PRIVACY POLICY

Last updated: 15.09.2026
This Website Privacy Policy explains how Orientodor Marketing L.L.C-FZ, a company registered in Dubai, U.A.E. (“Company”, “we”, “us” or “our”), processes personal data collected through our website https://orientodor.com/.  
We provide services in growth marketing, digital marketing, monetization engineering and data infrastructure.
This Privacy Policy applies only to personal data processed by us as a controller in connection with this website. Where we process personal data on behalf of our clients as a processor in the course of providing services, that processing is governed by the relevant client agreement and data processing agreement.

1. Controller and contact details
The controller of your personal data is:
Orientodor Marketing L.L.C-FZ
 Registered address: The Meydan Hotel, Grandstand, 6th floor, Meydan Road, Nad Al Sheba, Dubai, U.A.E PO Box 9305
 Email: fin@orientodor.com

2. Applicable legal framework and geographic scope
 DUBAI, UAE – PDPLThe Company is established in Dubai, United Arab Emirates. Federal Decree-Law No. 45 of 2021 Concerning the Protection of Personal Data (“UAE PDPL”), together with its applicable implementing regulations, applies where the Company controls or processes the collection, holding, storage, processing, transfer or use of personal data in or from the United Arab Emirates.European Union and European Economic Area - GDPR
The EU General Data Protection Regulation, Regulation (EU) 2016/679 ("GDPR"), applies where the relevant processing falls within its territorial scope. This may include processing carried out in the context of an establishment in the EU/EEA, or processing by a non-EU controller that is related to intentionally offering goods or services to individuals in the EU/EEA or monitoring their behavior there. Mere accessibility of the Website in the EU/EEA does not, by itself, determine that the GDPR applies.
We do not use Website analytics, behavioral advertising, profiling or other tools intended to monitor visitors' behavior. Where the GDPR does not legally apply to a particular Website interaction, we nevertheless aim to apply substantially equivalent transparency, security and rights-handling standards to individuals in the EU/EEA.
The operational parts of this Policy apply generally. Where a legal basis or right must be identified under a specific law, the relevant GDPR and UAE PDPL provisions are stated separately.

3. What personal data we collect through the website
 Data You Provide Directly
 When you interact with our website or contact us, we may collect the following categories of personal data:
 • Contact information: full name, company name, email address
 • Communication data: we may also collect the content of any message, enquiry or request that you submit to us through the form, if the form contains a message field or similar free-text field.

Providing the information requested in the contact form is voluntary; however, if you do not provide the information necessary to identify and respond to your enquiry, we may be unable to respond.

 Data Collected Automatically
 When you visit our website, we may automatically collect:
 • Technical data: IP address, browser type and version, operating system, device information

 Sensitive Personal Data
 We do not intentionally collect sensitive personal data (e.g. Identity Card numbers, passport numbers, health information, racial or ethnic origin, religious beliefs) through our website.
We do not use the website to collect personal data for marketing purposes. We do not operate newsletter subscriptions, marketing forms, analytics tools, profiling tools or advertising technologies through the website.

4. Cookies and technical data
Our website uses only strictly necessary cookies. These cookies are required for the website to operate securely and to provide the service requested by you, such as enabling the contact form or maintaining basic website functionality. They may be used, for example, to:

• enable basic website functionality;
• support secure website operation;
• remember essential technical settings;
• enable the contact form to function properly;
• prevent abuse or maintain website security.

We do not use:

• analytics cookies;
• marketing cookies;
• advertising cookies;
• social media tracking cookies;
• profiling cookies;
• third-party tracking cookies.

These cookies cannot be switched off through our website because they are necessary for the website to operate. You may be able to block or delete cookies through your browser settings, but doing so may affect the functionality or security of the website. 
If we introduce analytics, marketing or other non-essential cookies in the future, we will update this Privacy Policy and, where required, ask for your consent before using them.

5. Purposes of Collection and how this is permitted under the UAE PDPL and GDPR
We process personal data collected through the website for the following purposes:
We do not process website form data for marketing purposes.

6. No marketing through the website
We do not use the contact form to subscribe you to newsletters, marketing emails, promotional campaigns or advertising communications.
If you contact us through the website, we will use your personal data only to review, handle and respond to your message or related business request.

7. Children’s data
Our website and services are intended for business and professional users.
We do not knowingly collect or process personal data of children through the website. If you believe that a child has provided personal data to us through the website, please contact us and we will take appropriate steps to delete the information.

8. Disclosure of Personal Data
Third-Party Service Providers 
 We may disclose personal data to third-party service providers, including data processors, that process personal data on our behalf and for our purposes, such as IT and hosting providers, business systems providers, professional advisers and other operational support providers.
 Where we engage a data processor to process personal data on our behalf, we adopt contractual or other appropriate means to ensure that the processor does not retain the personal data longer than necessary and protects it against unauthorized or accidental access, processing, erasure, loss or use.
Regulatory and Legal Authorities
 We may disclose personal data to government agencies, regulators, law enforcement bodies, or courts where required by law, including under the UAE PDPL and/or GDPR and other applicable UAE laws or applicable anti-money laundering legislation. Such disclosures are made only to the extent required and permitted by law.

 Business Transfers
 In the event of a merger, acquisition, or sale of all or part of our business assets, personal data held by us may be transferred to the successor entity, subject to equivalent data protection obligations.

 No Sale of Personal Data
 We do not sell, rent, or trade your personal data to third parties for their own marketing purposes.

9. International transfers
The Company is established in Dubai, United Arab Emirates. Personal data submitted through the Website may therefore be received, stored or otherwise processed in the United Arab Emirates. The United Arab Emirates is outside the EEA and, as of the last update of this Policy, is not a country covered by an adequacy decision of the European Commission. Where the GDPR's international-transfer rules apply to a transfer of personal data to the United Arab Emirates or another country outside the EEA, we rely on an available lawful transfer mechanism, such as an applicable adequacy decision, the European Commission's Standard Contractual Clauses, together with supplementary measures where required, or another mechanism permitted under Chapter V GDPR. Derogations under Article 49 GDPR are used only where the applicable legal conditions are met.
Under Federal Decree-Law No. 45 of 2021 Concerning the Protection of Personal Data (“UAE PDPL”), cross-border transfers of personal data are governed principally by Articles 22 and 23. Personal data may be transferred outside the United Arab Emirates where the recipient jurisdiction provides an adequate level of protection as recognised in accordance with the UAE PDPL, including where applicable through relevant bilateral or multilateral arrangements. Where an adequate level of protection is not available, personal data may be transferred where an applicable condition under Article 23 is satisfied, including through contractual arrangements requiring appropriate data-protection safeguards, the explicit consent of the data subject where legally permitted, or where the transfer is necessary for contractual purposes, the establishment, exercise or defence of legal rights, international judicial cooperation, or the protection of the public interest. We may implement contractual, technical and organizational safeguards and other appropriate measures to protect personal data transferred internationally in accordance with applicable UAE data-protection law.

10. Retention
We retain personal data only for as long as necessary for the relevant purpose, taking into account applicable legal obligations, statutory limitation periods, security needs and the principle of data minimization.
Inquiry-form submissions and related correspondence are retained for up to six months after the inquiry is closed or after the last substantive communication. If an inquiry leads to pre-contractual negotiations or a contractual relationship, the relevant records may be transferred to separate business or client files and retained in accordance with the applicable contract, a separate privacy notice, applicable legal retention requirements and statutory limitation periods.
Routine server, security and error logs are normally retained for up to 90 days. Such logs may be retained for a longer period where necessary to investigate a security incident, prevent or address abuse, comply with applicable law, or establish, exercise or defend legal claims.
Data contained in strictly necessary technical cookies are retained only for the duration of the relevant session or for the limited technical period required for the relevant Website function. Such data may be retained for a longer period only where this is necessary for security, troubleshooting or the establishment, exercise or defense of legal claims.

11. Your rights
UAE - rights and complaints under the UAE PDPL
Subject to the conditions, procedures, limitations and exemptions under the UAE PDPL, you may:

• request information about the personal data we process about you, including the types of personal data processed, the purposes of processing, relevant automated-processing decisions, the categories of recipients with whom your personal data may be shared, applicable retention criteria, cross-border transfer safeguards and the procedures available for exercising your rights;
• request to receive personal data relating to you that you have provided to us in accordance with the applicable data-portability requirements, and request the transfer of such personal data to another controller where technically feasible;
• request correction of inaccurate personal data relating to you or completion of incomplete personal data without undue delay;
• request erasure of your personal data in the circumstances provided for under the UAE PDPL, including where the personal data is no longer necessary for the purposes for which it was collected or processed, where consent on which the processing is based has been withdrawn, or where the processing is carried out in violation of applicable law, subject to any applicable exceptions or legal retention requirements;
• request restriction or cessation of processing in the circumstances provided for under the UAE PDPL, including where you contest the accuracy of your personal data or where processing is carried out contrary to the agreed purposes or applicable legal requirements;
• object to and require us to stop processing your personal data for direct marketing purposes, including profiling to the extent that it relates to direct marketing, and in certain other circumstances specified by the UAE PDPL; and
• object to decisions resulting from automated processing, including profiling, where such decisions have legal consequences or significantly affect you, subject to the exceptions provided for under the UAE PDPL, and request human review of an automated-processing decision where applicable.

To exercise your rights, please contact us at fin@orientodor.com. We may need to verify your identity before responding to your request.
If you consider that our processing of your personal data may contravene the UAE PDPL, you may submit a complaint to the UAE Data Office in accordance with Article 24 of the UAE PDPL and the applicable procedures established by the competent authority.
European Union and European Economic Area – rights and complaints under the GDPR
Subject to the conditions and limitations under applicable data protection law, you may have the right to:

• request access to your personal data;
• request correction of inaccurate or incomplete personal data;
• request deletion of your personal data;
• request restriction of processing;
• object to processing based on legitimate interests;
• request data portability, where applicable;
• withdraw consent, where processing is based on consent;
• lodge a complaint with a supervisory authority.

To exercise any of the above rights, please submit a written request to our DPO at  
Email: fin@orientodor.com  
We may require reasonable information to verify your identity before processing your request.
Where the GDPR applies, you may lodge a complaint with a supervisory authority in the EU/EEA Member State of your habitual residence, place of work or the place of the alleged infringement. A list of EU/EEA supervisory authorities is available from the European Data Protection Board.

12. Security of Personal Data
 Orientodor Marketing implements appropriate technical and organizational security measures to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access. Our security measures include:
 • Access controls and role-based permissions limiting access to personal data to authorized personnel only;
 • Regular security assessments and vulnerability scanning of our website and systems;
 • Staff training on data protection and security awareness;
 • Contractual security obligations imposed on all third-party data processors;
 • Incident response procedures, including our Data Breach Response Plan.
 In the event of a personal data breach, we will comply with applicable notification requirements under the UAE PDPL and, where applicable, the GDPR. Where required by applicable law, this may include notifying the UAE Data Office, the competent EU/EEA data protection supervisory authority or authorities, and affected individuals within the applicable statutory timeframes and subject to the relevant legal thresholds and exceptions. 

13. Automated decision-making
We do not use personal data collected through the website for automated decision-making, including profiling, that produces legal effects concerning you or similarly significantly affects you. 

14. Links to third-party websites
Our website may contain links to third-party websites. We are not responsible for the privacy practices of those websites. We encourage you to read their privacy notices before providing personal data to them.

15. Changes to this Privacy Policy
We may update this Privacy Policy from time to time. The latest version will be published on this page with the “Last updated” date.

16. Contact us
For privacy questions, requests or complaints, please contact:
Orientodor Marketing L.L.C-FZ
 Registered address: The Meydan Hotel, Grandstand, 6th floor, Meydan Road, Nad Al Sheba, Dubai, U.A.E PO Box 9305
 Email: fin@orientodor.com