DRAFT: to be reviewed by a UAE lawyer before launch
Privacy Policy
What personal data we collect, why, and the rights you have under UAE law.
Last updated
Who we are
Anja is operated by [LEGAL ENTITY NAME TO FILL], trade licence [TRADE LICENCE NUMBER TO FILL], Park Horizon, Dubai Hills Estate, Dubai, United Arab Emirates ("we", "us"). We are the controller of the personal data described in this policy.
This policy is written with the UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (PDPL) in mind. If you have questions, write to conciergerie@tgasparato.com.
What we collect
- Newsletter: your email address.
- Private hire enquiries: your name, email, UAE mobile number, preferred date, number of guests and anything you choose to tell us.
- Shop orders: the items in your bag, your delivery or collection choice, and the details you send us on WhatsApp to complete the order (name, phone, delivery address).
- Technical data: your bag is stored in your own browser (local storage) so it survives a page refresh. We do not receive it until you send an order.
- Analytics, only if you accept: anonymous page views and device type, collected by Vercel Analytics without cookies that identify you.
Why we use it, and on what basis
- To answer enquiries and fulfil orders (taking steps at your request before entering a contract, and performing the contract).
- To send the newsletter (your consent, which you can withdraw at any time by replying "unsubscribe" or using the link in any letter).
- To understand which pages are useful (your consent, given through the cookie banner).
- To keep records required by UAE tax and commercial law (legal obligation).
Who we share it with
We do not sell personal data. We share it only with service providers who help us run the site and the café, under contracts that require them to protect it:
- Vercel Inc. (website hosting and, with consent, analytics)
- Resend (sending enquiry and newsletter emails)
- Meta Platforms (WhatsApp), when you choose to contact us there
- Delivery partners, who receive your name, phone and address to deliver an order
Some of these providers process data outside the UAE. Where they do, we rely on safeguards permitted by the PDPL. [LAWYER TO CONFIRM CROSS-BORDER TRANSFER BASIS]
How long we keep it
- Enquiries: 12 months after our last contact, unless you become a customer.
- Orders and invoices: as long as UAE tax law requires (currently at least five years).
- Newsletter: until you unsubscribe.
Your rights
Under the PDPL you may ask us to: give you access to your data; correct it; erase it; restrict or object to processing; and receive a copy in a portable format. You may also withdraw consent at any time without affecting processing that has already happened.
Email conciergerie@tgasparato.com and we will reply within 30 days. If you are not satisfied, you may complain to the UAE Data Office.
Security
The site is served only over HTTPS. Access to enquiries and order details is limited to the people who need them to serve you.
Changes
If we change this policy we will update the date at the top of this page. Significant changes will be highlighted on the home page for 30 days.