Privacy Policy
This Privacy Policy explains what personal data Bold Reflex FZ LLC (“Bold Reflex”, “we”, “us”) collects, why we collect it, how we look after it, and the rights you have. It applies to our website at www.boldreflex.ai (and related domains that redirect to it) and to the professional services we provide.
We operate from the United Arab Emirates. The UAE Personal Data Protection Law (Federal Decree-Law No. 45 of 2021, “PDPL”) and its Executive Regulations apply to how we handle personal data. Where we work with people or organisations in the European Economic Area or the UK, we also apply GDPR-minded practices (transparency, purpose limitation, minimisation, security and documented instructions to processors).
Important: This page is a practical privacy notice for our website and services. It is not a substitute for formal legal advice on a specific matter.
1. Who is responsible
Bold Reflex FZ LLC is the data controller for personal data collected through this website and our enquiries. Our public address for correspondence is Marina Plaza, 27, Dubai, UAE. For privacy requests, use the enquiry form and mark your message as a privacy request. We do not publish a public email address or phone number on this site, to reduce spam and social-engineering risk.
2. What we collect
- Enquiry and contact details — name, company, phone number, optional email, selected interests, optional company size / budget / timeline, and the message you send us.
- Service and project information — details you share about your systems, goals and requirements so we can reply and, if you proceed, deliver work.
- Technical and security data — IP address, approximate country, browser/user-agent, pages requested and security challenge results, collected through our hosting provider’s logs and bot-protection tools when you use the site or submit the form.
- Billing information — invoicing and tax details if you become a client. Card payments, if any, are handled by payment providers; we do not store full card numbers.
We ask only for what we need. Optional fields on the enquiry form can be left blank.
3. Why we use your data (and our bases)
- Enquiries and consultations — to reply, arrange a free consultation and prepare a proposal. Basis: your request / steps toward a contract, and our legitimate interest in responding to business enquiries.
- Client work — to provide, manage and improve services under a written order or contract. Basis: contract performance.
- Security and abuse prevention — including Turnstile checks and rate limits on the form. Basis: legitimate interests and, where applicable, legal obligation.
- Legal and accounting — to meet UAE commercial, tax and regulatory duties. Basis: legal obligation.
- Service updates — only where you have asked us to, or where a client relationship makes them necessary. You can ask us to stop non-essential updates at any time.
We do not sell your personal data. We do not use the content of your business documents to train shared or third-party AI models.
4. AI and client content
If we use AI tools in a project, we agree with you in writing what may be processed, where, and by whom. Client content is processed only to deliver the agreed work. A person you authorise remains responsible for approving anything that leaves your business. Public website enquiries are handled by people; they are not fed into model-training pipelines.
5. Sharing and processors
We share personal data only where needed to deliver our services. Typical categories:
- Hosting and security — Cloudflare (website hosting, CDN, bot protection / Turnstile).
- Transactional email — Resend (to deliver enquiry notifications to our inbox).
- Mailbox and DNS providers — our email hosting provider for receiving and storing mail.
- Payment providers, professional advisers — when needed for client work.
- Authorities — when UAE law requires disclosure.
Where partners process data for us, we expect appropriate contractual and security protections.
6. International transfers
We are based in the UAE. Some tools (including hosting, security and email delivery) may process data in other countries. Where that happens, we take steps appropriate to the risk and to applicable law (for example contractual clauses or provider terms). We will tell you when the location of processing matters to a paid project.
7. Retention
- Website enquiries — kept while we respond and for up to 24 months afterwards for follow-up and dispute context, then deleted or anonymised unless a longer period is required by law or an active proposal/contract.
- Security logs — kept for a short operational period (typically up to 90 days) unless needed to investigate abuse.
- Client records — for the life of the engagement and afterwards as required by UAE accounting and legal rules (often several years for invoices and contracts).
8. Your rights
Subject to UAE PDPL (and other applicable law), you may ask to access, correct, delete or restrict your personal data, object to certain processing, or withdraw consent where processing was based on consent. Use the enquiry form for these requests. We may need to verify your identity before acting. You may also have the right to complain to the UAE Data Office or another competent authority.
9. Cookies and similar technologies
Essential technologies may be used to make the site work (for example security challenges on the enquiry form). We do not currently use marketing cookies or advertising trackers on this site. If we add analytics or other non-essential cookies later, we will update this section and, where required, ask for consent before setting them.
10. Children
Our website and services are directed at businesses and professional adults. We do not knowingly collect personal data from children.
11. Changes
We may update this policy from time to time. The “Last updated” date at the top will change when we do. For material changes that affect how we use personal data already collected, we will take reasonable steps to inform affected clients.
Questions about privacy? Please use the enquiry form.