Privacy Notice

ManaraMED L.L.C-FZ is registered in Meydan Free Zone, Dubai, United Arab Emirates, with its office at:

Meydan Grandstand, 6th Floor
Meydan Road, Nad Al Sheba
Dubai, United Arab Emirates

ManaraMED L.L.C-FZ is the controller of the personal data covered by this Privacy Notice (referred to below as “ManaraMED”, “we”, “us” or “our”). ManaraMED also operates through ManaraMED LLC, a limited liability company registered in the State of Delaware, United States, with its office at 16192 Coastal Hwy, Lewes, DE 19958, United States. Where relevant to an engagement, enquiry or business relationship, personal data may be shared with ManaraMED LLC.

For privacy-related enquiries, contact us at office@manaramed.com.

This Privacy Notice applies to personal data we collect and process in connection with our business activities, including where you:

• visit or contact us through our website;
• communicate with us by email, telephone, messaging platforms or other correspondence;
• are a client, prospective client or a representative, employee or contact person of a client or prospective client;
• interact with us in connection with an advisory engagement, proposal, contract or business opportunity;
• are a business partner, investor, service provider, supplier, professional adviser or other business contact; or
• meet or interact with us through professional meetings, conferences, events or networking activities.

This Notice is intended to provide the privacy information relevant to these interactions without the need for a separate privacy notice for each ordinary business relationship, unless a particular activity requires additional or more specific information.

ManaraMED processes personal data in accordance with UAE Federal Decree-Law No. 45 of 2021 Concerning the Protection of Personal Data (the UAE PDPL) and, where applicable, other data-protection laws that apply to a particular processing activity or individual.

The personal data we process depends on how you interact with us and may include:

• identity and contact information, such as your name, job title, organisation, business address, email address and telephone number;
• professional and business information, such as your role, professional background, areas of responsibility and information about your organisation;
• communications and correspondence, including the content of emails, messages, meeting notes and enquiries;
• engagement and contractual information, including information necessary to prepare proposals, enter into and manage agreements, provide services and administer the business relationship;
• billing and administrative information, including information required for invoicing, payments, accounting and record keeping; and
• technical information generated when you use our website, such as IP address, browser type, device information, access times and pages visited.

We generally obtain personal data directly from you or from the organisation you represent. We may also receive business contact information from colleagues, professional contacts, publicly available professional sources or other persons involved in an engagement or business relationship.

We may use personal data to:

• respond to enquiries and correspondence;
• evaluate potential engagements, partnerships, investments or other business opportunities;
• prepare proposals, negotiate and enter into agreements, and deliver our advisory services;
• manage client, partner, supplier and other professional relationships;
• organise and participate in meetings, professional events and business-development activities;
• administer contracts, billing, payments, accounting and internal business operations;
• operate, maintain and secure our website, IT systems and communications; and
• manage our business and the professional relationships described in this Notice.

We do not sell personal data and do not use personal data for purposes unrelated to those described in this Notice.

Under the UAE PDPL, ManaraMED processes personal data with the consent of the individual or, where applicable, where processing is permitted without consent under the UAE PDPL.

Where you voluntarily provide personal data to ManaraMED for a specific purpose, for example by contacting us, submitting an enquiry, providing your contact details or corresponding with us in connection with a potential or existing business relationship, your clear affirmative action may constitute consent to the processing of that personal data for the relevant purpose.

Where processing is based on consent, you may withdraw your consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.

Where applicable, ManaraMED may also process personal data without consent where the processing is necessary to take steps at the request of the data subject with a view to entering into, amending or terminating a contract, or where another basis specifically applicable to the relevant processing is permitted by the UAE PDPL.

We may share personal data where reasonably necessary for the purposes described in this Notice, including with:

• ManaraMED LLC, where relevant to an enquiry, engagement or business relationship;
• technology, hosting, communications, accounting and other service providers that support our business operations;
• professional advisers and specialist consultants involved in an engagement or in supporting ManaraMED; and
• clients, counterparties, partners or other organisations where sharing is necessary for an engagement and is appropriate in the circumstances.

Where third parties process personal data on our behalf, we require appropriate confidentiality and data-protection protections in accordance with applicable law.

ManaraMED operates internationally and may transfer personal data, or make it accessible, to recipients outside the United Arab Emirates, including in the United States and other jurisdictions.

Where the UAE PDPL or another applicable data-protection law imposes requirements on cross-border transfers, ManaraMED will use the transfer mechanism, safeguards or other measures required by that law.

When you use our website, our hosting and technology providers may process technical information such as your IP address, browser type, device information, access times and pages visited. This information is used to operate, maintain and secure the website and is not used by ManaraMED for advertising profiling. The website does not use advertising or behavioural-tracking cookies. It may use technical storage or similar technologies where necessary to operate, secure and deliver the website. If our use of cookies, analytics or similar technologies changes, this Privacy Notice and, where required, our consent mechanisms will be updated.

ManaraMED uses appropriate technical and organisational measures designed to protect personal data against unauthorised or unlawful processing and against accidental loss, destruction, alteration, disclosure or access. Access to personal data is limited to persons who require it for legitimate business purposes.

We retain personal data only for as long as reasonably necessary for the purposes for which it was collected and for any additional period required by applicable law or reasonably necessary in connection with the relevant business relationship. The applicable retention period depends on the nature of the information, the relationship concerned, the purpose of processing and any relevant requirements.

Subject to the UAE PDPL and any other applicable data-protection law, you may have rights in relation to your personal data, including the right to:

• obtain information about the personal data we process about you and request access to it;
• request correction or updating of inaccurate personal data;
• request deletion of personal data where the applicable legal conditions are met;
• request restriction or cessation of certain processing;
• request transfer of your personal data where the applicable conditions are met;
• object to certain forms of processing where a right to object is provided by applicable law; and
• withdraw consent where processing is based on consent.

These rights may be subject to conditions, limitations or exceptions under applicable law. To exercise a right or ask a privacy-related question, contact office@manaramed.com. We may need to verify your identity before responding to a request.

If you believe that ManaraMED has processed your personal data in breach of the UAE PDPL, you may lodge a complaint with the UAE Data Office in accordance with the applicable procedures. Where another data-protection law applies to the processing of your personal data, you may also have the right to lodge a complaint with the competent supervisory authority under that law.

We may update this Privacy Notice from time to time to reflect changes in our business activities, processing practices or applicable law. The current version will be made available on our website together with the date of the latest revision.