Privacy Policy

[This draft has not been reviewed by a lawyer. Have UAE legal counsel review it before publishing.]

We are Titan Orbyt Technologies LLC, a limited liability company registered in Dubai, United Arab Emirates, trading as Titan Orbyt. Our registered address is Office 1-24A, Floor 1, Al Khabeesi Building, Al Khabeesi, Dubai, United Arab Emirates, and our trade licence number is [trade licence number].

For the purposes of the UAE Personal Data Protection Law and, where it applies, the EU and UK General Data Protection Regulation, we are the controller of the personal data described in this policy. We have not appointed a separate data protection officer. Questions about this policy and about your data go to hello@tot.ae.

This policy covers the website at https://tot.ae and the ways you can contact us from it: by email at hello@tot.ae and by phone at +971 58 993 1609.

It does not cover our products. ScoreDeck (tryscoredeck.pro) and Astro21 (astro21.io) are separate services with their own privacy policies, published on their own sites. If you use either product, that product's policy applies to the data it collects.

It also does not cover the work we do for clients under a written agreement. How we handle data in a client project is set out in that agreement.

We collect very little, and only in four ways.

• Contact data you send us. If you email hello@tot.ae or call +971 58 993 1609, we receive whatever you choose to share: your name, email address, phone number, company, and the content of your message. We only have this because you gave it to us.
• Technical data from server logs. Like every website, ours is served by a hosting provider whose servers keep standard access logs. A log entry can include your IP address, the date and time of the request, the page or file requested, your browser type and operating system, and the page that referred you. The site is hosted by Vercel Inc., which keeps these logs on our behalf.
• Visit and performance statistics. We use Vercel Web Analytics and Vercel Speed Insights to count page views and measure how fast pages load. They record the page visited, the referring page, your browser, operating system, device type and country, and timings such as how long a page took to display. They do not use cookies, do not store your IP address, and do not identify you: visits are grouped using a code derived from the request that changes every day. See the section on cookies and analytics below.
• Video delivery data. The background videos on this site are streamed from Amazon CloudFront, a content delivery network run by Amazon Web Services. When your browser requests a video, your IP address and basic request details reach Amazon's servers. See the section on video delivery below.

We use contact data to answer you, to discuss work you have asked about, and to keep a record of our correspondence. Under the UAE Personal Data Protection Law we process this data because you have asked us to and because it is necessary to deal with your enquiry or to enter into and carry out an agreement with you. For visitors covered by the GDPR or UK GDPR, the legal basis is the performance of a contract or the steps you asked us to take before one, and otherwise our legitimate interest in responding to people who contact us.

We use server logs to keep the website running, to detect abuse and attacks, and to fix faults, and visit and performance statistics to see which pages are read and to keep the site fast. Under the UAE law this is processing necessary to protect our systems and meet our legal duties; under the GDPR and UK GDPR it rests on our legitimate interest in running a secure, working website.

We do not use your data for advertising, profiling, or automated decisions that have a legal or similarly significant effect on you. We do not sell it. If we ever want to use your data for a new purpose, we will tell you first and, where the law requires it, ask for your consent.

This website does not set cookies, and it does not use advertising or social media tracking scripts. There is no Google Analytics, no Meta pixel, and no tag manager. The fonts are served from our own site, so no font provider sees your visit.

We do use two privacy-friendly measurement tools from our host, Vercel: Web Analytics, which counts page views and where visitors come from, and Speed Insights, which measures how quickly pages load on real devices. Neither sets cookies or stores your IP address, and neither builds a profile of you or follows you to other websites. Visits are grouped using a code derived from each request that is reset every day, so we see totals, not individuals.

Because we set no cookies, there is no cookie banner and nothing for you to accept or refuse. Your browser may still store ordinary technical items such as cached files; those are managed by your browser, not by us.

If we add any other analytics or third-party script in the future, we will update this policy before it goes live and, where the law requires it, ask for your consent.

The short background videos on this site are hosted on Amazon CloudFront, a content delivery network operated by Amazon Web Services. CloudFront serves files from a server close to you, which means your browser connects directly to Amazon when it loads a video.

In that connection Amazon receives your IP address, the time of the request, the file requested, and your browser type. Amazon processes this to deliver the file and to keep its own service logs. We do not receive any data about you from Amazon and we do not use CloudFront to identify or track you.

The server that responds may be outside the UAE and outside your own country, depending on where you are. Amazon's handling of this data is governed by the Amazon Web Services privacy notice.

The footer has an email subscribe box. It is not connected to any mailing list or storage service today. Anything you type into it is not sent anywhere and is not kept. If you want to hear from us, email hello@tot.ae instead.

If we connect the form to a mailing service in the future, we will update this policy to say which service we use, what it stores, and how you can unsubscribe.

Emails and call notes: we keep correspondence for as long as we need it to deal with your enquiry and, if it leads to work together, for as long as our business and tax records must be kept under UAE law. If nothing comes of an enquiry, we delete it within [retention period for unanswered or closed enquiries].

Server logs: our hosting provider keeps access logs for [log retention period] and then deletes or anonymises them. Visit and performance statistics are kept by Vercel in aggregated form and contain nothing that identifies you.

We do not keep data longer than we need it. When we no longer need it, we delete it or strip out anything that could identify you.

We do not sell personal data and we do not share it with advertisers. We share it only in these cases.

• Service providers that run our infrastructure: Vercel Inc. (website hosting, server logs, visit and performance statistics), Amazon Web Services (video delivery through CloudFront), and [email service provider] (the mailbox behind hello@tot.ae). Each of them processes data only to provide its service to us.
• Professional advisers such as lawyers, accountants and auditors, where we need their advice about a matter that involves your data.
• Authorities and courts, where the law requires us to disclose data, or where disclosure is necessary to establish, exercise or defend a legal claim.
• A buyer or successor, if Titan Orbyt is sold, merged or restructured, in which case your data would pass to the new owner under the same protections.

We are based in Dubai, so any data you send us is received and stored in the United Arab Emirates. If you contact us from the EU, the UK or another country, that is a transfer of your data to the UAE. The UAE is not currently covered by an EU or UK adequacy decision. We rely on the fact that the transfer is necessary to respond to your request or to perform a contract with you, and we protect the data as described in this policy.

Our service providers may process data outside the UAE. Amazon CloudFront serves videos from edge servers around the world; Vercel serves the site from its global network and processes logs and statistics in the United States; and [email service provider] may store data in [provider regions]. Where we transfer data out of the UAE, we do so in line with the UAE Personal Data Protection Law, which allows transfers to countries with adequate protection or under appropriate safeguards or where the transfer is necessary for a contract with you.

Under the UAE Personal Data Protection Law you have the right to know what data we hold about you and how we use it, to receive a copy of it, to have it corrected if it is wrong, to have it deleted when we no longer need it, to restrict or object to how we process it, to receive it in a portable format where that applies, and to withdraw consent where we rely on consent.

If you are in the EU or the UK, you have the matching rights under the GDPR or UK GDPR: access, rectification, erasure, restriction, portability, objection, and the right not to be subject to automated decisions with legal effect. You can also complain to your local data protection authority, for example the Information Commissioner's Office in the UK.

If you are in the UAE, you can complain to the UAE Data Office if you think we have breached the law. Wherever you are, we would prefer to hear from you first so we can fix the problem directly.

To use any of these rights, email hello@tot.ae and tell us what you want. We may ask you to confirm your identity so that we do not hand your data to someone else. We will reply without undue delay and in any case within the time the applicable law allows, and we will not charge you unless the law lets us and your request is clearly excessive.

This website is aimed at businesses and adults. We do not knowingly collect personal data from anyone under 18, and we do not ask for age information. If you believe a child has sent us personal data, email hello@tot.ae and we will delete it.

The website is served over HTTPS, so traffic between your browser and our site is encrypted. Our mailbox and systems are protected by access controls and are limited to the people who need them. We choose service providers that offer appropriate security and we review their terms before we use them.

No method of transmission or storage is completely secure. Email in particular is not an encrypted channel end to end, so please do not send us passwords, payment card numbers or other highly sensitive information by email. If we become aware of a breach that is likely to affect you, we will notify you and the relevant authority as the law requires.

This site links to other websites, including our own products ScoreDeck at https://tryscoredeck.pro and Astro21 at https://www.astro21.io. Each of those sites has its own privacy policy and collects its own data. This policy stops at the edge of tot.ae; once you follow a link, the other site's policy applies.

We are not responsible for the privacy practices of third-party sites we link to, and a link does not mean we endorse how they handle data. Please read their policies before giving them any information.

We will update this policy when the website changes in a way that affects your data, for example if we add other analytics, connect the subscribe form, or move to a new hosting provider. The date at the top shows when it was last updated. If a change is significant, we will say so clearly on this page. Continuing to use the site after a change means the updated policy applies.

For anything about this policy or your personal data, contact Titan Orbyt Technologies LLC at hello@tot.ae or on +971 58 993 1609. Our registered address is Office 1-24A, Floor 1, Al Khabeesi Building, Al Khabeesi, Dubai, United Arab Emirates.