Privacy Policy

Effective date: 16 July 2026

BSAB LLC (“BSAB”, “we”, “us”, or “our”) is committed to protecting the
privacy of visitors to ca-bhargava.com (the “Site”) and of the
individuals and organisations that engage with our International Tax and
Transfer Pricing practice. This Privacy Policy explains what personal data
we collect, why we collect it, how we handle it, and the rights available
to you.

We process personal data in a manner consistent with Federal Decree-Law
No. 45 of 2021 on the Protection of Personal Data (the UAE PDPL) and its
implementing regulations, and — where applicable to our engagements — with
comparable data protection standards in the jurisdictions we serve.

1. Who we are

BSAB LLC is a boutique tax advisory practice based in Dubai, United Arab
Emirates. For the purposes of applicable data protection law, BSAB LLC is
the controller of the personal data described in this policy. Questions
about this policy or your personal data can be directed to
sbhargava@ca-bhargava.com.

2. The personal data we collect

We collect only the data we need to respond to enquiries and deliver our
services:

• Enquiry details you submit through the contact form — your name, your
  corporate email address, your company or organisation name, an indicative
  turnover / transaction-scale band, the topic of your enquiry, and the
  message you write to us.
• Correspondence — information contained in emails, calls, WhatsApp
  messages, or documents you send us in the course of an enquiry or
  engagement.
• Technical data — standard server log information (such as IP address,
  browser type, and pages requested) generated automatically when you visit
  the Site, used for security and to keep the Site running reliably.

We do not knowingly collect special categories of personal data through
the Site, and we ask that you do not submit sensitive personal information
through the contact form. To keep enquiries qualified, our contact form
accepts corporate email addresses only and declines free webmail addresses.

3. How we use your data

We use personal data to:

• respond to your enquiry and provide the information, proposal, or scoped
  consultation you have requested;
• establish and administer a professional engagement, where one proceeds,
  including issuing a letter of engagement and delivering our services;
• maintain the security, integrity, and proper functioning of the Site; and
• comply with our legal, regulatory, and professional obligations.

4. Legal basis for processing

We process your personal data where it is necessary to take steps at your
request prior to entering into a professional engagement, to perform a
contract with you, to comply with a legal obligation, or on the basis of our
legitimate interest in operating and securing our practice — and, where
required by law, on the basis of your consent (which you may withdraw at any
time).

5. How we share your data

We do not sell your personal data, and we do not share it for advertising.
We disclose personal data only to:

• Service providers who process data on our behalf, under appropriate
  confidentiality and data-processing terms — including our email delivery
  provider (ZeptoMail) and our cloud hosting and storage infrastructure
  (including Cloudflare R2 for media assets); and
• Authorities, regulators, or professional advisers where disclosure is
  required by law or is necessary to establish, exercise, or defend legal
  claims.

Some of these providers may process data outside the United Arab Emirates.
Where personal data is transferred across borders, we take reasonable steps
to ensure it remains protected in accordance with applicable law.

6. How we store and protect your data

Enquiries submitted through the Site are transmitted by email to our
practice and retained in a secured backup record on our server. We apply
reasonable technical and organisational measures — including access
controls and encryption in transit — to protect personal data against
unauthorised access, loss, or misuse. No method of transmission or storage
is completely secure, and we cannot guarantee absolute security.

7. How long we keep your data

We retain personal data only for as long as necessary for the purposes for
which it was collected — to respond to your enquiry, to administer any
resulting engagement, and to meet our legal, regulatory, and professional
record-keeping obligations. When data is no longer required, we securely
delete or anonymise it.

8. Your rights

Subject to applicable law, you have the right to request access to the
personal data we hold about you; to request correction of inaccurate data;
to request erasure or restriction of processing; to object to certain
processing; to request portability of data you have provided; and to
withdraw consent where processing is based on consent. To exercise any of
these rights, contact us at sbhargava@ca-bhargava.com. You also have the
right to lodge a complaint with the competent UAE data protection authority.

9. Cookies

This Site uses only strictly necessary and functional storage. For details,
please see our Cookie Policy.

10. Changes to this policy

We may update this Privacy Policy from time to time to reflect changes in
our practice or in applicable law. The current version is always the one
published on this page, identified by the effective date above.

11. Contact us

For any privacy question or request, contact BSAB LLC at
sbhargava@ca-bhargava.com or by post to our office in Dubai, United Arab
Emirates.