Privacy Policy

Last updated: May 2026

1. Who We Are

Pearl Agency FZ-LLC ("Pearl Agency," "we," "us") is a limited liability company registered with the Ras Al Khaimah Economic Zone (RAKEZ), UAE. License number 0000004076930. Registered office: Al Shohada Road, Al Hamra Industrial Zone-FZ, FOB50582 Compass Building, Ras Al Khaimah, UAE.

For privacy inquiries, contact: hello@pearlmodels.agency. Under GDPR, you may also contact us using this address to exercise your rights as a data subject.

2. What Information We Collect

We collect information in the following ways:

3. Why We Collect It

We use your personal information for the following purposes:

• To deliver the coaching services you've engaged us for (contract performance)
• To communicate with you about your engagement, scheduling, and related matters (contract performance)
• To process payments and maintain financial records (contract performance and legal obligation)
• To improve our website and services (legitimate interest)
• To comply with legal obligations (legal obligation)
• To send occasional updates if you've explicitly opted in (consent)

We do not sell your personal information, ever, to anyone, for any purpose.

4. Legal Basis for Processing (GDPR)

For clients located in the European Economic Area or the UK, we process your personal data on one or more of the following legal bases:

• Contract performance: processing necessary to deliver the services you've engaged us for
• Legitimate interest: improving our services, security, and basic analytics
• Legal obligation: complying with tax, financial, and corporate record-keeping requirements
• Consent: where you've explicitly opted in (e.g., marketing communications)

You may withdraw consent at any time where consent is the legal basis.

5. Who We Share Information With

We share personal information only with the following categories of recipients:

• Payment processor: Stripe, for handling payments. Stripe's privacy policy is available at stripe.com/privacy.
• Scheduling tool: Cal.com (or our current scheduling provider), for managing call bookings.
• Email and communication providers: standard business email and messaging services.
• Professional advisors: accountants, lawyers, and similar advisors bound by confidentiality.
• Authorities: where legally required (e.g., tax authorities, court orders).

We do not share information with marketing platforms, advertising networks, or data brokers.

6. International Data Transfers

Pearl Agency is based in the UAE. Some of our service providers (Stripe, Cal.com, email providers) are based in the United States, the European Union, or other jurisdictions. Where personal data of EEA or UK residents is transferred outside the EEA or UK, we rely on:

• Standard Contractual Clauses approved by the European Commission
• The recipient's own adequacy decisions where applicable
• Other lawful transfer mechanisms

You may request more information about specific transfer safeguards by contacting us.

7. How Long We Keep Information

We retain personal information only as long as necessary:

• Active client information: for the duration of the engagement plus a reasonable period for follow-up
• Financial records (invoices, payment records): for a minimum of 7 years, as required by UAE tax and corporate law
• Communications: typically deleted within 2 years of the end of an engagement, except where retained for legal or business records
• Website analytics: aggregated and anonymized where possible

You may request earlier deletion (see "Your Rights" below), subject to our legal obligations to retain certain records.

8. How We Protect Information

We use reasonable technical and organizational measures to protect personal information, including:

• SSL/TLS encryption for all data transmitted to and from our website
• Encrypted storage where applicable
• Access controls limiting who can view personal information
• Regular review of our security practices

No system is perfectly secure. If we become aware of a data breach affecting your personal information, we will notify you and the relevant authorities as required by applicable law.

9. Your Rights

Under GDPR (and similar protections under UAE data protection law), you have the following rights regarding your personal information:

• Right of access: request a copy of the information we hold about you
• Right of rectification: correct inaccurate information
• Right of erasure: request deletion of your information, subject to our legal obligations to retain certain records
• Right to restrict processing: limit how we use your information in specific circumstances
• Right to data portability: receive your information in a structured, machine-readable format
• Right to object: object to processing based on legitimate interest
• Right to withdraw consent: where consent is the legal basis for processing
• Right to lodge a complaint: with a supervisory authority, including your local data protection authority in the EEA or UK

To exercise any of these rights, contact hello@pearlmodels.agency. We respond to all valid requests within 30 days.

10. Cookies

Our website uses cookies. See our separate Cookie Policy at /cookies for full details.

11. Children's Privacy

Our services are intended for adults (18+) only. We do not knowingly collect personal information from anyone under 18. If we become aware that we have collected information from a minor, we will delete it.

12. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be communicated to active clients and noted with the updated "last updated" date at the top of this page.

13. Contact

Questions about your privacy or this policy: hello@pearlmodels.agency

For GDPR-related complaints, you also have the right to lodge a complaint with your local supervisory authority. A list of EEA supervisory authorities is available at edpb.europa.eu/about-edpb/about-edpb/members_en.