Privacy Policy

1Introduction

PROGRAMMERS FORCE ARTIFICIAL INTELLIGENCE DEVELOPING SERVICES L.L.C ("GML", "we", "us") respects your privacy and is committed to protecting your Personal Data. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use the GetMeLeads AI SDR services.

This Policy is formulated in accordance with the UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (PDPL) and, where applicable, the data protection regulations of the Dubai International Financial Centre (DIFC) or Abu Dhabi Global Market (ADGM). We note that the PDPL implementing regulations are in a transitional period, and we will update this Policy as the regulations become clearer.

2Data Controller and Contact

2.1For lead data that you input, upload, or instruct us to process (i.e., personal data of third parties described in Section 3.3), you (the customer) are the controller and GML acts as a processor, except where GML's systems automatically source or enrich lead data from third-party platforms (such as LinkedIn or Sales Navigator) at your direction, in which case you remain the controller because you determine the targeting criteria, the sources to be used, and the purpose of the processing. GML does not independently determine which individuals to target, the purpose of outreach, or the lawful basis for processing.

2.2For your account registration information, billing information, and usage data generated when you use the Services (as described in Sections 3.1 and 3.2), GML is an independent controller, processing such data to provide you with the Services, manage our contractual relationship, and improve the Services.

3Personal Data We Collect

3.1 Information You Provide to Us

• Account registration information: name, company name, email address, phone number, password.
• Billing information: payment method details (processed by third-party payment processors).
• Configuration data: your defined ICP, target market settings, outreach scripts.

3.2 Data Automatically Collected

• Usage data: features accessed, time and frequency of use, device information, IP address.
• Log data: error logs, access times.

3.3 Our Role Regarding Lead Data

When you use the Services, you may input, upload, or cause GML to source and process Personal Data of third parties (such as potential leads), including names, job titles, company names, business email addresses, phone numbers, and social media profile information. Whether you provide this data directly or direct GML's systems to source it from third-party platforms, you are the Data Controller for such data because you determine the targeting criteria, the sources, and the purpose of processing. GML acts as a Data Processor and processes such data solely on your documented instructions. In the context of lead data processing, GML does not determine the lawfulness of the data source, the purpose of outreach, the content of communications, or the target audience. You are responsible for ensuring you have a lawful basis for processing such data. For lead data processing, the Data Processing Agreement (DPA) separately executed between you and GML governs the specific rights and obligations of both parties as controller and processor. In the event of any conflict between this Privacy Policy and the DPA regarding the processing of lead data, the DPA shall prevail.

3.4 AI-Generated Data

Records of outreach messages generated by the Services, and metadata related to sending status.

4Purposes and Legal Bases for Processing

We process your Personal Data based on the following legal grounds:

4.B Processing as Processor (Lead Data)

4.1For the role positioning and obligations regarding lead data, please refer to Section 3.3 of this Policy.

5Data Sharing and Disclosure

We do not sell your Personal Data. We may share data in the following circumstances:

5.1Service Providers: We engage third-party service providers (such as cloud hosting, payment processing, email delivery services) to assist in providing the Services. These providers are contractually bound to provide adequate data protection and process data only as necessary to provide services to GML.

5.2AI Model Providers: We use third-party LLM APIs to generate outreach content. When processing lead data on your behalf, transmitting necessary prompt data to sub-processors is done based on your authorization as controller (as set out in the DPA). We require such providers not to use the data for their own model training, and we remain liable for their processing activities to the extent required by law. A current list of sub-processors is available on request, and we will provide notice before engaging any new sub-processor that will process lead data.

5.3Legal Requirements: We may disclose data if required by UAE law, court order, or governmental authority.

5.4Business Transfers: In the event of a merger, acquisition, or asset sale, Personal Data may be transferred as part of the business assets, subject to the successor entity adhering to this Policy.

6Cross-Border Data Transfers

6.1GML's primary data storage and processing facilities are located in the UAE and may also utilize servers in other jurisdictions (such as the EU or US) where our service providers are located.

6.2When transferring Personal Data outside the UAE, we will take measures to ensure an adequate level of protection as required by the PDPL, including but not limited to: transferring to jurisdictions recognized by the UAE Artificial Intelligence and Data Authority as providing adequate protection, or using contractual safeguards (such as Standard Contractual Clauses). As of the date of this Policy, the UAE Artificial Intelligence and Data Authority has not published an official adequacy list, and the PDPL implementing regulations regarding cross-border transfers remain pending. For lead data processed on your behalf, cross-border transfers are executed based on your instructions as controller. Where you direct us to source data from third-party platforms whose servers are located outside the UAE, or to send messages through channels whose delivery infrastructure is located outside the UAE, you are responsible for determining whether such transfer is lawful and for implementing any required safeguards. GML will provide information about the locations of its sub-processors upon request to assist you in this assessment.

7Data Retention

7.1We retain your account data for the duration of your account's existence. After account termination, we will delete or anonymize your Personal Data within a reasonable period, unless we are required by law to retain it (such as for tax or accounting purposes).

7.2Third-party lead data processed on your behalf will be deleted within thirty (30) days after account termination or upon your earlier request, unless you have exported it.

8Data Security

We implement appropriate technical and organizational measures to protect Personal Data, including: encryption (TLS/SSL) for data in transit, access controls, and regular security reviews. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.

9Your Rights under PDPL

Subject to applicable law and certain exceptions, you have the following rights regarding your Personal Data.

9.1Scope of Application: If you are a customer of GML and you are the controller of the lead data (as described in Section 3.3), the data subject rights described in this section should be exercised against you as the controller. GML will provide reasonable technical assistance upon your request to enable you to respond to data subject requests.

9.2If you are a data subject and your personal data was input into our system by one of our customers as lead data, please contact that customer directly. If you are unable to determine the identity of that customer, you may contact us, and we will make reasonable efforts to assist you in identifying the relevant controller, but we do not have authority to decide on erasure or restriction requests involving that customer's data.

9.3The following rights may be exercised against GML only to the extent GML acts as controller in respect of the relevant Personal Data. For lead data where GML acts as a processor, please refer to Sections 9.1 and 9.2 above.

Rights List

• Right to be Informed: To know how we process your data (this Policy).
• Right of Access: To request a copy of your Personal Data.
• Right to Rectification: To correct inaccurate or incomplete data.
• Right to Erasure: To request deletion of your data in certain circumstances.
• Right to Restriction: To request restriction of processing in certain circumstances.
• Right to Object: To object to processing based on legitimate interest, including direct marketing.
• Right regarding Automated Processing: To object to decisions based solely on automated processing (including profiling) that produce legal or similarly significant effects, and to request human intervention.

To exercise these rights, please contact [email protected]. We will respond within the timeframe required by law. You also have the right to lodge a complaint with the UAE Artificial Intelligence and Data Authority.

10Cookies

We use essential cookies to maintain your login session and preferences. We may also use analytics cookies to understand how the Services are used. You can manage cookie preferences through your browser settings.

11Children's Privacy

The Services are not directed to individuals under the age of 18. We do not knowingly collect Personal Data from children.

12Changes to This Policy

We may update this Policy from time to time. The updated version will be posted on this page with a revised "Last Updated" date. For material changes, we will notify you via email or through the Services.

13Contact Us

For any questions, concerns, or requests regarding this Privacy Policy or your Personal Data, please contact:

• Email: [email protected]
• Address: Office No. 2401B, Business Central Towers, Internet City, Dubai