Privacy Policy
Last updated: 26 March 2026
1. Who We Are
Technology Spirits ("we", "us", "our") is a product development and engineering company based in Dubai, UAE. We are the data controller for personal data collected through this website (tspirits.com).
This policy explains what personal data we collect, why we collect it, how we process it, and what rights you have under the General Data Protection Regulation (GDPR) and applicable UAE data protection laws.
Data Controller: Technology Spirits
19th Floor, Conrad Dubai, Sheikh Zayed Road, Dubai, UAE
info@tspirits.com
2. What Data We Collect
We collect the following categories of personal data:
Contact Form Submissions
Name, email address, and message content that you voluntarily provide when submitting our contact form.
Browser Storage
We use browser localStorage to store your privacy notice dismissal preference, and sessionStorage for scroll position memory. We do not use cookies or analytics tracking. See Section 6 for details.
Server Logs
Standard web server logs including IP addresses, access timestamps, and requested URLs. These are generated automatically by our hosting infrastructure.
We do not collect sensitive personal data (racial or ethnic origin, political opinions, religious beliefs, health data, biometric data, etc.). We do not require you to create an account, and we do not process payment information through this Site.
3. How We Use Your Data
| Data | Purpose | Lawful Basis |
|---|---|---|
| Contact form data | Respond to your inquiry | Legitimate interest (pre-contractual communication) |
| Browser storage | Privacy notice preference, scroll position | Strictly necessary |
| Server logs | Security monitoring, abuse prevention | Legitimate interest |
4. Data Processors & International Transfers
Your personal data may be processed by the following third parties:
AWS (Amazon Web Services)
EU (Frankfurt)Website hosting. Data processed in the EU (eu-central-1, Frankfurt). AWS maintains EU-approved Standard Contractual Clauses and is compliant with GDPR.
AWS (Contact Form Processing)
EU (Frankfurt)Contact form submissions are processed via AWS Lambda and Amazon SES, both operating in eu-central-1 (Frankfurt). Your name, email, and message are forwarded to our business inbox (info@tspirits.com) via email. No form data is stored on AWS servers beyond the email delivery process.
Microsoft 365
EU / GlobalEmail delivery and storage. Contact form submissions are ultimately delivered to our Microsoft 365 mailbox. Microsoft maintains Standard Contractual Clauses and EU data residency commitments for core services.
Our team in Dubai, UAE accesses and responds to inquiries received via these services. The UAE does not currently hold an EU adequacy decision under GDPR. We rely on legitimate interest (responding to pre-contractual inquiries initiated by you) as the lawful basis for this processing.
5. Data Retention
- Contact form data: retained for the duration of our business correspondence, then deleted within 24 months of last contact
- Server logs: automatically rotated and deleted after 90 days
- Privacy notice preference: stored in your browser's local storage until you clear it
6. Browser Storage & Cookies
This site does not use cookies and does not use analytics tracking. We use the following browser storage mechanisms, all of which are strictly necessary for site functionality:
| Storage | Purpose | Persistence |
|---|---|---|
| localStorage | Stores your privacy notice dismissal preference so the notice is not shown again on return visits. | Until cleared |
| sessionStorage | Remembers your scroll position for navigation continuity when returning to the homepage. | Browser session |
No personal data is stored in browser storage. You can clear this data at any time through your browser settings. No third-party scripts, analytics tools, or tracking pixels are loaded by this site.
7. Your Rights Under GDPR
If you are located in the European Economic Area (EEA) or the United Kingdom, you have the following rights regarding your personal data:
Right of Access
Request a copy of the personal data we hold about you.
Right to Rectification
Request correction of inaccurate or incomplete personal data.
Right to Erasure
Request deletion of your personal data where there is no compelling reason for continued processing.
Right to Restrict
Request restriction of processing while we verify accuracy or consider your objection.
Right to Object
Object to processing based on legitimate interest. We will cease unless we demonstrate compelling legitimate grounds.
Right to Withdraw Consent
Where processing is based on consent (e.g., analytics cookies), you may withdraw consent at any time.
To exercise any of these rights, contact us at info@tspirits.com. We will respond within 30 days. If you are not satisfied with our response, you have the right to lodge a complaint with your local data protection supervisory authority.
8. Children's Privacy
This Site is not directed at individuals under the age of 16. We do not knowingly collect personal data from children. If you believe that we have inadvertently collected data from a child, please contact us and we will promptly delete it.
9. Changes to This Policy
We may update this Privacy Policy from time to time. Changes will be posted on this page with an updated revision date. For material changes, we will make reasonable efforts to provide notice (such as updating the cookie consent banner).
10. Contact
For any privacy-related questions, data access requests, or to exercise your GDPR rights:
Technology Spirits — Data Protection
19th Floor, Conrad Dubai, Sheikh Zayed Road, Dubai, UAE
info@tspirits.com