Data Protection & International Visitors
Effective date: [insert date]
AXEL is based in Dubai, United Arab Emirates, and our handling of your personal data — including the health data collected through the AXEL Terrain Kit™, lab uploads, prescriptions, and physician consultations — is governed primarily by the UAE Personal Data Protection Law (Federal Decree-Law No. 45 of 2021) and any implementing regulations issued by the UAE Data Office. Please read this page together with our Privacy Policy.
If You Are Visiting From the European Economic Area, UK, or Switzerland
Where the General Data Protection Regulation ("GDPR") or the UK GDPR applies to our processing of your personal data, we apply the following additional safeguards:
We process your data on the legal bases recognized under GDPR (consent, contract, legitimate interest, or legal obligation), matching the bases described in our Privacy Policy;
You have the same rights described in our Privacy Policy — access, correction, erasure, restriction, objection, and portability — plus the right to lodge a complaint with your local data protection supervisory authority;
Where we transfer your data outside the EEA/UK, we rely on an adequacy decision, Standard Contractual Clauses, or your explicit consent.
[Insert EU representative details here if AXEL is required to appoint one under Article 27 GDPR — this depends on your scale of EU customers and should be confirmed with counsel.]
A Note on HIPAA
AXEL is not a US-based healthcare provider and is not a "covered entity" under the US Health Insurance Portability and Accountability Act ("HIPAA"). HIPAA does not apply to our Services. We describe our actual safeguards — the UAE PDPL, and GDPR-equivalent protections for applicable visitors — above and in our Privacy Policy, rather than referencing US law that does not govern us.
Health Data Specifically
Because health data is treated as sensitive personal data under the UAE PDPL (and as a "special category" under GDPR), we only process it with your explicit, separate consent, and only for the purposes you consented to — matching you to a regimen, enabling physician review, and delivering your Retest Loop results. You can withdraw this consent at any time by contacting info@axel-int.com, though this will mean we can no longer provide the personalized aspects of the Service.
Contact
For any data protection question, including exercising your rights, contact info@axel-int.com [or insert dedicated Data Protection contact/DPO if appointed].
Effective date: [insert date]