Personal Data Processing Policy

Last Updated: 25 June 2026

Data Controller: Unum Innovations FZCO
License: IFZA License No. 40871
Registered at: IFZA Properties, DSO-IFZA, Dubai Silicon Oasis, Dubai, UAE
Email: info@theunum.io
Website: www.{{DOMAIN}}

1. Purpose of This Policy

This Personal Data Processing Policy ("Policy") sets out the principles applied by Unum Innovations FZCO ("Company", "we", "us", "our") when processing personal data in connection with www.{{DOMAIN}} ("Website"). It supplements our Privacy Policy and provides additional detail on our role and legal basis as a data controller, in accordance with UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (UAE PDPL).

Detailed information on what personal data is collected, how it is used, and your rights as a user is set out in our Privacy Policy. This Policy focuses specifically on the principles and governance framework applied to that processing.

This Policy will be reviewed and expanded as the Website's functionality and data processing activities evolve.

2. Roles: Controller and Processors

Unum Innovations FZCO acts as the data controller for personal data collected through the Website — meaning we determine why and how personal data is collected and used (for example, to provide account registration and respond to enquiries).

We engage a limited number of third-party service providers (data processors) to perform technical functions on our behalf, such as website hosting, email delivery, and analytics. These providers process personal data only on our instructions and only for the purposes we specify. They do not determine the purposes of processing and are contractually or technically restricted from using personal data for their own purposes.

3. Principles of Data Processing

The Company processes personal data in accordance with the following principles, consistent with UAE PDPL:

  • Lawfulness, fairness, and transparency: personal data is processed lawfully and transparently;
  • Purpose limitation: personal data is collected only for the specific purposes described in our Privacy Policy;
  • Data minimisation: we collect only the personal data necessary for those purposes — currently limited to basic account and contact information;
  • Accuracy: reasonable steps are taken to keep personal data accurate;
  • Storage limitation: personal data is retained only as long as necessary, as described in our Privacy Policy;
  • Integrity and confidentiality: appropriate security measures are applied to protect personal data, including password hashing and access controls.

4. Legal Bases for Processing

We process personal data on the following legal bases, as applicable to the specific processing activity:

  • Performance of a contract: to provide services you request, such as account registration;
  • Consent: for optional activities such as marketing communications or non-essential cookies;
  • Legitimate interest: for purposes such as Website security and fraud prevention;
  • Legal obligation: where required to comply with applicable law.

5. Data Security

We apply security measures appropriate to the nature and volume of personal data we currently process. In particular: account passwords are stored in hashed (encrypted, one-way) form and are not accessible to the Company in plain text; access to personal data is limited to personnel who require it to perform their role; and data is transmitted using secure, encrypted connections.

As the Website's functionality grows, we will review and, where necessary, enhance these measures, and will update this Policy accordingly.

6. Cross-Border Data Transfers

Where personal data is transferred outside the United Arab Emirates — for example, to hosting or analytics providers located internationally — such transfers are conducted in accordance with applicable law, using appropriate safeguards, as further described in our Privacy Policy.

7. Data Subject Rights

The rights available to you in relation to your personal data — including access, correction, deletion, restriction, objection, and withdrawal of consent — are set out in full in our Privacy Policy. To exercise any of these rights, contact us at info@theunum.io.

8. Future Updates to This Policy

This Policy reflects the Company's current data processing activities, which are limited in scope. As the Website introduces new features (such as paid subscriptions, additional account functionality, or more complex data processing), this Policy will be expanded to address matters such as formal records of processing activities, data protection governance, and any additional safeguards required by applicable law. The "Last Updated" date at the top of this Policy indicates when it was last revised.

9. Language and Priority

This Policy is issued in the English language. Versions in other languages are provided solely for user convenience. In the event of any conflict or inconsistency between the English version and any other language version, the English version shall prevail, in accordance with the governing law of the UAE.

10. Contact Us

If you have any questions about this Policy, please contact us:

Data Controller: Unum Innovations FZCO
License: IFZA License No. 40871
Address: IFZA Properties, DSO-IFZA, Dubai Silicon Oasis, Dubai, United Arab Emirates
Email: info@theunum.io
Website: www.{{DOMAIN}}