SureSpace Privacy Notice

Introduction

Welcome to SureSpace’s Privacy Notice. This Privacy Notice tells you everything you need to know about how we collect, use, and disclose your “Personal Data” when you interact with us, whether through our website, application, or otherwise.

What key information do you need to know about us?

Our legal entity name is SureSpace Technology Ltd, incorporated under the laws of Dubai International Financial Centre (DIFC) and regulated by the DIFC licensing authority.
Our registered address is within the DIFC, Dubai, United Arab Emirates.

As a Data Controller, we are responsible for protecting your privacy and rights and ensuring compliance with applicable DIFC Data Protection Law No. 5 of 2020 and other relevant data protection frameworks.

What key data protection terms do you need to know?

To help you understand this Privacy Notice, we’ve provided a glossary of key terms below:

• Consent: Freely given, specific, informed, and unambiguous agreement to the processing of Personal Data.

• Data Controller: An organisation responsible for deciding how and why Personal Data is processed.

• Data Processor: An organisation that processes Personal Data on behalf of a Data Controller.

• Personal Data: Information relating to an individual that can identify them, directly or indirectly.

• Processing: Any operation involving Personal Data, such as collecting, using, or sharing.

• Special Category Data: Data revealing racial or ethnic origin, religious beliefs, health data, or similar sensitive information.

What does our data protection compliance program look like?

We have implemented a robust data protection compliance programme, including policies, procedures, and technical security controls, to ensure alignment with DIFC Data Protection Law.

Our key principles:

• We only process Personal Data lawfully, fairly, and transparently.

• We collect Personal Data only as necessary and keep it accurate and up to date.

• We protect Personal Data using appropriate technical and organisational measures.

Do we have a data protection officer?

Currently, we are not required to appoint a Data Protection Officer under DIFC law. However, we regularly review this position and remain fully committed to upholding your data rights.

What types of Personal Data do we collect?

Depending on your relationship with us, we collect various types of Personal Data, including:

• Identity Data: First name, last name, date of birth, avatar

• Contact Data: Email address

• Transaction & Financial Data: Payment details

• Technical & Usage Data: IP address, browser type, and interactions with our website or application.

We may also collect aggregated data (e.g. statistical data) for analytical purposes. Aggregated data is not considered Personal Data as it does not identify you directly.

Cookies and Tracking Technology

We use cookies and tracking technologies to enhance your experience on SureSpace.

• Types of Cookies: Functional, analytical, and advertising cookies.

• Managing Cookies: You can adjust cookie preferences via your browser or the cookie banner. 

Do we use artificial intelligence (AI)?

Yes, SureSpace uses AI to support creativity and content generation (e.g., text, images).

• Data Processing: Only minimal input data is used to enable AI functionality.

• No automated decision-making: We do not make legally significant decisions using AI.

• Opting Out: You can opt out of AI features via your account settings.

How do we retain and manage AI-generated content?

AI-generated content is retained according to our general data retention policy. If you delete your account, associated AI content may be deleted unless retained in anonymised form for research or improvement purposes.

What are the lawful grounds for which we process Personal Data?

We process your Personal Data on one or more of the following legal grounds:

• Consent

• Performance of a contract

• Legal obligations

• Legitimate interests (balanced against your rights and freedoms)

What are the categories of Data Subjects that we engage with?

We collect Personal Data from:

• SureSpace users (aged 18+)

• Prospective employees

• Third-party suppliers, advisors, and contractors

Who do we share your Personal Data with?

We share Personal Data with selected third parties as needed:

• Technology providers (hosting, analytics, AI tools)

• Professional advisers (legal, accounting, financial)

• Regulatory or governmental authorities, when legally required

How do we protect your Personal Data?

We apply strong data security measures, including encryption, access controls, and regular audits. Third parties with access to data are contractually obligated to maintain equivalent security standards.

In the unlikely event of a data breach, we will notify the DIFC Commissioner of Data Protection and affected individuals where required, including the nature, potential impact, and remedial steps.

Do we transfer your Personal Data outside of the UAE?

Yes, we may transfer Personal Data outside of the UAE. Where we do:

• We rely on adequacy decisions or

• Use Standard Contractual Clauses or equivalent safeguards to ensure your data remains protected.

How long do we keep your Personal Data?

We retain your Personal Data only as long as necessary for:

• Delivering services

• Meeting legal or regulatory obligations

• Supporting legal claims

When data is no longer needed, we securely delete or anonymise it.

What rights do you have regarding your Personal Data?

You have the following rights:

• Access: Request a copy of your Personal Data.

• Rectification: Request correction of inaccurate data.

• Erasure: Request deletion in certain circumstances.

• Restriction: Ask us to limit how we use your data.

• Objection: Object to processing based on legitimate interests or direct marketing.

• Data Portability: Request transfer to another provider.

• Complaint: Lodge a complaint with the DIFC Commissioner of Data Protection.

To exercise these rights, contact us at [email protected].

How do we use your Personal Data in marketing?

With your consent, we may use your Identity, Contact, and Technical Data for marketing communications. You may withdraw consent at any time by contacting us or using the unsubscribe link.

Third-Party Processors

We use trusted third-party providers for services such as:

• Payment processing

• Cloud hosting

• AI services

All processors are contractually bound to protect your data and comply with data protection laws.

Intellectual Property and User-Generated Content

You retain IP rights over content you create. By uploading content, you grant us a licence to use and display it on SureSpace as needed to provide the service.

We respect your content and protect it according to our privacy and security policies.

Do you have any questions or concerns?

By using SureSpace, you agree to the practices outlined in this Privacy Notice. If you have any questions or concerns, feel free to contact us at [email protected].