Privacy Policy

Last updated: [DD Month YYYY]

This policy explains what personal information Zavaan collects when you use our website, the Zavaan app and the CNS Reset program, why we collect it, and the choices you have.

1. Who we are

Zavaan is operated by [LEGAL ENTITY NAME] (“Zavaan”, “we”, “us”), a company registered in [EMIRATE], United Arab Emirates, under trade licence number [LICENCE NO.], with its registered address at [REGISTERED ADDRESS].

We are responsible for the personal information described in this policy, which covers zavaan.com, the Zavaan app on iOS and Android, consultation calls and the CNS Reset coaching program (together, the “Services”).

We handle personal information in line with the UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data and, where they apply to you, other data protection laws such as the EU and UK GDPR.

2. Information we collect

Information you give us

• Contact details: your name, email address and phone number when you send an enquiry, book a consultation call or create an account.
• Enquiry and booking details: the topic you are interested in, your preferred call times and anything you write in a message.
• Account and program information: your login details, goals, schedule, training history, habit tracking entries and messages with your coach in the Zavaan app.
• Assessment information: lifestyle, mobility and stress profiling, body measurements and progress information you share during onboarding and fortnightly reviews (see section 3).
• Payment information: billing name and address and payment status. Card details are handled directly by our payment provider, [PAYMENT PROVIDER], and we never see or store your full card number.

Information collected automatically

• Device and usage data: IP address, browser and device type, operating system, pages and screens viewed, and how you interact with the website and app.
• Cookies and similar technologies: see section 10.

The TDEE calculator

The calculator on our website asks for gender, age, height, weight and activity level to estimate your daily energy expenditure. [CONFIRM: The calculation runs in your browser and these values are not sent to or stored by Zavaan.]

3. Health information

Information about your health, body and wellbeing is sensitive. We only collect it with your explicit consent, only use it to deliver and personalise your coaching, and only share it with the Zavaan coaches and nutritionists working on your program.

This can include sleep, stress, energy, digestion, mobility, injuries, body measurements, nutrition and any health conditions you choose to tell us about so that your plan is safe and suitable.

You can withdraw your consent at any time by contacting us. Withdrawing consent does not affect processing that has already taken place, but it may mean we can no longer personalise or continue your program.

4. How we use your information

We do not use your information to make decisions about you based solely on automated processing that have legal or similarly significant effects.

5. Who we share it with

We do not sell your personal information. We only share it where needed to run the Services:

• The Zavaan team: the coaches, nutritionists and support staff working on your program.
• Service providers who process information on our behalf under contract, such as website and app hosting, scheduling, email, payments and analytics. [LIST PROVIDERS, e.g. app platform, booking tool, payment provider, email platform]
• App stores: Apple and Google process information under their own policies when you download the app or pay through them.
• Authorities and advisers where the law requires it, or to protect the rights, safety and property of you, us or others.
• A buyer or successor if Zavaan’s business is sold, merged or restructured, in which case this policy will continue to protect your information.

6. International transfers

Some of our service providers store or process information outside the UAE. When we transfer personal information abroad, we make sure it is protected to the standard required by UAE law, for example by using providers in countries with adequate protection or by putting appropriate contractual safeguards in place.

7. How long we keep it

We keep personal information only for as long as we need it for the purposes in this policy, including to meet legal, accounting and reporting requirements.

• Enquiries that do not lead to a program: [12 months] after our last contact.
• Program, assessment and health information: [24 months] after your last program activity, unless you ask us to delete it sooner.
• Payment and transaction records: as long as UAE law requires us to keep them.

When information is no longer needed, we delete or anonymise it securely.

8. Security

We use technical and organisational measures to protect your information, including encrypted connections, access controls so that only the people working on your program can see your health information, and providers that meet recognised security standards. No system is completely secure, so please keep your app login details private and tell us straight away if you think your account has been accessed without permission.

9. Your rights

Depending on the law that applies to you, you have the right to:

• access the personal information we hold about you and receive a copy;
• ask us to correct information that is inaccurate or incomplete;
• ask us to delete your information;
• ask us to restrict or stop certain processing, including direct marketing;
• receive your information in a portable format;
• withdraw consent at any time where we rely on it.

To use any of these rights, email [PRIVACY EMAIL]. We may need to confirm your identity first, and we will respond within the time required by law.

If you are unhappy with how we have handled your information, please contact us first so we can try to put it right. You also have the right to complain to the UAE Data Office or to the data protection authority where you live.

10. Cookies

Our website uses cookies and similar technologies to:

• Make the site work: essential cookies for security, forms and remembering your choices. These cannot be switched off.
• Understand how the site is used: analytics cookies such as [Google Analytics], used only with your consent.
• Measure our advertising: marketing cookies such as [Meta Pixel], used only with your consent.

You can change your choice at any time through the cookie settings link in the website footer, or by adjusting your browser settings.

11. Marketing

We will only send you marketing emails or messages if you have agreed to receive them. Every marketing email includes an unsubscribe link, and you can also opt out by emailing us. Opting out of marketing does not stop service messages about your program or account.

12. Under 18s

The Services are designed for adults and are not intended for anyone under 18. We do not knowingly collect personal information from under 18s. If you believe a child has given us their information, please contact us and we will delete it.

13. Changes to this policy

We may update this policy from time to time. The latest version will always be on this page with the date it was last updated. If we make significant changes, we will let you know by email or through the app before they take effect.

14. Contact us

For any question about this policy or your personal information, contact:

• Email: [PRIVACY EMAIL]
• Phone: +971 [PHONE NUMBER]
• Post: [LEGAL ENTITY NAME], [REGISTERED ADDRESS], United Arab Emirates

See also

The rules for using the Zavaan website, app and CNS Reset program are in our Terms & Conditions.