Effective Date: August 26, 2025
TRAJAN INTERNATIONAL FZ-LLC (the "Company," "we," "us," or "our"), a company incorporated and based in the United Arab Emirates (UAE), specializes in automation and integration services. We provide consulting, workflow design, and implementation using third-party apps and software. Our services are offered globally to clients in regions including the EU, Australia (AU), UK, US, UAE, and New Zealand (NZ). We are committed to protecting your privacy and handle only limited personal data as described below.
This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information in compliance with applicable laws, including:
UAE Federal Decree-Law No. 45/2021 on Personal Data Protection.
EU General Data Protection Regulation (GDPR) and UK GDPR.
US state laws such as the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA).
Australian Privacy Act 1988 (including the Australian Privacy Principles - APPs).
New Zealand Privacy Act 2020.
Other relevant international regulations.
We do not process or hold any personal data from your workflows or automations (e.g., client data in booking systems, contracts, or CRMs). You manage those independently after setup and handover. We only process limited data related to our direct business relationship with you, such as contact details and accounting information for purchases.
By engaging our services or providing your information, you consent to the practices described in this Policy. If you do not agree, please do not provide your information or use our services.
1. Information We Collect
We collect and process only the following limited categories of personal data:
Contact Details: Name, email address, phone number, business address, and similar information you provide when inquiring about or engaging our services.
Accounting Information: Billing details, payment history, transaction records, and related financial data necessary for processing purchases (e.g., invoices and receipts).
This data is added to our systems, including contacts in Zoho CRM, Zoho Books, and Stripe for service delivery and billing.
We do not collect or process:
Any personal data from your end-clients or workflows (e.g., data in third-party apps or integrations).
Sensitive personal data (e.g., health, racial, or biometric information).
Data from children under 16 (our services are B2B and not directed at minors).
2. How We Collect Information
Directly from You: When you contact us via email, sign a Services Agreement, make a payment, or provide details during consulting/setup.
Through Our Tools and Services: Automatically via integrated cloud-based platforms, such as:
Google Sheets for internal tracking.
Zoho CRM and Zoho Books for managing client relationships and accounting.
Stripe for payment processing.
Email communications.
No Local Storage: We do not store any information on personal hard drives or local servers. All data is handled exclusively on secure cloud-based platforms, primarily Google Drive for storage, and the tools mentioned above.
3. Purposes of Processing
We process your personal data solely for the following purposes:
To provide, manage, and fulfill our automation and integration services, including consulting, workflow setup, training, and support.
For billing, accounting, and payment processing (e.g., handling setup fees, monthly service fees, and upfront payments via Stripe).
To communicate with you about your account, services, or updates.
To comply with legal obligations, such as tax reporting or regulatory audits in the UAE or your jurisdiction.
For internal business operations, such as record-keeping in Google Drive or Zoho systems.
We do not use your data for marketing, profiling, or automated decision-making without your explicit consent.
4. Legal Basis for Processing
Our processing is based on:
Contractual Necessity: To perform our Services Agreement with you (e.g., under GDPR Article 6(1)(b) or equivalent in other laws).
Legitimate Interests: For efficient business operations, fraud prevention, and service improvement (balanced against your rights).
Consent: Where required (e.g., for optional communications), which you can withdraw at any time.
Legal Compliance: To meet obligations under UAE law or international regulations (e.g., APP 1 in Australia for openness).
5. Data Sharing and Transfers
Who We Share With: We may share your data with trusted third-party service providers for operational purposes, such as:
Zoho (for CRM and Books).
Stripe (for payments).
Google (for Sheets, Drive, and email). These providers are bound by data protection agreements and process data only on our behalf.
No Sales or Marketing Sharing: We do not sell, rent, or share your data with third parties for their marketing purposes.
International Transfers: As a UAE-based company serving global clients, data may be transferred across borders (e.g., to EU, AU, UK, US, NZ). We ensure adequate safeguards:
For EU/UK: Standard Contractual Clauses (SCCs) or equivalent mechanisms under GDPR.
For US: Compliance with CCPA/CPRA, with no "sale" of data.
For AU/NZ: Reasonable steps to ensure protection equivalent to APPs or NZ Privacy Act. If additional safeguards are needed (e.g., a Data Processing Addendum), we will provide one upon request.
Government Disclosures: We may disclose data if required by law, court order, or regulatory authority (e.g., UAE authorities or your local regulators).
6. Data Security and Retention
Security Measures: We use industry-standard security practices, including encryption, access controls, and regular audits, to protect your data on cloud platforms. All storage is cloud-based (e.g., Google Drive), with no local hard drive usage.
Retention Period: We retain your data only as long as necessary:
Contact details: For the duration of our business relationship plus 1 year after termination.
Accounting information: Up to 7 years for legal/tax compliance (e.g., under UAE or AU laws). After this, data is securely deleted or anonymized.
Breach Notification: In case of a data breach, we will notify you and relevant authorities within required timelines (e.g., 72 hours under GDPR).
7. Your Rights
Depending on your jurisdiction, you have rights regarding your personal data:
Access, correct, or update your information.
Delete or restrict processing (subject to legal obligations).
Object to processing based on legitimate interests.
Data portability (e.g., receive your data in a structured format).
Withdraw consent where applicable.
For CCPA/CPRA: Opt-out of data "sales" (we do not sell data) and non-discrimination.
For GDPR/UK GDPR: Lodge a complaint with a supervisory authority (e.g., UAE Data Office, EU Data Protection Authority, or Australian Office of the Information Commissioner).
For AU/NZ: Rights under APPs or NZ Privacy Act, including correction and complaints to the OAIC (AU) or Privacy Commissioner (NZ).
To exercise these rights, contact us at trajaninternational@protonmail.com We respond within 30 days (or as required by law), free of charge unless requests are excessive.
8. Cookies and Tracking Technologies
If our website or services use cookies (e.g., for analytics), we will obtain consent where required (e.g., under GDPR). Currently, our operations are primarily B2B and do not involve extensive tracking. See our website for details if applicable.
9. Children's Privacy
Our services are not intended for individuals under 18. We do not knowingly collect data from minors.
10. Changes to This Policy
We may update this Policy to reflect changes in our practices or laws. Updates will be posted on our website www.trajaninternational.com/privacy-policy with the new effective date. For significant changes, we will notify ongoing clients via email.
11. Contact Us
For questions, requests, or complaints about this Policy or your data:
Address: Etihad Airways Centre 5th Floor, Abu Dhabi, UAE
Phone: +971566738208
This Policy is governed by UAE law, with considerations for your jurisdiction as outlined in our Services Agreement.
Last Updated: August 26, 2025