Privacy Notice
1. Introduction
Aramco Digital ("we," "us," or "our") is a Saudi joint stock company established in the Kingdom of Saudi Arabia with fully paid capital of SAR XXXXXXX registered in the city of Dhahran, under commercial registration no. E K J B 3128.
Aramco Digital is committed to protecting the privacy and personal data of all individuals who visit and interact with our website at https://www.aramcodigital.com (the "Website").
Aramco Digital is part of the Saudi Aramco Group of companies (Saudi Aramco Group). The Website may include links to other websites of Aramco Group businesses, products and services, each of which may have their own privacy notices. When visiting any other websites, please review and familiarize yourself with their relevant privacy notices
This Privacy Notice explains:
- Who we are;
- What personal data we collect and why;
- The legal basis of our processing activities;
- How we use, store, and protect your data;
- With whom we share it and under what safeguards;
- How long we retain it; and
- Your rights under applicable law and how to exercise them.
This notice applies to all website visitors, prospective clients, existing customers, and any other individual whose data is processed through the Website, regardless of their country of residence. By using our Website, you acknowledge that you have read and understood this Privacy Notice.
This Privacy Notice has been drafted to comply with applicable data protection laws, in particular the Kingdom of Saudi Arabia Personal Data Protection Law (KSA PDPL), issued by Royal Decree No. M/19 (2021) effective as of 14 September 2023, its Implementing Regulation as they are amended from time to time.
2. Who We Are / Data Controller
The entity responsible for the collection and processing of your personal data through this Website is:
| Company Name | Aramco Digital |
|---|---|
| Registered Address | E K J B 3128 |
| Licence / CR No. | 2052103711 |
| KSA Establishment | Global Integrated Digital Solutions Company (One - Person Company) |
| Data Protection Officer | Zeyad A. Alarfaj |
| Privacy Contact | Jay Kesari |
| Phone | 0138767799 |
Aramco Digital is the "Data Controller" as defined under the KSA PDPL.
If you have any questions about how we handle your personal data, please contact us via the channels listed in Section 14 "Contact Us", below.
3. Personal Data We Collect
We collect personal data in the following categories, depending on how you interact with our website. The term "Personal Data" means any data that can lead to identifying an individual directly or indirectly in conjunction with other information.
3.1 Data You Provide Directly
- Demographic, Personal and Contact information: full name, email address, mobile and phone number, company name, job title, nationality, date of birth, countries of birth, citizenship and/or residence.
- Enquiry and correspondence data: messages submitted via contact forms, chat tools, survey feedback or email
- Account / registration data (if applicable): username, password, and profile information
- Employment, background and career information: Education and employment history, work experience, general background information.
- Transaction and billing data: name, address, payment details – processed securely via PCI-DSS compliant third-party processors; we do not store full card numbers
- Marketing and communications data, including data and analysis about your interactions or engagement with content or marketing campaigns (including on third party sites), preferences in receiving marketing from us (and our third-party partners), and your communication preferences;
3.2 Data Collected Automatically
- Device and technical data: IP address, browser type and version, operating system, device type, and identifiers
- Usage data: pages visited, links clicked, time spent on pages, referral URLs, search terms
- Cookie and tracking data: see Section 6 for our full Cookie Policy
- Log data: server access logs, error logs, security event logs
3.3 Data from Third Parties
- Analytics providers (e.g., Google Analytics): aggregated usage and behaviour data
- Advertising platforms (e.g., Google Ads, LinkedIn Insight Tag, Meta Pixel): ad interaction data
- Publicly available information: We may collect Personal Data about you from publicly and commercially available sources (as permitted by law and the terms of use applicable to the source).
- Social media platforms and combining Personal Data: We may combine your Personal Data with other Personal Data we collect about you, including when you visit and use our Site. This may include (but is not limited to) Social Media websites where you publicly share information about yourself, such as those operated by Meta, Linked-in, or X (previously Twitter), as well as information from job sites or from other third-party sources. For additional information on our further use of Social Media sites.
- Business partners and referral sources: contact details shared with your prior consent
3.4 Sensitive / Special Categories of Data
We do not intentionally collect Sensitive Personal Data through this website. Please do not submit such information as set out below through this Website. If you do inadvertently provide sensitive data, we will delete it promptly. The KSA PDPL defines Sensitive Personal Data as health data, genetic or biometric data, and data relating to criminal records, ethnic origin, intellectual, political, or religious beliefs, or if either of a person's parentage is unknown.
4. How and Why, We Use Your Personal Data
We process personal data only where a lawful basis exists under applicable law. The table below outlines our processing purposes and the corresponding legal basis under the KSA PDPL.
| Purpose of Processing | Personal Data Used | KSA PDPL Legal Basis |
|---|---|---|
| Respond to enquiries and contact forms | Name, email, phone, message content | Legitimate interest; compliance with legal obligation; Necessary for contract |
| Evaluation and entering into a partnership, supplier, customer or other business relationship | Demographic, personal and contact information; Employment, background and career information; Transaction and billing data. | Legitimate interest; compliance with legal obligations. |
| Business execution, Provide products or services | Contact, transaction and billing data, account data | Implementation of a Contract |
| Process and manage payments | Billing and account data, payment data | Implementation of a Contract / Compliance with legal obligation |
| Website analytics and optimization | IP address, usage data, cookies | Consent |
| Targeted advertising and remarketing | Cookie data, device identifiers | Consent |
| Send marketing communications | Name, email, preferences | Consent |
| Comply with legal obligations | All relevant data | Compliance with legal obligation |
| Fraud prevention and security | All relevant data | Legitimate interest |
| Internal analytics and reporting | Aggregated / anonymized data | Legitimate interest |
| Improve Website and User experience | Usage data, feedback | Consent |
| Recruitment, vetting a candidate and processing a job application including background checking. | All personal data provided directly and obtained from third parties as relevant. | Legitimate interest. |
KSA PDPL Note: Under Saudi law, consent for marketing must be express and unambiguous. Residents of Saudi Arabia may withdraw consent at any time and we will cease processing for that purpose within 30 days.
Where we rely on "legitimate interests" as our legal basis, we have carried out a documented balancing test confirming that our interests do not override your fundamental rights and freedoms. You have the right to object to such processing (see Section 9).
5. Who We Share Your Data With
We do not sell, rent, or trade your personal data. We may share your data with trusted third parties only where necessary and under appropriate safeguards:
5.1 Service Providers (Data Processors / Sub-processors)
- IT and cloud hosting providers: to host our Website and store data securely
- Analytics platforms: Google Analytics, Hotjar, or similar services
- Email marketing platforms: Mailchimp, HubSpot, or similar
- Customer Relationship Management (CRM) systems
- Payment processors: Stripe, PayPal, or similar (PCI-DSS compliant)
- Cybersecurity and fraud-prevention providers
- Customer support platforms and chatbot providers
- To support our business with the general business processing, information technology, and system administration services provided to us; or
5.2 Professional Advisors
Lawyers, auditors, and accountants bound by professional and contractual confidentiality obligations, our bankers, advisors or consultants, where required, or appropriate for the management or support of our business, or to apply or enforce any agreements we have with you.
5.3 Legal and Regulatory Authorities
Where we or another Aramco Group entity have a duty or public interest to disclose information to Government bodies, law enforcement agencies, courts, or regulators in, KSA, or other applicable jurisdictions where we are required or permitted by applicable local law to disclose your data – including to the Saudi National Data Management Office (NDMO).
5.4 Business Transfers
In the event of an actual or proposed merger, divestment, acquisition, restructuring, or sale of some or all of our assets, stock to any successor your data may be transferred to the relevant third party, subject to appropriate data protection agreements and notification where required; or in connection with bankruptcy proceedings.
5.5 With your permission
Where we asked for your permission to share your Personal Data for a specific purpose, and you agreed. For example, in conjunction with marketing (set out further below) including with third parties who support those activities.
5.6 International Data Transfers
Some of our service providers operate outside the, KSA, and the EEA. Where personal data is transferred internationally, we implement appropriate safeguards:
- Standard Contractual Clauses (SCCs) approved by the relevant authority;
- Transfers to countries with an adequate level of protection as recognized by the, National Data Management Office, or European Commission;
- Binding corporate rules or other approved transfer mechanisms; or
- Your explicit consent where required by applicable law.
6. Cookies and Similar Technologies
Our Website uses cookies and similar tracking technologies (e.g., web beacons, pixels, local storage objects) to enhance functionality, analyze performance, and deliver relevant advertising. All non-essential cookies are deployed only with your prior consent.
6.1 What Are Cookies?
Cookies are small text files stored on your device when you visit a website. They enable the website to recognize your device, retain preferences, and gather usage data.
6.2 Cookies We Use
| Cookie Type | Purpose | Examples | Duration | Legal Basis |
|---|---|---|---|---|
| Strictly Necessary | Essential for the Website to function correctly (session management, security, load balancing) | Session ID, CSRF tokens | Session | Not required – necessary for service |
| Functional / Preference | Remember your settings such as language, region, and login state | Language cookie, Region pref | Up to 12 months | Consent |
| Analytics & Performance | Understand how visitors use the Website to improve performance and content | Google Analytics, Hotjar | Up to 24 months | Consent |
| Advertising & Marketing | Deliver targeted advertising and measure campaign effectiveness | Google Ads, Meta Pixel, LinkedIn | Up to 13 months | Consent |
| Social Media | Enable content sharing to social platforms and track social interactions | Facebook, Twitter, LinkedIn plugins | Session / Persistent | Consent |
6.3 Managing Your Cookie Preferences
Upon your first visit to our Website, a Cookie Consent Banner will appear. You may accept all cookies, reject non-essential cookies, or customize your preferences by category. You can update your preferences at any time by:
- Clicking the "Cookie Settings" link in the footer of our Website;
- Adjusting your browser settings to block or delete cookies; or
- Using third-party opt-out tools (e.g., Google Analytics Opt-out, NAI opt-out, YourAdChoices).
Blocking certain cookies may affect the functionality and user experience of our Website.
7. Data Retention
We retain personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law. Retention periods are set with reference to the business processes and legal obligations they support.
| Data Category | Retention Period | Legal / Regulatory Basis |
|---|---|---|
| Contact form / enquiry data | 3 years from last contact | Legitimate interests based on our business needs. |
| Customer / contract data | 10 years from contract end (KSA) | KSA Companies Law |
| Financial / transaction records | 10 years (KSA VAT) | KSA VAT Law |
| Marketing and consent records | Until consent withdrawn or 3 years from last engagement | Consent / Legitimate interests |
| Website analytics data | 26 months | Legitimate interests based on our business needs. |
| Cookie consent records | 3 years | Legal obligation (evidence of consent) |
| Security / server and access logs | 12 months | Legitimate interests / Cybersecurity regulations |
| Data subject request records | 3 years from request closure | Legal obligation |
Upon expiry of the applicable retention period, personal data will be securely deleted, anonymized, or pseudonymized in accordance with our Data Retention and Disposal Policy.
8. How We Protect Your Data
We implement appropriate technical and organizational security measures proportionate to the risk of processing, to protect your personal data against unauthorized access, loss, alteration, disclosure, or destruction. Our measures include but are not limited to:
- TLS/SSL encryption for all data transmitted between your browser and our Website;
- Access controls, role-based permissions, and multi-factor authentication for staff accessing personal data;
- Regular security assessments, vulnerability scanning, and penetration testing;
- Secure, encrypted storage on certified cloud infrastructure in compliant data centres;
- Data minimization and pseudonymization where technically feasible;
- Staff training on data protection, information security, and phishing awareness;
- Incident response procedures, including escalation protocols and data breach notification.
9. Your Rights
Depending on your country of residence and applicable data protection law, you may hold some or all of the following rights regarding your personal data. We honour these rights regardless of your location:
| Right | Description | Applicable Law | How to Exercise |
|---|---|---|---|
| Right of Access | Obtain a copy of the personal data we hold about you and information about our processing activities. | KSA PDPL | Submit a DSAR to email TBC |
| Right to Correction | Request correction of inaccurate or incomplete personal data held about you. | KSA PDPL | Contact email TBC |
| Right to request destruction of Personal Data | Request deletion of your personal data where there is no compelling reason to continue processing. | KSA PDPL | Contact email TBC |
| Right to Restriction | Request that we restrict processing of your data while we confirm its accuracy as per the KSA PDPL. | KSA PDPL | Contact email TBC |
| Right to Data Portability | Receive your data in a structured, machine-readable format (where processing is consent- or contract-based). | KSA PDPL | Contact email TBC |
| Right to Withdraw Consent | Withdraw consent at any time, without affecting the lawfulness of prior processing. | KSA PDP | Cookie Settings or contact us |
| Right to Lodge a Complaint | File a complaint with the relevant supervisory authority. | KSA PDPL | See Section 11 |
We will respond to all valid requests within 30 days. In complex or high-volume cases, this may extend to 60 days (GDPR) or as permissible under the KSA PDPL. We will notify you of any extension. No fee will be charged unless requests are manifestly unfounded or excessive.
10. Children's Privacy
Our Website is not directed to children under the age of 18. We do not knowingly collect personal data from minors.
If you are a parent or legal guardian and believe your child has provided us with personal data without your consent, please contact us immediately at email TBC. We will take prompt steps to verify and delete such data.
11. Supervisory Authorities
You have the right to lodge a complaint with the relevant data protection supervisory authority in your jurisdiction:
| Jurisdiction | Authority | Contact Details |
|---|---|---|
| KSA | National Data Management Office (NDMO) | www.ndmo.gov.sa | pdpo@ndmo.gov.sa |
| EU | Relevant national Data Protection Authority (DPA) | www.edpb.europa.eu (to find your local supervisory authority) |
| Global | Contact our DPO as a first step | privacy@company.com |
We encourage you to contact us first at privacy@company.com so that we may address your concern directly and promptly. This does not limit your right to contact the supervisory authority directly at any time.
12. Third-Party Links
Our Website may contain hyperlinks to third-party websites, plug-ins, and applications. Clicking those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and bear no responsibility for their privacy practices. We encourage you to review the privacy notice of every website you visit.
13. Changes to This Privacy Notice
We may update this Privacy Notice periodically to reflect changes in applicable law, regulatory guidance, or our data processing practices. The updated version will display a revised "Last Reviewed" date at the top and will take effect immediately upon publication on our Website.
We will notify you of material changes by posting a prominent notice on our Website and, where feasible and appropriate, by email. We encourage you to review this Privacy Notice regularly.
14. Contact Us
For any questions, concerns, or requests regarding this Privacy Notice, please contact us:
| Privacy Notice | Jay Kesaria |
|---|---|
| Jay.Kesaria@aramcodigital.com | |
| Phone | +966 55 045 6401 |
| KSA Address | 7244 King Saud Road, Al Turki Business Park |
| Online Form | See contact us page |
This document is for informational purposes only and does not constitute legal advice. Consult a qualified legal professional for advice specific to your organization and jurisdiction.