Privacy Policy

1. Introduction

 

Codeeo Technologies FZCO ('Codeeo', 'we', 'our', or 'us') is a company registered in the IFZA Free Zone, Dubai, United Arab Emirates. We operate as a digital agency and business setup consultancy providing services including UAE company formation, web development, branding, digital marketing, AI solutions, and offshore team staffing.

This Privacy Policy explains how we collect, use, disclose, retain, and protect personal data obtained through our website (www.codeeo.com), our services, marketing activities, and business operations. It applies to all clients, website visitors, prospective clients, vendors, partners, and any other individuals whose personal data we process.

We are committed to full compliance with the UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (PDPL) and, where applicable, the EU General Data Protection Regulation (GDPR) and any other applicable data protection legislation.

By engaging our services or using our website, you acknowledge that you have read and understood this Privacy Policy.

 

2. Definitions

 

For the purposes of this Privacy Policy, the following definitions apply:

• Personal Data: Any information relating to an identified or identifiable natural person.
• Processing: Any operation performed on personal data, including collection, storage, use, transmission, or deletion.
• Data Controller: Codeeo Technologies FZCO, which determines the purposes and means of processing personal data.
• Data Subject: Any natural person whose personal data is processed by Codeeo.
• Consent: A freely given, specific, informed, and unambiguous indication of the data subject's agreement to the processing of their personal data.
• Third Party: Any person or entity other than the data subject and Codeeo.

 

3. Information We Collect

 

3.1 Information You Provide Directly

• Full name, business name, job title, and designation
• Email address, phone number (including WhatsApp), and postal address
• Passport copy, Emirates ID, or other identification documents (required for company formation services)
• Payment and billing information (processed through secure third-party gateways)
• Business registration details, trade licence information, and shareholder data
• Content of enquiries, consultation requests, contracts, and correspondence
• Information provided in onboarding forms, lead forms, and service agreements

 

3.2 Information Collected Automatically

• IP address, device type, browser type, and operating system
• Pages visited, time spent on pages, referring URLs, and click behaviour
• Cookies, pixel tags, and similar tracking technologies (see Part Two)
• Geographic location data (country/city level)
• Form submissions and website interactions

 

3.3 Information from Third Parties

• Business contact information from LinkedIn, referral partners, or channel partners
• Information from government portals and free zone authorities during company formation
• Analytics data from Google Analytics, Meta Pixel, and similar platforms
• CRM data synced from Zoho CRM or connected platforms

 

4. Legal Basis for Processing

We process personal data only where a valid legal basis exists. These include:

• Contractual Necessity: Processing is required to perform or enter into a contract with you.
• Legal Obligation: Processing is required to comply with applicable UAE and international laws, including anti-money laundering (AML), know-your-customer (KYC), and corporate governance regulations.
• Legitimate Interests: Processing serves our legitimate business interests (e.g. fraud prevention, service improvement, business development), provided these do not override your rights.
• Consent: Where you have given clear, informed consent, such as for marketing communications or non-essential cookies. You may withdraw consent at any time.
• Vital Interests: In rare circumstances, to protect life or prevent serious harm.

 

5. How We Use Your Information

We use personal data for the following purposes:

• To provide and fulfil the services you have contracted us for, including company formation, web development, digital marketing, and related services
• To communicate with you regarding your project, account, or enquiry
• To process payments and issue invoices and receipts
• To fulfil legal and regulatory obligations, including KYC verification, document notarisation, and government filings
• To send service-related notifications, updates, or account communications
• To send marketing and promotional materials where you have opted in or where permitted by applicable law
• To conduct market research, analytics, and business intelligence to improve our services
• To manage and optimise our website performance and user experience
• To detect, prevent, and investigate fraud, security breaches, and unlawful activities
• To enforce our contractual rights, Terms and Conditions, and other legal rights
• To comply with court orders, regulatory requirements, or government requests

We do not use personal data for automated decision-making or profiling that produces legal or similarly significant effects without your consent.

 

6. Disclosure of Personal Data

We may share your personal data with the following categories of recipients:

6.1 Service Providers and Processors

We engage trusted third-party vendors to support our operations, including cloud hosting providers, payment processors, CRM platforms (Zoho CRM), email service providers, and analytics platforms. These parties process data solely on our documented instructions under binding data processing agreements.

6.2 Government and Regulatory Authorities

We are required to share identification and corporate documents with UAE free zone authorities (e.g., DMCC, IFZA, and JAFZA), the Ministry of Economy, UAE banks, and other regulatory bodies as part of company formation and compliance obligations.

6.3 Professional Advisors

We may share data with legal counsel, auditors, and compliance consultants under strict confidentiality obligations.

6.4 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of assets, personal data may be transferred to the relevant parties, subject to appropriate safeguards and notice to data subjects.

6.5 Other Disclosures

We will not sell, rent, or trade your personal data to any third party for commercial purposes. We will only disclose data beyond the above where required by law or with your explicit consent.

 

7. International Data Transfers

Some of our service providers and partners are located outside the UAE, including in the European Union, the United Kingdom, Pakistan, and the United States. Where we transfer personal data internationally, we ensure appropriate safeguards are in place, including:

• Standard contractual clauses approved by the relevant supervisory authority
• Transfers to countries with an adequate level of data protection recognised under UAE law
• Binding corporate rules or other lawful mechanisms under applicable law

Our Pakistan-based operations team (Karachi) acts under the direction of Codeeo Technologies FZCO and is contractually bound to the same data protection standards set out in this policy.

 

8. Data Retention

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law. Our standard retention periods are as follows:

• Client contractual and transaction records: 7 years (UAE commercial and tax law requirements)
• Company formation documents (KYC/AML): 5 years after the end of the business relationship, or as required by DMCC/IFZA regulations
• Marketing opt-in records: Until consent is withdrawn, plus 1 year
• Website analytics data: 26 months (Google Analytics default, configurable)
• Job applicant data: 12 months from the date of application
• Correspondence and support records: 3 years

After retention periods expire, data is securely deleted or anonymised. You may request earlier deletion subject to our legal obligations (see Section 10).

 

9. Data Security

Codeeo implements appropriate technical and organisational measures to protect personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. These measures include:

• SSL/TLS encryption for all data transmitted via our website
• Access controls and role-based permissions on all internal systems
• Password policies and two-factor authentication on critical platforms
• Regular security assessments and vulnerability reviews
• Staff training on data protection and information security
• Contractual security obligations with all third-party processors

In the event of a personal data breach that poses a risk to data subjects, we will notify the UAE Data Office (and any other relevant authority) and affected individuals within the timeframes required by applicable law.

 

10. Your Rights as a Data Subject

Subject to applicable law, you have the following rights with respect to your personal data:

• Right of Access: To obtain confirmation of whether we process your data and request a copy.
• Right to Rectification: To request correction of inaccurate or incomplete personal data.
• Right to Erasure: To request deletion of your personal data where it is no longer necessary or where you withdraw consent.
• Right to Restriction: To request that we restrict processing in certain circumstances.
• Right to Data Portability: To receive your personal data in a structured, machine-readable format.
• Right to Object: To object to processing based on legitimate interests or for direct marketing purposes.
• Right to Withdraw Consent: To withdraw consent at any time where processing is based on consent.
• Right to Lodge a Complaint: To lodge a complaint with the UAE Data Office or other competent authority.

To exercise any of these rights, please contact us at [email protected]. We will respond within 30 days. We may require proof of identity before fulfilling a request. Some rights are subject to legal exemptions (e.g., where retention is required by law).

 

11. Children's Privacy

Our services and website are directed exclusively at business professionals and are not intended for individuals under the age of 18. We do not knowingly collect personal data from minors. If we become aware that we have inadvertently collected data from a minor, we will promptly delete such data.

 

12. Marketing Communications

We may contact you with information about our services, offers, and industry insights where you have

• Opted in to receive marketing communications via our website or lead forms
• Provided your business contact details in a professional context where marketing is a legitimate expectation

You may opt out of marketing communications at any time by clicking the 'Unsubscribe' link in any email, replying 'STOP' to WhatsApp messages, or contacting us at [email protected]. Opting out of marketing does not affect communications relating to your active service or legal obligations.

 

13. Third-Party Links and Services

Our website may contain links to third-party websites, platforms, or tools (e.g. government portals, payment gateways, social media platforms). This Privacy Policy applies solely to data processed by Codeeo. We are not responsible for the privacy practices of third-party sites and encourage you to review their respective privacy policies.

 

14. Changes to This Privacy Policy

We reserve the right to update this Privacy Policy at any time to reflect changes in our practices, legal requirements, or the services we offer. Material changes will be communicated via our website and, where appropriate, by email. The 'Last Updated' date at the top of this policy reflects the most recent revision. Continued use of our services after the effective date constitutes acceptance of the updated policy.

 

15. Contact & Data Protection Enquiries

If you have any questions, concerns, or requests regarding this Privacy Policy or our data protection practices, please contact:

 

Codeeo Technologies FZCO

IFZA Business Park, Dubai Silicon Oasis, Dubai, UAE

Email: [email protected]

Website: https://www.codeeo.com