This Privacy Policy explains how Tiber Lake LLC (“Tiber Lake”, “we”, “us” or “our”) collects, uses, shares and protects personal data when you visit our website, contact us or work with us. We have tried to make it clear and readable; if anything is unclear, please contact us.
1. Who we are
Tiber Lake LLC is an AI solutions company registered in the United Arab Emirates. We design, build and operate AI chat agents, AI voice agents and custom AI software for businesses.
For the personal data described in this policy, Tiber Lake LLC is the controller, meaning the organisation that decides how and why your personal data is used. You can reach us at:
Tiber Lake LLCUnited Arab Emirates
Email: [email protected]
2. Scope of this policy
This policy applies to personal data we process about:
- visitors to our website (the “Site”);
- people who contact us or ask about our services;
- representatives and staff of our clients and prospective clients; and
- our suppliers and partners.
Systems we build for clients. When we build or operate AI systems for a client, those systems may process personal data about the client’s own customers or staff, for example the people who talk to a chat or voice agent. In that case the client is the controller and we act as its processor (or “service provider”). We process that data only on the client’s documented instructions and under a written agreement, and the client’s own privacy notice explains how it is used. If you have a question about how a business uses an agent we built for it, please contact that business first.
3. Personal data we collect
Information you give us
- Identity and contact details: your name, job title, company, email address and phone number.
- Enquiry details: what you tell us through our contact form, by email, by phone, on WhatsApp or in meetings.
- Conversations with our website assistant: the messages you write to the AI assistant on the Site, and any details you give it (see section 6).
- Client and contract information: information we need to scope, deliver and invoice our services, such as billing contacts and payment records.
- Correspondence and feedback: messages, call notes and feedback you share with us.
Information collected automatically
When you visit the Site, our hosting provider automatically receives standard technical information, such as your IP address, browser and device type, the pages you request, the referring page and the date and time of your visit. This is used to deliver the Site and to protect it against abuse.
When you send an enquiry through our contact form or our website assistant, the enquiry also records your IP address and browser, the page you were on, the page that referred you to the Site and any campaign tags (UTM parameters) in the link you followed, so that we know how you found us and can keep the Site secure.
The Site does not use advertising or analytics cookies, and we do not use third-party tracking tools on it. Our fonts and images are served from the Site itself rather than from third-party networks. Our Cookie Policy has the details.
Information from other sources
We may receive business contact details from people who refer you to us, or collect them from publicly available business sources such as company websites and professional networks, where this is relevant to a potential business relationship.
Sensitive information
We do not ask for special categories of personal data (such as health information, religious beliefs or biometric data) through the Site. Please do not include them in messages to us.
4. How we use personal data, and why
We use personal data only where we have a valid reason. Where the EU or UK General Data Protection Regulation (GDPR) applies, our legal bases are shown below.
| Purpose | Data used | Legal basis |
|---|---|---|
| Responding to enquiries and arranging consultations | Contact and enquiry details | Steps taken at your request before a contract; our legitimate interest in responding to business enquiries |
| Answering your questions through our website assistant | Your messages, the page you are on and technical information | Our legitimate interest in answering visitors’ questions about our services |
| Passing on an enquiry or consultation request you send from the assistant | The details you confirm and a transcript of the conversation | Steps taken at your request before a contract; your consent, given when you press Send |
| Providing our services and managing our contract with you | Contact, contract and project information | Performance of a contract |
| Invoicing, accounting and record-keeping | Billing and payment records | Compliance with legal obligations; performance of a contract |
| Operating and securing the Site | Technical information | Our legitimate interest in keeping the Site available and secure |
| Business communications about our services | Contact details | Our legitimate interest in keeping contacts informed, or your consent where required. You can opt out at any time. |
| Improving our services | Correspondence and feedback | Our legitimate interest in improving what we do |
| Complying with the law and protecting our rights | Any of the above, as needed | Compliance with legal obligations; our legitimate interest in establishing, exercising or defending legal claims |
Under the UAE Personal Data Protection Law (Federal Decree-Law No. 45 of 2021), we process personal data with your consent or where another lawful ground applies, for example where processing is necessary to perform a contract with you, to take steps you have asked for before entering into a contract, or to comply with our legal obligations.
We will not use your personal data for a new purpose that is incompatible with these purposes without telling you and, where required, asking for your consent.
5. AI and automated processing
- We do not make decisions about you based solely on automated processing that produce legal effects concerning you or similarly significantly affect you.
- When we use third-party AI services in our own work, for example to help draft or summarise documents, we choose services and settings that do not allow the provider to use that data to train its models wherever that option is available, and we avoid entering personal data unless it is needed.
- We do not use our clients’ data, including conversations handled by systems we build for them, to train AI models for anyone other than that client, and only with the client’s agreement.
6. Our website assistant
The Site offers an AI assistant, the Tiber Lake Assistant. It answers questions about our services, can show you the relevant pages of the Site, and can pass an enquiry or a consultation request to us when you ask it to.
What it processes
- the messages you write to it and its replies;
- the page of the Site you are on when you write, and, if you send an enquiry, the page that referred you to the Site and any campaign tags in the link you followed;
- any details you choose to give it, such as your name, company, email address or phone number; and
- technical information, such as your browser, device type and IP address. The conversation record holds your IP address only as a one-way, salted code, used to limit abuse; an enquiry you send records it in full, like any other enquiry.
How its replies are produced
Replies are generated by the Kimi K3 language model, developed by Moonshot AI, which we use through Ollama’s cloud service (Ollama Cloud). To produce each reply, your recent messages, the conversation so far and our instructions to the model are sent to Ollama, which processes them on its own cloud infrastructure. That infrastructure may be outside the United Arab Emirates, for example in the United States (see section 9). Ollama acts as our service provider.
We do not use your conversations with the assistant to train AI models, and where a provider offers the choice, we use settings that keep our data out of the training of its models.
When you send an enquiry
The assistant never sends anything to us on its own. When you ask it to pass on an enquiry or arrange a consultation, it first shows you the details it has prepared, and they reach us only when you press Send. Your details and a transcript of the conversation are then recorded in our customer relationship management system, so that Majd can reply with the full context, and they are handled like any other enquiry under this policy.
How long conversations are kept
Conversations are kept on our servers for 90 days after your last message and then deleted. If you send an enquiry from a conversation, we keep that conversation for one year after your last message. The enquiry and its transcript are kept as described in section 10.
On your device
Your browser keeps a random code in its local storage so that the conversation continues as you move between pages, and starting a new chat removes it. Our Cookie Policy lists everything the Site stores on your device.
Please take care
The assistant can make mistakes. Its replies are general information, not advice, and anything that matters, such as scope, fees and timelines, is confirmed by us in writing. Please do not share sensitive personal data, such as health or financial details, identity documents or passwords, with it.
7. The live demonstration
The Site offers a live demonstration, in which you message an AI agent acting for a fictional business, such as a restaurant or an insurer. The businesses, products and prices are invented, and no real order, booking or payment is made.
What it processes
- the messages you write and the agent’s replies, and the scenario you choose;
- any images or PDF files you upload to the chat; and
- technical information, such as your browser and device type. Your IP address is held only as a one-way, salted code, used to limit abuse.
How its replies are produced
Replies come from the same model and provider as our website assistant (see section 6): the Kimi K3 model, used through Ollama Cloud. To produce each reply, the conversation, the images you upload and the text read from PDF files you upload are sent to Ollama, which processes them on its own cloud infrastructure, possibly outside the United Arab Emirates (see section 9). We do not use demonstration chats to train AI models.
When you share your details
Nothing you write in the demonstration reaches us unless you choose to. If you share your details on the confirmation card in the chat and press Send, your name, contact details, the scenario you tried and a transcript of the chat are recorded in our customer relationship management system, and handled like any other enquiry under this policy.
How long it is kept
Demonstration chats are deleted 24 hours after the last message, and uploaded files 24 hours after they are uploaded.
On your device
Your browser keeps a code in its local storage so that the chat survives a page reload, along with your choice to show or hide the agent’s reasoning. Our Cookie Policy lists it.
Please take care
Please use the sample documents offered in the demonstration rather than your own, and do not upload identity documents or other sensitive personal data.
8. How we share personal data
We share personal data only where necessary, with:
- Service providers who help us run our business, such as website hosting, email and productivity tools, cloud infrastructure, AI model providers (including Ollama, which runs the model behind our website assistant and the live demonstration), telephony and messaging providers, and accounting and payment services. They may use the data only to provide their services to us and must keep it secure.
- Professional advisers such as lawyers, accountants and auditors, who are bound by duties of confidentiality.
- Authorities, regulators and courts where the law requires it, or where necessary to protect our rights, property or safety, or those of others.
- A buyer or successor if all or part of our business is reorganised, sold or transferred, in which case this policy will continue to protect your data.
- Anyone else with your consent or at your direction.
We do not sell personal data, and we do not share it for cross-context behavioural advertising.
WhatsApp. If you contact us on WhatsApp, your messages are also processed by WhatsApp (part of Meta) under its own terms and privacy policy.
9. International transfers
We are based in the United Arab Emirates, and some of our service providers process data in other countries, including in the European Union and the United States. When personal data is transferred across borders, we take the steps that applicable law requires to protect it, for example by relying on adequacy decisions, standard contractual clauses, or the other safeguards and conditions permitted under the UAE Personal Data Protection Law, the EU GDPR and the UK GDPR.
Conversations with our website assistant and the live demonstration, including files uploaded to the demonstration, are processed by Ollama on its cloud infrastructure, which may be outside the United Arab Emirates, for example in the United States.
10. How long we keep personal data
We keep personal data only for as long as we need it for the purposes described above:
- Enquiries that do not lead to a business relationship: up to 24 months after our last contact.
- Client, contract and invoicing records: for the duration of the relationship, and afterwards for as long as applicable commercial, accounting and tax laws require (typically up to seven years).
- Website assistant conversations: 90 days after your last message, or one year after it if you send an enquiry from the conversation.
- Live demonstration chats and uploads: 24 hours after the last message or upload.
- Technical logs: for the limited period needed to operate and secure the Site.
When personal data is no longer needed, we delete or anonymise it.
11. How we protect personal data
We use appropriate technical and organisational measures to protect personal data, including encryption in transit, access controls based on least privilege, multi-factor authentication on our business accounts and careful selection of service providers. No method of transmission or storage is completely secure, but we work hard to protect your data, and we will notify you and the relevant authorities of a personal data breach where the law requires.
12. Your rights
Depending on where you live, you may have the right to:
- access the personal data we hold about you and receive a copy of it;
- have inaccurate or incomplete data corrected;
- have your data deleted;
- restrict or object to certain processing, including direct marketing;
- receive your data in a portable format;
- withdraw your consent at any time, where we rely on consent (this does not affect processing that took place before you withdrew it);
- not be subject to decisions based solely on automated processing that significantly affect you; and
- complain to a data protection authority: in the UAE, the UAE Data Office; in the EU, your local supervisory authority; in the UK, the Information Commissioner’s Office.
To exercise any of these rights, email [email protected]. We may need to verify your identity before acting on your request. We will respond within the time required by applicable law (for example, within one month under the GDPR) and will not charge a fee unless the law allows it.
California residents
To the extent the California Consumer Privacy Act, as amended by the California Privacy Rights Act, applies to us, you have the right to know about, access, correct and delete your personal information, and not to be discriminated against for exercising these rights. We do not sell or share personal information as those terms are defined in that law, and we do not use sensitive personal information for purposes that would require us to offer a right to limit its use.
13. Children
Our services are intended for businesses. The Site is not directed at children under 18, and we do not knowingly collect their personal data. If you believe a child has given us personal data, please contact us and we will delete it.
14. Links to other websites
The Site links to other websites and services, such as WhatsApp. We are not responsible for their privacy practices, and we encourage you to read their privacy policies.
15. Changes to this policy
We may update this policy from time to time. The “Last updated” date at the top of this page shows when it last changed. If we make significant changes, we will take reasonable steps to let you know.
16. Contact us
For questions, requests or concerns about privacy, email [email protected]. We aim to respond to every privacy request promptly.