Effective date: 22 June 2026 · Last updated: 22 June 2026
1. Introduction and who we are
Welcome to the Privacy Policy of Neovara L.L.C-FZ (“Neovara”, “we”, “us”, “our”), Licence No. 2421703.01.
We are an AI and data consultancy and back-office-as-a-service company established in the United Arab Emirates. We are committed to protecting and respecting your privacy and personal data in accordance with the UAE Personal Data Protection Law — Federal Decree-Law No. 45 of 2021 (the “PDPL”) and its implementing regulations.
We are based in Dubai, UAE, and work with a delivery team across the UK, UAE, Philippines and India.
2. Scope — when we are a “controller” and when we are a “processor”
Because we are a data consultancy, it is important to distinguish two situations:
Where we are the data controller. This Privacy Policy governs personal data for which we decide the purposes and means of processing — principally data about our website visitors, prospects, clients’ representatives, marketing subscribers, suppliers and business contacts.
Where we are a data processor. When we clean, structure, migrate, analyse or otherwise process personal data contained in our clients’ systems on their behalf as part of a project, the client is the controller and we act as their processor. That processing is governed by the services agreement and data processing agreement (DPA) between us and the client — not by this Privacy Policy. We process such data only on the client’s documented instructions.
This Privacy Policy covers the first situation (Neovara as controller).
3. The personal data we collect
We may collect, use, store and transfer the following categories of personal data:
- Identity data — first name, last name, job title, the organisation you represent.
- Contact data — email address, telephone number, business address.
- Enquiry / booking data — the content of messages you send us, and details you provide when booking a consultation.
- Marketing and communications data — your marketing preferences and subscription status.
- Technical and usage data — IP address, browser type/version, device information, and how you interact with our website, collected via cookies and similar technologies (see section 7).
- Client relationship and billing data — where you are (or represent) a client: records of engagements, correspondence, and invoicing/payment details necessary to provide and bill for our services.
We do not seek to collect special categories of personal data (such as data revealing health, religious belief or similar) through our website, and ask that you do not submit such data to us via our forms.
4. How we collect your data
- Directly from you — when you complete a form, book a call, email us, subscribe, or engage us as a client.
- Automatically — via cookies and analytics when you use our website (section 7).
- From third parties — e.g. our CRM, analytics and booking providers (section 8), and publicly available professional sources (such as LinkedIn or company websites) for legitimate business-development purposes.
5. How and why we use your data (purposes and lawful bases)
Under the PDPL we process personal data on the basis of your consent and/or the other lawful bases the PDPL permits (such as performance of a contract, compliance with a legal obligation, or our legitimate interests). The table below summarises how we use your data and the basis we rely on.
| Purpose | Lawful basis (UAE PDPL) |
|---|---|
| Respond to enquiries and arrange consultations | Steps prior to a contract; legitimate interests / consent |
| Provide our services and manage the client relationship | Performance of a contract |
| Invoicing, payments and record-keeping | Performance of a contract; legal obligation |
| Send marketing communications (where you have opted in) | Consent |
| Business development and relationship management | Legitimate interests / consent |
| Operate, secure and improve our website (incl. analytics) | Legitimate interests; consent for non-essential cookies |
| Comply with legal and regulatory obligations | Legal obligation |
Where we rely on consent, you may withdraw it at any time (section 12).
6. Marketing
Where you have opted in, we may send you relevant insights and updates. You can unsubscribe at any time via the link in our emails or by contacting hello@neovara.io. If you opt out, we will retain the minimum data needed to ensure we do not contact you again.
7. Cookies and analytics
Our website uses strictly necessary cookies and, with your consent, analytics cookies (such as Google Analytics via Google Tag Manager) to understand and improve how the site is used. When you first visit, our cookie banner lets you accept or reject non-essential cookies, and you can change your choice at any time. Most browsers also let you block or delete cookies. We do not operate a separate Cookie Policy; cookie information is provided here and in the consent banner.
8. Sharing your data and our service providers
We do not sell your personal data. We share it with trusted service providers (“processors”) who act on our instructions, including:
- CRM, forms and booking — HubSpot.
- Website hosting — Amazon Web Services (AWS Amplify).
- Analytics & tag management — Google Analytics 4 and Google Tag Manager.
- Email and productivity — Microsoft 365.
We may also share personal data with professional advisers, and with authorities or other parties where required by law, regulation or legal process, or in connection with a sale or reorganisation of our business. All processors are bound by contract to protect personal data and use it only as instructed.
9. International data transfers
We work with a delivery team in the Philippines and India, and some of our service providers are based in the EU and UK. The PDPL permits transfers of personal data outside the UAE where the destination jurisdiction provides an adequate level of protection, or — where it does not — where appropriate safeguards or contractual protections are in place, or with your consent. We apply such safeguards to our international transfers.
10. How long we keep your data
We retain personal data only for as long as necessary for the purposes set out above, including to satisfy legal, accounting, tax or reporting requirements, and may retain data longer where there is a complaint or a realistic prospect of litigation.
11. Data security
We implement appropriate technical and organisational measures — including access controls, encryption where appropriate, staff confidentiality obligations and training, and incident-response procedures — to protect personal data against unauthorised access, loss or misuse. In the event of a personal data breach, we will notify the UAE Data Office and affected individuals where required by the PDPL. No transmission over the internet is fully secure, so we cannot guarantee absolute security.
12. Your rights
Subject to the PDPL, you have the right to: be informed about how your data is processed; access your data; request rectification of inaccurate or incomplete data; request erasure; restrict or stop processing; request data portability; object to processing (including direct marketing and automated processing); and withdraw consent at any time.
To exercise any right, contact hello@neovara.io. We will respond within the timeframe required by the PDPL, and may need to verify your identity first. If you are unhappy with how we handle your data, you may lodge a complaint with the UAE Data Office.
13. AI and your data
As an AI consultancy, we use AI tools responsibly. We do not use your personal data, or personal data contained in our clients’ data that we process, to train publicly available or third-party AI models, and we do not input client confidential or personal data into public AI tools except under controls agreed with the client.
14. Children
Our website and services are directed at businesses, not children. We do not knowingly collect personal data relating to children.
15. Changes to this policy
We keep this Privacy Policy under review and will post any updates on this page, indicated by the “Last updated” date. Continued use of our website after changes constitutes acceptance of the updated policy.
16. Contact us
Neovara L.L.C-FZ (Licence No. 2421703.01) · Email: hello@neovara.io · Dubai office: Vision Tower, Business Bay, Dubai · neovara.io