WEALTHCODERS LIMITED • Application Privacy Policy

1. Introduction

Welcome to the applications developed and operated by WEALTHCODERS LIMITED (000010089), a Private Company Limited by Shares incorporated in Abu Dhabi Global Market (ADGM), United Arab Emirates.

Our applications are designed for invitation-only enterprise users and are not intended for the general public.

WEALTHCODERS LIMITED is committed to privacy, security, and data minimization. We collect and process only the limited information necessary to operate, secure, and support our applications.

This Privacy Policy is intended to explain what information is collected, how it is used, and what information is not collected, including a clear disclosure regarding health data.

2. Data Ownership and Hosting

2.1 Client-Hosted Deployments

When the Application is deployed on the enterprise client’s own infrastructure, that enterprise acts as the primary data controller and determines how data are managed within its environment.

In this model, WEALTHCODERS LIMITED may provide software maintenance and technical support, but does not independently determine the purposes of processing enterprise-controlled data.

2.2 Cloud Hosting at ADGM (WEALTHCODERS-Owned Infrastructure)

If the enterprise chooses hosting on infrastructure operated by WEALTHCODERS LIMITED, systems and storage are operated within the United Arab Emirates under enterprise service arrangements.

Under this model, WEALTHCODERS LIMITED acts only to provide the application, hosting, security, maintenance, and related technical support in accordance with the enterprise arrangement.

3. Information We Collect

WEALTHCODERS LIMITED follows a data minimization approach. We do not collect personal information unless it is necessary for application functionality, security, or support.

We do not collect:

Users’ personal health data
Medical records, diagnoses, treatment information, or biometric health information
Users’ personal phone numbers
Users’ personal email addresses
Users’ personal contact lists or address books
Advertising identifiers for profiling or marketing
Payment card or consumer financial transaction information

We may collect only limited technical and operational information necessary for the service:

Data Category	Description	Purpose	Collected?	Storage Location
Enterprise-assigned user identifier	An internal identifier assigned by the enterprise or system	Authentication, account access, and session management	✅	Enterprise environment and/or UAE servers
Device-related technical identifiers	Technical device information required for secure operation and diagnostics	Security, troubleshooting, and performance monitoring	✅	UAE servers or enterprise environment
Operational logs	System and usage events necessary for audit, reliability, and incident response	Security, audit, diagnostics, and service integrity	✅	UAE servers or enterprise environment
Health data	Medical, clinical, diagnostic, biometric, or treatment-related information	Not applicable	❌	Not stored by WEALTHCODERS LIMITED
Personal contact information	Personal phone number or personal email address	Not applicable	❌	Not stored by WEALTHCODERS LIMITED
Contact lists / address books	Contacts stored on the user device	Not applicable	❌	Not stored by WEALTHCODERS LIMITED
Advertising / tracking identifiers	Identifiers used for behavioral advertising or cross-app tracking	Not applicable	❌	Not stored by WEALTHCODERS LIMITED
Payment or transaction data	Consumer payment information	Not applicable	❌	Not stored by WEALTHCODERS LIMITED

4. Health Data Disclosure

WEALTHCODERS LIMITED does not access, collect, store, share, sell, or use Health Data.

For the purpose of this Privacy Policy, “Health Data” includes information such as medical records, diagnoses, treatment information, laboratory results, biometric measurements, physiological data, fitness or wellness measurements, and any other data relating to a person’s physical or mental health.

Our applications are not designed by WEALTHCODERS LIMITED to collect or process Health Data for our own purposes. Health Data is not used by WEALTHCODERS LIMITED for advertising, profiling, analytics, or product marketing.

If an enterprise customer independently uses the software in a context related to healthcare or health-related workflows, WEALTHCODERS LIMITED still does not collect Health Data for its own purposes, and any such content remains under the enterprise customer’s control and responsibility.

5. Permissions and Device Access

Some application features may request access to device capabilities only when such access is needed for a specific enterprise-enabled function and only after user permission is granted.

Permission / Access	Purpose	Always Required?
Camera	To capture images or scan content only when the user intentionally uses a feature requiring the camera	❌
Microphone	To support voice or audio features only when enabled and initiated by the user or enterprise workflow	❌
Notifications	To deliver operational alerts, updates, or communication notifications	❌

Permissions are not used to collect Health Data.
Permissions are not enabled by default unless required by the operating system for feature use.
Users may deny or revoke permissions at any time through device settings, subject to feature limitations.

6. Use of Data

Any information collected by WEALTHCODERS LIMITED is used only for legitimate operational purposes, including:

Authenticating users and enabling secure access;
Maintaining application functionality and service reliability;
Monitoring performance, diagnosing faults, and resolving incidents;
Protecting systems, users, and enterprise environments from security threats;
Maintaining audit and operational records where necessary.

WEALTHCODERS LIMITED does not use collected information for advertising, cross-app tracking, profiling, behavioral analytics, or marketing.

7. Data Sharing and Disclosure

WEALTHCODERS LIMITED does not sell user information and does not share user information with advertisers, data brokers, or third-party marketing or analytics providers for their own independent use.

Information may be disclosed only in limited situations such as:

Event	Recipient	Reason
Compliance with applicable law, court order, or lawful governmental request	Competent authority	Legal obligation
Security incident investigation or prevention of fraud, abuse, or unauthorized access	Authorized internal personnel or legally authorized parties	Security and protection of services
Provision of services under enterprise instructions and contractual arrangements	Enterprise customer or authorized enterprise representative	Service delivery and support

Any such disclosure is limited to what is necessary and subject to appropriate review and controls.

8. Security and Cyber Protection

WEALTHCODERS LIMITED applies reasonable technical and organizational measures to protect information, including:

Encryption in transit using modern transport security protocols
Access controls and authentication safeguards
System monitoring, logging, and incident response procedures
Internal security controls designed to reduce unauthorized access, alteration, or disclosure

No method of transmission or storage is absolutely secure, but WEALTHCODERS LIMITED takes reasonable steps to protect the information it processes.

9. Data Retention and Deletion

Information is retained only for as long as necessary to operate, secure, and support the application, or as required by law or contract.
Operational and security logs may be retained for a limited period as necessary for audit, troubleshooting, or incident response.
When information is no longer required, it is deleted or securely disposed of in accordance with applicable procedures.

10. User Rights

Subject to applicable law and the enterprise relationship governing the application, users may have the right to request access to, correction of, or deletion of their personal information, or to object to or restrict certain processing.

Requests may be submitted to privacy@wealthcoders.com. WEALTHCODERS LIMITED may require reasonable verification before responding.

11. Children’s Privacy

The application is intended for authorized enterprise users and is not directed to children. WEALTHCODERS LIMITED does not knowingly collect personal information from children.

12. International Data Transfers

Where WEALTHCODERS LIMITED hosts or processes information, it aims to do so within the United Arab Emirates or as otherwise agreed with the enterprise customer. If any cross-border processing occurs, it will be handled in accordance with applicable legal and contractual requirements.

13. Changes to This Privacy Policy

WEALTHCODERS LIMITED may update this Privacy Policy from time to time to reflect operational, legal, regulatory, or platform-related changes. The updated version will be published with a revised effective date.