Privacy Policy — United Arab Emirates
How Cerrax handles personal data under the UAE's Personal Data Protection Law, in plain terms.
1. Who we are
Cerrax Ltd ("Cerrax", "we") provides software for moving companies: a pricing engine, and the enquiries, customer records, quotes and jobs around it. We are a company registered in England and Wales, and we have no office, branch or agent in the United Arab Emirates. This policy explains what personal data we handle for moving companies in the UAE and the people they quote, why, and your rights under Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (the "PDPL"). Questions: hello@cerrax.io.
If your business is established in the Dubai International Financial Centre (DIFC) or Abu Dhabi Global Market (ADGM), that free zone's own data protection law applies instead of the PDPL, and where this policy refers to the PDPL, read it as referring to that law. We honour the same rights under it.
We have not appointed a data protection officer, because the PDPL requires one only for large-scale or high-risk processing, which we do not carry out. Contact us directly at the address above.
2. Two different roles
Our role under the PDPL depends on whose data it is:
- Your data (the moving company using Cerrax). For account holders' own details, we are the controller.
- Your customers' data. When a moving company uses Cerrax to price a job, any personal data about that company's customers (names, phone numbers, building, community and emirate) is handled by us as a processor, on the company's instructions. The company is the controller; our processing is governed by the data processing agreement between us.
- Website visitors. We are the controller for the limited data you give us directly (e.g. a waitlist or contact form).
- A customer's video kept to train software. If a customer agrees to Cerrax keeping their video or photographs for that purpose, we are thecontroller for that use alone (see §3).
3. What we collect
From companies using Cerrax: account and contact details (name, company, email, phone, and your Tax Registration Number, which we need before you can subscribe), and the job inputs you enter to produce a price. Within job data: addresses and job details, which may be personal data of your customers — processed only to produce and explain a price and record the outcome you tell us. From the job itself: where your crew use Cerrax on the day, photographs they take of the property, its access and any damage found; if you ask your customer to sign the inventory, the name they give and the signature they draw; and, if you invite it and your customer chooses to, a video of their home that they send you to be quoted from. These are held as the record of the job, on your instructions, and are used for nothing else: they never affect a price and are never shared with another company, unless the company chooses to send a link to its crew or its insurer (see below). From website visitors: what you submit in a waitlist, demo or contact form. We do not record your browsing sessions or track behaviour for advertising.
We do not ask for sensitive personal data — health, religious belief, biometric or similar — and nothing in Cerrax recognises a face, keeps any measurement of one, or extracts an identifier from a photograph, a video or a signature (where faces are blurred, software finds them only to blur them).
Contacts and enquiries (for companies that switch them on). A company can keep a contact record for each of its customers and enquirers — their name, email addresses, phone numbers, company, preferred language, the addresses they have moved from or to, where the enquiry came from, the company's notes, and any choice the person made about the company's messages. The company decides what is kept; we hold it on its behalf, only within that company's account, and never share it with another company. To recognise the same person arriving twice, we keep a scrambled key made from their email address or phone number that cannot be read back without a secret held only by us.
Enquiry emails and AI. A company can give lead websites a Cerrax address to send enquiries to. We receive those emails (through Amazon Web Services) and read them to fill in the enquiry. If an email isn't laid out in labelled lines, we send its text — without the forwarding headers or earlier quoted messages — to Anthropic, an AI provider in the United States, which suggests the name, contact details, addresses, date and size of the move. A suggestion is only used if the words appear in the email, and a person at the company checks it before anything is priced or sent. Anthropic does not use it to train its models and deletes it within 30 days (longer only if it is flagged for misuse). We do not keep the email's text for any purpose of our own. When a company describes a job's items and rooms to Cerrax, we keep that description — with any email address, phone number or address removed — for 30 days to improve how Cerrax recognises items, and then delete the text.
Messages a company sends through Cerrax. A company can switch on emails in its own name: a thank-you after a move, and — only if the customer ticked a box agreeing to it — one email after the move asking whether they know anyone else who is moving. Reminder emails about a quote are not available here. Every one identifies the company, carries its postal address and a one-tap way to stop them; stopping takes effect at once and covers all of these emails from that company to that person. We keep a record of each choice and when it was made so the company can show it later, and a scrambled note of a stop so it is honoured even after other records are deleted. The company is responsible for these messages; we send them on its instructions.
If your customer lets us keep their video to train software. When a customer sends a video or photographs, they may tick a separate box allowing Cerrax to keep them to train software that recognises furniture and rooms. It is never ticked for them and it is not a condition of being quoted. For that use, and only that use,Cerrax is the controller and processes the data on the customer'sconsent under the Personal Data Protection Law. Before any footage is used to train software, faces, documents and anything else that identifies a person or the home are blurred. Where Cerrax blurs faces as soon as a video arrives, the company sees it with faces already blurred. Nothing uses it today: it is kept, not yet used. The customer can withdraw their consent at any time, by asking the moving company or by writing to us at hello@cerrax.io; the video and photographs are then deleted under the 90-day rule in §10.
Links a company chooses to share. A company can send its crew a link to a job sheet, and can give its insurer, broker or claims handler a link to a job's evidence — the customer's name, the photographs, video and signatures, never their email address or phone number. Evidence links expire after a period the company chooses, at most 90 days; they can be revoked at any time and record each time they are opened. Who receives a link is the company's decision.
Calendar feeds. If a company subscribes its own calendar (for example Google, Apple or Microsoft) to its Cerrax calendar link, that calendar provider fetches the company's booked jobs — including the customer's name, addresses and phone number unless the company chooses the private version — and holds that copy under the company's own agreement with it.
Messages about a job. As part of a job, a company can send its customer booking confirmations, move-day reminders, requests for a video or a payment, a note before a quote expires and, after the move, a request for a review — by WhatsApp where the company has connected it and the customer uses it, otherwise by email. The customer can instead answer the review request privately, with a rating from 1 to 5 and a comment that only the company sees. A company can also keep follow-up tasks about a customer, with notes.
When a customer accepts a quote, we record the time, the version of the company's terms and the cancellation statement shown, and any box the customer ticked. We do not record their IP address or device. We also count how many times the page for a quote is opened, and note when it was last opened, so the company can see whether its quote has been read.
A company's team. The logins of the people a company invites — their name, email address and sign-in details, including two-step sign-in if they turn it on (the secret that links their authenticator app, and one-time recovery codes kept in scrambled form) — are account data that we are responsible for. What a company records about its crew for its jobs — the mobile numbers used to send them job sheets, who is assigned to which job, and the times they mark arrival or completion — is the company's data, which we hold on its behalf. No location is ever captured.
Faces in photographs and video. Nothing in Cerrax recognises a face or keeps any measurement of one. Where faces are blurred, software finds them only to blur them, and the unblurred original is then deleted.
Feedback and problem reports. If someone at a company reports a problem or sends us feedback from inside Cerrax, we keep it with their name and account so we can look into it and tell them when it is fixed. We may use Anthropic to sort feedback into categories.
Dictation. If you dictate into Cerrax, your browser's own speech-recognition service (Google in Chrome, Apple in Safari) turns your speech into text before it reaches us, under your browser's terms. We receive only the text; you can type instead.
Email delivery records and the audit trail. For each email sent through Cerrax we keep the recipient's address, the subject and whether it was delivered, to investigate delivery problems. We also keep a record of consequential actions in an account and who took them, to keep the service secure and accountable.
4. Cookies
We use only the cookies needed to make the site and service work (for example, keeping you signed in). We don't use advertising or cross-site tracking cookies. If we ever add analytics or other non-essential cookies, we'll ask for your consent first.
We measure how many people visit these pages using Vercel Web Analytics, which is privacy-preserving by design: it sets no cookie, stores no identifier, and cannot follow you between sites or sessions. It tells us page counts, referring sites and countries — never who you are.
We also keep a few things in your browser so the service works — for example a draft you have not saved yet, or your language. These are strictly necessary and are never used for tracking.
5. Why we use it, and on what basis
- To provide the service — because it is necessary to perform our contract with you: pricing jobs, holding job records, billing and support.
- To meet legal obligations — e.g. accounting, tax, and responding to lawful requests.
- To keep the service secure and prevent abuse — rate limits, blocking attacks, and checking that a visitor to the public price check is a person; necessary to perform our contract with you and to meet our legal obligations to keep the service and the companies on it secure.
- To improve the pricing engine — using only de-identified data, which is no longer personal data (see §7); and, to improve how Cerrax recognises items, keeping a company's descriptions of a job's items and rooms for 30 days with email addresses, phone numbers and addresses removed — a use the company agrees to in section 3 of our Data Processing Agreement (see §3).
- To keep a customer's video or photographs to train software — the customer's consent, which they can withdraw at any time (see §3).
Where we rely on your consent — for example, marketing emails — you can withdraw it at any time, and withdrawing it does not affect what we did before.
6. Automated pricing
Cerrax produces a price automatically from the inputs and settings provided. This is a tool for the moving company: the company decides what to charge its customer (see our Terms). The automated price is not a decision Cerrax makes about a customer that produces a legal effect on them or seriously affects them, and Cerrax does not profile anyone.
Cerrax can price an enquiry as soon as it arrives, but that price is a proposal to the company: the company reviews it and chooses to send it, change it, or not to quote, and a customer is always free to decline a quote. AI in Cerrax only suggests details for a person to confirm; it never sets a price.
7. The learning corpus (important)
Cerrax gets more accurate as it sees real outcomes. When a job is completed, we make a separate de-identified record of it, on the company's instruction: the volume, a distance band, access features, crew, vans, hours, the price and cost, the month of the move, and an area no finer than the first two letters of an area's name — never the area, street or building. It never holds a name, contact detail, full address or address, map position, free text, photograph, video, signature, the company's identity, or any reference that links it back to the job. While we still hold the original job it is treated as personal data like the job itself; once the original is deleted, no one could reasonably identify a person from it — it is then anonymous, and we keep it indefinitely. We will not try to re-identify anyone, and we require anyone we share it with to make the same commitment. Aggregated insight may inform regional benchmarks; we never expose an individual company's prices or any customer's identity.
8. Who we share it with
We don't sell personal data. We use a small set of service providers (sub-processors) under contract, currently including: cloud hosting, database and file storage (Google Cloud and Firebase, London region), account sign-in (Firebase) and geocoding (Google Maps, for distance between addresses). Where a company uses a feature that reads what it is given — the capture bar and narrative capture, photographs of a written list, spreadsheet import, and enquiry emails with no labelled layout (§3) — those inputs are processed by an AI provider (Anthropic, United States), which does not train on them and deletes them within 30 days. Our website, the Cerrax app and the pages your customers open are run by Vercel, which also provides the cookieless visitor analytics described in §4. Cloudflare Turnstile checks that a visitor to our public price check is a person, not a bot. Email is delivered — to you, and on your behalf to your customers — by Amazon Web Services (SES and SNS, London region), which also receives the enquiry emails sent to your Cerrax lead address. Payments are taken by Stripe; we never see or store your card details. If you connect your own WhatsApp Business number, the messages you send your customers through it are delivered by Meta (WhatsApp Business). If you connect your own Xero account, the invoice details of the jobs you send to it — your customer's name and address and the amounts — are written into it as draft invoices by Xero. If you connect your own Sage account instead, the same details are written into it as invoices by Sage. We keep this sub-processor list current and reflect only services actually in use, and email account owners at least 30 days before a new provider starts handling their customers' data. We may also disclose information where the law requires it, or to a successor if our business is transferred.
Anthropic is also used to suggest adjustments from the notes on a quote, to write a move-preparation checklist for a customer from the job's areas and addresses, date and notes, and to sort feedback sent to us. It does not train on this data and deletes it within 30 days.
9. Where your data is stored
Your data is held in the United Kingdom, in London. For a company in the UAE that is a transfer of personal data out of the country, and we make it under Articles 22 and 23 of the PDPL: the United Kingdom has data protection legislation (the UK GDPR and the Data Protection Act 2018) that gives personal data a level of protection comparable to the PDPL's, and in any case we are bound by contract — our Data Processing Agreement — to protect it to the PDPL's standard. Where a provider processes data outside the UK — AI processing in the United States and card payments by Stripe are the cases today — we bind it by contract to protection no less than ours. We don't move personal data anywhere without a basis the law recognises.
As things stand today: the data behind every Cerrax account is held in London. That is a statement of fact on the date at the top of this page rather than a promise about the future — if you need it in writing for a particular account, or want to know where a specific service processes data, ask us at hello@cerrax.io and we will tell you.
10. How long we keep it
Your account data (where we are the controller): for as long as your account is active and for up to six years after it closes, to meet our legal, accounting, and tax obligations — unless the law requires us to keep it longer.
Your customers' data (where we are your processor): for as long as you keep it with us, and deleted or returned when you ask, as the Data Processing Agreement sets out. Unless you tell us otherwise, job records — a quote, its booking and outcome, the crew's sheets, and any survey or damage photographs attached to them — are kept for six years after the move (or after the quote, if the job did not go ahead), unless a claim or dispute about that job is still open, and then deleted. Photographs have no separate clock: they are kept for as long as the job record they belong to and are deleted with it. A customer's video is deleted 90 days after the job's last date unless the customer has agreed to Cerrax keeping it to train software (§3) and has not withdrawn that consent.
De-identified outcome data: retained for the learning corpus. You can ask us to erase personal data (§12); committed pricing records are never silently altered, but personal identifiers within them can be redacted.
Unless a company sets different periods: an enquiry that was never priced or sent is deleted 12 months after its last activity; a quote that was sent but never accepted, 24 months after it was sent; a contact record is kept while any job record linked to it is kept, and deleted 12 months after the last one goes (or 12 months after it was made, if it was never linked to a job). A record of a person's consent is kept for as long as their contact record and six years after, so the company can show it; a scrambled record of a request to stop messages is kept indefinitely, so it keeps being honoured. Our own records: waitlist, demo and contact enquiries, 24 months after our last contact with you (or sooner if you ask); security logs, 90 days.
Also: email delivery records, 90 days; security logs, 90 days (a block on an address is kept while it lasts, then 90 days); the audit trail, up to six years after the account closes, with a customer's details removed when that customer is erased; feedback and problem reports, while the account is open and up to six years after it closes; two-step sign-in details, until they are switched off or the login is removed.
11. Marketing and communications
We'll send you service messages needed to run your account. We send marketing only with your consent: if you ask for a demo or sign up and agree to hear from us, we may email you about Cerrax. Every marketing message says it is from us and carries a free way to unsubscribe, which we honour promptly; we send between 07:00 and 21:00 UAE time, and we do not send marketing text messages or make marketing calls. We follow the TDRA's rules on unsolicited electronic communications.
12. Your rights
Under the PDPL you can ask us for information about the personal data we hold about you and a copy of it; to receive it in a portable form; to correct it or erase it; to restrict or stop its processing; and to object to a decision based solely on automated processing that affects you. For your customers' data (where we are processor), direct requests to the moving company as controller; we assist them. To exercise a right, contact hello@cerrax.io. We answer within one month, and will not treat you differently for using your rights.
You can object to our marketing at any time, and we will stop.
13. Children
Cerrax is a tool for businesses and is not directed at children. We don't knowingly collect data from children.
14. Complaints
If you're unhappy with how we handle your data, tell us at hello@cerrax.io — we will acknowledge your complaint within 30 days and work to resolve it. You can also complain to the UAE Data Office. If your business is in the DIFC, the authority is the DIFC Commissioner of Data Protection; in ADGM, the ADGM Office of Data Protection. The arbitration clause in section 17 of our Terms governs disputes between Cerrax and the moving company that contracts with us; it does not stop anyone complaining to a data protection authority or exercising a right in this policy.
15. Security
We protect data with access controls, encryption in transit and at rest via our cloud provider, and audited administrative actions. No system is perfectly secure, but we take reasonable measures appropriate to the data.
If a personal data breach occurs, we act promptly: where we are the controller we notify the UAE Data Office, and affected individuals, as the PDPL requires; where we are a processor we notify the affected moving company without undue delay, and within 48 hours, so it can meet its own obligations.
16. Changes
We may update this policy; we'll post the new version here with a revised effective date, and email account owners about any change that affects them.
17. Contact
Cerrax Ltd, 71–75 Shelton Street, Covent Garden, London, WC2H 9JQ, United Kingdom. hello@cerrax.io.