PRIVACY POLICYElamo Studio website · Irina Ivchenko Decoration Design & Implementation L.L.C.1. General ProvisionsThis Privacy Policy (the "Policy") sets out how personal data of users of the website elamo.studio (the "Website"), operated by Irina Ivchenko Decoration Design & Implementation L.L.C., trading as Elamo Studio, registered in the United Arab Emirates (the "Company", the "Operator"), is collected, stored, used, and protected.
This Policy has been prepared with reference to UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (the "PDPL"), in effect since 2 January 2022.
The Company's legal form is an L.L.C. (Limited Liability Company), which in the UAE is used for mainland companies rather than free zone entities: DIFC and ADGM entities are structured as "Ltd" and operate under their own data protection regimes. Accordingly, this Policy assumes that the federal PDPL applies, rather than a free zone framework.
2. Data We CollectWhen the User completes the contact form on the Website, the Company collects the following personal data, voluntarily provided by the User:
● name;
● phone number;
● email address;
● the content of the message/inquiry.
The Company does not request special categories of personal data (health information, religious or political views, biometric data, etc.) through the contact form.
This section covers only the data submitted through the contact form. For cookies and analytics, see Section 9.
3. Purposes of Processing● handling inbound inquiries and communicating with the User via the contact details they provide;
● preparing a commercial proposal at the User's request;
● keeping an internal record of inquiries received through the Website.
4. Legal Basis for ProcessingPersonal data submitted by the User through the contact form is processed without a separate consent request, on the basis that processing is necessary to take steps at the User's request prior to entering into a contract — namely, to review the inquiry and prepare a commercial proposal (Article 4 of Federal Decree-Law No. 45 of 2021, which permits processing without consent where necessary for the performance of a contract with the User or for steps taken at their request prior to entering into a contract).
The User may object to such processing at any time using the contact details set out in Section 11 of this Policy.
5. Disclosure to Third Parties and Cross-Border TransferThe Company's team is distributed across several countries, while the Company itself is registered and primarily operates in the United Arab Emirates.
To store data and organise its work (including client contacts and contract preparation), the Company uses third-party cloud services for file storage and project management. Such services may process and store data on servers located outside the UAE.
These services act as independent processors of personal data and apply their own protective measures, including Standard Contractual Clauses for international data transfers. The Company relies on these safeguards as sufficient for the purposes of cross-border data transfer, consistent with the practice adopted by most companies using such services.
Company employees are given access to data within these systems to the extent necessary for the purposes of processing set out in Section 3, regardless of the country from which access is made.
The Company does not disclose Users' personal data to external third parties (beyond the services referred to above), except where expressly required by applicable law, or where disclosure is necessary to provide services to the User themself (for example, when engaging contractors or suppliers at the client's initiative and with their consent).
6. Retention PeriodPersonal data is retained for as long as necessary to achieve the purposes of processing set out in Section 3, and in any case for no longer than 3 years from the User's last contact, unless that contact developed into a contractual relationship with the Company — after which it is deleted or anonymised, except where longer retention is required by applicable law.
7. Data Subject RightsIn accordance with Federal Decree-Law No. 45 of 2021, the User has the right to:
● obtain information about the processing of their personal data;
● request access to their personal data;
● request correction of inaccurate data;
● request deletion of their personal data;
● request restriction of the processing of their personal data;
● object to the processing of their personal data.
To exercise these rights, the User may contact the Company using the contact details set out in Section 11.
8. Data Protection MeasuresThe Company takes reasonable organisational and technical measures to protect personal data from unauthorised access, alteration, disclosure, or destruction.
9. CookiesThe Website may use cookies and similar technologies, including web analytics tools (such as Google Analytics) and advertising pixels, to analyse traffic and improve the Website's functionality. Where such tools are used, the User is provided with relevant information and, where required, a consent mechanism in accordance with applicable law.
10. Changes to This PolicyThe Company may amend this Policy from time to time. The current version is always available on the Website. Material changes (such as an expansion of the categories of data collected or the purposes of processing) are accompanied by a corresponding notice on the Website.
11. Operator's Contact DetailsFor questions regarding the processing of personal data, the User may contact:
info@elamo.studio.