Privacy Notice
This notice describes how Hitomorrow Assessment Data Classification and Analysis L.L.C ("we", "us") processes personal information collected through two of its public pages: the self-assessment questionnaire (the “Check”) and the eight-lesson introductory course on how the US market works (the “Course”). It supplements, and should be read together with, our Privacy & Cookie Policy.
Effective 23 August 2026
1. Controller
Hitomorrow Assessment Data Classification and Analysis L.L.C, Licence No. 1275729, of Bur Dubai, Burj Khalifa, Dubai, United Arab Emirates, determines the purposes and means of the processing described in this notice and acts as controller in respect of it.
2. Information We Process
We process the following limited categories of personal information:
- the responses you submit to the questionnaire and the summary generated from them, where you use the Check;
- where you use the Course: which lessons you open, how far through each lesson you play, and whether you switch subtitles on or off. This information is recorded by us and is used to operate the Course and to decide which lesson to send you next;
- the single-use identifier contained in the links of the emails we send you, which allows the Course page to recognise you without asking for your address a second time;
- your email address, where you elect to receive the summary by email or where you ask us to send you the lessons of the Course, together with the choices you make by the checkboxes shown next to that field;
- the referring source through which you reached this page, together with standard technical information transmitted by your browser, including device type, browser type and approximate geographic region.
We do not request your name, telephone number, postal address, identification documents or financial information, and no such information is required in order to use this page.
3. Purposes and Legal Bases
Where you provide an email address in order to receive your summary, or in order to receive the lessons of the Course, we process that address for the sole purpose of delivering the material you have requested. The legal basis is the performance of the request you have made to us.
Where you ask us to tell you when further lessons become available, we process your address for that single purpose. The legal basis is your consent.
We record which lessons you open and how far you play them in order to operate the Course, to send you the next lesson at the right time, and to understand which lessons hold attention and which do not. The legal basis is our legitimate interest in delivering and improving material we have undertaken to provide to you. This recording is carried out by us, does not depend upon your cookie choices, and produces no decision having legal effects concerning you.
Where you separately indicate that you wish to receive further communications, we process your address in order to send periodic informational material, updates concerning our organisation and information about products and services we offer. The legal basis is your consent, which is given by an affirmative action and may be withdrawn at any time without affecting the lawfulness of processing carried out before withdrawal.
We additionally process questionnaire responses in aggregated form, from which individual identifiers have been removed, for the purpose of evaluating and improving the questionnaire. The legal basis is our legitimate interest in maintaining the quality of the materials we publish.
No decision producing legal effects concerning you, or similarly significantly affecting you, is taken on the basis of automated processing of your responses.
4. Recipients
Personal information is disclosed only to the following categories of recipient, and only to the extent necessary for the purposes set out above:
- our email service provider, which delivers communications on our instructions and acts as processor under a written agreement;
- Brevo (Sendinblue SAS, France), which delivers our email communications on our instructions and acts as processor under a written agreement;
- Meta Platforms Ireland Limited, which receives information relating to interactions with these pages for the purpose of measuring and delivering our advertising, and only where you have accepted advertising cookies. Where an email address is included, it is transmitted only in irreversibly hashed form;
- Google LLC, which provides the audience measurement used on these pages, and only where you have accepted statistics cookies;
- personnel within our organisation and our group entities who require access in the course of their duties.
We do not sell, licence or otherwise make personal information available to third parties for their own marketing purposes.
5. International Transfers
We operate from the United Arab Emirates and engage service providers established in other jurisdictions. Personal information may accordingly be processed outside the country in which you are resident. Where such transfers occur, we require recipients to afford the information a standard of protection consistent with this notice by means of contractual undertakings.
6. Retention
Where you have consented to further communications, your email address is retained until you withdraw that consent or until eighteen months have elapsed without engagement, whichever occurs first, after which it is deleted.
Records of which lessons you opened are retained for twelve months from your last activity and are then deleted or reduced to a form from which you can no longer be identified. Cookie identifiers set with your agreement are retained for no longer than thirteen months.
Where you have not so consented, your address is retained only for the period necessary to deliver the material requested and is deleted thereafter. Questionnaire responses are retained in aggregated form from which you can no longer be identified.
7. Withdrawal and Objection
Each communication we send includes a link enabling you to unsubscribe. Withdrawal takes effect promptly, requires no explanation and is no more difficult than the giving of consent. Communications relating to services you have separately obtained from us are not affected.
8. Age
These pages are intended for persons aged eighteen years or older. We do not knowingly process the personal information of minors and do not direct advertising to them. Should you become aware that a minor has submitted information to us, please contact us and it will be deleted.
9. Your Rights
Subject to applicable law, you are entitled to request access to the personal information we hold about you, to request its correction or erasure, to withdraw consent where processing is based upon it, and to object to processing carried out for direct marketing purposes. Requests may be made using the contact details below and are answered within thirty days.
Where you consider that a matter has not been resolved satisfactorily, you may raise it with the supervisory authority competent in your place of residence.
10. Cookies
No cookie serving audience measurement or advertising is placed on either page until you make a choice in the banner shown when you first arrive. Declining changes nothing in the material available to you: the questionnaire and all eight lessons work either way. You may change or withdraw your choice at any time using the “Cookie choices” link at the foot of the page. Where your browser transmits a Global Privacy Control signal, advertising cookies are not set and that signal prevails over any earlier choice. Cookies strictly necessary to display the page and to remember your progress through the Course are set without consent, as the law permits.
11. Contact
Hitomorrow Assessment Data Classification and Analysis L.L.C
Bur Dubai, Burj Khalifa, Dubai, United Arab Emirates
privacy@hi2morrow.com
12. Amendments
We may amend this notice from time to time. The effective date appears at the head of this page, and material changes will be brought to the attention of subscribers by email.