Privacy Policy

Effective date: 14 June 2026 · Last updated: 14 June 2026

This Privacy Policy explains how Closed Orbit ("Closed Orbit", "we", "us", or "our") collects, uses, shares, and protects information in connection with our marketing-technology services, including our campaign-management and conversion-tracking software and our management of advertising campaigns on platforms such as Google Ads, Meta, TikTok, and Snapchat on behalf of our clients.

Contact. For any privacy question or data request, email [email protected].

1. Who this policy covers

This policy applies to (a) visitors to our websites, (b) our business clients and their authorized users, and (c) end-users whose data our clients process through our software (for example, leads who contact our clients). For client end-user data, our clients are the data controllers and Closed Orbit acts as a service provider / processor under their instructions.

2. Information we collect

3. How we use information

4. Google API Services & Google Ads API

Our use of information received from Google APIs (including the Google Ads API and Google Analytics) adheres to the Google API Services User Data Policy, including the Limited Use requirements. We use Google data only to provide and improve the advertising and measurement features described in this policy, we do not sell it, we do not use it for advertising unrelated to the client's own campaigns, and we do not allow humans to read it except where required for security, to comply with law, or with the client's explicit consent. Our use of the Google Ads API complies with the Google Ads API Terms of Service and applicable Google Ads policies.

5. How we share information

We do not sell personal information.

6. Data retention

We retain personal data only as long as necessary to provide our services, comply with legal obligations, resolve disputes, and enforce agreements. Clients may request deletion of their data at any time.

7. Security

We use technical and organizational measures including encryption in transit, access controls, and least-privilege credentials. Secrets and API credentials are stored securely and never exposed publicly.

8. Your rights

Depending on your jurisdiction, you may have the right to access, correct, delete, or restrict the processing of your personal data, and to withdraw consent. To exercise these rights, contact [email protected]. End-users of our clients should contact the relevant client directly; we will assist that client as their service provider.

9. Cookies & tracking

Our websites and our clients' websites may use cookies and similar technologies (including Google Tag Manager, Google Analytics, and advertising pixels) to measure performance and attribute conversions. You can control cookies through your browser settings.

10. International transfers

We are based in the United Arab Emirates and may process data in other countries where our service providers operate. Where required, we put appropriate safeguards in place for such transfers.

11. Children

Our services are intended for businesses and are not directed to children under 16. We do not knowingly collect data from children.

12. Changes to this policy

We may update this policy from time to time. Material changes will be posted on this page with a revised "Last updated" date.

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