01Introduction and scope
This Privacy Policy explains how IncrementumME FZ-LLC ("we", "us" or "our") processes Personal Data when you visit incrementumme.com (the "Website"), contact us, or deal with us as a prospective client, client, supplier or business contact.
We process Personal Data in accordance with the Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (the "PDPL"), its implementing regulations and decisions, and other applicable laws of the United Arab Emirates ("UAE").
Where you are located outside the UAE and a foreign data protection law applies to our processing of your Personal Data, such as the EU or UK General Data Protection Regulation, we will also respect the rights that law gives you.
This Policy does not apply to websites or services operated by third parties, including those linked from the Website. Please read their privacy notices separately.
02Definitions
- Personal Data
- Any data relating to an identified natural person, or to a natural person who can be identified directly or indirectly, as defined in the PDPL.
- Processing
- Any operation performed on Personal Data, including collection, recording, storage, use, disclosure, transfer, restriction and erasure.
- Controller
- The person who determines the purposes and means of Processing. For the purposes of this Policy, that is IncrementumME.
- Processor
- A person who processes Personal Data on behalf of, and on the instructions of, the Controller.
- Data Office
- The UAE Data Office established under Federal Decree-Law No. 44 of 2021, the authority responsible for supervising compliance with the PDPL.
- Data Subject
- The natural person to whom Personal Data relates.
03Who we are
IncrementumME FZ-LLC, a free zone limited liability company incorporated on 10 September 2024 and registered with the Ras Al Khaimah Economic Zone Authority (RAKEZ), Government of Ras Al Khaimah, under registration number 0000004056055, is the Controller of the Personal Data described in this Policy.
You can contact us about this Policy or about your Personal Data at enquiry@incrementumme.com, marked for the attention of the Data Protection Contact.
04Personal Data we collect
We collect the following categories of Personal Data:
| Category | Examples | Source |
|---|---|---|
| Identity and contact data | Full name, job title, company, country, work email address, telephone number | You, when you submit the consultation form or contact us |
| Enquiry data | The area of your challenge and the problem statement you provide, and our correspondence with you | You |
| Technical data | IP address, browser type and version, device type, operating system, pages requested, date and time of access | Your device, through our hosting provider and font services |
| Preference data | Your cookie choices | Your device, stored in your browser |
| Engagement data | Information exchanged in the course of a client engagement, under the terms of that engagement | You and your organisation |
We do not intentionally collect sensitive Personal Data, such as data revealing racial or ethnic origin, political opinions, religious beliefs, health, biometric or genetic data, or criminal records. Please do not include such data in the problem statement or in any correspondence with us.
If you provide Personal Data about another person, such as a colleague, you confirm that you are authorised to do so and that the person has been informed of this Policy.
05Sources of Personal Data
We collect most Personal Data directly from you. We may also receive business contact details from your colleagues or organisation, from people who refer you to us, at professional events, and from publicly available sources such as company websites, professional networks and public registers.
Where we obtain Personal Data from a third party, we use it only for purposes compatible with those described in this Policy.
06Principles we apply
In line with the PDPL, we process Personal Data fairly, transparently and lawfully; we collect it only for specified and clear purposes; we limit it to what is adequate and necessary for those purposes; we keep it accurate and up to date; we keep it no longer than necessary; and we protect it with appropriate security measures.
Where we combine or analyse data, we use anonymised or aggregated data wherever possible. Data that has been anonymised so that it no longer identifies you is not Personal Data and is not subject to this Policy.
07How and why we use Personal Data
We process Personal Data only for specified, clear and legitimate purposes, and only to the extent necessary for those purposes. The table below sets out each purpose and the legal basis we rely on.
| Purpose | Personal Data used | Legal basis |
|---|---|---|
| Responding to your enquiry and arranging a consultation | Identity and contact data, enquiry data | Your consent, given when you submit the form; and taking steps at your request before entering into a contract |
| Providing our services to clients and managing the relationship | Identity and contact data, engagement data | Performance of a contract with you or your organisation |
| Operating, maintaining and securing the Website | Technical data | Necessary to provide the Website you request and to protect our systems, as permitted under the PDPL |
| Remembering your cookie choices | Preference data | Necessary to give effect to your choice |
| Meeting legal, regulatory and accounting obligations | Any category, as required | Compliance with obligations under UAE law |
| Establishing, exercising or defending legal claims | Any category, as required | Processing permitted under the PDPL for judicial proceedings |
Where we rely on your consent, you may withdraw it at any time. Withdrawal does not affect the lawfulness of Processing carried out before you withdrew it.
We do not sell Personal Data.
We send insights, event invitations or other marketing communications only where you have given your prior consent, or where the law otherwise permits. Every such communication includes a simple way to unsubscribe, and you can withdraw your consent at any time by writing to us.
We do not make decisions about you based solely on automated Processing that produce legal effects concerning you or similarly affect you.
08Disclosure of Personal Data
We disclose Personal Data only where necessary for the purposes in this Policy, and only to:
- service providers acting as our Processors, including our website hosting provider (Vercel Inc.), the provider that delivers consultation form submissions to us by email (Resend, Inc.), our email and productivity providers, and IT support providers, who may process Personal Data only on our documented instructions and under written obligations of confidentiality and security;
- font delivery services (Google Fonts and Fontshare), which receive technical data when your browser downloads fonts used on the Website;
- our professional advisers, such as lawyers, auditors and insurers, under duties of confidentiality;
- courts, public prosecution, regulators, law enforcement or other competent authorities, where we are required or permitted to do so by law; and
- a purchaser, investor or successor entity in connection with a restructuring, merger or sale of all or part of our business, subject to equivalent protections.
We require every recipient to protect Personal Data to a standard at least equivalent to this Policy.
09Cross-border transfers
Some of our service providers store or process Personal Data outside the UAE, including in the United States and the European Union.
We transfer Personal Data outside the UAE only in accordance with Articles 22 and 23 of the PDPL. This means transferring to jurisdictions that the competent authority considers to provide an adequate level of protection or, where that is not the case, relying on a lawful alternative recognised by the PDPL, such as binding contractual commitments that require the recipient to protect the data, or your express consent where appropriate.
You may request more information about the safeguards that apply to a particular transfer by writing to enquiry@incrementumme.com.
10Retention
We keep Personal Data only for as long as necessary for the purpose for which it was collected, and then delete or anonymise it securely.
- Enquiry data: up to 24 months from our last contact with you, unless a client relationship begins.
- Client and engagement records: for the duration of the engagement and afterwards for the period required by UAE commercial, accounting and tax laws.
- Technical data: for the short period set by our hosting provider's logging configuration.
- Preference data: stored in your browser until you clear it.
We may keep Personal Data for longer where required by law or where needed to establish, exercise or defend legal claims.
11Security
We apply appropriate technical and organisational measures to protect Personal Data against unauthorised or unlawful Processing, accidental loss, destruction or damage. These include encryption in transit (HTTPS), access controls limited to personnel who need the data, confidentiality obligations, and due diligence on our service providers.
Where a breach of Personal Data is likely to prejudice the privacy, confidentiality or security of your Personal Data, we will notify the Data Office and, where required, you, within the periods and in the manner required by the PDPL.
No method of transmission over the internet or of electronic storage is completely secure. You are responsible for keeping any credentials you use to communicate with us confidential.
12Your rights
Subject to the conditions and exceptions set out in the PDPL, you have the right to:
- obtain information about the Personal Data we hold about you, the purposes of Processing, the recipients and the retention period;
- receive your Personal Data in a structured, commonly used and machine-readable format, and have it transmitted to another controller where technically feasible;
- request the correction of inaccurate Personal Data and the completion of incomplete Personal Data;
- request the erasure of your Personal Data where it is no longer required for the purpose for which it was collected, where you withdraw consent, or where the Processing is unlawful;
- request the restriction of Processing in the circumstances set out in the PDPL;
- object to or request that we stop Processing your Personal Data, including Processing for direct marketing; and
- object to decisions based solely on automated Processing that produce legal effects concerning you.
To exercise any of these rights, contact us at enquiry@incrementumme.com. We may need to verify your identity before acting on your request. We will respond without undue delay and within any period prescribed by applicable law.
We do not charge a fee for responding to a request unless the PDPL permits us to do so, for example where a request is manifestly unfounded or excessive.
13Your responsibilities
Please keep the Personal Data you give us accurate and tell us if it changes. If you provide Personal Data about another person, you are responsible for having a lawful basis to do so and for informing them of this Policy.
14Complaints
If you have a concern about how we handle your Personal Data, please contact us first so that we can try to resolve it.
You also have the right to lodge a complaint with the UAE Data Office or, if you are located outside the UAE, with the data protection authority in your country of residence.
15Children
The Website is intended for business users. It is not directed at persons under 18 years of age, and we do not knowingly collect their Personal Data. If you believe a minor has provided us with Personal Data, please contact us and we will delete it.
16Changes to this Policy
We may amend this Policy from time to time to reflect changes in our practices or in applicable law. The version number and date at the top of this page indicate when it was last revised.
Where changes are material, we will give notice on the Website before they take effect and, where required by law, seek your consent.
17Language and governing law
This Policy is written in English. Where it is translated into Arabic or another language and there is any inconsistency, the English version prevails to the extent permitted by applicable law.
This Policy is governed by the laws of the Emirate of Ras Al Khaimah and the applicable federal laws of the UAE.
If you have any question about this document, contact enquiry@incrementumme.com. See also our Terms of use and Cookie policy.