How we handle your data.

1. Introduction

The Global Trade Management Network (“The GTM Network”, “we”, “our”, or “us”) is a private, vetted professional network for trade compliance, customs, and global trade practitioners. This Privacy Policy explains how we collect, use, share, and protect personal information when you visit our website, apply to join, or participate in our member community.

We respect your privacy and are committed to handling your personal information in accordance with applicable data protection laws, including the United Arab Emirates Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (the “UAE PDPL”), the European Union General Data Protection Regulation 2016/679 (“EU GDPR”), the United Kingdom General Data Protection Regulation (“UK GDPR”), and other regional frameworks where applicable.

By accessing the website or submitting an application, you acknowledge that you have read and understood this Privacy Policy.

2. Who We Are

The GTM Network is a private professional community. For the purposes of applicable data protection laws, The GTM Network is the data controller of personal information processed in connection with the network.

For any privacy-related question, request, or complaint, contact: [email protected].

3. Information We Collect

3.1 Information You Provide

When you apply to join, register, or interact with the network, we may collect:

• Identification data: first name, last name.
• Contact data: work email address.
• Professional data: LinkedIn profile URL, professional role or title, country of residence or work, employer, years of experience, areas of trade compliance specialization.
• Application content: responses to screening questions and any information voluntarily submitted.
• Member content: posts, comments, files, questions, answers, and discussions you contribute inside the member community.
• Communications: emails, messages, and other correspondence you send to or receive from us.

3.2 Information We Collect Automatically

When you visit our website or use the platform, we may automatically collect:

• Device and browser data, including IP address, browser type, operating system, and device identifiers;
• Usage data, including pages viewed, time spent, click activity, and referring URLs;
• Cookies and similar tracking technologies (see Section 10).

3.3 Information from Third Parties

We may receive information about you from:

• Publicly available sources, including public LinkedIn profile content;
• Authentication providers if you use single sign-on;
• Analytics, marketing, fraud-prevention, and security service providers.

4. How We Use Your Information

We use personal information for the purposes set out below, on the lawful bases indicated:

We do not sell your personal information.

5. Sharing of Personal Information

We share personal information only with:

• Service providers that support the operation of the network (for example, hosting, email delivery, analytics, customer support, and security). These providers are contractually obligated to handle personal information confidentially and only on our instructions.
• Authorized members within the network, to the extent that you choose to share information through your participation. Members agree to the confidentiality obligations in our Terms of Service and Code of Conduct.
• Legal and regulatory authorities when required by law, court order, regulatory request, or to protect the rights, property, or safety of The GTM Network, its members, or others.
• Successor entities in the event of a merger, acquisition, restructuring, or sale of assets, subject to equivalent privacy protections.

We do not share your personal information with advertisers and we do not use it for behavioral advertising.

6. International Data Transfers

Depending on where you reside and where the technical infrastructure used to deliver the network is located, your personal information may be transferred to, stored in, or processed in countries other than the country from which you submitted it. Some of these countries may have data protection laws that differ from those of your home country.

Where transfers of personal information take place, we take reasonable steps to ensure that your information is treated securely and in line with this Privacy Policy. Where required by applicable law, we implement appropriate safeguards for such transfers, which may include:

• Standard contractual clauses approved by the relevant authorities;
• Adequacy decisions, where available;
• Other lawful transfer mechanisms permitted under applicable law.

You may request information about the safeguards in place by contacting [email protected].

7. Data Retention

We retain personal information only for as long as is necessary to fulfill the purposes set out in this Policy, including to:

• Maintain your membership and provide network services;
• Comply with applicable legal, regulatory, accounting, tax, and reporting obligations;
• Resolve disputes and enforce our agreements.

When personal information is no longer required, we will delete it, anonymize it, or restrict its processing in accordance with applicable law. Specific retention periods include:

• Application data for rejected applicants: up to 24 months from the decision date, unless a shorter period is required by law.
• Member account data: for the duration of your membership and up to seven (7) years after termination, to comply with regulatory and audit requirements.
• Marketing email logs: up to three (3) years following the last interaction.

8. Your Rights

Subject to applicable law, you have the following rights in relation to your personal information:

• Right of access — to request a copy of the personal information we hold about you.
• Right to rectification — to request correction of inaccurate or incomplete information.
• Right to erasure — to request deletion of your personal information in certain circumstances.
• Right to restriction — to request restriction of processing in certain circumstances.
• Right to object — to object to processing based on our legitimate interests or for direct marketing.
• Right to data portability — to receive your personal information in a structured, commonly used, and machine-readable format.
• Right to withdraw consent — where processing is based on consent.
• Right to lodge a complaint — with your local data protection authority, including the UAE Data Office, the relevant EU supervisory authority, the UK Information Commissioner’s Office, or another applicable regulator.

To exercise any of these rights, contact [email protected]. We may need to verify your identity before responding. We will respond within the timeframes required by applicable law.

9. Security

We implement reasonable technical and organizational measures to protect personal information, including encryption in transit, access controls, audit logging, and ongoing monitoring. However, no system is completely secure. You are responsible for maintaining the confidentiality of any credentials we provide and for promptly notifying us of any suspected unauthorized use.

10. Cookies and Tracking Technologies

We use cookies and similar technologies for essential site operation, analytics, performance, and limited marketing measurement. Where required by applicable law, we will obtain your consent for non-essential cookies via a cookie banner. You may control cookies through your browser settings. Disabling certain cookies may affect website functionality.

11. Children

The GTM Network is intended exclusively for trade compliance, customs, and global trade practitioners aged eighteen (18) years or older. We do not knowingly collect personal information from individuals under 18. If you believe a minor has provided us with personal information, contact us immediately at [email protected] and we will take appropriate action.

12. Changes to This Policy

We may update this Privacy Policy from time to time to reflect operational, legal, or regulatory changes. We will post the updated Policy on the website and update the “Effective Date”. Material changes will be communicated to active members by email or in-network notice. Your continued use of the network after the Effective Date of the updated Policy constitutes acceptance of the changes.

13. Contact

If you have any questions about this Privacy Policy or our handling of your personal information, contact:

The Global Trade Management Network (“The GTM Network”)
Email: [email protected]