Privacy Policy

1. Who we are

This Privacy Policy explains how Seyran Digital (Seyran Digital Technology L.L.C) (“Seyran Digital”, “we”, “us” or “our”) handles personal data in connection with the website https://seyran.digital/ (the “Website”).

For the purposes of the EU General Data Protection Regulation (GDPR), the UK GDPR, the UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (PDPL) and similar laws, Seyran Digital is the controller of the personal data described in this policy.

2. Scope of this policy

This policy applies to personal data processed when you visit the Website or contact us by email using the address published on it. It does not cover services we provide to clients under a separate written agreement; the processing of personal data in that context is governed by the relevant contract and any data processing terms agreed with the client.

The Website is a corporate information website. It is not used for selling products or services online (no e-commerce), and it has no user accounts, no contact forms and no newsletter sign-up.

3. Personal data we process

3.1 Technical data needed to deliver the Website

We do not collect or keep personal data of visitors, we do not analyse visits and we do not build profiles of visitors. However, when you visit the Website, your browser automatically sends certain technical information, which is processed only as necessary to deliver the Website to your device and keep it secure:

• your IP address;
• the date and time of the request;
• the page or file requested;
• your browser type.

This technical data is processed by our hosting provider and by Cloudflare, Inc. (“Cloudflare”), a service provider that helps us deliver the Website securely (see section 7). It is not used to identify visitors, it is not combined with other data sources, and it is kept only as long as technically necessary.

3.2 Emails you send us

The only way you send us personal data through the Website is by emailing us at [email protected] (for example by clicking the email link, which opens your own email program). In that case we receive your name, email address, the content of your message and any other information you decide to include. We use this information only to reply to you and handle your enquiry. Please do not send us special categories of personal data (for example health data) unless strictly necessary.

4. Cookies and what we do not collect

The Website is deliberately built to minimise data collection. In particular, the Website does not:

• use tracking, analytics or advertising cookies;
• use analytics or statistics tools;
• use advertising, remarketing or tracking pixels, or profile visitors;
• include social media plugins or embedded third-party content (such as videos or maps);
• contain contact forms, user accounts or online purchasing.

4.1 Strictly necessary cookies

We use only strictly necessary cookies and similar technologies:

• Security cookies set by Cloudflare, such as __cf_bm (bot protection, about 30 minutes) and cf_clearance (set after a security check is passed, short-lived), which help protect the Website against malicious traffic;
• Your cookie notice choice, which our cookie notice stores in your browser’s local storage under the key cookie_consent (your choice and the date, kept for 12 months) so that the notice is not shown again.

Strictly necessary cookies do not require your consent, but we inform you about them through our cookie notice. You can change your choice at any time using the “Cookie settings” link in the footer. The JavaScript on the Website controls display behaviour (for example the menu, animations and the cookie notice) and does not send any data to us or to third parties. See our Cookie Policy for more information.

5. Purposes and legal bases

We process personal data only for the following purposes and on the following legal bases:

Where we rely on legitimate interests, we have balanced those interests against your rights and freedoms. You may object to such processing at any time (see section 10). Under the UAE PDPL and other laws, we rely on the equivalent grounds available under those laws, including processing necessary to perform or prepare a contract, to comply with legal obligations, or as otherwise permitted.

We do not currently rely on consent for any processing on the Website. If we ever do, you will be able to withdraw your consent at any time without affecting the lawfulness of processing before withdrawal.

6. How long we keep data

• Technical request data is not used to identify visitors and is kept only as long as technically necessary to deliver and secure the Website.
• Your cookie notice choice is stored only in your own browser for 12 months, after which the notice is shown again. You can delete it at any time by clearing your browser’s site data.
• Email correspondence is kept only as long as needed to reply to you and deal with your enquiry and any resulting business relationship. It is then deleted, unless we are required by law to keep it for longer (for example under tax or commercial record-keeping rules) or need it to establish, exercise or defend legal claims.

7. Who we share data with

We do not sell or rent your personal data, and we do not share it with third parties for their own marketing. We share personal data only with:

• Cloudflare, Inc., a service provider that helps us deliver the Website securely (content delivery and protection against malicious traffic). Cloudflare processes technical request data, such as IP addresses, on our behalf. See the Cloudflare Privacy Policy;
• Our hosting provider, which processes technical request data on our behalf to serve the Website;
• Our email service provider, which hosts our mailbox and processes the emails you send us on our behalf;
• Professional advisers (such as lawyers, accountants and auditors) where necessary, under a duty of confidentiality;
• Public authorities, courts or regulators where we are required to do so by law or to protect our legal rights.

Service providers acting on our behalf process personal data only on our instructions and are bound by appropriate confidentiality and data protection obligations.

8. International transfers

Because we work with international clients and use service providers that may operate in different countries, your personal data may be processed in a country other than the one in which you live, including countries that may not offer the same level of data protection.

In particular, Cloudflare may process technical request data outside your country. Cloudflare applies appropriate safeguards for such international transfers.

Where the law applicable to you requires it, we put appropriate safeguards in place for such transfers, for example:

• transfers to countries recognised as providing an adequate level of protection;
• the European Commission’s Standard Contractual Clauses, the UK International Data Transfer Agreement or Addendum, or equivalent contractual safeguards recognised under the UAE PDPL or other applicable laws;
• other lawful transfer mechanisms, such as where the transfer is necessary to respond to your enquiry or to take steps you have requested prior to entering into a contract.

You can contact us at [email protected] for more information about the safeguards used.

9. Security

We take appropriate technical and organisational measures to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access. These include serving the Website over an encrypted connection (HTTPS), using a service provider that protects the Website against malicious traffic, restricting access to our mailbox to authorised personnel, and selecting service providers that maintain appropriate security standards.

No method of transmission over the internet or of electronic storage is completely secure. Standard email is not end-to-end encrypted, so please consider this before sending us confidential information by email.

10. Your rights

Depending on the law that applies to you, you may have some or all of the following rights in relation to your personal data:

• Access: to obtain confirmation of whether we process your personal data and a copy of it;
• Rectification: to have inaccurate or incomplete data corrected;
• Erasure: to have your data deleted in certain circumstances;
• Restriction: to ask us to limit how we use your data in certain circumstances;
• Objection: to object to processing based on our legitimate interests;
• Data portability: to receive data you provided to us in a structured, commonly used, machine-readable format, or to have it transmitted to another controller, where technically feasible;
• Withdrawal of consent: where processing is based on consent, to withdraw it at any time;
• Complaint: to lodge a complaint with a supervisory authority, such as the data protection authority in the country where you live or work or where an alleged infringement took place (for example your EU member state’s authority, the UK Information Commissioner’s Office, or the UAE Data Office).

Visitors in other jurisdictions may have rights under their local laws, as applicable, for example under the South African Protection of Personal Information Act (POPIA), the Nigeria Data Protection Act 2023 (NDPA), the Kenya Data Protection Act 2019, or the California Consumer Privacy Act as amended by the California Privacy Rights Act (CCPA/CPRA). We will respect those rights to the extent they apply to us. We do not sell or share personal information for cross-context behavioural advertising, as those terms are defined under the CCPA/CPRA.

We would appreciate the opportunity to address any concerns before you approach a supervisory authority, so please feel free to contact us first.

11. How to exercise your rights

To exercise any of your rights, please email us at [email protected]. We will respond within the time limits set by applicable law (generally within one month under the GDPR and UK GDPR). We may need to ask you for information to confirm your identity before acting on your request. Exercising your rights is free of charge, unless a request is manifestly unfounded or excessive.

Please note that because we do not use tracking cookies or identifiers and do not link technical data to individuals, we are generally unable to identify any technical data relating to you specifically.

12. No automated decision-making

We do not use your personal data for automated decision-making, including profiling, that produces legal effects concerning you or similarly significantly affects you.

13. Children

The Website is intended for businesses and professionals and is not directed at children under the age of 16. We do not knowingly collect personal data from children. If you believe a child has sent us personal data, please contact us and we will delete it.

14. Third-party websites

The Website may contain links to other websites. We are not responsible for the privacy practices or content of those websites. Please read the privacy policy of any website you visit.

15. Changes to this policy

We may update this Privacy Policy from time to time, for example if the Website changes or if the law requires it. The “Last updated” date at the top of this page shows when it was last revised. Where changes are significant, we will make this clear on the Website.

16. Contact us

If you have any questions about this Privacy Policy or how we handle personal data, please contact us: