Privacy Policy

AXEL ("AXEL," "we," "us," "our") is operated by [insert full registered legal entity name and UAE trade license number], with its registered office at [insert full registered address, Dubai, UAE]. AXEL provides personalized supplement regimens, physician consultations, and related wellness services through axel-int.com and our related applications (together, the "Services").

This Privacy Policy explains what personal data we collect, why we collect it, how we use and protect it, and the rights available to you under the UAE Personal Data Protection Law (Federal Decree-Law No. 45 of 2021, the "UAE PDPL") and, where applicable, other data protection laws.

Questions about this Policy or how your data is handled can be sent to info@axel-int.com [or insert Data Protection Officer name/email, if appointed].

This Policy applies to personal data we collect through the Site, the AXEL Terrain Kit™, physician consultations, customer support, our newsletter, and our partner/affiliate program. It does not apply to third-party websites we link to, which have their own privacy practices.

We collect the following categories of personal data:

Account & contact data — name, email address, phone number, delivery address, account credentials, and language preference.

Order & payment data — items ordered and subscription/regimen details. Card and payment details themselves are collected and processed directly by our payment processor, [insert payment processor name]; AXEL does not store full card numbers.

Health data (sensitive personal data) — this is the most sensitive category we handle, and includes:

Hair sample test results and the Six Terrain Pillars™ scores derived from them;

Lab results, bloodwork, or medical panels you upload for physician review;

Prescriptions you upload to unlock a regimen;

Information you provide in a health intake questionnaire ahead of a physician consultation;

Notes, protocols, and recommendations generated by AXEL-affiliated physicians;

Wearable device data you choose to connect (e.g. heart-rate variability, sleep, activity), where this feature is offered;

Any other health information you voluntarily share with our clinical team.

Communications — messages sent via the contact form, consultation booking, physician messaging, or customer support.

Marketing preferences — your newsletter subscription status and communication preferences.

Technical & usage data — IP address, browser/device type, and pages visited, collected via cookies and analytics tools [list the specific tools actually in use, e.g. Google Analytics] (see Section 9).

Partner/affiliate data — for healthcare professionals, ambassadors, and distributors: business details, professional license/registration (for healthcare professionals), referral activity, and payout information.

We only process health data with your explicit, separately obtained consent, as required for sensitive personal data under the UAE PDPL. Beyond consent, we rely on:

Performance of a contract — to process your order, manage your subscription, arrange cold-chain shipping, and deliver the regimen or consultation you purchased;

Legitimate interest — to secure the Site, prevent fraud, and improve our Services, balanced against your right to privacy;

Legal obligation — where we must retain records for tax, consumer-protection, or healthcare recordkeeping purposes.

We use your data to: operate the clinical review gate that confirms a valid hair test, lab upload, or prescription before any regimen can be ordered; match you to a personalized regimen and route it to an AXEL-affiliated physician; fulfil and ship your order while maintaining the 2–8°C cold chain; schedule your free Retest Loop kit at the end of each cycle; provide consultation booking and post-consultation messaging; process payments and manage subscriptions; respond to support requests; send marketing only where you've opted in; meet legal and tax obligations; and improve the Site through aggregated, de-identified analytics.

We share personal data only as needed to provide the Services:

AXEL-affiliated physicians and clinical partners, to review your test results, labs, or prescription and design your regimen or protocol;

Our laboratory partner(s), to process your hair sample and/or biomarker panel;

Our manufacturing partner, [Neosino GmbH — confirm], solely for order fulfilment — they do not receive your health data, only what's needed to prepare your shipment;

Our payment processor, [insert name], to process payments securely;

Our shipping and cold-chain logistics partners, to deliver your order;

Our hosting and technology providers, including Base44, to operate the Site;

Email/marketing platform providers, only where you've opted in to marketing;

Professional advisors and regulators, where required by law;

A buyer or successor, in the event of a merger, acquisition, or sale of assets, under the same protections described here.

We do not sell your personal data, and we do not share your health data with any third party for their own marketing purposes.

[Insert: where is data hosted — inside the UAE, or does Base44/your hosting provider store data outside the UAE? Where is the lab that processes hair samples located?] Where we transfer personal data outside the UAE, we do so only to countries recognized as providing an adequate level of protection, or by putting in place appropriate safeguards (such as standard contractual clauses) or obtaining your explicit consent, as required under the UAE PDPL.

We retain personal data only as long as necessary for the purposes in this Policy, including legal, tax, and healthcare recordkeeping obligations. [Insert specific retention periods once set with counsel — e.g. "Health data connected to an active regimen is retained for the duration of your relationship with AXEL plus [X] years thereafter; consultation records are retained for [X] years in line with applicable medical recordkeeping requirements."]

We use administrative, technical, and physical safeguards designed to protect your personal data, including encryption of data in transit, access controls limiting who at AXEL and our physician network can view your health data, and secure video infrastructure for consultations. No system is completely secure, and we encourage you to also protect your own account credentials.

We use cookies and similar technologies to operate the Site, remember your preferences, and understand how visitors use it. [Insert the specific analytics/marketing tools in use, e.g. Google Analytics, Meta Pixel — and add a cookie-consent banner letting visitors accept/reject non-essential cookies before they load.] You can also control cookies through your browser settings.

Under the UAE PDPL, you have the right to:

Access the personal data we hold about you;

Request correction of inaccurate or incomplete data;

Request erasure of your data, subject to legal retention requirements;

Restrict or object to certain processing;

Withdraw consent at any time, including consent to process your health data — note that withdrawing this consent may mean we can no longer provide your personalized regimen or consultation;

Request a copy of your data in a portable format;

Object to automated decision-making that produces legal or similarly significant effects concerning you (AXEL does not make purchasing decisions using automated decision-making alone — every regimen is reviewed by a physician).

To exercise any of these rights, contact info@axel-int.com. You may also lodge a complaint with the UAE Data Office if you believe we have not handled your data lawfully.

If you access our Services from outside the UAE, including from the European Economic Area or United Kingdom, we apply the protections in this Policy together with the additional safeguards described on our Data Protection & International Visitors page, to the extent applicable law requires them.

Our Services are not directed at, and we do not knowingly collect personal data from, anyone under 18. If you believe a minor has provided us with personal data, contact us and we will delete it.

We may update this Policy from time to time. We will post the updated version here with a new effective date, and where changes are material, we will provide additional notice such as an email or Site banner.

Questions, requests, or complaints about this Policy or your personal data can be sent to info@axel-int.com, or in writing to [insert registered address].

Effective date: [insert date]