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Nothing matches that.
This website is operated by COGNOVATE LABS FZCO, a company registered in the United Arab Emirates, which trades as Lumina Clippers. In this policy, "we", "us" and "our" mean COGNOVATE LABS FZCO.
We are the controller of the personal information described below, which means we decide what is collected and what it is used for. If you would rather speak to a person than read a policy, write to rhys@ugcagency.io and we will answer.
It covers the information we collect when you browse ugcagency.io, when you send us an enquiry through the contact form, and when you email us. It also covers the information we hold about you while we are running a campaign for you.
It doesn’t cover the social platforms your campaign runs on. When a creator posts a video on TikTok, Instagram, YouTube or X, that platform collects data under its own policy and we have no control over it.
The contact form on this site is the only place we ask you for anything. These are the exact fields, and nothing else on the page collects information about you:
The free-text box is yours, so please only put in it what you’re comfortable sending by email. We don’t need and don’t ask for identity documents, payment card numbers or any sensitive personal information at the enquiry stage.
If you go on to become a client, we hold the ordinary business details needed to run and invoice the work, like your billing contact, the brand assets you send us and the approvals you give on scripts and videos.
Like every website, this one sits on a server that keeps standard technical logs, which can include your IP address, the browser and device you used, the page you requested and the time you requested it. Our hosting provider keeps them to serve the site, block abuse and diagnose faults.
When you submit the contact form, the record of your enquiry may also carry the page you sent it from along with the same technical details, since that’s how the form software stores a submission. We don’t use any of it to build a profile of you.
The lawful basis is simple. When you send an enquiry you’re asking us to take steps before entering a contract, and we act on that. Once you’re a client we process what’s necessary to perform that contract. Beyond those we rely on our legitimate interest in running and protecting a business, and on the law where we’re required to keep a record.
We don’t send marketing emails to people who haven’t asked for them, and we don’t add enquiry addresses to a mailing list. If we ever start a newsletter it’ll be opt-in and unsubscribing will take one click.
This is the short section, and it is short on purpose.
The only cookies we set are functional ones. Our host and content delivery network set a small performance cookie so pages load correctly, and WordPress sets a session cookie for our own team when we are logged in to edit the site. None of them follow you to other websites, and none of them are used for advertising.
There is one third party on the site and it is worth naming plainly. The booking calendar on our home page is Calendly, loaded inside a frame from calendly.com. Calendly sets its own cookies so the calendar can work, and it shows its own consent notice where the law requires one. If you go ahead and book a call, Calendly receives the name, email address and time zone you type in, and passes the booking to us. It is a scheduling tool, not an advertising one, and it is only there because a calendar has to come from somewhere.
Beyond that, we set no tracking or advertising cookies, which is why the rest of the site has no consent banner. If that ever changes, the banner will appear before the tracking does, and this section will be rewritten first.
Only the small number of suppliers it takes to actually run the business, and only what they need:
We may also disclose information if a law, a court or a regulator requires it, or to protect our rights, our people or our clients from harm. Outside of that, your information stays with us.
You can ask us to delete an enquiry sooner than that and we will, unless we’re legally required to keep it.
We’re based in the United Arab Emirates, and our website, email and business tools come from international suppliers, so your information may be stored or processed on servers outside the UAE, including in the European Union and the United States.
Where that happens we use suppliers that offer recognised safeguards for international transfers, like standard contractual clauses, and we keep the amount of information involved to the minimum the service needs.
Whatever country you are writing from, you can ask us to:
Email rhys@ugcagency.io with what you want and we will deal with it within 30 days. We will not charge you and we will not make it difficult. If you are in the European Union or the United Kingdom, you also have the right to complain to your national data protection authority, and if you are in the UAE you may raise the matter with the relevant federal authority.
The site runs over HTTPS, admin access uses strong unique passwords, and access to enquiries is limited to the people who need it. We keep the software behind the site patched.
No system is perfect and anyone who tells you otherwise is selling something. If a breach ever affected your personal information in a way that posed a real risk to you, we’d tell you and the relevant authority without unnecessary delay.
This site and our services are for businesses. They aren’t directed at children and we don’t knowingly collect information from anyone under 18. If you believe a child has sent us information, tell us and we’ll delete it.
If we change how we handle your information we’ll update this page and change the date at the top. Material changes, like adding any form of tracking, get described here in plain language rather than buried in a redraft.
Privacy questions, requests and complaints all go to the same place, and a person reads them.
Read this far and still want to talk about a campaign? That part is much shorter.
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