WEALTHCODERS LIMITED

1. Introduction

Welcome to the applications developed and operated by WEALTHCODERS LIMITED (000010089), a Private Company Limited by Shares, incorporated on 31 May 2023 in Abu Dhabi Global Market (ADGM), United Arab Emirates.

At WEALTHCODERS LIMITED, your privacy and security come first. Our applications are designed for invitation-only enterprise users and are not intended for the general public.

We are committed to collecting and processing only the minimum data necessary to provide secure and reliable services — in full compliance with:

• Apple App Store, Google Play, and Huawei AppGallery data protection and user-consent requirements;
• UAE Federal Decree-Law No. 45 of 2021 (Personal Data Protection Law); and
• ADGM Data Protection Regulations 2021 (amended 2023).

Our applications include no advertising, no tracking, and no in-app payments.

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 sole data controller and processor.

In this case, WEALTHCODERS LIMITED:

• Does not access, store, or process any personal data;
• Does not determine how data are collected, retained, or deleted; and
• Provides only software maintenance and technical support.

The enterprise is fully responsible for compliance with all data-protection and cybersecurity obligations under UAE PDPL and ADGM Data Protection Regulations.

2.2 Cloud Hosting at ADGM (WEALTHCODERS-Owned Infrastructure)

If the enterprise chooses cloud hosting with WEALTHCODERS LIMITED:

• All servers and storage systems are owned and operated directly by WEALTHCODERS LIMITED.
• Physical infrastructure is located within ADGM, Abu Dhabi, at Mubadala-owned facilities managed by licensed UAE operators under ADGM-approved agreements.
• Physical access to the WEALTHCODERS server room is restricted to authorized, security-cleared staff under the building’s access control and ADGM security rules.
• All systems run on licensed software.
• Telecommunication and connectivity services are provided by UAE-licensed operators (e.g., e&, du) in compliance with TDRA regulations.
• All application code is developed, compiled, and maintained in-house by WEALTHCODERS LIMITED employees based in Abu Dhabi, ADGM.
• No outsourced or third-party development is used.

Under this model, WEALTHCODERS LIMITED acts as a data processor under the written instructions of the enterprise client, which remains the data controller. All processing occurs exclusively within the UAE, with no cross-border data transfers.

3. Information We Collect

Minimal-data principle: we avoid collecting personal data unless strictly necessary.

We do not collect or access:

• End users’ phone numbers
• End users’ personal or corporate email addresses
• Users’ contact lists, address books, or stored communications

We collect only technical and operational data necessary to maintain application functionality and security:

Access to optional device features (camera, microphone, notifications) occurs only after explicit user consent and only when required for enterprise-enabled functions.

4. User Consent and Control

• Application access is by enterprise invitation only.
• Permissions are disabled by default and activated only with user consent.
• WEALTHCODERS LIMITED does not automatically access phone contacts, camera, microphone, or emails.
• Users may revoke permissions at any time via device or enterprise settings.

5. Use of Data

Personal or technical data, when collected, is used solely to:

1. Authenticate users and enable secure sessions;
2. Monitor system performance and detect anomalies;
3. Ensure cybersecurity and operational integrity.

No data is used for marketing, profiling, or behavioral analytics.

6. Data Disclosure

Data may be disclosed only under lawful and verified circumstances, such as:

Every disclosure request is authenticated, logged, and reviewed under legal supervision.

7. Security and Cyber Protection

WEALTHCODERS LIMITED implements a defence-in-depth cybersecurity framework, including:

• End-to-end encryption (AES-256 / TLS 1.3)
• Multi-factor authentication
• ISO/IEC 27001-aligned security policies
• 24/7 intrusion monitoring
• Annual penetration testing
• Incident response and breach notification in line with ADGM FSRA Cyber Risk Management Framework (2024)

8. Data Retention and Deletion

• Data is retained only as long as required for service operation or legal obligations.
• Upon verified request, data is securely erased using NIST SP 800-88 data-destruction standards.
• Security logs retained for a maximum of 180 days, unless extended by law or contract.

9. User Rights

In accordance with UAE PDPL and ADGM DPR, users may:

• Access their personal data;
• Request correction or deletion;
• Restrict or object to processing;
• Request data portability (where applicable).

To exercise rights: send an email to privacy@wealthcoders.com with subject Data Request – [Your Name]. Requests are verified and answered within 30 calendar days.

10. Children’s Data

This application is not directed to or intended for minors. Access is limited to authorized enterprise users only.

11. Policy Updates

This Privacy Policy may be updated to reflect regulatory or platform changes. Enterprise administrators will be notified prior to any material modifications.

12. Contact Information