Privacy policy
Last updated: 27 October 2026
This Privacy Policy explains how OCTATEL HUB - FZCO, operating the Virtual Secretary service at virtualsecretary.online, collects, uses, stores and protects personal data when you visit our website, email us, telephone us or use our secretary and concierge services.
We aim to handle personal data in accordance with applicable data protection laws, including the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018 and, where applicable, the UAE Federal Personal Data Protection Law.
1. Who is responsible for your personal data?
The data controller is:
OCTATEL HUB - FZCO
Dubai Unified Licence (DUL) reference: DW7863
Registered address: DSO-IFZA-51059, Dubai Silicon Oasis, Dubai, United Arab Emirates.
OCTATEL HUB - FZCO operates the Virtual Secretary website and service.
For privacy enquiries, data protection requests or questions about this policy, contact:
Email: [email protected]
Website: https://virtualsecretary.online/
We have not appointed a statutory Data Protection Officer, unless otherwise required by applicable law.
Where UK data protection law requires us to appoint a UK representative, we will identify that representative and provide their contact details in this notice.
2. Personal data we collect
The personal data we collect depends on how you interact with us.
2.1 When you visit our website
We may collect:
- Technical information, including your IP address, date and time of access, pages requested, browser type and device information, through server logs.
- Your cookie preferences and consent choices.
- Analytics information, where non-essential analytics tools are enabled and you have provided any consent required by law.
2.2 When you email or telephone us
We may collect:
- Your name, telephone number and email address.
- Information you provide in correspondence or during telephone calls.
- Instructions and information required to perform secretary or concierge tasks.
- Diary entries, appointment details, draft correspondence and booking requests.
- Payment references and related transaction information where necessary to administer a service.
We do not need you to disclose full payment card details to us through ordinary telephone conversations or email.
2.3 Information concerning private or sensitive matters
Information supplied for an appointment or booking may incidentally include health information or other sensitive personal details.
We will use such information only where necessary and lawful for the task requested. Where applicable law requires an additional legal condition, such as explicit consent for special-category personal data under the UK GDPR, we will obtain and document that condition before processing.
Please do not send sensitive information unless it is necessary for the service you have requested.
3. Why we use personal data and our lawful bases
We process personal data only for specified purposes and where an appropriate legal basis applies.
| Purpose | Potential lawful basis |
|---|---|
| Responding to enquiries and providing secretary or concierge services | Performance of a contract or taking steps at your request before entering into a contract |
| Making bookings and contacting third parties on your instructions | Performance of a contract or your requested service |
| Maintaining website security, preventing misuse and diagnosing technical problems | Legitimate interests, where those interests are not overridden by your rights |
| Operating non-essential analytics | Consent, where required by applicable law |
| Maintaining accounting records and meeting legal requirements | Compliance with a legal obligation |
| Establishing, exercising or defending legal claims | Legitimate interests or another applicable legal basis |
| Processing sensitive personal information | An applicable special-category condition or other legal authorisation, where required |
Where we rely on legitimate interests, you may have the right to object to the processing, depending on the circumstances.
You are not generally required to provide personal data to browse our website. However, we may be unable to complete a booking or provide a requested service if you do not supply information necessary for that task.
4. Who we share personal data with
We may share personal data with service providers who help us operate the website or deliver our services. Depending on the systems actually used, these may include:
- Website hosting and technical support providers.
- Business email and telephone service providers.
- Analytics providers, where analytics is enabled and permitted.
- Payment or accounting service providers, where necessary.
- Professional advisers, where appropriate and subject to applicable confidentiality obligations.
When you instruct us to make a booking or contact a third party, we may share the information reasonably necessary to complete that instruction with the relevant restaurant, hotel, clinic, travel provider, council, carrier or other organisation.
Those organisations may process the information they receive as independent data controllers under their own privacy policies.
We may also disclose personal data where required by law or where necessary to establish, exercise or defend legal claims.
We do not sell personal data.
5. International transfers of personal data
OCTATEL HUB - FZCO is a Dubai-registered entity and serves UK and international customers.
Personal data may be accessed or processed in the United Arab Emirates, the United Kingdom or other countries, depending on where our personnel and service providers operate.
Where applicable data protection law restricts an international transfer, we will ensure that the transfer is supported by an appropriate legal mechanism, such as an applicable adequacy decision, approved contractual safeguards or another lawful transfer mechanism.
For transfers subject to the UK GDPR, relevant safeguards may include the UK International Data Transfer Agreement or the UK Addendum to the applicable standard contractual clauses, where appropriate.
You may contact us using the details in Section 1 to request further information about relevant international transfers and safeguards, subject to applicable law.
6. How long we retain personal data
We retain personal data only for as long as reasonably necessary for the purposes for which it was collected, including legal, accounting, security and dispute-resolution requirements.
- Unconverted enquiries: up to 12 months after the last contact.
- Service and booking records: up to six years after the relevant task ends, where justified by applicable recordkeeping or legal-claims requirements.
- Accounting records: up to six years after the end of the relevant tax year, or for any other period required by applicable law.
- Server logs: up to 12 months.
- Cookie preferences: until you clear the relevant site data or change your preferences, subject to the cookie technology used.
We may retain information for longer where required by law or where necessary to resolve a dispute, and we will securely delete or anonymise information when it is no longer needed.
7. Your data protection rights
Depending on the law applicable to your personal data and the circumstances of the processing, you may have the right to:
- Request access to your personal data.
- Request correction of inaccurate or incomplete information.
- Request deletion of your personal data where the legal conditions are met.
- Request restriction of processing.
- Object to processing based on legitimate interests.
- Request a copy of certain personal data in a portable format where the right to data portability applies.
- Withdraw consent where processing relies on consent. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.
- Complain to the relevant data protection supervisory authority.
These rights are subject to applicable legal conditions and exceptions. For example, we may need to retain certain records to comply with a legal obligation.
To exercise your rights, contact [email protected].
We may ask for information reasonably necessary to verify your identity and protect your personal data. We will respond within the time limit required by applicable law. Where an extension is permitted, we will explain the reason.
8. Complaints and supervisory authorities
If you have a concern about how we use your personal data, please contact us first at [email protected] so we can investigate and attempt to resolve it.
If UK data protection law applies, you may also complain to the UK Information Commissioner’s Office (ICO):
https://ico.org.uk/make-a-complaint/
If UAE data protection law applies, you may have the right to raise a complaint with the relevant UAE data protection authority, depending on the company’s jurisdiction and the law governing the processing.
9. Cookies and analytics
Our website may use cookies and similar technologies for essential website functionality, storing your preferences and, where enabled, analytics.
Where required by law, we will request consent before placing non-essential cookies or using non-essential tracking technologies. You can change your preferences using the website’s available cookie controls.
For more information, please refer to our Cookie Policy.
10. Automated decision-making and profiling
The service does not make decisions about individuals solely by automated means and does not use personal data for profiling.
If that changes, we will update this policy and, where applicable law requires it, provide information about the processing and the rights available to affected individuals.
11. Children’s privacy
The Virtual Secretary website and service are intended for adults. We do not knowingly collect personal data from individuals under 18 through the service.
If you believe a person under 18 has provided us with personal data, contact [email protected]. We will review the circumstances and take appropriate action in accordance with applicable law.
12. Security of personal data
We take reasonable technical and organisational measures designed to protect personal data against unauthorised access, loss, alteration, disclosure or misuse.
No method of transmitting or storing information is completely secure. We therefore cannot guarantee absolute security, but we will take appropriate steps to protect the information we process.
13. Changes to this Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our business, services, data processing practices or applicable law.
The latest revision date will be shown at the top of this page. Where a change materially affects how we process personal data, we will provide additional notice where required by law.
14. Contact
For questions about this Privacy Policy or our handling of personal data, contact:
OCTATEL HUB - FZCO
Dubai Unified Licence reference: DW7863
DSO-IFZA-51059, Dubai Silicon Oasis, Dubai, United Arab Emirates.
Email: [email protected]
Website: https://virtualsecretary.online/