Privacy Policy

1. Introduction

This Privacy Policy describes the information and data collection, storage, and use practices and policies of Ecomma FZCO ("Ecomma FZCO," "Ecomma," "we," "our," "us") on the website at ecomma.co (along with all subdomains, collectively, the "Website"). This Privacy Policy applies only to the Website and not to any other websites that you may access from the Website, each of which may have privacy practices that differ from this Privacy Policy. When you leave the Website via a link to another website, you are subject to that site's policies (the "Third Party website policies"), and you should review them carefully.

2. Information Collection and Use Practices

i. Types of Information Collected

We may collect two types of information: Personally Identifiable Information ("PII") and Non-Personally Identifiable Information ("Non-PII"). We collect PII and Non-PII when you use the Website and may also collect such information during in-person discussions, phone calls, and electronic or written communications.

PII we collect may include:

1. Contact Data (name, mailing address, email address, phone number);
2. Financial/Billing Data (e.g., payment card details processed by Stripe; we do not store full card numbers);
3. Demographic Data (e.g., zip/postal code, age);
4. Account & Communications Data (emails you send us, form submissions, support chats, survey responses, forum posts).

Non-PII we collect automatically may include:

1. IP address and approximate location;
2. Domain/Referrer URLs;
3. Device identifiers and device type;
4. Browser type and settings;
5. Operating system;
6. Pages viewed and time spent;
7. General usage patterns and interactions (collectively "Non-PII").

Non-PII does not directly identify you but helps us improve the Website and services.

ii. Uses of Information Collected

We use PII and Non-PII to:

• Provide, operate, maintain, and improve the Website and our services;
• Process transactions and provide customer support;
• Personalize content and your experience;
• Send service notices and administrative messages;
• Conduct analytics, research, reporting, and troubleshooting;
• Detect, prevent, and respond to fraud, abuse, security risks, and technical issues;
• Comply with legal obligations and enforce our terms;
• With your consent (where required), send marketing communications we think may interest you.

We do not sell your PII.

iii. Technology We May Use: Cookies, Web Beacons, Pixels, and Clear Gifs

We (and our partners) use cookies, web beacons, pixels (including Meta Pixel), SDKs, and clear gifs to collect information about your interactions with the Website, such as the page viewed, referring page, time on page, device/browser settings, and conversions. We use these technologies to:

• Understand traffic patterns and aggregate usage;
• Measure how you use and interact with the Website;
• Improve our services and optimize your experience;
• Provide auditing, research, and reporting (e.g., Google Analytics);
• Enable login/session continuity and remember preferences;
• Provide relevant content and advertising;
• Manage and secure the Website.

Some cookies are essential for the Website to function (strictly necessary). Other cookies are for analytics and advertising—these may be optional and used with your consent where required. You can manage cookies via your browser settings and, where offered, via our cookie banner/preferences tool.

iv. Sharing of Personal Information

We may share PII with:

• Affiliates and service providers/processors that support our operations (e.g., Stripe for payments; Google Analytics for analytics; Meta for advertising pixels; Mailchimp and HubSpot for email/CRM; Lovable for site/app building and hosting features). These parties are contractually obligated to protect your data and use it only to provide services to us. We do not share full payment card numbers with third parties other than our payment processor(s).
• Business transfers: In connection with a merger, acquisition, restructuring, bankruptcy, or sale of assets, data may be transferred to the successor.
• Legal and safety: When required by law or to protect our rights, property, users, or others.

Because Non-PII does not identify you personally, we may use and disclose Non-PII for any lawful purpose.

v. Interest-Based Ads

We may share Non-PII with advertising partners to provide interest-based advertising on non-affiliated sites. Ads may be personalized based on your activities on the Website and other sites over time. We do not share PII with ad partners for these purposes.

Opt-out: You can opt out of some interest-based ads via:

• Network Advertising Initiative (NAI): networkadvertising.org/managing/opt_out.asp
• AboutAds (DAA): aboutads.info/choices
• Your mobile device's ad settings (Limit Ad Tracking/Opt out of Ads).

vi. Email Marketing

By submitting your email on the Website, you consent to receive emails from Ecomma FZCO (and, where permitted, affiliates/partners). To opt out, click "Unsubscribe" in any marketing email. Please allow up to 10 business days to process. You may still receive transactional or service emails.

Contact for email preferences: itsystems@ecomma.co

3. Confidentiality and Security of Personal Information

i. User Ability to Access, Update, and Correct PII

You may request access, correction, or deletion of your PII by contacting itsystems@ecomma.co. If your username/password is lost or used without permission, promptly email support@ecomma.co.

ii. Opt-Outs and Do Not Sell/Share

• Marketing emails: Use the Unsubscribe link or email itsystems@ecomma.co.
• Analytics/Advertising cookies: Manage via browser settings and our cookie banner/preferences tool (where available).
• California (CPRA): We do not "sell" PII for monetary consideration. Certain sharing for cross-context behavioral advertising may be deemed "sharing." You may exercise your "Do Not Sell or Share My Personal Information" rights by emailing itsystems@ecomma.co and by using the cookie preferences tool (where offered).

iii. Security

We maintain reasonable administrative, technical, and physical safeguards designed to protect PII against unauthorized access, disclosure, alteration, and destruction. However, no method of transmission or storage is 100% secure.

4. Your Privacy Rights (GDPR / UK-GDPR / CCPA-CPRA and others)

Depending on where you live, you may have rights including:

• Access to your PII and portability (copy of your data);
• Correction (rectification) of inaccurate data;
• Deletion (erasure) of your PII;
• Restriction or objection to certain processing (including direct marketing);
• Withdraw consent where processing is based on consent (without affecting prior lawful processing);
• Appeal/Complaint to your local supervisory authority (e.g., an EU Data Protection Authority or the UK ICO).

How to exercise: Email itsystems@ecomma.co with your request. We will verify your identity before acting. If you are a California resident, you can designate an authorized agent.

Legal Bases (GDPR/UK-GDPR): We process PII on bases including:

• Performance of a contract (to provide services you request);
• Legitimate interests (e.g., website security, analytics, improvement, fraud prevention);
• Compliance with legal obligations;
• Consent (e.g., non-essential cookies/marketing where required).

5. Data Retention

We retain PII only as long as necessary for the purposes described above, to comply with legal obligations, resolve disputes, and enforce agreements. Retention periods may vary by data category and purpose. When we no longer need PII, we will delete or de-identify it.

6. International Data Transfers

We are based in the United Arab Emirates and may process data in other countries, including the United States and EU/UK via our processors. Where required, we rely on appropriate safeguards for cross-border transfers (e.g., Standard Contractual Clauses (SCCs) for EU/UK residents and comparable mechanisms where applicable).

7. Children's Privacy

The Website is not directed to children under 13 (or under 16 where required by local law), and we do not knowingly collect PII from such children. If you believe a child has provided PII to us, contact itsystems@ecomma.co and we will take appropriate steps.

8. Third-Party Links, User-Generated Content & Public Areas

Except where expressly stated, we are not affiliated with third-party sites that link to or from our Website. Review the Third Party website policies of each site you visit. We are not responsible for the security or accuracy of third-party sites or for information you choose to disclose in public areas (e.g., forums, message boards). Information disclosed in public areas may become public.

9. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Changes take effect upon posting to the Website with a revised Effective Date. Your continued use of the Website after changes are posted constitutes acceptance.

10. Contact Us

If you have questions about this Privacy Policy or want to exercise your rights, contact us at:

itsystems@ecomma.co or write to:
Ecomma FZCO, Dubai Silicon Oasis, DDP, Building A2, Dubai, United Arab Emirates
Trade License Number 22368

11. Data Subprocessors (Summary)

We use reputable providers to help operate the Website and services. These include, for example:

• Stripe (payments)
• Google Analytics (analytics/measurement)
• Meta Pixel (ads/attribution)
• Lovable (site/app building and hosting features)
• Mailchimp (email marketing)
• HubSpot (CRM/marketing automation)

Each subprocessor's use is limited to providing contracted services to us under appropriate data protection terms.