Privacy Policy

We are very delighted that you have shown interest in our enterprise. Data protection is of a particularly high priority for the management of The Seed & Foster Foundation. The use of the Internet pages of The Seed & Foster Foundation is possible without any indication of personal data; however, if a data subject wants to use special enterprise services via our website, the processing of personal data may become necessary. If the processing of personal data is necessary and there is no statutory basis for such processing, we generally obtain consent from the data subject.

The processing of personal data, such as the name, address, e-mail address, or telephone number of a data subject shall always be carried out in accordance with the Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data(UAE Data Protection Law), and where applicable, the DIFC Data Protection Law, as well as international data protection principles including the General Data Protection Regulation (GDPR).

Through this data protection declaration, The Seed & Foster Foundation aims to inform the general public of the nature, scope, and purpose of the personal data we collect, use, and process. Furthermore, individuals are informed of their rights under the applicable data protection laws, including the right to access, correct, or request deletion of their personal data, and the right to object to certain types of processing.

As the data controller, The Seed & Foster Foundation has implemented appropriate technical and organizational measures to ensure a high level of security and confidentiality for the personal data processed through this website. Nevertheless, Internet-based data transmissions may be vulnerable to security risks, and absolute protection cannot be guaranteed. For this reason, every data subject is free to transfer personal data to us via alternative means, such as by telephone.

1. Definitions

This data protection declaration is based primarily on the terminology used in the UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data, and where relevant, the DIFC Data Protection Law. Where helpful for clarity and consistency, reference is also made to internationally recognized principles, including those found in the EU General Data Protection Regulation (GDPR).

Our goal is to ensure transparency and ease of understanding so that this policy is clear to the general public, our customers, and business partners. Below are the key terms used throughout this declaration:

a) Personal Data

Personal data refers to any data relating to an identified or identifiable natural person (“data subject”). An identifiable person is someone who can be identified, directly or indirectly, by reference to an identifier such as a name, identification number, location data, online identifier, or by one or more factors specific to their physical, physiological, genetic, mental, economic, cultural, or social identity.

b) Data Subject

A data subject is any natural person whose personal data is processed by Seed & Foster Foundation, acting as the data controller.

c) Processing

Processing refers to any operation or set of operations performed on personal data, whether by automated or non-automated means. This includes collecting, recording, organizing, structuring, storing, adapting or altering, retrieving, consulting, using, disclosing by transmission or dissemination, aligning or combining, restricting, erasing, or destroying personal data.

d) Restriction of Processing

Restriction of processing means the marking of stored personal data to limit its future processing.

e) Profiling

Profiling refers to any form of automated processing of personal data used to evaluate personal aspects relating to a natural person—such as analyzing or predicting behavior, preferences, performance, health, or movements.

f) Pseudonymization

Pseudonymization is the processing of personal data in such a way that the data can no longer be attributed to a specific individual without the use of additional information, provided that such information is kept separately and protected by appropriate technical and organizational measures.

g) Controller

A controller is the natural or legal person, public authority, or entity that determines the purposes and means of the processing of personal data. In this context, Seed & Foster Foundation acts as the controller.

h) Processor

A processor is a party that processes personal data on behalf of the controller and in accordance with its instructions.

i) Recipient

A recipient is any individual or organization to whom personal data is disclosed, whether or not they are a third party. Governmental authorities that receive data in accordance with UAE law are not considered recipients when acting within their official capacity.

j) Third Party

A third party is any individual or entity other than the data subject, controller, processor, or persons who, under the direct authority of the controller or processor, are authorized to process personal data.

k) Consent

Consent is a clear, freely given, specific, informed, and unambiguous indication by the data subject, by which they agree to the processing of personal data concerning them—whether by written statement, electronic confirmation, or other affirmative action.

2. Name and Address of the Controller

The controller responsible for the processing of personal data under the Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (UAE Data Protection Law), and where applicable, the DIFC Data Protection Law, is:

The Seed & Foster Foundation

Unit IH-00-01-02-OF-01, Level 2

Dubai International Financial Centre

Dubai, United Arab Emirates

License Number: OL10156

Email: service@seed-foster.com

Website: www.seed-foster.com

3. Cookies

The Internet pages of Seed & Foster Foundation use cookies and similar technologies to enhance user experience, analyze website usage, and support the delivery of our services.

Cookies are small text files that are stored on a user’s device by their web browser. These files allow the website to recognize the user’s browser and remember certain information, such as user preferences or login status.

Many websites use cookies for legitimate purposes. A cookie typically contains a unique identifier, which helps websites and servers distinguish one browser from another. This enables us to optimize our content and provide features tailored to individual user behavior.

Through the use of cookies, Seed & Foster Foundation aims to provide users with a more convenient and efficient browsing experience. For example, cookies may allow returning users to remain logged in or enable the retention of items in a shopping cart.

Cookies also assist in understanding how visitors interact with our website, allowing us to improve the design and functionality of our pages based on aggregate analytics.

Users have the ability to manage or disable cookies at any time through their web browser settings. Most browsers allow users to delete cookies already stored, block future cookies, or receive notifications before a cookie is placed. Please note that disabling cookies may affect the functionality and features of our website, and some services may not operate as intended.

By continuing to use our website without adjusting cookie settings, you consent to the use of cookies in accordance with this policy and the applicable data protection laws of the United Arab Emirates, including the Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data. Where applicable, we also align with the standards of other jurisdictions, such as the DIFC Data Protection Law and GDPR, for users in those regions.

4. Collection of General Data and Information

When a user or automated system accesses the website of Seed & Foster Foundation, a range of general data and technical information is automatically collected and stored in server log files. This information may include:

• The type and version of the browser used

• The operating system of the accessing device

• The referring website (referrer URL)

• Sub-pages visited on our website

• The date and time of access

• The user’s Internet Protocol (IP) address

• The Internet service provider used to access the website

• Other technical data and diagnostic information relevant for system security

This data is collected automatically and does not, by itself, identify the individual user. Seed & Foster Foundation does not draw conclusions about specific individuals from this information.

The primary purposes for collecting this general information are to:

• Ensure the stable and secure operation of our website

• Monitor and improve our website’s performance and user experience

• Detect, prevent, and investigate cyber threats or unauthorized access

• Support compliance with applicable legal obligations, including the provision of information to law enforcement authorities if required

The analysis of such data is conducted on an aggregated and anonymized basis, solely for the purpose of improving our security posture and the functionality of our digital services.

All log file data is stored separately from any personal data voluntarily provided by users, and is retained only for as long as is necessary for the purposes outlined above, in accordance with applicable data protection laws in the United Arab Emirates, including Federal Law No. 45 of 2021, and, where relevant, the DIFC Data Protection Law.

5. Contact Possibility via the Website

The website of Seed & Foster Foundation provides users with the ability to quickly contact us electronically, including through a general email address or via a contact form. When a user chooses to reach out to us through one of these channels, any personal data voluntarily submitted—such as name, email address, phone number, or message content—will be collected and securely stored.

This data is used solely for the purpose of responding to the inquiry, processing the request, or engaging in further communication initiated by the user. The processing of this personal data is carried out in accordance with the lawful bases defined under applicable data protection laws in the United Arab Emirates, including the Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data, and, where applicable, the DIFC Data Protection Law.

No personal data collected through contact forms or email communication will be shared with third parties without the express consent of the data subject, unless such disclosure is required to fulfill a lawful obligation.

All such personal data is stored securely and retained only for as long as necessary to fulfill the purpose for which it was collected, after which it is securely deleted or anonymized in accordance with our data retention policy.

6. Routine Erasure and Retention of Personal Data

Seed & Foster Foundation processes and stores personal data only for as long as necessary to fulfill the purpose for which it was collected, or as required under applicable laws and regulations of the United Arab Emirates, including the Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data, and, where applicable, the DIFC Data Protection Law.

Once the purpose for data storage no longer applies, or if a legally mandated retention period has expired, the personal data is securely deleted or anonymized, in accordance with our internal data retention policy and relevant legal obligations.

We take appropriate measures to ensure that personal data is not retained for longer than necessary and that it is securely handled throughout its lifecycle. Where required, data may be blocked from further processing instead of being erased—particularly in cases where continued retention is needed to meet legal, regulatory, or contractual obligations.

7. Rights of the Data Subject

Under the applicable data protection laws of the United Arab Emirates, individuals whose personal data is processed by Seed & Foster Foundation have the following rights:

a) Right to Confirmation

Data subjects have the right to obtain confirmation as to whether or not personal data concerning them is being processed by Seed & Foster Foundation. If a data subject wishes to exercise this right, they may contact us at any time.

b) Right of Access

Data subjects have the right to request access to their personal data stored by Seed & Foster Foundation. Upon request, we will provide information regarding:

• The purposes of the processing

• The categories of personal data processed

• The recipients or categories of recipients to whom the data has been or will be disclosed

• The expected retention period or the criteria used to determine it

• The rights of the data subject regarding rectification, erasure, restriction, or objection

• Information about the source of data if it was not collected directly from the data subject

• Whether the data is subject to international transfer, and the safeguards in place for such transfer (if applicable)

• Whether automated decision-making, including profiling, is involved (if applicable), and relevant information about the logic, significance, and consequences

Requests for access can be made at any time by contacting us.

c) Right to Rectification

Data subjects have the right to request the rectification of inaccurate personal data and the completion of incomplete data, taking into account the purposes of processing.

d) Right to Erasure

Data subjects have the right to request the deletion of their personal data, without undue delay, under certain circumstances, including but not limited to:

• The data is no longer necessary for the purposes for which it was collected

• The data subject withdraws consent (where applicable), and there is no other legal ground for processing

• The data has been unlawfully processed

• The data must be erased to comply with a legal obligation under applicable UAE laws

If the data has been made public, Seed & Foster Foundation will take reasonable steps, including technical measures, to inform other processors of the request for erasure.

e) Right to Restriction of Processing

Data subjects have the right to request the restriction of processing if:

• The accuracy of the data is contested

• The processing is unlawful and the data subject opposes erasure

• The controller no longer needs the data for processing purposes, but the data is required for legal claims

• The data subject has objected to processing, and verification is pending

f) Right to Data Portability

Where technically feasible, and where the processing is based on consent or a contractual necessity, data subjects have the right to receive their personal data in a structured, commonly used, and machine-readable format and to transmit it to another controller.

g) Right to Object

Data subjects have the right to object to the processing of their personal data, including for direct marketing purposes or where the processing is based on legitimate interest. If an objection is made, Seed & Foster Foundation will stop processing the data unless there are compelling legitimate grounds or the processing is necessary for legal claims.

h) Rights Related to Automated Decision-Making and Profiling

Data subjects have the right not to be subject to a decision based solely on automated processing, including profiling, that significantly affects them. If such processing is necessary for entering into or performing a contract, or is based on consent, appropriate measures will be taken to safeguard the rights of the data subject, including the right to human intervention.

i) Right to Withdraw Consent

Where processing is based on consent, the data subject has the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out prior to withdrawal.

8. Legal Basis for the Processing

Seed & Foster Foundation processes personal data in accordance with the applicable legal bases set out under the Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data in the United Arab Emirates, and, where relevant, the DIFC Data Protection Law.

We may process personal data under one or more of the following legal grounds:

• Consent: Where we have obtained the clear and explicit consent of the data subject for a specific purpose. This applies, for example, when a user subscribes to a newsletter or submits information via a contact form.

• Contractual necessity: Where the processing is necessary for the performance of a contract to which the data subject is a party, or in order to take steps at the request of the data subject prior to entering into a contract. For example, when fulfilling orders, processing payments, or providing services.

• Legal obligation: Where the processing is necessary to comply with legal obligations applicable to Seed & Foster Foundation, such as tax, accounting, regulatory reporting, or anti-fraud requirements.

• Vital interests: In rare situations, we may process personal data to protect the vital interests of the data subject or another individual—for example, in the case of a medical emergency requiring disclosure of health-related information.

• Legitimate interests: Where the processing is necessary for the legitimate interests of Seed & Foster Foundationor a third party, provided that such interests are not overridden by the interests or fundamental rights and freedoms of the data subject. This may include activities such as internal administrative purposes, website security, fraud prevention, or improving user experience.

We ensure that all processing activities are proportionate, transparent, and consistent with the rights of data subjects under the applicable UAE data protection laws.

9. The Legitimate Interests Pursued by the Controller or by a Third Party

Where the processing of personal data is based on the legitimate interests of the controller or a third party under Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data, the legitimate interest of Seed & Foster Foundationis to carry out its operations in a manner that supports the well-being of its employees, partners, and stakeholders, while ensuring operational efficiency, security, and service quality.

10. Period for Which the Personal Data Will Be Stored

The period for which personal data is stored is determined based on the purpose of the processing and any statutory or regulatory retention obligations under UAE law. Once the purpose has been fulfilled, or the applicable retention period has expired, the personal data is securely deleted or anonymized, unless further storage is required to comply with legal obligations or for the establishment, exercise, or defense of legal claims.

12. Existence of Automated Decision-Making

As a responsible organization, Seed & Foster Foundation does not engage in automated decision-making or profiling that produces legal effects or similarly significant impacts on individuals.

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