Please read this Privacy Policy carefully. It explains how Inovista FZCO collects, uses, stores, and protects your personal data when you visit the PAWRFL website and register your interest for early access to the PAWRFL service.
1. Introduction and Data Controller
1.1 This Privacy Policy ("Policy") sets out how INOVISTA FZCO ("Inovista", "PAWRFL", "we", "us", or "our"), a free-zone company established in Dubai Silicon Oasis, Dubai, United Arab Emirates, collects, uses, stores, discloses, and protects your personal data when you access or use the PAWRFL website at www.pawrfl.com and any associated systems (the "Website").
1.2 PAWRFL is a pet longevity platform operated by Inovista FZCO. The PAWRFL service is in development and is not yet available; the Website currently provides information about the forthcoming service and allows you to register your interest for early access.
1.3 For the purposes of applicable data protection legislation, Inovista FZCO is the "data controller" in respect of the personal data processed through the Website. We determine the purposes and means of processing your personal data.
1.4 This Policy forms an integral part of our Terms and Conditions ("Terms"). Capitalised terms used but not defined in this Policy have the meanings given to them in the Terms.
1.5 By using the Website and submitting your details, you acknowledge that you have read and understood this Policy. If you do not agree with it, please do not use the Website.
2. Applicable Data Protection Framework
2.1 Our collection, storage, processing, and use of personal data is carried out in compliance with Federal Decree-Law No. 45 of 2021 concerning the Protection of Personal Data (the UAE Personal Data Protection Law, "PDPL") and its implementing regulations, as overseen by the UAE Data Office.
2.2 Inovista FZCO is established in Dubai Silicon Oasis. As Dubai Silicon Oasis does not operate a separate data protection regime of its own (unlike the financial free zones of the DIFC and ADGM), the federal PDPL is the data protection law applicable to our processing of personal data.
3. Personal Data We Collect
3.1 We collect and process the following categories of personal data in connection with the Website:
Contact Data — the email address you provide when you register your interest for early access.
Technical and Usage Data — when you visit the Website, we collect limited technical information such as your IP address, browser type and version, device type, and how you interact with the Website (such as pages viewed and traffic source). This is collected through standard server logs and through analytics tools, namely Google Analytics (see Clause 6).
3.2 We do not intentionally collect any sensitive or special categories of personal data through the Website.
4. How We Collect Your Data
4.1 Data you provide directly — we collect the email address you submit when you register your interest for early access, and any information you provide when you contact us.
4.2 Data collected automatically — when you access the Website, Technical and Usage Data may be collected through standard server logs, strictly necessary cookies, and analytics cookies (Google Analytics), as described in Clause 6. Analytics cookies are only set with your consent.
5. Purposes and Legal Basis for Processing
5.1 We process your personal data for the following purposes and on the following legal bases under the PDPL:
| Purpose | Legal Basis |
|---|---|
| Registering you on the PAWRFL early-access waitlist | Consent |
| Contacting you about the launch, early-access opportunities, and updates | Consent |
| Sending marketing communications where you have opted in | Consent |
| Operating, maintaining, securing, and improving the Website | Legitimate interest (service administration) |
| Complying with applicable legal and regulatory obligations | Legal obligation |
5.2 Where processing is based on your consent, you may withdraw that consent at any time in accordance with Clause 11. Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.
6. Cookies and Tracking Technologies
6.1 The Website uses cookies and similar technologies, which fall into two categories: (a) strictly necessary cookies, required for the basic operation of the Website; and (b) analytics cookies, which help us understand how visitors use the Website.
6.2 We use Google Analytics, a web analytics service provided by Google LLC, to understand how visitors interact with the Website — for example, which pages are viewed, time spent on the Website, and where visitors arrive from. Google Analytics sets cookies that collect this information. For more information on how Google uses data, please refer to Google's Privacy Policy.
6.3 Analytics cookies are only set after you provide consent. When you first visit the Website, you will be presented with a cookie consent banner allowing you to accept or decline non-essential cookies. You can change or withdraw your choice at any time through your browser settings. Strictly necessary cookies do not require consent, as they are essential to the operation of the Website.
7. Sharing and Disclosure
7.1 We may share your personal data with the following categories of recipients, solely for the purposes described in this Policy:
Service Providers (Processors) — including our email and marketing platform, Brevo (operated by Sendinblue SAS); our website analytics provider, Google Analytics (operated by Google LLC); our website hosting provider; and other providers that support the operation of the Website. These providers are permitted to process your personal data only on our instructions and for the purposes we specify.
Legal and Regulatory Recipients — where we are required to disclose data by applicable law, regulation, court order, or a request from a competent authority.
Business Transfers — in connection with any merger, acquisition, financing, or sale of assets.
7.2 We do not sell, rent, or trade your personal data.
7.3 All third parties with whom we share personal data are bound by obligations of confidentiality and data protection and are required to process personal data only for the specified purposes.
8. International Data Transfers
8.1 Some of our service providers store or process personal data on servers located outside the United Arab Emirates. In particular, our email and marketing platform, Brevo, stores and processes personal data on servers located in the European Union, and Google Analytics may process data on servers located in the United States and other countries in which Google LLC operates. Where we transfer personal data outside the UAE, we take steps to ensure that the data continues to receive an adequate level of protection consistent with the PDPL.
9. Data Storage and Security
9.1 We implement appropriate technical and organisational measures to protect personal data against unauthorised access, alteration, disclosure, destruction, or accidental loss, including encryption in transit, access controls limiting data to authorised personnel, and contractual data protection obligations on our service providers.
9.2 No method of transmission over the internet or method of electronic storage is completely secure, and we cannot guarantee absolute security.
9.3 In the event of a personal data breach likely to result in a risk to your rights and freedoms, we will notify the UAE Data Office and, where required, affected individuals, without undue delay and in accordance with the PDPL.
10. Data Retention
10.1 We retain your email address and related data for as long as necessary to fulfil the purposes set out in this Policy. Specifically, we retain early-access registration data until the launch of the PAWRFL service and for twenty-four (24) months thereafter, unless you withdraw your consent or request deletion sooner.
10.2 Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymised.
11. Your Rights
11.1 Subject to the conditions and exceptions in the PDPL, you may have the right to:
- Access — request confirmation of whether we process your personal data and obtain a copy of it;
- Rectification — request the correction of inaccurate or incomplete personal data;
- Erasure — request the deletion of your personal data;
- Restriction / Objection — request that we restrict, or object to, certain processing of your personal data;
- Data Portability — request the transfer of your personal data in a structured, commonly used, machine-readable format, where technically feasible;
- Withdraw Consent — withdraw your consent at any time, without affecting the lawfulness of prior processing.
11.2 To exercise any of these rights, please contact us at info@pawrfl.com. We may need to verify your identity before responding, and we will respond within thirty (30) days of receiving your request.
11.3 If you are not satisfied with our response, you have the right to lodge a complaint with the UAE Data Office.
12. Marketing Communications
12.1 Where you have provided your email address to join the early-access list, you consent to receive communications from us about the launch of PAWRFL, early-access opportunities, and related updates.
12.2 You can opt out of marketing communications at any time by clicking the "unsubscribe" link in any email we send, or by contacting us at info@pawrfl.com. Opting out does not affect the lawfulness of processing carried out before you opted out.
13. Children's Privacy
13.1 The Website and the PAWRFL service are intended for adults (18 years and over) and are not directed at children. We do not knowingly collect personal data from minors. If you believe a minor has provided us with personal data, please contact us so that we can delete it.
14. Third-Party Links and Services
14.1 The Website may contain links to third-party websites or services that are not owned or controlled by us. This Policy does not apply to those third parties, and we are not responsible for their privacy practices. We encourage you to review their privacy policies.
15. Changes to This Policy
15.1 We may amend this Policy from time to time to reflect changes in our practices or legal requirements. When we do, we will revise the "Last Updated" date above, and where changes are material we will take reasonable steps to notify you.
15.2 Your continued use of the Website following the effective date of any amendment constitutes your acceptance of the revised Policy.
16. Contact and Complaints
16.1 If you have any questions, concerns, or requests regarding this Policy or our data protection practices, please contact:
Building A1, Dubai Digital Park, Dubai Silicon Oasis, Dubai, United Arab Emirates
Email: info@pawrfl.com
16.2 If you are not satisfied with our response, or if you believe we have processed your personal data inconsistently with applicable data protection law, you have the right to lodge a complaint with the UAE Data Office (www.dataoffice.gov.ae).