Privacy Policy

PRIVACY & DATA PROTECTION NOTICE — UAE (PDPL) COMPLIANT

Effective date: 02/09/2026

  1. Scope and application
  • This Notice applies to Elev8 Collective FZ-LLC trading as Veaudry UAE (“we”, “us”, “Organisation”) and describes how we collect, use, store, disclose and otherwise process personal data of: (a) consumers (customers, visitors, prospects) and (b) employees and job applicants in the United Arab Emirates (UAE).
  • This Notice implements requirements of the UAE Federal Decree‑Law No. 45 of 2021 on the Protection of Personal Data (PDPL) and applicable implementing regulations.
  1. Definitions
  • “Personal data” / “Personal information” means any information relating to an identified or identifiable natural person.
  • “Processing” means any operation or set of operations performed on personal data.
  • “Special categories of personal data” means data revealing race, religion, health, biometric data, criminal convictions and similar sensitive attributes as defined by PDPL.
  1. Personal data we process Depending on the relationship and purpose, we may process:
  • Identity and contact data: name, date of birth, national ID / passport number, nationality, gender, email, postal and physical address, telephone numbers, language preference.
  • Employment data: CV, education, employment history, references, professional qualifications, payroll and bank details, performance and disciplinary records, visa/immigration details.
  • Transactional and commercial data: purchase history, billing / payment information, order details, returns.
  • Technical and use data: IP address, device identifiers, browser and cookie data, log files, online activity on our website or apps.
  • Special categories (only where necessary and lawful): health information (e.g., for medical leave), criminal conviction data (where required by law or for background checks), or biometric data (only if explicitly required and lawful). We will obtain explicit consent for special categories unless another lawful ground under PDPL applies.
  1. Lawful bases for processing We will process personal data only where at least one PDPL lawful basis applies, including:
  • Consent (freely given, specific, informed and revocable);
  • Performance of a contract or steps to enter into a contract;
  • Compliance with a legal obligation;
  • Protection of vital interests;
  • Exercising or defending legal claims;
  • Legitimate interests of the Organisation where those interests do not override the rights of the data subject (we will document and assess such interests).
  1. Purposes of processing We process personal data for purposes including:
  • Provision, management and improvement of products and services, customer support and order fulfilment;
  • Employment administration, payroll, benefits, training, performance management and workplace health & safety;
  • Compliance with legal, regulatory, tax, immigration and audit obligations;
  • Fraud prevention, risk management, and security;
  • Marketing and promotions (where permitted and subject to marketing preferences and opt-outs);
  • Analytics, business reporting and service improvement;
  • Responding to enquiries, complaints and legal requests.
  1. Data minimisation and accuracy We collect only personal data necessary for the stated purposes and take reasonable steps to keep it accurate, complete and up to date. Data subjects should inform us of any changes.
  2. Retention We retain personal data only as long as necessary for the purpose for which it was collected, to satisfy legal, regulatory, tax or accounting obligations, or as otherwise permitted by PDPL. Retention periods are documented in our records-retention schedule. When no longer needed, personal data is securely deleted or rendered irreversible.
  3. Cross-border transfers
  • Our operations are UAE-based. We do not export personal data outside the UAE except where required for legitimate operational reasons and only in compliance with PDPL. Where transfers are necessary, we will ensure an adequate level of protection (e.g., transfers to countries with an adequacy decision, appropriate contractual safeguards, or explicit consent), and document the lawful basis for each transfer.
  1. Data security We implement appropriate organisational, technical and physical measures to protect personal data against unauthorised access, disclosure, loss, alteration or destruction. Security measures are reviewed regularly. Where processors (service providers) process data on our behalf, we require written contracts imposing PDPL-compliant obligations (security, confidentiality, purpose limitation, return/deletion).
  2. Data subject rights Under PDPL you have rights including:
  • Right to access: confirm if we process your personal data and obtain a copy;
  • Right to rectification: correct inaccurate or incomplete data;
  • Right to erasure (right to be forgotten) where PDPL permits;
  • Right to restriction/objection: restrict or object to certain processing, including profiling and direct marketing;
  • Right to withdraw consent at any time (withdrawal does not affect prior lawful processing);
  • Right to data portability where applicable.
    To exercise rights, contact our Data Protection Officer (DPO) using the details below. We will respond within the timeframes required by PDPL and may require identity verification. Where requests are manifestly unfounded or excessive, we may charge a reasonable fee or refuse as permitted by PDPL.
  1. Children We do not knowingly collect personal data of children except with verifiable parental or guardian consent as required by PDPL. If we learn we have collected a child’s personal data without consent, we will take steps to delete it.
  2. Special category data Processing of special category personal data requires explicit consent or another PDPL-permitted legal basis. We will obtain explicit consent when required and limit processing to what is necessary.
  3. Cookies and tracking technologies We use cookies and similar technologies to provide functionality, analyze site usage and improve our services. Non-essential cookies require consent. You may manage cookie preferences via our cookie tool or your browser settings; disabling cookies may affect site functionality.
  4. Direct marketing We may contact you with product or service offers where we have a lawful basis (consent or legitimate interest). You may object or unsubscribe at any time using the unsubscribe link or by contacting the DPO. We will honor opt-outs promptly.
  5. Data breach notification If a security incident causes unlawful or unauthorised access to personal data that creates a risk to data subjects’ rights and freedoms, we will follow PDPL requirements for notification: notify the competent UAE authority and affected data subjects without undue delay, unless notification is not required under PDPL.
  6. Processors and third-party disclosures We may share personal data with third parties (processors, service providers, affiliates, regulators) only for legitimate purposes and subject to PDPL-compliant contracts and safeguards. We do not sell personal data.
  7. Accountability, governance and privacy impact assessments We maintain records of processing activities, implement privacy governance, and perform data protection impact assessments for high‑risk processing as required by PDPL.
  8. Complaints and supervisory authority You may lodge a complaint with us (see DPO contact below). You also have the right to lodge a complaint with the competent UAE supervisory authority as prescribed by PDPL.
  9. Contact / Data Protection Officer (DPO) For exercises of rights, enquiries, complaints or privacy requests, contact:
  • Data Protection Officer: [Name / DPO title]
  • Emai: info@veaudry.ae Postal: [Organisation postal address]
    (We will verify identity before fulfilling requests.)
  1. Changes to this Notice We may update this Notice to reflect changes in law or business practices. We will publish the revised Notice on our website and indicate the effective date.
  2. Miscellaneous
  • Precedence: this Notice governs our personal data processing. Other internal policies (e.g., employee handbook) will be aligned with PDPL and this Notice.
  • Where this Notice refers to forms, contact the DPO for templates or assistance.