Privacy Policy
This consolidated legal document includes the Privacy Policy, Cookie Policy, GDPR Compatibility Addendum, and the integrated Data Processing Agreement (DPA). It reflects updates inspired by structures used by major Dubai-based companies and incorporates local UAE PDPL requirements as well as GDPR compatibility where applicable.
1. INTRODUCTION
This integrated legal document governs the processing of personal data by UONE PROFESSIONAL DEVELOPMENT PORTAL - FZCO ("Company", "we", "us", "our"), licensed under Dubai Integrated Economic Zones Authority (License No. 75115).
It contains:
- Privacy Policy compliant with UAE Federal Decree-Law No. 45/2021 (PDPL);
- Cookie Policy;
- GDPR Compatibility Addendum for EU/EEA users;
- Data Processing Agreement (DPA), forming Part IV of this document.
We reserve the right to amend or update this Policy at any time. Changes will be posted with an updated "Last Updated" date. Continued use of our Services after changes constitutes acceptance. Users are encouraged to review this Policy periodically.
2. COMPANY INFORMATION
| Company Name | UONE PROFESSIONAL DEVELOPMENT PORTAL - FZCO |
| Legal Status | FZCO |
| Trade License No. | 75115 |
| Issuing Authority | DIEZA |
| Registered Address | DSO-IFZA, IFZA Properties, Dubai Silicon Oasis, UAE |
| Privacy Contact | Compliance@UnitedOne.Global |
3. CATEGORIES OF PERSONAL DATA
We collect the following categories of personal data depending on engagement:
- Identification Data: name, date of birth, nationality, identification documents (passport, Emirates ID), residency information.
- Contact Data: address, email, phone number, communication details.
- Account/MLM Data: username, hashed passwords, upline/downline structure, rank, performance metrics.
- Financial/Transactional Data: bank details, payouts, transfers, invoices, purchase history.
- Technical Data: IP address, device identifiers, browser data, cookies, access logs.
- Communication Data: emails, messages, support tickets.
- KYC/AML Data: identity verification documents, PEP/sanction screening results.
We collect personal data when users register, log in, make transactions, interact with the portal, or communicate with us. We may also automatically collect technical data such as browser type, operating system, usage patterns, and device information.
4. LEGAL BASIS FOR PROCESSING (PDPL)
Processing occurs under:
- Contractual necessity: to provide access, manage accounts, calculate commissions.
- Legal obligations: KYC/AML compliance, accounting/tax obligations.
- Legitimate interests: fraud prevention, security, analytics, network management.
- Consent: marketing communications, certain analytics or optional processing.
5. DATA SHARING AND INTERNATIONAL TRANSFERS
We may disclose personal data to:
- Hosting and cloud infrastructure providers.
- Payment processors, banks, accounting providers.
- Analytics, marketing, and cybersecurity vendors.
- Professional advisors (lawyers, auditors).
- Regulatory authorities when required by law.
International transfers comply with PDPL safeguards including contractual protections.
6. DATA RETENTION
Data is retained only as required for legal, contractual, operational, and compliance purposes, after which it is securely deleted or anonymized.
7. DATA SUBJECT RIGHTS (PDPL)
Individuals may request access, correction, deletion, restriction of processing, objection, consent withdrawal, and portability, subject to applicable legal limitations.
8. SECURITY MEASURES
The Company implements technical and organizational measures including encryption, access controls, audit logging, network security, backup procedures, and restricted data access policies. We implement appropriate technical and organizational controls including:
- Encryption of data in transit and at rest.
- Access control and least-privilege authorization.
- Logging and monitoring.
- Periodic security assessments.
- Secure hosting and backup measures.
Sensitive data such as KYC/AML files is treated with heightened security.
9. COOKIE POLICY
The platform uses essential cookies for authentication and security, functional cookies for preferences, analytics cookies (subject to consent), and third-party cookies where applicable. Users may manage non-essential cookies through browser settings.
10. GDPR COMPATIBILITY ADDENDUM
For EU/EEA users, processing is justified under Articles 6-9 GDPR, including contractual necessity, legal obligations, legitimate interests, and explicit consent. GDPR rights include access, rectification, erasure, restriction, portability, objection, and withdrawal of consent. Transfers outside the EU rely on Standard Contractual Clauses or appropriate safeguards.
11. PART IV - DATA PROCESSING AGREEMENT (DPA)
This DPA forms an integral part of the Company's service terms and applies where the Company acts as a data processor on behalf of a client ("Controller").
- Subject Matter: Processing relates to provision of Back Office MLM services and related support functions.
- Nature and Purpose: Processing includes storage, transmission, organization, and operational handling of personal data.
- Obligations: Processor shall process data only on documented instructions, ensure confidentiality, and implement appropriate security measures.
- Security Incidents: Processor notifies Controller without undue delay upon confirming a personal data breach.
All inquiries, rights requests, and DPA-related matters shall be directed to: Compliance@UnitedOne.Global.
