Privacy Policy

This document is a working draft prepared for Digiloom Solutions and has not been reviewed by a lawyer. It should be checked by a qualified adviser in Tunisia before the site goes live, and re-checked if anything is ever added to the site, because adding analytics, a map, an embedded video, a chat widget, or a hosted font would each change what is true below.

The short version

This site uses Google Tag Manager, a container script from Google that can load other tags (an analytics tool, for example) without a separate code change to the site. It does not run, and no cookie from it is set, unless you click "Accept" on the banner shown on your first visit; see section 6. The only personal data we receive directly is what you choose to type into the enquiry form, and we use it to answer you.

1. Who we are
2. What we collect
3. Why, and on what basis
4. Who else sees it
5. Where it is processed
6. Cookies
7. How long we keep it
8. Security
9. Your rights
10. Children
11. Changes
12. Contact

1. Who we are

The controller of personal data collected through this site is Digiloom Solutions, an unregistered venture based in Bizerte, Tunisia. Because it is not yet a registered company, no RNE or matricule fiscal number applies.

For anything about privacy, write to digiloom.solutions@gmail.com. There is no separate data protection contact; the same address handles everything.

2. What we collect

What you send us

The enquiry form asks for your name, your email address, optionally a company or project name, optionally which services you are interested in, and your message. If you email us directly instead, we receive whatever is in that email, including your address and anything you attach.

While the form is configured to open your own email application, your message travels through your email provider in the ordinary way before it reaches us. If the form is later connected to a form-handling service, this policy has to be updated to name that service.

What is collected automatically

Our hosting provider keeps standard server logs for security and troubleshooting: the IP address of the request, the time, the page requested, the referring page, and the browser user agent string. We do not build profiles from these logs and we do not connect them to enquiries.

This site also runs Google Tag Manager (GTM), a container that loads on every page and can add other tags, such as an analytics tool, without us changing the site's code each time. Depending on what is configured inside it, that can mean data such as the pages you viewed, your approximate location from your IP address, and your device and browser type is collected and sent to Google. There is no session recording, A/B testing tool, advertising pixel, or chat widget on this site.

3. Why, and on what basis

Purpose	Data	Basis
Reading and answering your enquiry	Name, email, company, selected services, message	Steps taken at your request before entering a contract, and our legitimate interest in replying to people who contact us
Keeping a record of what was discussed if the enquiry turns into a project	The same	Performance of the contract, and our legitimate interest in keeping accurate business records
Keeping the site available and secure	Server logs	Legitimate interest in the security and availability of our own site
Meeting accounting and tax obligations once you become a client	Contract and invoicing records	Legal obligation

We do not sell personal data, we do not share it for advertising, and we do not use it to make automated decisions about you. We will not add you to a mailing list because you sent an enquiry.

4. Who else sees it

Enquiries are read by the people at Digiloom Solutions who need to answer them. Beyond that, the only parties involved are:

• Cloudflare, Inc., United States, which serves this site and holds the server logs described above
• Google LLC (Gmail), United States, which carries and stores our email, including your enquiry
• Google LLC, United States, again but separately, through Google Tag Manager and whatever tag is configured inside it, as described in section 2 and section 6
• Our accountants and legal advisers, where a specific matter requires it
• A public authority, where the law requires us to disclose something

We ask providers to process data only on our instructions and to protect it properly.

5. Where it is processed

Digiloom Solutions is established in Tunisia and processes enquiries there. Email is handled by Google LLC, and hosting by Cloudflare, Inc.; both process data in the United States and other countries under their own standard contractual safeguards.

Processing of personal data in Tunisia is subject to Organic Law 2004-63 on the protection of personal data, which is overseen by the Instance Nationale de Protection des Donnees Personnelles. Whether this processing requires a declaration to, or authorisation from, the INPDP has not yet been confirmed with an adviser.

6. Cookies

This site uses Google Tag Manager (GTM), which loads on every page. GTM itself is a delivery mechanism: whether it sets a cookie depends on what tag is configured inside it. If an analytics tag such as Google Analytics is active, it sets cookies used to distinguish returning visitors and measure how the site is used. We have not built a full cookie table here yet, because it would need to list every cookie a currently-configured tag actually sets, and that can change from inside the Tag Manager console without a code change to this site.

A banner asks first. Google Tag Manager does not load, and nothing inside it can run, until you click "Accept" on that banner; clicking "Decline" keeps it switched off. Your choice is stored in your browser (not as a cookie itself, since remembering the choice does not need consent) and applies to every page here, not just the one you were on. You can change your mind at any time using "Cookie settings" in the footer, which forgets the stored choice and asks again.

Consent Mode signals are also set for Google's own tools: denied by default, updated to granted only when you accept. This has not been reviewed by a lawyer; if you are in the EU, EEA, or UK, the ePrivacy Directive and GDPR set the actual bar for what counts as valid consent here, and that should be confirmed by a qualified adviser rather than assumed from this description.

You can also block these cookies yourself at any time using your browser's cookie settings, or with a browser extension that blocks Google Tag Manager and Google Analytics specifically, regardless of what you click on the banner.

7. How long we keep it

Data	Kept for
Enquiries that do not become projects	24 months from the last contact
Correspondence with clients	The life of the engagement, then 24 months
Invoices and accounting records	The period required by Tunisian tax and accounting law
Server logs	Set by Cloudflare's own retention policy

8. Security

The site is served over HTTPS. Access to the mailbox that receives enquiries is limited to the people who need it and is protected by two-factor authentication. No system is completely secure, and we cannot promise otherwise, but if something went wrong with your data we would tell you about it.

9. Your rights

Depending on where you live, you can ask us to:

• tell you what personal data we hold about you and give you a copy
• correct anything that is wrong
• delete it, where we have no continuing reason to keep it
• restrict or stop a particular use of it
• send it to you, or to someone else, in a portable format
• object to processing we carry out on the basis of legitimate interest

Email digiloom.solutions@gmail.com and we will deal with it within one month. We may need to check who you are first, so that we do not hand your data to somebody else.

If you are in the EEA or the UK and you think we have handled your data badly, you can complain to your national data protection authority. If you are in Tunisia, you can complain to the Instance Nationale de Protection des Donnees Personnelles. Please tell us first if you can, because most problems are faster to fix directly.

10. Children

This site is aimed at businesses and is not directed at children. We do not knowingly collect data about anyone under 16. If you think a child has sent us something, tell us and we will delete it.

11. Changes

If we change this policy, the date at the top changes with it. If a change matters, for example if we start using an analytics tool, we will say so on the site rather than quietly editing this page.

12. Contact

Digiloom Solutions
Bizerte, Tunisia
digiloom.solutions@gmail.com