United Arab Emirates and use service providers located in other countries, including the European Economic Area and the United States.
Where we transfer personal data internationally, we rely on appropriate safeguards, which may include:
- Transfers to jurisdictions recognised as providing an adequate level of protection;
- Standard Contractual Clauses or equivalent contractual protections;
- Your explicit consent, where permitted.
You may request a copy of the relevant safeguards by contacting privacy@wellengi.com.
11. DATA RETENTION
We retain personal information only as long as necessary for the purposes for which it was collected:
| Data type | Indicative retention |
|---|---|
| Account data | Duration of the account, plus 24 months after closure |
| Transaction and invoicing records | 5 years, per UAE accounting and tax requirements |
| KYB and compliance screening records | 5 years from the end of the business relationship |
| Marketing contact data | Until you unsubscribe or withdraw consent |
| Server logs and analytics | 12 months |
| Support correspondence | 24 months |
After the applicable period, information is securely deleted or irreversibly anonymised.
Certain information may be retained longer where required for legal, regulatory, accounting, fraud-prevention, or dispute-resolution purposes.
You may request account deletion by contacting support@wellengi.com.
12. SECURITY
We implement reasonable technical and organisational measures to protect personal information, including:
- Encryption in transit (TLS) and at rest;
- Hashed and salted password storage;
- Role-based access controls and least-privilege principles;
- Logging and monitoring;
- Regular backups;
- Vendor due diligence.
Where payments are processed through the Service, payment card information is handled by our payment processor in accordance with PCI-DSS standards, and we do not store full payment card numbers.
Access to personal information is limited to authorised personnel and service providers who require such access to perform their duties.
No system is completely secure, and we cannot guarantee absolute security. Where a personal data breach is likely to result in a risk to your rights, we will notify the competent authority and, where required, affected individuals without undue delay.
13. YOUR RIGHTS
Depending on your jurisdiction, you may have the right to:
- Access the personal information we hold about you;
- Correct inaccurate or incomplete information;
- Request deletion of your information;
- Restrict or object to certain processing, including direct marketing;
- Data portability — receive your data in a structured, machine-readable format;
- Withdraw consent at any time, without affecting the lawfulness of prior processing;
- Object to automated processing, and request human review of decisions;
- Stop processing where processing causes you harm, under the PDPL.
To exercise your rights, contact privacy@wellengi.com. We will respond within the period required by applicable law. We may need to verify your identity before acting on a request.
Complaints
- United Arab Emirates: you may lodge a complaint with the UAE Data Office.
- EEA / UK: you may lodge a complaint with your local supervisory authority.
- California: residents may have additional rights under the CCPA/CPRA, including the right to know, delete, correct, and not be discriminated against for exercising those rights.
Nothing in this Policy limits your right to lodge a complaint with a competent data protection authority.
14. CHILDREN
Our website and the Marketplace are business-to-business only and is not directed at, or intended for use by, individuals under 18 years of age. We do not knowingly collect personal information from children. If we become aware that we have done so, we will delete it.
15. THIRD-PARTY LINKS
Our website may contain links to third-party websites, including seller websites and manufacturer documentation. We are not responsible for the privacy practices of those sites, and we encourage you to review their privacy policies.
16. CHANGES TO THIS POLICY
We may update this Policy periodically. The updated version will be posted on this page with a revised “Last updated” date.
Where changes are material, we will notify registered users by email or through the Marketplace before the changes take effect.
17. CONTACT
WELLENGI FZCO Office 308-J, Building A2, IFZA, Dubai Digital Park, Dubai Silicon Oasis, Dubai, United Arab Emirates
Privacy enquiries: privacy@wellengi.com General enquiries: support@wellengi.com Sales enquiries: sales@wellengi.com