1. DATA CONTROLLER INFORMATION

Legal Name: Kydyrbekkyzy Rauan
Business Type: Freezone Company
Jurisdiction: Dubai
Business Activity: Digital Subscription
Contact Email (Privacy & Compliance): [email protected]
Business Location: Dubai

For the purposes of applicable data protection laws, Kydyrbekkyzy Rauan acts as the Data Controller.
2. APPLICABLE LAWS & REGULATIONS

This Privacy Policy is designed to comply with:

• European Union

  • General Data Protection Regulation (GDPR)

• United States (California)

  • California Consumer Privacy Act (CCPA)

  • California Privacy Rights Act (CPRA)

• Messaging & Telecommunications

  • A2P 10DLC requirements

  • CTIA and carrier guidelines

3. PERSONAL DATA WE COLLECT

3.1 Data You Provide Directly

We may collect the following categories of personal data:

• Full name

• Email address

• Phone number (including SMS-enabled numbers)

• Country, state/province, and city

• Business name, industry, and role

• Business structure and operational information (as voluntarily provided)

• Business processes, workflows, systems, and documentation shared during consulting

• Intake forms, assessments, project notes, and communications

• Communication preferences

• Any other information you voluntarily provide during consultations or sessions

3.2 Automatically Collected Data

When you visit our website or interact with our systems, we may automatically collect:

• IP address

• Device and browser information

• Log data and timestamps

• Cookies and similar tracking technologies

4. PURPOSES OF PROCESSING

Personal data is collected and processed for the following purposes:

• Provision of Services: To provide access to the AI-powered assistant, perform the "wave check-up" analysis based on your uploaded photos, and grant access to the digital library and community platform.

• Payment Processing: To facilitate secure transactions via our third-party payment processor (Stripe), verify your subscription status, and manage renewals or refunds.

• Account Management: To create and maintain your user profile, send password resets, and provide technical support.

• Communication: To send you essential service updates, administrative notifications, and responses to your inquiries sent to [email protected].

• Service Improvement: To analyze how users interact with the AI tool and community content in order to improve the accuracy of our algorithms and the quality of our educational materials.

• Legal Compliance: To comply with applicable laws, tax requirements (such as issuing invoices), and to protect against fraudulent or unauthorized transactions.

5. LEGAL BASES FOR PROCESSING (GDPR)

For individuals located in the European Union, personal data is processed based on:

• Consent (email and SMS marketing communications)

• Contractual necessity (delivery of consulting services)

• Legitimate interests (business operations and service improvement)

• Legal obligations (record-keeping and compliance)

6. EMAIL & SMS MARKETING

6.1 Types of Communications

We may send:

• Transactional messages (appointments, confirmations, reminders)

• Service-related communications

• Educational content

• Marketing and promotional messages

6.2 Consent & Opt-In

We collect explicit consent before sending marketing emails or SMS messages.

Consent may be collected through:

• Website or landing page forms

• CRM intake and onboarding forms

• Booking systems

• Explicit opt-in checkboxes

• SMS keyword opt-in mechanisms

6.3 SMS & A2P 10DLC COMPLIANCE

All SMS communications comply with:

• A2P 10DLC regulations

• Applicable telecommunications laws

• GDPR and CCPA/CPRA where applicable

Key principles:

• No cold or unsolicited SMS messages

• No purchased, rented, or scraped contact lists

• Message frequency disclosed at opt-in

• Message and data rates may apply

• Opt-out instructions included in every message (e.g., “Reply STOP to unsubscribe”)

No mobile information will be shared with third parties for marketing purposes without explicit consent.

6.4 Opt-Out

You may opt out at any time by:

• Clicking the “unsubscribe” link in emails

• Replying “STOP” to SMS messages

• Contacting us at [email protected]

7. GO HIGH LEVEL CRM & DATA PROCESSING

We use Go High Level CRM to manage:

• Client records and communication history

• Email marketing and transactional communications

• SMS messaging and calling logs

• Scheduling and workflow automation

Go High Level acts as a Data Processor and processes personal data only on our behalf and under our instructions.

Appropriate technical and organizational safeguards are in place to protect personal data.

8. CALLING, SMS & CRM COMMUNICATIONS

Through Go High Level, we may:

• Send one-to-one SMS communications

• Send consent-based marketing and informational messages

• Place outbound calls related to services

All communications are conducted in accordance with applicable laws and carrier requirements.

9. REBUNDLING / RE-REGISTRATION

In the event of changes to CRM platforms, messaging providers, routing, or rebundling:

• Existing user consent remains valid unless withdrawn

• Personal data continues to be protected under this Privacy Policy

• No new or undisclosed purposes of processing are introduced

10. DISCLOSURE OF PERSONAL DATA

We may disclose personal data only:

• To trusted service providers acting on our behalf

• To comply with legal or regulatory obligations

• To protect our rights, safety, or property

• With your explicit consent

We do not sell personal data.

11. DATA RETENTION

Personal data is retained only for as long as necessary to:

• Provide services

• Fulfill contractual and legal obligations

• Resolve disputes

• Enforce agreements

12. DATA SECURITY

We implement appropriate technical and organizational measures, including:

• Secure CRM and data storage systems

• Access controls and data minimization

• Confidentiality obligations

13. YOUR DATA PROTECTION RIGHTS

13.1 UAE

You have the right to:

• Access your personal data

• Request correction or deletion

• Withdraw consent where processing is based on consent

• Object to unlawful processing

13.2 European Union (GDPR)

You have the right to:

• Access, rectify, or erase personal data

• Restrict or object to processing

• Data portability

• Withdraw consent at any time

• Lodge a complaint with a supervisory authority

13.3 California (CCPA / CPRA)

You have the right to:

• Know what personal data is collected

• Request deletion or correction

• Opt out of data sharing (if applicable)

• Not be discriminated against for exercising your rights

14. INTERNATIONAL DATA TRANSFERS

Personal data may be transferred and processed outside your country of residence.
Appropriate safeguards are implemented to protect such transfers.

15. CHILDREN’S PRIVACY

Our services are intended for individuals 18 years of age or older.
We do not knowingly collect personal data from minors.

16. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time.
Any changes will be posted with an updated “Last Updated” date.

17. CONTACT INFORMATION

For privacy-related questions or requests:

📧 Email: [email protected]
📍 Jurisdiction: Dubai

COMPLIANCE STATEMENT

This Privacy Policy is designed to meet:

• Law of Dubai on Personal Data Protection

• GDPR requirements

• CCPA / CPRA obligations

• A2P 10DLC messaging standards