Introduction and Scope

Yuwab Consulting FZ LLC (“Yuwab”, “we”, or “us”) is committed to protecting your privacy in accordance with United Arab Emirates law, including Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (PDPL). This Privacy Policy explains how we collect, use, disclose, and safeguard personal data when you use the Yuwab platform (our website, mobile app, and related services). It applies to all users of Yuwab – Individual Clients, Corporate Clients, and Coaches – as well as visitors using our site or app. By using the Yuwab platform, you acknowledge that you have read and agree to this Privacy Policy and consent to the handling of your data as described herein.

Our goal is to collect and process personal data only for clear, specific purposes related to delivering and improving our coaching services, and to do so in compliance with UAE law and our contractual commitments. We do not collect more data than necessary and we do not sell your personal data to third parties. All processing of personal data is done lawfully, fairly, and transparently, with appropriate security and confidentiality measures in place

Legal Basis for Processing Personal Data

Under UAE’s PDPL and other applicable laws, we rely on one or more of the following legal bases to process your personal information.

• • Your Consent: In general, we obtain your consent to process your personal data in situations where consent is required. For example, we will ask for your consent to send marketing communications or, where required, to collect any sensitive personal information. You have the right to withdraw your consent at any time (see Your Rights below).

• • Performance of a Contract: Much of our data processing is necessary to provide you with the services you request (in other words, to fulfill our contractual obligations to you as a user of the Yuwab platform). This includes processing that is needed to create and manage your account, connect you with Coaches, facilitate coaching sessions, and process payments.

• • Compliance with Law: We may process personal data as required to comply with applicable legal obligations. For instance, consumer protection and financial regulations in the UAE may require certain record-keeping, and we may need to disclose data in response to lawful requests by government authorities or court orders.

• • Public Interest or Vital Interest: In rare cases, we might process data if it’s necessary to protect a public interest (for example, public health) or someone’s life, health, or safety. These situations are uncommon in our context, but UAE law permits such processing when critical.

• • Exercise of Legal Rights: The PDPL allows processing that is necessary to exercise or defend legal claims or rights. We may retain and use personal data as needed to enforce our Terms of Use or Coaching Services Agreement, to prevent fraud or platform abuse, and to resolve disputes or legal matters, consistent with applicable law

We will always ensure we have a valid legal basis for processing your data and will document our justifications as required. Where consent is the basis, we will be able to demonstrate that you gave it (for example, by electronic acceptance records), and you can opt out or withdraw consent where applicable.

Personal Data We Collect

We collect various types of personal data from and about our users. This includes information you provide directly, data we collect automatically through your use of the platform, and information from third parties (such as corporate client administrators or integrated service providers). The types of personal data we collect include:

• • Account and Contact Information: When you create a Yuwab account or fill out your profile, we collect information such as your full name, email address, phone number, and login credentials. If you represent a Corporate Client, we also collect your company or organization name and work contact details. This basic contact data is necessary to register you and communicate with you.

• • Personal Profile and Demographics: You may choose to provide additional profile information such as your age or age range, gender, professional title, industry, location, native language or other language proficiencies, and a brief biography or goals for coaching. For example, an individual Client might share their career goals or areas they want coaching in, and a Coach will provide details about their expertise and coaching style. Providing this information is optional but helps us match Clients with suitable Coaches and personalize your experience.

• • Identification and Verification Documents (Coaches): If you are a Coach, as part of our onboarding and verification process we will collect certain data to verify your identity and qualifications. This may include copies of identification documents (such as your passport or Emirates ID), proof of professional qualifications or certifications, background information like your résumé or references, and any licenses or permits required under UAE law for providing coaching services. We use this information to vet Coaches and ensure they meet our platform standards and legal requirements.

• • Payment and Transaction Data: When you make or receive payments via the platform, we (or our payment processors) collect information necessary to process those transactions. For Clients, this may include billing details and partial payment card information (like the card type and expiration date) or in-app purchase receipts. Note: Yuwab does not store full credit/debit card numbers; payments are handled securely by accredited third-party processors. For Coaches, we collect payout information such as bank account details or payment wallet addresses to remit coaching fees to you. We also maintain records of transactions, subscriptions, session bookings, and invoices for accounting and compliance purposes.

• • Coaching Session Information: We do not record or monitor the audio/video of coaching sessions by default. The content of your one-on-one coaching conversations with your Coach remains private between you and your Coach, unless you explicitly consent to a recording or sharing (for example, if you agree with your Coach to record a session for your personal review, or in a special program that involves session recordings). Yuwab will never access or use the substance of your coaching discussions except as needed for safety, to investigate a violation of our terms, or if required by law. However, we may collect scheduling details and metadata about sessions (e.g. session dates and times, duration, whether a session took place or was missed) to manage your service and facilitate billing or reporting.

• • User Communications and Content: If you participate in platform features like messaging your Coach or Client through our app, posting reviews or testimonials, or contacting Yuwab support, we will collect and store those communications. User Content you submit (such as a review of a Coach or a profile description) remains your own, but by submitting it you give us a license to use and display it as needed to operate the platform. For example, if you write a testimonial about your Coach, we may publish it on the platform or in our marketing materials, using your first name and last initial or other agreed attribution. We moderate and use user-submitted content in line with our Terms of Use and this Policy. Private messages between Users and Coaches are not public, but Yuwab’s support team may review communications if necessary (for instance, to investigate misuse or provide assistance).

• • Corporate Client Data: If you are using Yuwab as part of a corporate-sponsored program, your employer or organization may provide us personal data about you to set up your access. This could include your name, work email, employee ID, department, or other enrollment details. We handle any employee data provided by Corporate Clients in accordance with this Policy and our agreements with the Corporate Client. The corporate organizer is responsible for ensuring they have authority or consent to share employee data with us. We may also generate aggregated reports for the Corporate Client about program usage (e.g. overall number of sessions used, completion rates, or other non-sensitive metrics) as agreed with that client. We will not disclose the content of your coaching sessions to your employer, and any sharing of personal data with the Corporate Client (such as your name, coaching participation status, or feedback surveys) will be made clear to you as part of that program.

• • Usage Data and Device Information: Like most online services, we automatically collect certain technical data when you use our platform. This includes log information such as the dates and times you log in, features you use, pages viewed or screens accessed, and other usage statistics. We also collect device and network information: for example, your device type, operating system version, browser type, IP address, general geographic location (city/country), and unique device identifiers. If you use our mobile app, we may collect mobile-specific identifiers (such as your device’s advertising ID) and data about app performance or any crashes. We use this information to maintain the security of the platform, optimize our services for different devices, and analyze and improve our user experience.

• • Cookies and Similar Technologies: When you visit our website or use the app, we use cookies and similar tracking technologies (explained in Cookies and Tracking below) to collect information about your interactions and to remember your preferences. This can include data such as what pages you visited, how you navigated the site, and other analytics data. Some cookies may collect elements of personal data (like your IP address or account ID) as part of their function. Please see the Cookies and Tracking section for details on how we use these technologies and your choices.

• • Sensitive Personal Data: We generally do not require any “sensitive” personal data (such as health information, racial or ethnic origin, religious beliefs, biometric data, etc.) for the standard use of the platform. We advise users and Coaches to limit sharing of sensitive details unless it is directly relevant to the coaching (for instance, discussing your stress or well-being with a life coach might involve some health-related information). In the event that you do share sensitive personal data through the platform or with your Coach, we will treat it with heightened confidentiality and security. Where required by law, we will obtain explicit consent to process sensitive data. Coaches are instructed to handle any sensitive information with the utmost care and only for the purpose of your coaching sessions.

Failure to Provide Data: You can choose not to provide certain personal data, but please note this may limit your ability to use some features of Yuwab. For example, if you do not provide a valid email address, we cannot create an account for you; if a Coach does not provide required verification documents, we cannot list them on the platform. We will indicate clearly when certain information is required to use a service.

How We Use Your Personal Data

Yuwab uses your personal data only for legitimate purposes related to operating our platform, providing our services, and fulfilling our legal and contractual obligations. The main purposes for which we process personal data are:

• • Providing and Improving the Service : We use personal information to operate the Yuwab platform and deliver our coaching services to you. This includes using data to create and manage user accounts, facilitate profile setup, and personalize your experience. For Clients, we use your information to connect you with suitable Coaches (for example, matching by expertise or language), enable you to schedule sessions, and allow Coaches to prepare personalized coaching plans. For Coaches, we use your data to list your profile for Clients to view, to match you with potential Clients, and to manage your availability and bookings. We also use various data (like usage patterns and feedback) to understand how our platform is performing and to improve our features, user interface, and content. This may involve analyzing usage data to troubleshoot technical issues, to optimize navigation, or to develop new functionality that benefits users.

• • Communications and Support: We process your contact information to communicate with you about your account and the services. This includes sending service-related communications such as confirmations and reminders for upcoming sessions, notifications of messages from your Coach or Client, receipts and invoices for payments, and alerts about important updates (like changes to our terms or privacy policy). Such communications are part of our service delivery and are sent via email, in-app notifications, or SMS/phone when appropriate. For example, we might send you a text reminder the day of your coaching session, or an email alert if we suspect unauthorized access to your account. You cannot opt out of essential service communications, as they are necessary for using Yuwab. However, marketing communications (such as newsletters, promotions, or new service offers) will only be sent in accordance with applicable law and your preferences. We may ask for your consent before adding you to a mailing list, and you can unsubscribe from marketing emails at any time by using the opt-out link or contacting us. If you reach out to Yuwab with a question or request (e.g. contacting customer support), we will use your provided information to respond and resolve your issue, and we may follow up to ensure your satisfaction.

• • Facilitating Coaching Sessions: We use personal data to enable effective coaching interactions. For Clients, information you provide about your goals or background is shared with your chosen Coach so they can tailor the coaching to your needs. Coaches may use the personal details and any pre-session questionnaires or assessments you complete to prepare for sessions. Conversely, for Coaches, we use your profile information (qualifications, bio, etc.) to introduce you to Clients on the platform, and we may highlight relevant details to help Clients choose a coach (for example, years of experience or languages spoken). During sessions, Yuwab’s platform may facilitate communication (e.g. through our video conferencing tool or in-app chat), but as stated, we do not use session content for any purpose other than transmitting it between you and your Coach, except with consent or if required for dispute resolution or legal compliance.

• • Processing Payments and Subscriptions : We use personal data to handle billing and payments on the platform. If you are a Client purchasing coaching sessions or subscriptions, we will use your provided payment method details to charge for the services as described in our Terms (via our payment provider). We will send you payment receipts and maintain transaction records. If you have a recurring subscription, we will use your data to process periodic charges until you cancel. For Coaches, we calculate commissions and use your bank or payout details to send your earnings. We also use data to detect and prevent fraudulent transactions (for example, our system might use device information and payment identifiers to flag suspicious payment activities for manual review).

• • Sharing Information at Your Direction: Some data processing occurs when you actively share information with others on the platform. For instance, if you write a public review for a Coach, we will publish that content along with your chosen display name. If you are a Corporate Client administrator uploading a list of coachee participants, we will use that data to invite those individuals and manage their access. We use and disclose personal data in these cases as directed by you, and as necessary to carry out your requests.

• • Ensuring Platform Security and Integrity: We process certain data to keep Yuwab safe, secure, and in compliance with our policies and laws. This includes using log and device information to monitor for suspicious or unauthorized activity on user accounts, detecting violations of our Terms of Use, and preventing misuse of the platform. For example, we may analyze IP addresses and login patterns to detect if an account is being accessed from multiple countries suspiciously, or we may review communications if we receive reports of harassment or other prohibited behavior. We also use personal data to conduct risk assessments and fraud prevention (such as verifying identity documents for coaches to prevent impersonation). These activities are essential to protect all our users and Yuwab’s legitimate interests in maintaining a trustworthy service.

• • Legal Compliance and Legitimate Business Interests: Finally, we may use your personal data as needed to comply with applicable laws (e.g. responding to lawful requests for information, fulfilling data retention obligations) and to pursue our legitimate business interests as long as those are aligned with your rights. For instance, we might use aggregated usage data to compile business metrics, or use contact information to enforce agreements (sending notices of owed fees or informing you of updates to terms). If we need to use personal data for a purpose that is materially different from the purposes listed in this Policy, we will update this Policy or request your consent as required.

We will not use your personal data for any incompatible secondary purposes without obtaining your consent. Specifically, we do not sell or rent your personal information to third-party marketers, and we do not engage in invasive profiling or automated decision-making that has legal or similarly significant effects on you without human involvement (if we ever introduce automated decision processes, we will ensure compliance with legal requirements and your rights to object).

How We Share and Disclose Personal Data

Yuwab treats your personal data with care and confidentiality. We only share your information with third parties in the following circumstances:

• • With Your Coach or Client: If you are a Client, we share your relevant personal information with the Coach(es) you choose to work with so they can provide you with effective coaching. This typically includes the profile information you filled in (e.g. your name, occupation, goals or focus areas, and any pre-session survey answers) and may include updates you make to your profile or schedule. Coaches will also see your booking history with them (e.g. past and upcoming sessions) and any messages or files you send through the platform. Coaches are contractually bound to use your data only for your coaching and to keep it confidential and secure. If you are an Individual Client, your Coach generally will not know any information beyond what you provide on the platform. If you are using Yuwab under a Corporate Client program, the Coach may receive additional context from the Corporate Client about the coaching engagement (for example, general objectives of a company coaching initiative or any assessment results, if applicable). Likewise, if you are a Coach, the personal information you provide (such as your name, photo, qualifications, biography, languages, and coaching offerings) will be displayed to Clients on the platform so that they can consider and select you for services. Your profile may be visible to any user or visitor browsing our publicly accessible coach listings, except for certain contact details (like your email or phone) which are kept private. Clients who book sessions with you will also receive your full name and may receive your email or phone contact if needed for session logistics (we primarily encourage in-platform communication for privacy and tracking). We do not share a Coach’s personal identification documents or background check details with Clients; those are only used internally by Yuwab for verification.

• • With Corporate Client Organizers: If your coaching access is provided by a Corporate Client (such as your employer or a sponsoring organization), we may share limited information about your usage with authorized Corporate Client representatives for program management purposes. For example, we might inform a corporate HR contact that you have activated your account, the number of sessions you have completed, or aggregate feedback scores if those are part of program evaluation. Any such reporting will be disclosed to participants in that program, and we will ensure it complies with UAE data protection requirements (often using aggregated or de-identified data where possible). We will not share detailed personal data or coaching content with a Corporate Client without your consent, unless required by law or under a specific arrangement that you are informed about. Corporate Clients are themselves responsible for handling any personal data they receive in compliance with applicable laws and our agreements (they should only use it for program administration and not for unrelated purposes).

• • With Service Providers (Processors): We use trusted third-party companies to perform certain business-related functions on our behalf. This includes, for example, cloud hosting providers (to store our application data and backups), payment processors (to handle secure credit card transactions and in-app purchases), email/SMS delivery services (to send out notifications and verification codes), analytics providers (to help us understand how users engage with our app or website), and customer support tools. When we share data with these service providers, they are only given the information necessary to perform their specific services for us. They are contractually obligated to process personal data only for our purposes and to provide at least the same level of data protection as we do. In other words, they act under our instructions and may not use your information for their own unrelated purposes. Examples of such third parties include: payment gateways that process your credit card securely, cloud infrastructure services that host our databases, or an email service that sends the emails we draft (like a password reset email). We ensure all service providers are bound by confidentiality and data protection agreements

• • For Legal Compliance or Protection: We may disclose personal data to third parties if we believe in good faith that such disclosure is required to: (a) comply with a law, regulation, legal process, or enforceable governmental request (such as a court order or an inquiry by UAE authorities); (b) enforce our Terms of Use or other agreements, or investigate potential violations thereof; (c) detect, prevent, or address fraud, security, or technical issues; or (d) protect the rights, property, or safety of Yuwab, our users, or the public. For example, if required by a law enforcement demand, we might need to provide logs or account information as mandated. If we are compelled to disclose your data, we will attempt to notify you in advance if legally permitted to do so, so you have an opportunity to object or seek legal remedies. We also might share information with our professional advisors (lawyers, accountants, auditors) on a need-to-know basis, under duties of confidentiality, if that is necessary to obtain advice about legal or financial matters related to Yuwab’s operations.

• • Business Transfers: If Yuwab undergoes a business transaction such as a merger, acquisition by another company, reorganization, or sale of all or part of its assets, your personal data may be transferred to the successor entity as part of that transaction. Any new owner will continue to be bound by the terms of this Privacy Policy (or one with equivalent protections) with respect to your personal information, and we will notify you of any change in data control. Likewise, if Yuwab is involved in a bankruptcy or restructuring process, personal data could be considered an asset and transferred accordingly, subject to this same commitment to privacy.

• • With Your Consent: In situations other than those described above, if we ever need to share your personal data with a third party in a way that is not already covered in this Policy, we will obtain your consent. You have the choice to approve or deny such sharing. For example, if we wanted to feature your success story in a marketing campaign and that involved sharing your contact or personal details with a media partner, we would only do so with your explicit consent.

We do not share any personal data with third-party advertisers or social media companies for their own marketing purposes, unless you separately consent to such activity. We may share anonymized or aggregated data (which cannot be linked back to you) publicly or with partners (for example, publishing overall platform usage statistics or trends) but in these cases no individual is identifiable from that data.

When we share data with any third party, we apply the principle of data minimization (only the information needed for that purpose is disclosed). All third parties who receive personal data are expected to handle it with integrity and security, and we strive to choose partners and providers who demonstrate a strong commitment to privacy.

Cross-Border Data Transfers

Yuwab is based in the UAE, but we utilize global cloud infrastructure and service providers. This means that your personal data may be transferred to, stored, or processed in countries outside of the United Arab Emirates. For example, we might use secure servers located in Europe or the United States for data hosting, or a customer support service that operates in another region. We take steps to ensure any such transfers comply with UAE data protection requirements and that your data remains protected to the standards of UAE law regardless of where it is processed. UAE’s PDPL places restrictions on transferring personal data outside the UAE unless certain conditions are met. Yuwab abides by these rules by implementing one or more of the following safeguards for international data transfers:

• • Adequacy: We primarily transfer data to countries that the UAE government (or Data Office) has deemed to have an adequate level of personal data protection comparable to UAE law. When regulations identifying “approved” jurisdictions are in effect, we will ensure data only flows to those jurisdictions unless other safeguards are used.

• • Contractual Safeguards: If we transfer data to a country that is not yet formally approved, we will rely on legally recognized transfer mechanisms such as Standard Contractual Clauses (SCCs) or other approved data protection agreements. These are contractual commitments between us and the data recipient that ensure your information receives the same high level of protection it has under UAE law, even in another country.

• • Consent or Necessity: In some cases, we may transfer data with your explicit consent or because it is necessary to perform a contract with you (for example, if you are traveling and access our platform from outside the UAE, that inherently involves transferring your data to that location upon your access). The PDPL also allows transfers that are necessary to carry out your requests or for contract performance. By using the Yuwab platform and its services, you consent to your information being transferred and processed outside the UAE for the purposes described in this Policy. We will only do so in line with the safeguards noted.

• • Other Permitted Grounds: Additionally, the law permits cross-border transfers in certain situations like to protect public interest or establish/exercise legal claims. We generally will not rely on these unless absolutely applicable.

No matter where your data is located, Yuwab remains responsible for its privacy and security. We will monitor changes in international data transfer regulations and update our practices accordingly. If required by law, we will also seek approval from the UAE Data Office for specific transfers or maintain records of cross-border transfer assessments. Our goal is that your personal data will have continuous protection, whether on a server in the UAE or in another country.

If you have questions about international data transfer or want to obtain a copy of the relevant safeguards (such as the contractual clauses we use), you can contact us at any time (see Contact Us section below).

Data Subject Rights

Under UAE law (PDPL) and other applicable data protection regulations, you have certain rights regarding your personal data. Yuwab is committed to respecting these rights and has processes in place to enable you to exercise them. Your principal rights are:

• • Right to Access: You have the right to request a copy of the personal data we hold about you and to obtain information about how we process it. This includes understanding what data we have, the purposes of processing, the categories of recipients with whom it’s shared, and, if the data was collected from a third party (like a corporate program), the source of that data. We will provide you with a readable copy of your data, usually in electronic form. For example, you can request a summary of your profile information, session history, or communications we have on file. We will also confirm whether we are processing your data and provide additional information as required by law. In most cases, access requests will be fulfilled free of charge within the legally required timeframe, provided they are reasonable and not excessive.

• • Right to Rectification (Correction): We want to ensure that your personal data is accurate and up-to-date. You have the right to have inaccurate personal data corrected or completed if it is incomplete. Many portions of your basic data can be updated directly by you through your account settings at any time (for example, you can edit your profile, change contact info, etc.). If you find any other information we hold is incorrect or requires an update (such as a misspelled name or an outdated qualification on your profile), you may contact us to request a correction. We may ask for verification in some cases (for instance, evidence of a legal name change) before making major changes, to ensure the integrity of our records.

• • Right to Deletion (Erasure): You have the right to request that we delete your personal data in certain circumstances. You can delete basic profile information by removing or clearing fields in your account, and you can also request complete account deletion. If you wish to close your account and have us delete the personal data we hold about you, you can contact us at our designated email or use any account deletion function we provide. We will delete your data upon request provided that we do not have a valid legal reason to retain it (for example, some data may need to be kept for a limited time to comply with financial record-keeping regulations or to resolve disputes). We will inform you of what data, if any, we must retain and for how long. Once your data is deleted, it will typically be removed from our active systems immediately or within a short period, and we will also instruct any processors holding the data to delete it. Some residual data may persist in backups for a period of time but will be overwritten or purged according to our backup retention schedule. Important: Deleting certain data (or your entire account) will mean you lose access to services that rely on that data. For instance, if you delete your account, you will no longer be able to log in or use any remaining sessions, and deletion of contact info will prevent us from reaching you for session reminders. We will warn you of these consequences when you make a deletion request. As noted, we may retain minimal information to document that we fulfilled your request and to maintain records required by law.

• • Right to Restrict or Object to Processing: You have the right to request that we limit or stop certain processing of your personal data, particularly if you believe the data is inaccurate, the processing is unlawful, or we no longer need the data for our purposes but you want us to retain it for your own legal needs. You also have the right to object to any processing that is based on our legitimate interests or done for direct marketing. For example, you can request that we stop using your email for marketing messages (and in fact, any marketing email we send will include an easy opt-out mechanism). If we ever engaged in profiling or automated decision-making that affects you significantly, you could object to that as well. In practice, Yuwab’s processing is mostly based on contract performance and consent, so your ability to object may more commonly apply to scenarios like direct marketing or continued storage of data you want deleted. If you raise an objection, we will evaluate it and comply unless we have compelling legitimate grounds to continue the processing that override your interests or it’s needed for legal claims. We will communicate with you to resolve any objection satisfactorily.

• • Right to Withdraw Consent: Where we rely on your consent to process personal data, you have the right to withdraw that consent at any time. If you opt in to receive promotional emails or newsletters, you can opt out via the unsubscribe link in those emails or by changing your preferences in our app settings. If you have given consent for any optional data collection, you can contact us to revoke that consent. Withdrawal of consent will not affect the legality of any processing we conducted prior to your withdrawal, and in some cases we may need to limit or terminate your use of certain services if they rely on the data you no longer consent to us using.

• • Right to Data Portability: To the extent provided by law, you may have the right to receive a copy of certain personal data in a structured, commonly used, machine-readable format so you can transfer it to another service provider if you wish. For example, you might request an export of your basic profile and session history. Where feasible, and applicable (portability typically applies to data you provided to us, processed by automated means, and based on consent or contract), we will provide the data in a format that you can import elsewhere. If you prefer and it’s technically possible, we may also transfer the data directly to another provider at your direction.

• • Rights Regarding Automated Decisions: Yuwab does not currently make any decisions about users that are based solely on automated processing (without human involvement) that produce legal or similarly significant effects. In the event we implement automated decision-making (for instance, an algorithm that automatically assigns a Coach based purely on questionnaire data), you would have the right not to be subject to such a decision without human review, and the right to express your point of view and contest the decision.

• • Right to Information and Complaint: You have the right to be informed about how your data is being used (which is one reason we provide this Privacy Policy). If you have any questions or concerns about our handling of your personal data, we encourage you to contact us so we can address them. If you are not satisfied with our response, under PDPL you may have the right to lodge a complaint with the UAE Data Office or other regulatory authority. We sincerely hope to resolve any issues directly and promptly, but you do have the right to seek enforcement of your data protection rights through official channels if you believe we are not complying with the law.

How to Exercise Your Rights: Most rights can be exercised by contacting us at the contact information provided in this Policy (see Contact Us). For certain requests like accessing or deleting data, we may ask you to submit the request from the email associated with your account or through a verified in-app process, to ensure it’s a genuine request from you. We may need to verify your identity (for example, by asking you to confirm some basic account details) before fulfilling sensitive requests, especially for access, data portability, or deletion, to prevent unauthorized access or deletion of your data by someone else. We will respond to your requests within a reasonable time and as required by law (typically, we aim to answer within 30 days or the timeframe set by PDPL). If we need more time or cannot fulfill your request (due to a legal exception), we will inform you and explain the reasoning. For instance, PDPL may allow us to deny or defer an access request if it adversely affects the rights of others or a legal investigation; we will only do so in strict accordance with the law.

There is generally no fee for exercising your rights. However, if a request is manifestly unfounded or excessive (e.g. repeated requests without basis), we may charge a reasonable fee or refuse to act on it, as permitted by law.

Yuwab is dedicated to honoring your rights and ensuring you have control over your personal data. We have internal procedures and trained staff to handle data subject requests. Coaches and any partners are also expected to cooperate in fulfilling these requests (for example, if you ask us to delete your data, Coaches are required to delete any copies they hold as well). Your privacy and satisfaction are very important to us, and we will do our best to accommodate your needs while also complying with our legal obligations.

Data Retention

We retain personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required or permitted by law. This means your data will be kept for at least the duration of our relationship with you (while your account is active or you are using our services), and for a period afterward where there is a legitimate need to retain it.

Our retention practices are as follows:

• • Active Account Data: If you have an active Yuwab account, we will retain the personal information in your account profile, your content, and your usage records for as long as your account is in use. This allows us to provide the service to you continuously. For example, we keep your coaching session history so you (and your Coach) can review past sessions, and so we can track your remaining session credits or subscription status.

• • Account Deactivation or Inactivity: If you choose to deactivate your account or stop using Yuwab, we may retain your data for a grace period. Sometimes users return to the service, and keeping the data for a short time can make reactivation easier. For instance, we might retain your profile and session records for a certain number of months in case you reactivate your account, instead of immediately deleting everything the moment you log out for the last time. We will specify in the app or at the time of deactivation how long this grace period is. During this time, your account would typically be in a suspended state (not visible to others). If the grace period passes without reactivation, or if you specifically request deletion, we will proceed to permanently delete or anonymize your personal data.

• • Fulfilling Legal and Business Obligations: Even after you stop using Yuwab, we may retain some personal data for longer periods if necessary for legal, compliance, or legitimate business purposes. Examples include: financial transaction records and invoices (which we might need to keep for a number of years under UAE tax law); records of consents and agreements (to prove compliance with data protection or e-signature laws); data relating to dispute resolution (if you had a dispute or claim, we would retain relevant info until it is resolved and no further action is expected); and backup copies of the database. We will not keep data longer than required.

• • Deletion and Anonymization: When personal data is no longer needed, we will either delete it in a secure manner or anonymize it so that it can no longer be associated with an identifiable individual. Secure deletion may involve permanently removing records from our databases and purging them from backup systems (which might occur with a slight delay based on backup cycles). Anonymization means we alter or remove personal identifiers so that the data can be used for statistical or analytical purposes without any way to trace it back to you (for example, converting a dataset of user activity into aggregated trends with all names and IDs removed). In some cases, we might keep anonymized data indefinitely since it no longer contains personal information.

In summary, Yuwab’s policy is to retain personal data for only as long as it serves the purposes stated in this Privacy Policy or as required by law, and to delete or anonymize data when those purposes have been fulfilled.

Information Security Measures

Yuwab takes the security of your personal data seriously. We have implemented a range of technical, administrative, and physical security measures designed to protect your information from unauthorized access, disclosure, alteration, and destruction. These measures include:

• • Encryption: We use encryption to protect sensitive data in transit and at rest.

• • Access Controls: We restrict access to personal data strictly to personnel and service providers who need to know that information in order to process it on our behalf. Yuwab staff and Coaches access user data through controlled interfaces with user-based access permissions.

• • Secure Infrastructure: We host our platform on reputable cloud services that maintain high security standards. Our servers are protected by firewalls, network monitoring, and intrusion detection systems to guard against external attacks. We keep our software and systems updated with security patches to address vulnerabilities. Data centers housing our servers have physical security controls like access badges, surveillance, and 24/7 monitoring.

• • Testing and Monitoring: We conduct regular security assessments, such as vulnerability scans and penetration testing, to identify and fix potential weaknesses. We monitor our systems for unusual activity and have automated alerts for certain events (e.g., multiple failed login attempts may trigger a security review). Our team has procedures to investigate and respond to any suspicious activity.

• • Organizational Practices: All Yuwab employees and contractors receive training on data protection and are bound by confidentiality obligations. We have internal policies on how to handle user data, and we ensure that anyone with access to personal data understands their responsibility to safeguard it. Coaches, through their agreement with Yuwab, are also required to follow privacy and security best practices (e.g., using secure devices, not downloading client data unnecessarily, etc.). If we work with third-party service providers, we require them to adhere to equivalent security standards.

• • Payment Security: Any payment transactions carried out through our platform are handled in compliance with appropriate global standards via our payment processors. We do not store your payment card details on our systems beyond maybe the last four digits for reference; full card processing is done securely by the payment gateway.

• • Anonymity and Pseudonymity: Where feasible, we employ techniques like pseudonymization (using ID codes instead of names) in our internal data processing, especially for analytics. This helps to minimize the risk to your data in case of any unauthorized access.

Despite all these measures, it is important to note that no method of transmission over the Internet or electronic storage is 100% secure. We strive to protect your data, but we cannot guarantee absolute security. Users also have a role to play in protecting their own data. We encourage you to choose a strong, unique password for your Yuwab account and to keep your login credentials confidential. Do not share your account password with anyone, and be cautious of phishing attempts (Yuwab will never ask for your password via email). If you use a public or shared device, always log out after accessing our platform. Also, be mindful of what you share during coaching sessions or on your profile; avoid posting personal information in public areas of the platform that you wouldn’t want to be publicly visible.

Data Breach Response: In the event of a data breach that affects your personal data, Yuwab has an incident response plan to promptly mitigate the issue and comply with breach notification requirements. If despite our safeguards an unauthorized party accesses or obtains your personal data, we will immediately contain the incident and investigate its scope. We will notify the UAE Data Office (the data protection regulator) as required by law, and we will also inform you of the breach if it poses a risk to your privacy or security. Our notification to you will outline the nature of the data involved, the steps we are taking, and any recommendations for you to protect yourself (for example, changing passwords). We will not delay notification unduly, except if instructed by law enforcement for a pending investigation. Yuwab will also take measures to prevent any further breaches and to strengthen our security if such an incident occurs.

By using Yuwab, you acknowledge that you understand the inherent risks of online activities. We continuously improve our security practices to adapt to new threats and protect our community. If you have reason to believe that your data or account may have been compromised (for example, you notice unauthorized activity on your account), please contact us immediately so we can assist and investigate.

Cookies and Tracking Technologies

When you visit the Yuwab website or use our mobile application, we and our partners may use cookies and similar tracking technologies to enhance your experience, analyze usage, and deliver certain functionalities. This section explains what these technologies are and how we use them.

What Are Cookies? Cookies are small text files that are placed on your computer or mobile device when you visit a website. They allow the site (or a third party) to recognize your device and store some information about your preferences or past actions. Other similar technologies include web beacons (tiny transparent images embedded in webpages or emails that can track if you’ve opened them), SDKs (software development kits embedded in apps), or local storage in apps. For simplicity, we refer to all of these as “cookies” or “tracking technologies.”

How Yuwab Uses Cookies: We use cookies for a variety of purposes:

• • Necessary Cookies: These are essential for the operation of our platform. For example, when you log in, we use a session cookie to remember you are authenticated as you navigate between pages – without it, you would have to log in again on each page. Necessary cookies also help us load the website faster and ensure basic features work (such as remembering your language preferences or keeping items in a cart if we had an e-commerce element).

• • Functional Cookies: These cookies remember choices you make to improve your experience. For instance, if you adjust certain settings on our site or app, a cookie might save those preferences so that they persist next time. If we offer a “remember me” option at login, a cookie will store your login ID (but not password) to auto-fill the field for your convenience (we only do this if you opt in to such feature). Functional cookies can also help in providing you a more personalized interface (like greeting you by name or showing relevant content based on previous usage).

• • Analytics and Performance Cookies: We use these to collect information about how users interact with our platform so we can understand and improve it. For example, we use Google Analytics (or similar analytics tools) that set cookies to gather data on which pages are visited, how long users stay, how they found our site, and any errors encountered. This information is aggregated and does not directly identify individuals; it helps us see usage patterns, identify popular features, and troubleshoot issues. We might also track conversion metrics (like how many people who view a coach’s profile actually book a session) to gauge the effectiveness of our features. We use this data to make Yuwab better for our users.

• • Advertising and Marketing Cookies: As of the current policy, Yuwab is not displaying third-party ads on our platform, and we do not heavily rely on advertising cookies. However, we may use cookies for our own marketing efforts – for example, a cookie might note that you visited our site and allow us to show you an advertisement for Yuwab on other websites (this is known as retargeting). Similarly, if in the future we partner with advertisers or social media platforms, those partners might use cookies to track the effectiveness of campaigns (such as if a user signed up after clicking an ad). If we implement such cookies, we will do so in compliance with applicable law and typically with your consent. We will update our policy to reflect any significant changes in advertising cookie usage.

• • Third-Party Functionality: Our platform may integrate third-party services that set their own cookies. For example, if we embed a video from YouTube, YouTube may place cookies to track video views. If you use a social media “share” button, the social network may set a cookie when you log in to share. We do not control these cookies, but we aim to inform you when such third-party integrations are present. The privacy policies of those third parties will apply to their handling of any information they collect.

Mobile App Tracking: In our mobile app, instead of cookies, we might use mobile identifiers and analytics SDKs for similar purposes (e.g. Apple’s Identifier for Advertisers (IDFA) or Google’s Advertising ID, as well as Firebase Analytics or other tools). These help us understand app usage and performance. You can usually reset or limit these identifiers in your device settings (for example, by resetting your Advertising ID or opting out of ad personalization on your device).

Your Choices: We respect that you may want to manage how cookies and trackers are used:

• • Browser Settings: For web cookies, you can set your browser to refuse all or some cookies, or to alert you when cookies are being sent. You can also delete cookies that have already been set. Please note, however, that if you disable or refuse necessary cookies, some parts of the Yuwab platform might become inaccessible or not function properly – for example, you might not be able to stay logged in or use the booking features without cookies. Each browser is different, but you can typically find cookie settings in the “Options” or “Preferences” menu.

• • Cookie Consent Banner: When you first visit our website, you may see a cookie notice or banner. We will use this to inform you about non-essential cookies and, if required, obtain your consent to use them. For example, we might ask you to agree to analytics cookies. You can always change your preferences later, either through our site’s privacy settings or by clearing cookies.

• • Opt-Out of Analytics: If you do not want to be included in Google Analytics data, Google provides an opt-out browser add-on you can install. Similarly, other analytics providers may offer their own opt-outs. We honor “Do Not Track” signals in browsers to the extent possible; if your browser is set to DNT, we will treat it as an opt-out of marketing/analytics cookies where feasible.

• • Mobile Opt-Out: If you’re using our mobile app and wish to limit interest-based advertising, you can adjust your device’s privacy settings (such as “Limit Ad Tracking” on iOS or “Opt out of Ads Personalization” on Android). This informs companies not to use your device’s advertising ID to build profiles for targeted ads.

• • Email Tracking: If we send you emails, we may use an invisible beacon to tell us if you opened the email or clicked on links, which helps us gauge engagement. You can disable remote images in your email client to avoid some of this tracking, or simply unsubscribe if you prefer not to receive our marketing emails.

We do not use cookies to collect sensitive personal data or to run any hidden programs on your device. All our cookies are meant to improve your experience or help us understand how to serve you better. We also don’t use cookies to knowingly target or profile children or any vulnerable individuals.

For more detailed information on the cookies and trackers we use, you can refer to our Cookies Notice (if provided separately on our website) or contact us with any specific questions. We will update this section to reflect changes in our use of cookies or in case UAE issues new guidelines around online tracking.

By continuing to use our site or app, you agree to our use of cookies and similar technologies as described here, unless you have disabled them through your browser or device settings.

Changes to This Privacy Policy

Yuwab may update or revise this Privacy Policy from time to time, to reflect changes in our practices or for other operational, legal, or regulatory reasons. We will notify users of any significant changes. For minor updates that do not materially affect your rights, we may just update the “Last Updated” date at the top and publish the new policy on our website/app. If we make major changes (for example, expanding the types of data we collect or changing how we use data in a way that you might not expect), we will provide a more prominent notice (such as an email notification to registered users or a pop-up notice within the platform) and obtain your consent if required by law.

We encourage you to periodically review this Privacy Policy to stay informed about how we are protecting your information. Your continued use of the Yuwab platform after any changes to this Policy constitutes your acceptance of the updated terms (to the extent permitted by law). If you do not agree with the changes, you should discontinue use of the platform or exercise your rights (such as withdrawing consent or requesting deletion, as appropriate).

For reference, if there’s any inconsistency between this Privacy Policy and our Terms of Use regarding data privacy matters, this Privacy Policy will take precedence in interpreting our data handling commitments.

Contact Us (Data Controller Information)

Yuwab Consulting FZ LLC, a company organized under the laws of the United Arab Emirates, is the Data Controller responsible for your personal data collected via the Yuwab platform. If you have any questions, concerns, or requests regarding this Privacy Policy or your personal data, you can reach out to us at:

Email: hello@yuwab.com

Attn: Data Protection Officer / Privacy Team

We are here to help. Whether you need assistance exercising your rights, or you want more clarification about our data practices, please do not hesitate to contact us. We will respond to inquiries as promptly as possible, typically within a few business days.

By communicating with us, you may provide personal data (like your contact details and nature of your request) which will of course be kept confidential and used only for purposes of addressing your inquiry.

Thank you for trusting Yuwab with your coaching journey. We value your privacy and strive to protect it in every aspect of our service.