Prime Advertising Services LLC ("Prime Advertising", "we", "us", "our") is a digital marketing agency registered in Abu Dhabi, United Arab Emirates, commercial licence number CN-5745872.
We design and operate advertising campaigns on platforms including Meta (Facebook and Instagram), TikTok, Snapchat, and Google on behalf of our business clients, and we operate a customer relationship management system ("Prime CRM") through which enquiries generated by those campaigns are delivered to and managed by those clients.
This Policy explains how we collect, use, share, and protect personal data in connection with:
It applies to individuals who submit an enquiry through an advertisement we operate, visitors to our websites, and personnel of our business clients who use Prime CRM.
In relation to enquiry data, Prime Advertising and the advertising client on whose behalf the campaign was run each determine purposes and means of processing, and each is therefore a controller in respect of its own use of that data. Where we process data solely on a client's documented instructions, we act as a processor for that client. Our client's own privacy policy governs their independent use of your data once it has been delivered to them; we are not responsible for their practices.
When you submit an enquiry through an advertisement we operate, we collect the information you enter, which typically includes:
The exact fields vary by campaign. The advertising platform's form displays the fields being collected at the point of submission.
When you submit an enquiry through an advertising platform, that platform provides us with technical and attribution information alongside your submission, including:
Once your enquiry is delivered, the following is generated and recorded:
Standard technical data including IP address, browser type and version, device type, operating system, referring URL, pages viewed, session duration, and interaction events, collected through cookies and similar technologies. See §10.
We may obtain personal data from:
We do not seek sensitive personal data — this includes data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic or biometric data, health data, or data concerning sexual orientation. Please do not include such information in free-text fields. If you do, we will treat it as incidental and delete it where practicable.
| # | Purpose | Lawful basis |
|---|---|---|
| 4.1 | To receive your enquiry and deliver it to the advertising client whose product or service you enquired about | Performance of steps taken at your request prior to entering a contract; consent given at submission |
| 4.2 | To enable that client and its authorised sales personnel to contact you regarding your enquiry | Steps taken at your request; consent |
| 4.3 | To operate, maintain, secure, and support Prime CRM | Legitimate interests in operating our services |
| 4.4 | To verify enquiry authenticity and detect duplicate, fraudulent, automated, or invalid submissions | Legitimate interests in service integrity and fraud prevention |
| 4.5 | To measure, analyse, and improve advertising performance, including the relationship between advertisement, audience, creative, placement, and enquiry outcome | Legitimate interests in improving our services |
| 4.6 | To transmit conversion and outcome signals to advertising platforms so that campaign delivery can be optimised toward higher-quality enquiries (see §7) | Legitimate interests; consent where required by the platform or by law |
| 4.7 | To construct, maintain, and use audience segments for advertising targeting, exclusion, and suppression | Legitimate interests; consent where required |
| 4.8 | To score, segment, classify, and prioritise enquiries by likely relevance and quality (see §6) | Legitimate interests in service quality |
| 4.9 | To combine, enrich, and analyse enquiry data with other data we hold or lawfully obtain, including our own proprietary datasets, for analytical and quality purposes (see §5.4) | Legitimate interests in service quality and market analysis |
| 4.10 | To produce reports, statistics, benchmarks, and insights for our clients and for our own business development, in aggregated or de-identified form wherever practicable | Legitimate interests |
| 4.11 | To develop, test, and improve our systems, models, tools, and methodologies | Legitimate interests |
| 4.12 | To comply with legal, regulatory, tax, and accounting obligations | Legal obligation |
| 4.13 | To establish, exercise, or defend legal claims, and to respond to disputes and regulatory enquiries | Legal obligation; legitimate interests |
| 4.14 | To communicate with you about your enquiry and respond to your requests | Steps taken at your request |
Where we rely on legitimate interests, we assess whether our interest is outweighed by your rights and freedoms, and we record that assessment. You may object to processing based on legitimate interests — see §11.
Where consent is our basis, you may withdraw it at any time. Withdrawal does not affect processing carried out before withdrawal. Note that withdrawing consent with us does not withdraw it from a client who has already received your enquiry and is processing it as an independent controller; you should contact them directly.
The primary purpose of your enquiry is delivery to the client whose product or service you enquired about. We share your enquiry data — including all fields you submitted, the campaign attribution data in §3.2, and the handling data in §3.3 — with that client and with its authorised personnel, including its sales representatives, managers, and administrators.
The client is an independent controller of that data. Their retention, marketing, and disclosure practices are governed by their own privacy policy, and we do not control them. Where the client operates its own CRM, your enquiry may be delivered to that system in addition to Prime CRM.
We engage third parties to provide the infrastructure and services on which our operations depend. These act on our documented instructions under written agreements imposing confidentiality and security obligations. Categories include:
We transmit data to advertising platforms for measurement, attribution, conversion reporting, campaign optimisation, and audience construction, as described in §7.
We ask you to read this section carefully, as it describes processing that may be less familiar.
We operate advertising campaigns for multiple clients, frequently in related sectors and in the same geographic markets. Where the same individual submits enquiries in response to more than one campaign, whether for the same client or for different clients, we may link those submissions internally to a single contact record maintained by us.
We may also combine enquiry data with:
We do this in order to:
Important limitations we apply:
If you object to this processing, contact us using the details in §1 and see §11.
If Prime Advertising is involved in a merger, acquisition, restructuring, financing, or sale of all or part of its business or assets, personal data may be transferred as part of that transaction. We will require any recipient to honour commitments materially equivalent to those in this Policy, and we will notify you where required by law.
We may disclose personal data where we believe in good faith that disclosure is necessary to: comply with applicable law, regulation, legal process, or an enforceable governmental request; enforce our terms and agreements; detect, prevent, or address fraud, security, or technical issues; or protect the rights, property, or safety of Prime Advertising, our clients, our users, or the public.
We do not sell your personal data. We do not disclose your personal data to third parties for their own independent marketing purposes, other than to the advertising client to whom your enquiry was directed as described in §5.1.
We apply automated analysis to enquiries in order to assess their likely quality, relevance, and priority. This may produce a numerical score or classification band assigned to your enquiry.
Factors that may contribute include: the completeness and content of your answers; the number of enquiries you have submitted and their timing; the characteristics of the campaign and form through which you enquired; the outcome of previous enquiries associated with the same contact details; matches against proprietary datasets we hold; and the time and context of submission.
It helps us and our clients prioritise which enquiries to contact first, and helps us assess and improve campaign performance. It may also determine which advertising audience segments you are included in or excluded from.
It does not produce a decision with legal effect or similarly significant effect on you. Every enquiry remains available to a human sales representative regardless of score, and no product, service, price, or opportunity is withheld from you on the basis of a score.
You may request information about the logic involved, and you may contest a score or request human review, using the contact details in §1.
Advertising platforms allow advertisers to report back what happened to an enquiry after it was generated — for example, that it was qualified, that a meeting was arranged, or that it did not proceed. Platforms use these signals to improve the targeting of future advertising.
We transmit such signals to advertising platforms, including through Meta's Conversions API. When we do:
We create and maintain custom audience segments on advertising platforms using irreversibly hashed contact information, in order to reach audiences with characteristics similar to previous enquirers, and to exclude individuals from advertising where appropriate — for example, to avoid showing you advertisements for something you have already told us you are not interested in.
Advertising platforms process data under their own privacy policies and terms, and act as independent controllers or joint controllers for certain of their processing. We recommend reviewing:
| Data category | Retention |
|---|---|
| Enquiry records and associated handling data | 36 months from the date of last interaction, unless a longer period is required by law or for the establishment or defence of legal claims |
| Internal contact records and analytical datasets (§5.4) | 36 months from last activity, subject to periodic review |
| Raw platform payloads and ingestion logs | 90 days |
| System audit and access logs | 24 months |
| Website analytics data | 26 months |
| Business client contractual and financial records | As required by UAE commercial, tax, and accounting law, currently a minimum of 5 years |
| Data subject request records | 24 months from resolution |
Where a business client ceases working with us, we retain enquiry records generated during the engagement for the periods above, for the purposes of contractual record-keeping, dispute resolution, regulatory compliance, and the analytical purposes described in §5.4.
When a retention period expires, we delete the data or irreversibly anonymise it so that it can no longer be associated with an identifiable individual.
Prime Advertising is established in the United Arab Emirates. Personal data may be transferred to, stored in, and processed in countries outside the UAE, including where our service providers and the advertising platforms operate infrastructure — this includes the United States, the European Union, and other jurisdictions.
Where we transfer personal data outside the UAE, we do so in accordance with applicable UAE law, relying on:
You may request further information about the safeguards applied using the contact details in §1.
Our websites use cookies and similar technologies for:
Where required, we request consent before setting non-essential cookies, and you may change your preferences at any time through the cookie preference control on www.primeadvertising.ae or through your browser settings. Blocking cookies may affect site functionality.
Subject to applicable law and to any exemptions that apply, you have the right to:
| Right | What it means |
|---|---|
| Access | Obtain confirmation of whether we process your data, and a copy of it |
| Rectification | Have inaccurate or incomplete data corrected |
| Erasure | Request deletion of your data in certain circumstances |
| Restriction | Request that we limit how we use your data in certain circumstances |
| Objection | Object to processing based on legitimate interests, including profiling and the cross-client analysis in §5.4 |
| Portability | Receive data you provided in a structured, commonly used, machine-readable format |
| Withdraw consent | Withdraw consent where consent is the basis, without affecting prior processing |
| Object to direct marketing | Opt out of marketing communications at any time |
| Automated decisions | Request human review of, and information about, automated processing (§6) |
| Complain | Lodge a complaint with the UAE Data Office or another competent supervisory authority |
Contact us at info@primeadvertising.ae with the subject line "Privacy Request". We will verify your identity before acting, which may require additional information. We respond within 30 days, and will tell you if we need longer and why. There is no charge unless a request is manifestly unfounded or excessive.
Where your enquiry has already been delivered to an advertising client, that client processes it independently. We will act on your request in respect of our own processing and will forward your request to the client where practicable, but you may also need to contact them directly. We will provide their contact details on request.
We maintain technical and organisational measures appropriate to the risk, including:
No system is completely secure, and we cannot guarantee absolute security. If a personal data breach occurs that is likely to result in a risk to your rights, we will notify the competent authority and, where required, you, in accordance with applicable law.
Our services are directed at adults. We do not knowingly collect personal data from individuals under 18. If we become aware that we have collected such data without appropriate consent, we will delete it. If you believe a child has provided us with personal data, contact us at info@primeadvertising.ae.
We may update this Policy from time to time. The "Last updated" date at the top indicates when it was last revised. Where changes are material, we will provide additional notice by a prominent banner on www.primeadvertising.ae and, where we hold a valid contact address for you and are required to do so, by email. We encourage you to review this Policy periodically.
Commercial licence: CN-5745872
We have not appointed a formal Data Protection Officer. Privacy matters are handled by the contact named above. Should our processing activities require the appointment of a Data Protection Officer under applicable law, this Policy will be updated accordingly.
If you are not satisfied with our response, you may lodge a complaint with the UAE Data Office, the federal supervisory authority for data protection in the United Arab Emirates.
To request deletion of your personal data, email info@primeadvertising.ae with the subject line "Data Deletion Request", including the name, telephone number, or email address you used when submitting your enquiry.
We will verify your identity, action the request within 30 days, and confirm completion. Where we are required to retain certain data for legal, regulatory, or dispute-resolution purposes, we will tell you what has been retained and why.
Where your enquiry was delivered to an advertising client, we will forward your deletion request to that client where practicable; you may also contact them directly, and we will provide their details on request.