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, and you should review them carefully.

Ecomma FZCO is the data controller for the personal data described here. Our contact details are in section 13.

2. Information We Collect

i. Information you give us

We collect the information you choose to submit, which may include:

• Contact details: name, email address, phone number, and company name;
• Enquiry details: the answers you give in our intake forms (for example the type of business, revenue range, market, timeline, and free-text notes);
• Correspondence: emails you send us, chat messages, and notes from calls and meetings;
• Booking details: the information you provide when you schedule a call;
• Offer documents: the details you enter into the offer form when you submit a non-binding letter of intent.

We do not take payments on the Website and we do not collect or store payment card details.

ii. Information collected automatically

When you visit the Website, our hosting infrastructure records ordinary technical data such as your IP address, the pages requested, the referring page, and your browser and device type. This is necessary to serve and secure the site.

If you consent to analytics or marketing cookies, we also collect information about how you use the site and, if you arrived by clicking one of our ads, the advertising click identifier that brought you here. Nothing in this second category is collected before you consent. The full list of cookies, what each one does, and how long it lasts is in our Cookie Policy.

We use your IP address to determine, at the country level only, whether you are in a region where prior consent is required before any non-essential cookies load. We do not store this determination.

3. How We Use Your Information, and Our Legal Basis

We do not sell your personal data, and we do not use automated decision-making that produces legal or similarly significant effects about you.

4. Cookies and Similar Technologies

Analytics and marketing cookies are off by default for visitors who require consent, and load only after you accept them. You can change or withdraw your choice at any time using the Cookie preferences link in the Website footer. Our Cookie Policy lists every cookie we set, its purpose, and its duration.

5. Marketing Emails

We send marketing emails only to people who have ticked the marketing consent box on one of our forms. The box is never pre-ticked, and submitting a form without ticking it does not sign you up. Where we rely on your consent, you may withdraw it at any time.

To unsubscribe, click the unsubscribe link in any marketing email, or email itsystems@ecomma.co. Withdrawing consent does not affect the lawfulness of processing carried out before you withdrew it. You may still receive service messages that relate to an enquiry or transaction you started, such as replies to your questions and call confirmations.

6. Who We Share Your Information With

We share personal data with service providers who process it on our behalf, under contracts that require them to protect it and use it only to provide services to us:

We may also disclose personal data:

• to our professional advisers (such as lawyers and accountants) where necessary for the services they provide to us;
• to a buyer or successor in connection with a merger, acquisition, restructuring, or sale of assets;
• where required by law, or to establish, exercise, or defend legal claims, or to protect the rights and safety of our users or others.

7. International Transfers

We are based in the United Arab Emirates, and some of our providers process data in the United States, as set out in the table above. Where personal data leaves the EEA or the UK, we rely on appropriate safeguards, principally the European Commission's Standard Contractual Clauses (with the UK Addendum where the UK GDPR applies), together with any additional measures required in the circumstances. You may request a copy of the relevant safeguards by emailing itsystems@ecomma.co.

8. How Long We Keep It

Where a longer period is required by law, or where data is needed for an ongoing legal claim, we keep it for as long as that requires and then delete or anonymize it.

9. Your Rights

Depending on where you live, you have rights over your personal data. If you are in the EEA or the UK, these include the right to:

• Access the personal data we hold about you, and receive a copy;
• Rectify data that is inaccurate or incomplete;
• Erase your data where the law allows;
• Restrict how we process it in certain circumstances;
• Object to processing based on our legitimate interests, and to object to direct marketing at any time;
• Data portability: receive data you gave us in a structured, machine-readable format;
• Withdraw consent at any time where we rely on it, without affecting processing carried out beforehand;
• Complain to your local supervisory authority, an EU Data Protection Authority, or the UK Information Commissioner's Office at ico.org.uk.

How to exercise them: email itsystems@ecomma.co. We respond within one month of receiving your request. If your request is complex, or you have made several, we may extend that by up to two further months, and we will tell you within the first month if we do. We may need to verify your identity before we act. Exercising these rights is free of charge.

California residents: we do not sell personal information for monetary consideration. Some cookie-based sharing may qualify as "sharing" for cross-context behavioral advertising under the CCPA/CPRA; rejecting non-essential cookies via our banner stops it. You may also submit a "Do Not Sell or Share My Personal Information" request, and designate an authorized agent, by emailing itsystems@ecomma.co. We will not discriminate against you for exercising your rights.

10. Interest-Based Advertising Opt-Outs

Rejecting marketing cookies in our banner stops the advertising-related processing described in this policy. To opt out of interest-based advertising more broadly, across other companies' sites, you can also use these industry tools:

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

11. Security

We maintain administrative, technical, and physical safeguards designed to protect personal data against unauthorized access, disclosure, alteration, and destruction. The Website is served over HTTPS, and access to our customer-relationship system is restricted to staff who need it. No method of transmission or storage is completely secure, so we cannot guarantee absolute security.

12. Children's Privacy

The Website is a business service and is not directed to children. We do not knowingly collect personal data from anyone under 16. If you believe a child has provided personal data to us, contact itsystems@ecomma.co and we will delete it.

13. Contact Us

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

Privacy correspondence address
Ecomma FZCO, Dubai Silicon Oasis, DDP, Building A2, Dubai, United Arab Emirates
Trade License Number 22368
itsystems@ecomma.co

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Changes take effect when posted to the Website with a revised Effective Date. Where a change materially affects how we use your personal data, we will take reasonable steps to bring it to your attention.