[DRAFT: have a lawyer review before publishing]
Privacy Policy
Last updated: [PUBLICATION DATE]
This policy explains what personal data Najmetric collects, why we collect it, and the choices you have. We have written it to follow the UAE Federal Decree Law No. 45 of 2021 on the Protection of Personal Data (PDPL) and the principles of the EU General Data Protection Regulation (GDPR): collect only what we need, use it only for clear purposes, keep it safe, and keep it no longer than necessary.
The data controller is [LEGAL COMPANY NAME], registered in [COUNTRY OF REGISTRATION]. You can contact us about privacy at hello@najmetric.com.
1. What data we collect
Data you give us through forms, WhatsApp, email or calls:
- your name, business name, website and country;
- your email address and WhatsApp or phone number;
- information about your advertising, such as monthly ad spend, platforms used and challenges; and
- anything else you choose to tell us in a message.
Data collected automatically when you visit our website:
- essential technical data such as your browser type and IP address, used by our hosting provider to deliver and secure the site; and
- if you accept analytics cookies, usage data such as the pages you visit, how long you stay and the website that referred you. See our Cookie Policy.
Data we access when we work for clients: if you become a client, we may access data in your ad accounts, analytics and CRM. We process that data on your behalf and only to deliver our services, as described in our Terms of Service.
2. Why we use your data, and our legal basis
| Purpose | Legal basis |
|---|---|
| Preparing your free audit and replying to your enquiry | Your consent, and steps you ask us to take before a contract |
| Delivering our services and managing your account | Performance of our contract with you |
| Sending invoices and keeping financial records | Legal obligation |
| Understanding how our website is used, to improve it | Your consent (analytics cookies) |
| Measuring our own advertising, if you accept advertising cookies | Your consent |
| Keeping our website and systems secure | Our legitimate interests |
We do not sell your personal data. We do not use it for automated decisions that have legal or similarly significant effects on you.
3. Who we share data with
We share personal data only with service providers who help us run our business, and only as much as they need:
- Website hosting: [HOSTING PROVIDER]
- Email: [EMAIL PROVIDER, for example Google Workspace]
- Forms: [FORM PROVIDER]
- CRM: [CRM PROVIDER]
- Messaging: WhatsApp (Meta Platforms)
- Analytics: Google Analytics (Google), only with your consent
- Advertising: Meta and Google, only with your consent, for measuring our own ads
We may also share data where the law requires it, or with professional advisers such as lawyers and accountants who are bound by confidentiality.
4. International transfers
Some of our service providers, and members of our team, are based outside the UAE. When personal data is transferred abroad, we make sure it is protected by appropriate safeguards, such as transfers to countries with adequate data protection, contractual protections like standard contractual clauses, or your consent where required.
5. How long we keep data
- Enquiries and audit requests that do not lead to a contract: up to 24 months after our last contact, then deleted.
- Client records: for the length of our contract, and afterwards for as long as the law requires, for example for tax and accounting records.
- Analytics data: up to 14 months, then deleted automatically.
6. How we protect data
We use access controls, two factor authentication, encrypted connections and limited permissions to protect personal data. Only people who need data for their work can access it.
7. Your rights
Subject to applicable law, you have the right to:
- ask for a copy of the personal data we hold about you;
- ask us to correct data that is wrong or incomplete;
- ask us to delete your data;
- ask us to restrict or stop processing your data, or object to it;
- ask for your data in a portable format; and
- withdraw your consent at any time, including for cookies, without affecting processing that already happened.
To use any of these rights, email hello@najmetric.com with the subject "Privacy request". We will reply within 30 days. If you are not satisfied with our answer, you can complain to the UAE Data Office or the data protection authority where you live.
8. Children
Our services are for businesses. We do not knowingly collect personal data from anyone under 18.
9. Changes to this policy
We may update this policy. The date at the top shows when it last changed. If we make important changes, we will show a notice on our website.
10. Contact
For any privacy question or request, email hello@najmetric.com.