Privacy Policy

Meena Business Consultancy Services F.Z.C.

1. Who we are

This Privacy Policy explains how Meena Business Consultancy Services F.Z.C. (“Meena”, “we”, “us” or “our”), a company registered in Ajman Free Zone, United Arab Emirates, with its registered office at Building C1, Ajman Free Zone, UAE, collects, uses, discloses and protects personal data when you visit meenasonline.com, use the Meena Circle or Meena Events applications, or otherwise interact with us (together, the “Online Offerings”).

Meena is the data controller for the personal data described in this Policy, unless stated otherwise. If you have any questions about this Policy or how we handle your personal data, contact us using the details in Section 12.

2. Personal data we collect

Depending on how you interact with us, we may collect:

• Contact details: name, email address, telephone number, job title, company name;
• Information you submit through forms, consultation bookings, the Meena Circle or Meena Events apps, support requests, surveys or comments;
• Business and trade information you provide in connection with market-entry, matching, trade-finance or grant/fund services (e.g. company registration details, trade documentation, tender interests);
• Technical and usage information: IP address, device and browser type, pages visited, referral source, and date/time of visits, collected via cookies and similar technologies (see Section 4); and
• Where relevant to compliance screening or trade-finance facilitation: business registration numbers, and information from publicly available business/trade registers.

We do not knowingly collect special categories of sensitive personal data (e.g. health, biometric or genetic data) through the Online Offerings, and ask that you do not submit such data to us unless specifically requested.

3. How we use personal data and our legal basis

We process personal data for the following purposes:

• To operate, secure and improve the Online Offerings, including your Meena Circle account where applicable;
• To respond to enquiries, book and manage consultations, and deliver the market-entry, trade-matching, trade-finance and grants/funds services you request;
• To verify your identity and carry out due diligence, sanctions and compliance checks where required for cross-border trade and finance facilitation;
• To send you marketing communications, newsletters, event and delegation invitations, where you have consented or as otherwise permitted by law, and to run customer-satisfaction surveys (see Section 6);
• To meet our legal and regulatory obligations, including export control, anti-money-laundering and sanctions compliance; and
• To establish, exercise or defend legal claims, and to prevent fraud or misuse of the Online Offerings.

Our legal bases for these purposes are, as applicable: performance of a contract with you or your organisation, compliance with a legal obligation, our legitimate interests (e.g. improving and securing our services, preventing fraud), and your consent (e.g. for marketing communications and non-essential cookies), which you may withdraw at any time.

4. Cookies and similar technologies

The Online Offerings use cookies and similar technologies. Where cookies are not strictly necessary, we ask for your consent before they are set, through a cookie banner presented on your first visit. Full details of the categories of cookies we use, their purpose, duration, and how to manage your preferences, are set out in our separate Cookie Policy, available at meenasonline.com/cookie-policy.

5. Business partners

Where you act as a contact for a (prospective) client, supplier, distributor, partner, embassy, trade or investment agency (a “Business Partner”), we process your business contact details, and information relating to the project, order, tender, financing or compliance-screening context, to manage that relationship, deliver services, and meet our legal and compliance obligations.

6. Marketing and customer satisfaction

Where permitted by law, we may use your contact details for direct marketing (e.g. trade fair and delegation invitations, newsletters, service updates) and customer satisfaction surveys. You can object or withdraw consent at any time by writing to management@meenasonline.com or using the unsubscribe link in our communications.

7. Who we share personal data with

We may share personal data with:

• Group companies and affiliates, and business partners such as government trade and investment agencies, financing institutions or on-the-ground partners, where necessary to deliver the requested service;
• Service providers who process data on our behalf (e.g. hosting, IT support, email, CRM, analytics, and scheduling providers such as Bitrix24), under contractual confidentiality and data-protection obligations; and
• Regulators, law enforcement or other third parties where required by law, or to establish, exercise or defend legal claims.

Where personal data is transferred outside the country in which you are located, including from the UAE to the EU, GCC states, Iraq or Pakistan and vice versa, we use appropriate safeguards, such as standard contractual clauses, an assessed adequate level of protection, or your explicit consent, consistent with the UAE PDPL, GDPR and other applicable transfer rules.

8. Data retention

We keep personal data only as long as necessary for the purposes described in this Policy, or as required by applicable law (for example, commercial, tax, anti-money-laundering or export-control record-keeping obligations, which commonly require retention for several years after the end of a business relationship). Marketing consent-based data is kept until you withdraw consent. Unless indicated otherwise at the time of the collection of your personal data (e.g. within a form completed by you), we erase your personal data if the retention of that personal data is no longer necessary for the purposes for which they were collected or otherwise processed, or to comply with legal obligations (such as retention obligations under tax or commercial laws).

9. Your rights

Your rights depend on where you are located and which law applies to the processing of your personal data.

9.1 United Arab Emirates, PDPL

If the UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (“PDPL”) and its Executive Regulation (Cabinet Decision No. 33 of 2024) apply to you, you have the right to: be informed of the processing of your personal data; access and obtain a copy of your data; request correction or erasure; restrict or object to processing, including for direct marketing; withdraw consent at any time; request data portability; and lodge a complaint with the UAE Data Office.

9.2 European Economic Area, GDPR

If the General Data Protection Regulation applies to you, you have the right to access, rectify, erase or restrict your personal data, to data portability, to object to processing (including profiling and direct marketing), to withdraw consent at any time, and to lodge a complaint with your local data protection supervisory authority.

9.3 Saudi Arabia, PDPL

If the Saudi Personal Data Protection Law (Royal Decree No. M/19/2021, as amended) applies to you, you have rights to access, correct and request destruction of your personal data, to be informed of the purposes of collection, and to file a complaint with the Saudi Data & AI Authority (SDAIA).

9.4 Qatar, Law No. 13 of 2016

If Qatar’s Personal Data Privacy Protection Law (Law No. 13 of 2016) applies to you, you have the right to access your personal data, request correction, and object to processing that causes damage or distress, and may complain to the Compliance and Data Protection Department at the Ministry of Transport and Communications.

9.5 United States, CCPA/CPRA

If you are a California resident, you have the right to: know what personal information we collect, use, disclose and (where applicable) sell or share, and the categories and sources of that information; request deletion of your personal information; request correction of inaccurate personal information; opt out of the sale or sharing of personal information and the use of sensitive personal information beyond what is necessary to provide the service; and not be discriminated against for exercising these rights. Meena does not sell personal information for money. To the extent our use of advertising cookies is considered “sharing” under the CPRA, you may opt out via the cookie banner described in Section 4.

9.6 China, PIPL

If the Personal Information Protection Law of the People’s Republic of China applies to your data, you have the right to know, decide, access, copy, correct, delete, and withdraw consent regarding your personal information, and to request an explanation of our processing rules.

To exercise any of these rights, contact us using the details in Section 12. We will respond within the timeframe required by the applicable law.

10. Children’s privacy

The Online Offerings are directed at businesses and are not intended for children. We do not knowingly collect personal data from children under 13 (or the relevant minimum age in your jurisdiction) without appropriate consent, and will delete such data if we become aware of it.

11. Security

We use appropriate technical and organisational measures, including access controls, encryption in transit, and staff confidentiality obligations, to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access. No system can be guaranteed fully secure. If personal data is affected by hacking, a cyberattack or other unauthorised access despite these measures, we will take appropriate legal measures, including reporting the incident to the competent UAE authorities and pursuing action against the responsible party, and will notify affected individuals and the relevant supervisory authority where required by applicable data protection law.

12. Contact us and Data Protection Officer

For any privacy questions, requests or complaints, contact:

• Email: dataprotection@meenasonline.com (privacy/DPO contact) or management@meenasonline.com (general enquiries)
• Post: Meena Business Consultancy Services F.Z.C., Building C1, Ajman Free Zone, UAE

13. Changes to this Policy

We may update this Policy from time to time to reflect changes in our practices or legal requirements. The “Last updated” date below shows when it was last revised. Material changes will be highlighted on our website.

Last updated: September 19, 2026

14. Governing law and jurisdiction

This Policy is governed by the laws of the United Arab Emirates. The courts of the United Arab Emirates shall have exclusive jurisdiction over any dispute arising out of or in connection with this Policy, without prejudice to any mandatory data-protection or consumer-protection rules that may entitle you to bring proceedings in your own jurisdiction or before your local supervisory authority.