TEKVEL-FZCO
Added a description of how we process email engagement data (message opens and link clicks) and video watch telemetry, together with their retention periods.
Privacy Policy
Version: 3.0, effective 1 September 2026.
1. Introduction
1.1. This Privacy Policy explains how Tekvel FZCO (the "Controller", "we", "us") collects, uses, discloses and protects personal data of individuals who use the website fee.digital (the "Site") and our related training and educational services.
1.2. We process personal data in accordance with UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (the "PDPL") and its implementing regulations. As a company established in Dubai Silicon Oasis (Dubai Integrated Economic Zones Authority), the Controller is subject to the UAE Federal PDPL.
1.3. This Policy applies to the international region of the Site. Other regions of the Site are served under separate privacy policies published on the Site.
2. Controller details
Tekvel FZCO Registered address: Techno Hub 2, Office 237, Dubai Silicon Oasis, Dubai, United Arab Emirates Trade Licence No.: 22594 KHDA permit / accreditation: 630949 Contact email for privacy matters: aao@tekvel.com Responsible contact for data-protection matters: Alexey Anoshin (Manager) — aao@tekvel.com
3. Personal data we collect
| Category | Data |
|---|---|
| Identity | first name, last name |
| Contact | email address, phone number, postal address |
| Professional | job title, organisation, area of interest |
| Account | username, hashed password, interface language, country |
| Order | order contents, amount, payment status, promo code |
| Technical | IP address (stored hashed), browser information, cookies, UTM parameters |
| Learning | progress through course parts; video viewing data (which intervals of a recording were played, playback speed, how often a passage was replayed, session length, playback quality, and player diagnostics); material ratings; exam results |
| Communications | a record of each email we send you (type, subject, language, time sent) and its delivery outcome (delivered, deferred, bounced, reported as spam); for marketing messages only, and only with your consent, whether the message was opened and which links in it were followed, together with the time, the hashed IP address and the mail-client information reported by the request |
3.1. We do not collect special categories of personal data (health, religious or philosophical beliefs, racial or ethnic origin, etc.) or biometric data.
3.2. Our services are directed to adults. We do not knowingly collect data from persons under the age of 18.
4. Purposes and legal basis
We process personal data on the following bases under Article 4 of the PDPL:
| Purpose | Legal basis (PDPL Art. 4) |
|---|---|
| Provide training/educational services; account and enrolment management | Performance of a contract |
| Record learning progress, including confirming that course material was actually studied, as the basis for issuing a certificate of completion | Performance of a contract |
| Improve course materials from aggregated, anonymised viewing statistics | [[legitimate interest / basis confirmed by counsel]] |
| Process payments and refunds | Performance of a contract; legal obligation |
| Send service (transactional) messages | Performance of a contract |
| Keep a record of the messages we sent you and whether they were delivered | Performance of a contract; legal obligation (proof of notice); legitimate interest in operating a working mail service |
| Send marketing communications | Consent (separate, opt-in) |
| Measure whether marketing messages were opened and which links were followed | Consent (the same marketing consent; see section 12) |
| Analytics and Site improvement (aggregated) | Consent (via cookie banner) / legitimate interest |
| Comply with applicable law | Legal obligation |
5. Consent and its withdrawal
5.1. Where we rely on consent, we obtain it through a clear, affirmative action (an un-pre-ticked checkbox). Consent for marketing is requested separately from, and is not a condition of, receiving our services.
5.2. You may withdraw consent at any time — via the unsubscribe link in any marketing email, or by contacting aao@tekvel.com. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.
6. How we share and transfer data
6.1. We engage the following categories of processors, under contracts requiring PDPL-level protection:
- cloud hosting and object storage provider;
- payment processor (Stripe) for international card payments;
- email service provider (Amazon SES) for transactional and, subject to consent, marketing email.
6.2. Cross-border transfer. Some processors (e.g. Stripe, Amazon SES) process personal data outside the UAE. We transfer personal data across borders only where the PDPL permits (Articles 22–23) — to jurisdictions with an adequate level of protection, or subject to appropriate safeguards and/or your explicit consent.
6.3. We do not use a third-party marketing-analytics or email-tracking provider. The delivery, open and click measurement described in section 12 is performed on our own infrastructure and the resulting data is not shared with any advertising network, data broker or profiling service.
7. Data retention
We retain personal data only as long as necessary for the purposes described, or as required by law. When no longer needed, data is deleted or anonymised.
7.1. Video viewing data. Detailed records of individual viewing sessions are retained for no longer than 24 months from the session and are then deleted. The summary of a learner's progress through a part (the proportion of the recording watched, the date the completion threshold was reached) is retained for as long as the learner's course access lasts and for the retention period of the certificate it supports, because it is the evidence behind that certificate. Aggregated, anonymised statistics for a course part are retained indefinitely and do not identify any individual.
7.2. Message data. The record that a given message was sent to you, its subject and its delivery outcome is retained for as long as your account exists and for any period required by law thereafter, because it is the evidence that a notice — an order confirmation, a certificate, a change to a course you booked — was actually given. Detailed engagement events (opens and clicks on marketing messages) are retained for no longer than 12 months from the event and are then deleted; aggregated campaign statistics that no longer identify an individual may be retained beyond that.
8. Your rights
Under the PDPL you have the right to: access your personal data; request correction; request erasure; restrict or object to processing; data portability; and withdraw consent. To exercise these rights, contact aao@tekvel.com. You also have the right to lodge a complaint with the UAE Data Office.
9. Security
We apply appropriate technical and organisational measures, including TLS encryption in transit, hashed password storage, hashed IP addresses, access controls and backups.
10. Cookies
Our use of cookies and similar technologies is described in our Cookie Policy.
11. Learning progress and video analytics
11.1. To confirm that course material has actually been studied, we record how course videos are watched in the learner's account. The legal basis is performance of our contract with the learner: without a record of progress we cannot confirm completion or issue a certificate.
11.2. We record which intervals of a recording were played, at what playback speed, how many times a passage was replayed, the length and time of each viewing session, the playback quality selected, and player diagnostics (pauses, seeks, buffering, whether the tab was in the background). We do not record the learner's image or voice, the contents of their screen, their activity outside the course-material page, or their behaviour on any third-party site.
11.3. This applies only to videos played through the Site's own player. Some course material is played by a third-party content-protection provider's player; for that material no viewing data is available to us and none is processed.
11.4. A course part marks itself complete once the viewing threshold is reached. A learner may mark any part complete, or clear that mark, at any time regardless of what the tracking shows; a mark made by the learner is recorded as such and remains distinguishable from one confirmed by measurement. No decision producing legal effects is taken solely on the basis of this automated processing.
11.5. Aggregated statistics for a course part (which passages are replayed, where learners stop watching) are produced in anonymised form. We do not disclose such statistics for a part where too few learners contributed to them for the result to remain non-identifying.
11.6. You may request the viewing record we hold about you under section 8 above.
12. Email delivery and engagement measurement
12.1. Delivery records — all messages. For every email we send you we record that it was sent, to which address, in which language, with what subject, and what the receiving mail system did with it (accepted, delayed, rejected/bounced, or reported as spam). This is not a tracking technology: it is the outcome our own mail transport reports back. We keep it because we must be able to show that a notice was given, to stop mailing an address that no longer works, and to honour spam complaints. The legal basis is the performance of our contract with you, our legal obligations, and our legitimate interest in operating a mail service that does not send to dead addresses.
12.2. Open and click measurement — marketing messages only. Where you have given marketing consent, our marketing messages contain a small transparent image loaded from our server and links that pass through our server before redirecting to their destination. This lets us record that a message was opened and which of its links were followed, with the time, a hashed IP address (never the address itself) and the mail-client information your request reports. We use this to see which topics are worth writing about and to stop sending to people who never read.
12.3. Service and transactional messages are not open- or click-tracked. Order confirmations, certificates, password resets, cohort changes and similar operational messages carry no tracking image and no redirect links. Only paragraph 12.1 applies to them.
12.4. What we do not do. We do not read your mailbox, see any message you did not receive from us, see what you do after leaving a link's destination page, track you across other websites, sell or share this data, or use it to build advertising profiles. We do not take any decision producing legal effects about you on the basis of this data.
12.5. Accuracy. Many mail providers (for example Apple Mail Privacy Protection and Gmail's image proxy) load remote images automatically without the recipient ever seeing the message. Open data is therefore approximate by nature, and we treat it as such.
12.6. How to switch it off. Configuring your mail client not to load remote images prevents open measurement entirely. Not following links in a message prevents click measurement. Withdrawing marketing consent — the unsubscribe link in any marketing message, the switch in your account settings, or a request to aao@tekvel.com — stops both, because it stops the marketing messages themselves. Withdrawal does not affect service messages, which are not tracked in any case.
12.7. You may request the message record we hold about you under section 8 above.
13. Changes
We may update this Policy. The current version and its effective date appear at the top of the document; prior versions are retained and available on request.