1 Who we are
Digital Gloss LLC (“we”, “us”, “our”) is a web design, marketing and branding business based in Abu Dhabi, United Arab Emirates. We are the “controller” of the personal information described in this policy, which means we decide how and why it is used.
This policy applies to this website (the “Website”) and to the services we provide, wherever our visitors and clients are located. If you have a question about it, or want to use any of your privacy rights, contact us at team@digitalgloss.com.
2 Laws that apply
We handle personal information in line with the laws that protect it where we work and where you are located, including:
- United Arab Emirates: Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (the “PDPL”), its implementing regulations as they are issued, and other UAE laws that apply to us.
- European Economic Area and United Kingdom: the EU General Data Protection Regulation (“GDPR”) and the UK GDPR and Data Protection Act 2018.
- United States: state privacy laws, such as the California Consumer Privacy Act as amended by the California Privacy Rights Act (“CCPA”).
- Elsewhere: the data protection laws of the other countries where our visitors and clients are based, for example in Saudi Arabia, Bahrain, Qatar, Oman, India, Singapore, Australia, Canada and Brazil.
Where more than one law applies to you, we apply the higher standard of protection. The UAE’s data protection framework is still developing, and we will update this policy as new regulations and guidance are issued.
3 Information we collect
Information you give us
- Enquiry form: your first name and second name, company name (optional), email address, telephone number and country code, website address (optional), the services you are interested in, and your message.
- Direct contact: what you share when you email, call or message us, including through WhatsApp: your name, contact details, the content of your messages and any files you send.
- Client projects: business and brand information, content and images, account and access details you give us so we can do the work, billing details, and records of our dealings with you.
Information collected automatically
When you visit the Website, our hosting provider’s servers record technical information such as your IP address, browser and device type, the pages requested, and the date and time. We use this to deliver the Website, keep it secure and fix problems. We do not use it to build profiles of visitors.
The Website’s typeface is hosted on the Website itself, so loading it does not send your details to a font provider or any other third party.
Information we do not want
We do not need sensitive personal information, such as health details, religious beliefs, biometric data, government ID numbers or payment card numbers, to answer an enquiry. Please do not include them in your message.
4 How and why we use your information
We only use personal information when we have a valid reason under the law. Under the PDPL we rely on your consent, or on the other grounds the law allows, such as where processing is necessary to take steps you ask for or perform a contract with you, or to comply with a legal obligation. Under the GDPR and UK GDPR, the lawful bases we rely on are shown below.
| What we use it for | Examples | Lawful basis (GDPR / UK GDPR) |
|---|---|---|
| Replying to your enquiry | Answering questions, arranging calls, preparing a proposal | Steps at your request before a contract; our legitimate interest in running our business |
| Providing our services | Designing, building, hosting, maintaining and marketing your website or brand | Performance of a contract |
| Running our business | Invoicing, accounting, record keeping | Performance of a contract; legal obligation |
| Keeping the Website secure and working | Server logs, fixing errors, preventing misuse | Our legitimate interest in a secure, reliable website |
| News and marketing | Updates about our services, if you ask for them | Your consent, or our legitimate interest in keeping in touch with existing clients where the law allows |
| Meeting legal duties | Tax and accounting rules, responding to lawful requests from authorities | Legal obligation |
| Protecting our rights | Handling disputes or claims | Our legitimate interest in protecting our business |
We do not use automated decision-making or profiling that has legal or similarly significant effects on you.
5 Cookies and similar technologies
The Website does not currently set cookies or use analytics, advertising or tracking tools. Your browser may keep technical data such as cached files so pages load faster. This is normal and is not used to identify you.
If we add analytics or other non-essential cookies in future, we will update this policy and ask for your consent first wherever the law requires it. Because we do not track you across websites, there is nothing to opt out of today.
6 Who we share your information with
- Service providers: companies that help us run the Website and our business, such as web hosting, email and form handling, communication tools, accounting software and cloud storage. They may only use your information to provide their service to us, and are bound by contracts to protect it.
- Third-party companies you approve: companies that provide extended services you have agreed to. We share your information with them only after you have approved it, and only what they need to provide those services.
- Professional advisers: accountants, lawyers and insurers, where needed.
- Authorities: where the law, a court order or a regulator requires it, or where we need to protect our rights, safety or property.
- If our business changes: if we merge with, or sell part of our business to, another company, your information may be transferred to it, and this policy’s protections will continue to apply.
- People you tell us to: anyone you ask us to share information with.
We do not sell your personal information, and we do not share it for cross-context behavioural advertising.
7 Transfers outside your country
We are based in the UAE, and our service providers and clients may be elsewhere. Your information may therefore be processed outside the country where you are located, including outside the UAE and the EEA or UK.
When that happens, we make sure the transfer is lawful. For example, we only transfer information to countries or providers recognised as giving adequate protection, or we use safeguards such as the European Commission’s standard contractual clauses, the UK International Data Transfer Agreement or Addendum, or binding contracts with equivalent protections. Under the PDPL, we transfer personal information outside the UAE only where the law allows, and on the basis of your consent where it is required. You can ask us for details of the safeguards we use.
8 How long we keep your information
We keep personal information only as long as we need it for the reasons above, then delete or anonymise it:
- Enquiries that do not lead to work: up to 24 months after our last contact with you.
- Client records: for the length of our relationship and, for accounting and tax records, typically five years afterwards, or longer if the law requires.
- Marketing preferences: until you unsubscribe or withdraw your consent, plus a short record that you did so.
- Server logs: for the short period set by our hosting provider.
We may keep information for longer if we need it to deal with a legal claim or investigation, or if the law requires it.
9 Keeping your information safe
We use appropriate technical and organisational measures to protect personal information from loss, misuse and unauthorised access, including encryption of information in transit (HTTPS), restricting access to people who need it, and choosing reputable providers. No system is completely secure, so we cannot guarantee absolute security.
If a security incident puts your rights at risk, we will notify you and the relevant authority as the law requires.
10 Your rights
Depending on where you are located, you may have the rights below. We honour them wherever we reasonably can, whichever country you are in.
Everyone
- Ask what personal information we hold about you and how we use it, and get a copy.
- Ask us to correct information that is wrong or incomplete.
- Ask us to delete your information, or to restrict or stop using it.
- Withdraw your consent at any time. This does not affect anything we did before you withdrew it.
United Arab Emirates (PDPL)
The PDPL gives you the right to be informed about how your data is processed, to access it, to have it corrected or erased, to restrict processing or object to it, to receive your data in a portable form, to object to decisions made solely by automated means, and to withdraw your consent.
EEA and United Kingdom (GDPR / UK GDPR)
You have the rights of access, rectification, erasure, restriction, data portability and objection (including to direct marketing), the right to withdraw consent, and the right to complain to a data protection authority.
United States, including California
Residents of California and some other states have the right to know what personal information we collect, use and disclose, to request deletion and correction, to opt out of the sale or sharing of personal information (we do neither), and not to be treated unfairly for using these rights. You can use an authorised agent to make a request for you, and we may ask for proof of their authority.
Other countries
If the privacy law where you are located gives you other rights, tell us and we will respect them.
How to use your rights
Email team@digitalgloss.com and tell us what you would like us to do. We may need to confirm your identity first, to keep your information safe. We aim to reply within 30 days, or sooner where the law requires, and we will tell you if we need more time and why. There is no charge, unless a request is clearly unreasonable or excessive. In some cases the law allows or requires us to keep information or to decline a request, and if so we will explain why.
11 Marketing messages
We only send you news and offers about our services if you ask for them, or where the law lets us contact existing clients. Every message includes a simple way to unsubscribe, and you can also email team@digitalgloss.com at any time to stop them. Service messages about work in progress are not marketing and may still be sent.
12 Children
The Website and our services are for businesses and are not aimed at anyone under the age of 18. We do not knowingly collect personal information from children. If you believe a child has given us information, contact us and we will delete it.
13 Third-party services and links
- Social networks: our footer links to LinkedIn, Instagram and Facebook. Those sites have their own privacy policies, and we are not responsible for how they handle information once you leave the Website.
- WhatsApp, telephone and email: if you contact us through these services, your messages and details are also handled by the service provider under its own terms.
14 Changes to this policy
We may update this policy as our business, the Website or the law changes. The “last updated” date and latest version can be found on our privacy policy on our Website. Please check back from time to time.
15 Contact and complaints
For any privacy question, request or complaint, contact us at team@digitalgloss.com. We would like the chance to put things right first.
You also have the right to complain to a data protection authority:
- United Arab Emirates: the UAE Data Office.
- United Kingdom: the Information Commissioner’s Office.
- European Economic Area: the authority in the country where you are located or work.
- Elsewhere: the privacy regulator in your own country or state.
This policy is governed by the laws of the United Arab Emirates, without affecting any rights you have under mandatory local law.