PRIVACY POLICY

1. Who We Are

If you have questions about this Privacy Policy or our data practices, please contact us using the details above.

2. Personal Data We Collect

We may collect the following categories of personal data:

a) Information you provide directly

• Identity and contact data (name, email address, telephone number, postal address, company name, job title)
• Account registration data (username, password, profile information)
• Payment and billing information (billing address, payment method details – note: we do not store full credit card numbers where processed by third-party payment providers)
• Communications data (messages, inquiries, feedback, support requests)
• Any other information you choose to provide

b) Information collected automatically

• Technical data (IP address, browser type and version, device type, operating system, unique device identifiers)
• Usage data (pages visited, features used, time spent, clickstream data, referral URLs)
• Location data (approximate location derived from IP address)
• Cookies and similar tracking technologies data (see Section 10)

c) Information from third parties

• Data from business partners, service providers or publicly available sources (where permitted by law)
• Social media or single sign-on providers (if you choose to link accounts)

We do not intentionally collect special categories of personal data (sensitive data) unless necessary and with your explicit consent or as otherwise permitted by law.

3. How We Collect Personal Data

We collect personal data through:

• Direct interactions (when you create an account, fill forms, contact us or use the Services)
• Automated technologies (cookies, server logs, analytics tools)
• Third parties (payment processors, analytics providers, business partners)

4. Purposes and Legal Bases for Processing

We process your personal data for the following purposes and on the following legal bases under the PDPL and applicable law:

• To provide, operate and maintain the Services – Performance of a contract / Legitimate interests
• To create and manage your Account – Performance of a contract
• To process payments and manage subscriptions – Performance of a contract / Legal obligation
• To communicate with you (support, updates, transactional emails) – Performance of a contract / Legitimate interests
• To send marketing communications (where permitted) – Consent / Legitimate interests
• To improve and develop our Services, conduct analytics – Legitimate interests
• To detect, prevent and address fraud, security issues or illegal activity – Legitimate interests / Legal obligation
• To comply with legal obligations – Legal obligation
• To enforce our Terms and Conditions and protect our rights – Legitimate interests

Where we rely on consent, you may withdraw it at any time. Where we rely on legitimate interests, you may object to the processing.

5. Sharing and Disclosure of Personal Data

We may share your personal data with:

• Service providers and processors who assist us in operating the Services (hosting, payment processing, analytics, customer support, email delivery). These parties are contractually required to protect your data and process it only on our instructions.
• Business partners in connection with joint offerings or events (only with your consent where required).
• Professional advisors (lawyers, accountants, auditors) under confidentiality obligations.
• Authorities and regulators when required by law, court order, or to protect our rights, safety or property (including RAK DAO Authority and UAE authorities).
• Successors in the event of a merger, acquisition, reorganization or sale of assets (your data may be transferred as part of the transaction, subject to this Privacy Policy or equivalent protections).

We do not sell your personal data.

6. International Data Transfers

Your personal data may be transferred to and processed in countries outside the United Arab Emirates. Where we transfer personal data outside the UAE, we ensure appropriate safeguards are in place in accordance with the PDPL, such as:

• Adequacy decisions (where available)
• Standard contractual clauses or other approved transfer mechanisms
• Binding corporate rules or other legally recognized safeguards

You may request further information about the safeguards we use by contacting us.

7. Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, including to satisfy legal, accounting or reporting requirements.

Typical retention periods:

• Account data: for the duration of your account plus a reasonable period thereafter
• Transactional and billing records: as required by UAE commercial and tax laws
• Support communications: for a reasonable period after resolution
• Marketing data: until you withdraw consent or unsubscribe

When data is no longer needed, we securely delete or anonymize it.

8. Your Rights

Under the PDPL and applicable law, you have the following rights (subject to certain exceptions and conditions):

• Right of access – request a copy of the personal data we hold about you
• Right to rectification – request correction of inaccurate or incomplete data
• Right to erasure (“right to be forgotten”) – request deletion of your data in certain circumstances
• Right to restriction of processing – request that we limit how we use your data
• Right to data portability – receive your data in a structured, commonly used format
• Right to object – object to processing based on legitimate interests or for direct marketing
• Right to withdraw consent – where processing is based on consent
• Right to lodge a complaint – with the UAE Data Office or other competent authority

To exercise any of these rights, please contact us using the details in Section 1. We may need to verify your identity before responding. We will respond within the timeframes required by applicable law.

9. Data Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure or destruction. These measures include encryption, access controls, secure servers and regular security assessments.

However, no method of transmission or storage is completely secure. We cannot guarantee absolute security.

10. Cookies and Tracking Technologies

We use cookies and similar technologies to:

• Enable essential functionality of the Services
• Analyze usage and improve performance
• Remember your preferences
• Deliver relevant marketing (where permitted)

You can manage cookie preferences through your browser settings or our cookie consent tool (where available). Disabling certain cookies may affect the functionality of the Services.

11. Children’s Privacy

Our Services are not directed to individuals under the age of 18. We do not knowingly collect personal data from children. If we become aware that we have collected personal data from a child without appropriate consent, we will take steps to delete it. If you believe we may have collected data from a child, please contact us.

12. Third-Party Links and Services

Our Services may contain links to third-party websites or integrate with third-party services. This Privacy Policy does not apply to those third parties. We encourage you to review their privacy policies before providing any personal data.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements or other factors. The updated version will be posted on our website with a revised “Last Updated” date.

Where required by law, we will notify you of material changes by email or through a notice on the Services. Your continued use of the Services after the effective date of changes constitutes acceptance of the updated Privacy Policy.

14. Governing Law

This Privacy Policy shall be governed by and construed in accordance with the laws and regulations of the Ras Al Khaimah Digital Assets Oasis Authority, the laws of the Emirate of Ras Al Khaimah and the applicable federal laws of the United Arab Emirates (including the PDPL).

15. Contact Us

If you have any questions, concerns or requests regarding this Privacy Policy or our data practices, please contact: