Privacy Policy of Vita Liberta Corporate Services Provider L.L.C.

Last Updated: 18 August 2025

1. General Provisions

1.1. This Policy has been developed in accordance with UAE Federal Law No. 45 of 2021 on the Protection of Personal Data (PDPL) and its executive regulations, including Cabinet Executive Regulation No. 44 of 2023.

1.2. Key Definitions:

Data Controller: Vita Liberta Corporate Services Provider L.L.C., commercial license No. 120672, registered in the Emirate of Dubai.
Personal Data: Any information relating to an identified or identifiable natural person.
Processing: Any operation performed on personal data, such as collection, storage, and transfer.

2. Data Processing Principles

2.1. We adhere to the following principles of the PDPL:

Lawfulness, fairness, and transparency
Purpose limitation
Data minimization
Accuracy
Storage limitation
Security and confidentiality

3. Categories of Processed Data

3.1. Basic Data:

Identification data (full name, date of birth, nationality)
Contact details (address, email, telephone number)
Financial information (solely for payment processing purposes)

3.2. Special Categories (processed only with explicit consent or as required by law):

Biometric data
Criminal conviction data (only when required by a regulator)

4. Legal Basis for Processing

4.1. Processing is carried out on the following legal grounds:

To perform a contract with the user (Article 5 PDPL)
To comply with a legal obligation (Article 6 PDPL)
Based on the user’s explicit consent (Article 7 PDPL)

5. Data Subject Rights

5.1. In accordance with Article 13 of the PDPL, users have the right to:

Access their personal data
Rectify inaccurate data
Request erasure of data (the “right to be forgotten”)
Restrict processing
Data portability
Object to processing
Withdraw consent at any time

6. International Data Transfer

6.1. In accordance with Article 19 of the PDPL, the transfer of data outside the UAE is only permitted to:

Jurisdictions with an adequate level of data protection
Recipients who provide appropriate contractual safeguards
With the data subject’s explicit consent

7. Security Measures

7.1. We implement stringent security measures, including:

Encryption of data in transit (TLS 1.2+)
Role-based access control
Regular security audits
Data breach response procedures (as mandated by Article 14 PDPL)

8. Data Protection Officer

8.1. Our appointed Data Protection Officer (DPO) is:

Name: Konon S.M.
Email: client@vitaliberta.com
Phone: +971 52 364 9091

9. Complaint Procedure

9.1. Complaints regarding data processing should be directed first to our company at legal@vitaliberta.com.

If unresolved, you have the right to lodge a complaint with the UAE Data Office.

10. Policy Changes

10.1. Any changes to this policy will be published on our website at least 30 days before they take effect. Users will be notified of material changes via:

Email notification
A prominent banner on our website
An updated version number and date on this page