Privacy Policy
Effective Date: October 29, 2025
Flair XL FZCO ("we," "us," or "our") is a lead generation company registered in Dubai, United Arab Emirates. We are committed to protecting the privacy and security of the personal information we collect, process, and transfer. This Privacy Policy outlines our practices regarding the collection, use, and disclosure of information through our services and website, www.flair-xl.com.
1. Scope and Application
This policy applies to all information collected by Flair XL FZCO from:
- Website Visitors: Individuals who browse our website.
- Lead Subjects: Individuals whose personal information we collect and process as part of our lead generation services.
- Clients: Businesses that purchase our lead generation services.
2. Information We Collect
We collect information primarily for the purpose of generating, qualifying, and selling business leads to our clients.
A. Information from Lead Subjects (Data Subjects)
This information is typically collected through third-party marketing channels (e.g., online forms, surveys, co-registration agreements) and may include:
- Contact Information: Name, email address, phone number, and physical address.
- Demographic Data: Age, gender, and income range.
- Intent Data: Specific interest in a product or service (e.g., "interested in debt relief," "seeking solar panel installation quote").
- Technical Data: IP address, device type, and time of consent.
B. Information from Clients and Website Visitors
- Client Data: Business contact information, company name, payment details, and service preferences.
- Website Usage Data: Information about how our website is accessed and used, such as browser type, pages visited, and time spent on the site.
3. How We Use Information
We use the information we collect for the following purposes:
- Lead Generation and Fulfillment: To generate, verify, and transfer qualified leads to our clients for their marketing and sales purposes.
- Service Improvement: To analyze market trends, improve our lead generation methodologies, and enhance our website performance.
- Communication: To respond to inquiries, provide customer support, and send service-related updates to our clients.
- Legal Compliance: To comply with legal obligations, including maintaining records of consent and responding to lawful requests from public authorities.
4. Legal Basis for Processing (Lead Subjects)
Our primary legal basis for processing personal data of Lead Subjects is Consent. We require that all third-party sources providing us with leads confirm that the Lead Subject has given explicit, informed, and unambiguous consent for their data to be transferred to a third party for marketing purposes related to their stated interest.
5. Sharing and Disclosure of Information
We share personal information only in the following circumstances:
- With Clients: We disclose Lead Subject information to the specific client(s) who have purchased the lead, strictly for the purpose of offering the product or service the Lead Subject expressed interest in.
- Legal Requirements: We may disclose information if required to do so by law or in the good faith belief that such action is necessary to comply with a legal obligation, protect our rights or property, or ensure the safety of the public.
6. Data Security
We implement reasonable technical and organizational measures to protect the personal data we process from unauthorized access, disclosure, alteration, and destruction. However, no method of transmission over the Internet or method of electronic storage is 100% secure.
7. International Data Transfer
As a company based in Dubai, we may process and store data in the UAE and transfer data to clients located in other jurisdictions, including Canada. By using our services, you consent to the transfer of information to countries outside your country of residence, which may have different data protection laws. We ensure that such transfers comply with applicable data protection laws.
8. Your Data Protection Rights
Lead Subjects and Clients have rights regarding their personal data, including:
- Right of Access: To request copies of their personal data.
- Right to Rectification: To request correction of inaccurate or incomplete data.
- Right to Erasure: To request the deletion of their personal data, subject to legal retention periods.
- Right to Withdraw Consent: To withdraw consent at any time where we rely on consent to process their personal data.
9. Contact Us
If you have any questions about this Privacy Policy or our data practices, please contact us: