PrivacyPolicy

We, at PROVENTUM LABS - FZCO, a company established and existing under the laws of the United Arab Emirates, are dedicated to serving our customers and contacts to the best of our abilities. Our primary goals in processing personal data include:

• • Enhancing the user experience on our platform by understanding customer needs and preferences
• • Providing timely support and responding to inquiries or service requests
• • Improving our products and services to meet the evolving demands of our users
• • Conducting necessary business operations, such as billing and account management

We adhere to all relevant regulations and guidelines to ensure that the data we handle is protected against unauthorized access, disclosure, alteration, and destruction. We do not have a designated Data Protection Officer (DPO) but remain fully committed to addressing your privacy concerns. Should you have any questions or require further information about how we manage personal data, please contact us at welcome@proventumlabs.com.

Your privacy is our priority. This commitment extends to our collaboration with third-party services that may process personal data on our behalf, such as in the case of sending invoices. All activities are conducted in strict compliance with applicable privacy laws.

Our privacy policy is designed to protect the personal data of all our stakeholders, including website visitors, registered users, and customers. Whether you are just browsing our website proventumlabs.com, using our services as a registered user, or engaging with us as a valued customer, we ensure that your personal data is processed with the highest standards of privacy and security. This policy outlines our practices and your rights related to personal data.

We gather personal data through various interactions, including but not limited to, when you utilize our services or products such as Software Engineering and Development, or directly provide information to us. The following list details the types of personal data we may process:

• • First and last name
• • Date of birth
• • National ID numbers (e.g., social security number, passport ID)
• • Email address and/or Phone number
• • Address and city
• • Real-time location
• • IP-based approximate location
• • Device ID
• • IP address
• • Browser information and language
• • Operating system and version
• • Browser fingerprint
• • Payment information (method, history, details)
• • Purchase history
• • Browsing history
• • Interaction logs (e.g., clicks, time spent on pages)

We only process information that is essential for delivering our services, complying with legal obligations, or enhancing your user experience.

The data we collect serves multiple purposes, all aimed at enhancing the services we offer and ensuring the highest level of satisfaction among our users, customers, and employees. The key ways in which we use the personal data collected are:

• • Authentication and security
• • Customizing and adapting user experience
• • Content delivery
• • Communication efforts
• • Analytics and performance tracking
• • Marketing and advertising
• • Providing access to exclusive content
• • Compliance with legal obligations
• • Research and development
• • Customer support
• • Fraud prevention and risk management
• • User engagement and retention
• • User feedback and satisfaction
• • Tag management

We process your personal data transparently and in accordance with your preferences and applicable privacy laws. We are committed to ensuring that your data is used solely for the purposes for which it was collected and in ways that you have authorized.

Data storage

Personal data is stored in secure servers located in the following locations: United Arab Emirates, Federal Republic of Germany. For services that require international data transfer, we ensure that such transfers comply with all applicable laws and maintain data protection standards equivalent to those in our primary location.

Data hosting partners: We partner with reputable data hosting providers committed to using state-of-the-art security measures. These partners are selected based on their adherence to stringent data protection standards.

Data protection measures

• • Encryption: To protect data during transfer and at rest, we employ robust encryption technologies.
• • Access control: Access to personal data is strictly limited to authorized personnel who have a legitimate business need. We enforce strict access controls and regularly review permissions.
• • Security audits and monitoring: Regular security audits are conducted to identify and remediate potential vulnerabilities. We also monitor our systems for unusual activities to prevent unauthorized access.

We are committed to safeguarding your personal data and ensuring it is treated with the utmost respect. This commitment extends to how we handle the sharing and disclosure of your data.

Sharing personal data

We may share your information with third-party service providers who perform services on our behalf. Such trusted parties may have access to personally identifiable information on a need-to-know basis and will be contractually obliged to keep your information confidential. These partners are prohibited from using your personal data for any purpose other than to provide these services to PROVENTUM LABS - FZCO.

When we share your data with third-party service providers, we do so, when and if required, under the protection of Data Processing Agreements (DPAs) that ensure your information is managed in accordance with the Federal Decree by Law No. (45) of 2021 'Concerning the Protection of Personal Data' (the PDPL), and other relevant data protection laws (when and if applicable). These agreements, when and if required, mandate that third parties implement adequate technical and organizational measures to ensure the security of your data.

Transparency and control

We believe in transparency and providing you with control over your personal data. You will always be informed about any significant changes to our sharing practices, and where applicable, you will have the option to consent to such changes. For any queries or concerns about how we share and disclose personal data, please reach out to us at welcome@proventumlabs.com.

We recognize and respect your rights regarding your personal data, in accordance with the PDPL and other applicable data protection laws (when and if applicable). In plain terms, here is what you can ask us to do with your data — and how to do it.

Your rights under the PDPL

Exercising your rights

To exercise any of these rights, please contact us at welcome@proventumlabs.com. We will respond to your request in accordance with applicable data protection laws and within the timeframes stipulated by those laws. Please note, in some cases, we may need to verify your identity as part of the process to ensure the security of your personal data.

We value your privacy and are committed to being transparent about our use of cookies and other tracking technologies on our website proventumlabs.com. These technologies play a crucial role in ensuring the smooth operation of our digital platforms, enhancing your user experience, and providing insights that help us improve.

Understanding cookies and tracking technologies

Cookies are small data files placed on your device that enable us to remember your preferences and collect information about your website usage. Tracking technologies, such as web beacons and pixel tags, help us understand how you interact with our site and which pages you visit.

How we use these technologies

• • Essential cookies: Necessary for the website’s functionality, such as authentication and security. They do not require consent.
• • Performance and analytics cookies: These collect information about how visitors use our website, which pages are visited most frequently, and if error messages are received. These cookies help us improve our website.
• • Functional cookies: Enable the website to provide enhanced functionality and personalization, like remembering your preferences.
• • Advertising and targeting cookies: Used to deliver advertisements more relevant to you and your interests, limit the number of times you see an advertisement, and help measure the effectiveness of advertising campaigns.

Your choices and consent

Upon your first visit, our website will present you with a cookie consent banner, where you can:

• • Accept all cookies: Consent to the use of all cookies and tracking technologies.
• • Reject non-essential cookies: Only essential cookies will be used to provide you with necessary website functions.
• • Customize your preferences: Choose which categories of cookies you wish to allow.

Changes to our cookie use

We may update our use of cookies and tracking technologies to improve our services or comply with legal requirements. We will seek your consent where necessary. Should you have any questions or concerns about our use of cookies and tracking technologies, please do not hesitate to contact us at welcome@proventumlabs.com.

We may transfer your personal data to locations outside of your country of residence, including to countries that may have different data protection laws than those in your jurisdiction. Any such transfers are conducted with the utmost care and in compliance with applicable data protection regulations, including the PDPL.

Jurisdictions with proper level of protection (adequate jurisdictions)

A jurisdiction will be considered 'adequate' in one or both of the following cases: (1) the state or province to which the personal data is transferred has legislation addressing personal data protection, including significant provisions, measures, controls and rules related to the protection of privacy and confidentiality, along with a judicial or regulatory authority imposing appropriate measures against the controller or processor; and / or (2) if the UAE joins a bilateral or multilateral agreement related to the protection of personal data concluded with countries to which the personal data is transferred. Generally, we conduct cross-border transfers to jurisdictions that are adequate. When and if the UAE Data Bureau or another competent mainland UAE authority publishes a list of jurisdictions recognised as adequate, we shall adhere to it.

Jurisdictions without proper level of protection (non-adequate jurisdictions)

Ordinarily we do not conduct transfers to jurisdictions that are non-adequate, however, where due to business, regulatory or operational necessity we may need to conduct such cross-border transfers. In such case we will rely on (1) the relevant contractual provisions in the contracts entered between us and our counterparties (Art. 23(1) of the PDPL), (2) your explicit consent (if available, Art. 23(1)(b) of the PDPL), and/or (3) the provisions of the PDPL. When and if we rely on contractual provisions, such clauses are usually based on representations made by the counterparty and may be inspired by the EU SCCs; however, such clauses may deviate from the EU SCCs in accordance with the specifics of the PDPL and best practices.

According to the PDPL your personal data may be transferred to non-adequate jurisdictions in the following cases even without contractual provisions or your explicit consent (Art. 23(1) of the PDPL):

• • if the transfer is necessary to fulfil obligations and establish rights before judicial entities, exercise or defend the same;
• • if the transfer is necessary to sign or implement a contract made between you and us, or between us and third parties to serve your interests;
• • if the transfer is necessary to implement an action related to international judicial cooperation; and / or
• • if the transfer is necessary to protect the public interest.

We will process your personal data only for the period required by law or for the period necessary to achieve the purposes of the processing specified above. In our view it is impossible to determine an explicit data retention period. The exact period we will process your personal data will be determined by a range of factors:

• • the nature of the personal data;
• • the circumstances in which the personal data was obtained;
• • the nature of the services the personal data relates to;
• • the nature of rights and obligations we or you may seek to enforce or defend;
• • our data retention obligations under applicable laws and regulations; and
• • our legitimate interest in operating our business in the most professional way.

Further information about our retention periods is available on request.

At the time we become aware of any breach or violation of your personal data that could prejudice the privacy, confidentiality, or security of such data, we shall notify the UAE Data Bureau of the breach or violation and provide it with all necessary details, including those required by law.

Kindly note that the period for such notifications is to be set out in the Executive Regulations of the PDPL. In the absence of such Executive Regulations, we shall make such notifications within as short a period as is reasonably possible. If you have any questions about this Privacy and Cookies Policy, please contact us at welcome@proventumlabs.com.