Privacy Policy

This Privacy Policy explains how PRIMEREACH MARKETING - FZCO ("PrimeReach", "we", "us", "our") collects, uses, discloses and protects personal data.

PRIMEREACH MARKETING - FZCO is a Free Zone Company (FZCO) with limited liability incorporated in Dubai Silicon Oasis, United Arab Emirates, under Dubai Law No. 16 of 2021 and the DIEZA Implementing Regulations 2023.

We are the data controller in respect of the personal data described in this Policy, except where we act as a processor on behalf of our clients (see Section 9).

This Policy applies to www.primereach.pro and its subdomains (the "Website") and to our services: media buying and the planning, delivery and optimisation of commercial advertising campaigns on social media platforms (the "Services"). We work primarily with clients in the fintech and e-commerce sectors.

This Policy does not apply to third-party websites, advertising platforms or social networks that we do not control.

3.1 Data you provide

• Identity and contact data: full name, company name, job title, email address, telephone number, messaging identifiers.
• Commercial data: enquiry details, contract and billing information, payment and settlement details, company registration and tax identifiers of client entities.
• Correspondence: the content of emails, calls, meetings and support requests.

3.2 Data collected automatically on the Website

• Technical data: IP address, device and browser type, operating system, language, referring URL, timestamps.
• Usage data: pages viewed, time on page, clicks and other interaction events.
• Cookie and similar identifiers, as described in Section 6 and in our Cookie Policy.

3.3 Data from third parties

• Social media advertising, analytics and attribution platforms that we are authorised to use on behalf of our clients.
• Publicly available company registers and business directories.
• Referrals from partners and clients.

We do not intentionally collect sensitive personal data (such as data relating to health, religious or philosophical beliefs, political opinions, biometric or genetic data), and we ask you not to submit such data to us.

We use personal data to:

• (a) provide, operate and improve the Services;
• (b) plan, buy, deliver, measure and optimise advertising campaigns on social media platforms for our clients;
• (c) respond to enquiries and manage our relationships with clients and partners;
• (d) issue invoices, process payments and maintain accounting records;
• (e) send service communications and, where permitted, information about our own services;
• (f) operate and secure the Website and detect and prevent fraud, invalid traffic and abuse;
• (g) perform Know Your Customer (KYC) and due diligence checks on prospective clients;
• (h) comply with legal, regulatory, tax and licensing obligations in the United Arab Emirates;
• (i) establish, exercise or defend legal claims.

We process personal data in accordance with UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data and its implementing regulations, on the following bases:

• performance of a contract with you, or steps taken at your request before entering into a contract;
• our legitimate interests in operating, securing and developing our business, where these do not override your rights;
• your consent, in particular for non-essential cookies and for marketing communications, which you may withdraw at any time without affecting the lawfulness of earlier processing;
• compliance with a legal or regulatory obligation.

We use strictly necessary cookies to operate the Website and, subject to your consent, analytics and advertising cookies and pixels. You can manage your preferences through the cookie banner on the Website at any time, and through your browser settings. Full details are set out in our Cookie Policy.

As a media buying agency, we and the advertising platforms we use may rely on pseudonymous identifiers (such as cookie IDs, advertising IDs and hashed contact details supplied by a client) to deliver, cap, measure and attribute advertising campaigns.

• We do not sell personal data.
• We do not knowingly direct advertising to children.
• We do not use sensitive personal data for advertising targeting.
• We comply with the advertising policies, data-use terms and certification requirements of every platform and network we work with.
• For campaigns in regulated sectors such as fintech, we require our clients to hold and evidence the licences and approvals required in each target market before campaigns go live.

Where campaigns run on third-party social media platforms, those platforms determine their own processing of the data they collect and their own privacy notices apply.

We may disclose personal data to:

• our clients, where we process data on their behalf;
• social media advertising platforms, advertising networks, publishers, analytics and attribution providers engaged to deliver the Services;
• service providers, including hosting, cloud storage, CRM, email, payment and accounting providers;
• professional advisers (legal, audit, tax), banks and insurers;
• competent UAE authorities, regulators or courts, where required by law or necessary to protect our rights;
• a purchaser or successor in the event of a merger, acquisition or reorganisation of our business.

We require all processors to act only on our documented instructions and to apply appropriate technical and organisational safeguards.

When we deliver campaigns, audiences or analytics using data supplied by, or collected on behalf of, a client, that client is the controller and we act as processor. In those cases we process personal data only in accordance with the client's documented instructions and the data processing terms agreed with that client. Requests to exercise data subject rights in relation to such data should be addressed to the relevant client; if you contact us, we will forward your request without undue delay.

We operate from the United Arab Emirates and use service providers and advertising platforms located in other countries. Any transfer of personal data outside the UAE is made in accordance with Articles 22 and 23 of UAE Federal Decree-Law No. 45 of 2021, either to jurisdictions recognised as providing an adequate level of protection or on the basis of contractual safeguards. A summary of the safeguards applied may be requested at marketing@primereach.pro.

We retain personal data only for as long as necessary:

• client, contractual and accounting records: for the duration of the relationship and thereafter for the period required by applicable UAE commercial and tax law (currently 5 years);
• enquiries and prospect data: 24 months from last contact;
• website analytics and cookie data: up to 14 months, or the shorter period set by the relevant tool;
• KYC and due diligence records: for the period required by applicable UAE law.

When data is no longer required it is deleted or irreversibly anonymised.

We maintain technical and organisational measures appropriate to the risk, including encryption in transit, access control on a need-to-know basis, multi-factor authentication for administrative and advertising accounts, logging, vendor due diligence and confidentiality obligations for all personnel. No method of transmission or storage is entirely secure and we cannot guarantee absolute security.

Subject to applicable law, you have the right to:

• request access to the personal data we hold about you and information about how it is processed;
• request correction of inaccurate or incomplete data;
• request erasure of your data;
• request restriction of, or object to, processing;
• request transfer of your data to another controller in a structured, machine-readable format;
• withdraw consent at any time where processing is based on consent;
• object to direct marketing at any time, free of charge.

To exercise any right, write to marketing@primereach.pro. We may need to verify your identity before responding. We respond within 30 days.

If you are not satisfied with our response, you may lodge a complaint with the UAE Data Office.

We send marketing emails only where we have a lawful basis to do so. Every message contains an unsubscribe link, and you may also opt out at any time by writing to marketing@primereach.pro.

The Website and the Services are directed at businesses and are not intended for children. We do not knowingly collect personal data from persons under the age of 18. If you believe a child has provided us with personal data, contact us and we will delete it.

The Website may link to third-party sites and platforms. We are not responsible for their content or their privacy practices and we encourage you to read their own privacy notices.

We may update this Policy from time to time. The current version is always published on the Website with the effective date shown at the top.