Privacy Policy

ResoluteX Technology Labs Ltd. (“ResoluteX”, “we”, “our”, or “us”) respects your privacy and is committed to protecting your personal information. This Privacy Policy explains what information we collect, how and why we process it, your rights under the DIFC Data Protection Law No. 5 of 2020, and how you can contact us. For the purposes of this Policy, ResoluteX is the Data Controller.

1. Information We Collect

We may collect the following categories of personal data when you visit our website, interact with us, or use our services:

• Personal Information: Name, email address, phone number, organization, job title, billing and shipping details, and other information you voluntarily provide when you contact us, register, or make a purchase.
• Usage Data: IP address, device identifiers, browser type, operating system, pages visited, time spent, and other analytics to help us secure and improve our services.
• Cookies & Similar Technologies: We use cookies and similar tools to enhance functionality, analyze traffic, and personalize content. (See our Cookie Policy, if applicable.)

Notice when collected from other sources (Article 30): If we obtain personal data about you from a source other than you, we will provide you with this notice within one (1) month of obtaining the data, or at our first communication with you, or when we first disclose the data to a third party, whichever occurs first.

2. Lawful Basis for Processing (Article 29)

We process personal data under one or more of the following bases:

• Performance of a Contract: To deliver products or services you request and to manage purchases and support.
• Legitimate Interests: To operate, secure, and improve our website and services; to prevent fraud; and to understand service usage, provided these interests are not overridden by your rights.
• Consent: For optional activities such as sending newsletters, promotional updates, or running surveys. You can withdraw consent at any time.
• Legal Obligation: To comply with applicable laws, regulations, and regulatory requests.

3. How We Use Your Information

• To provide, operate, and maintain our products and services.
• To communicate about updates, transactions, and support.
• To analyze usage and improve user experience and security.
• To send marketing communications where you have expressly opted in (you may opt out at any time).
• To comply with legal obligations and resolve disputes.

We will not use your personal data for purposes incompatible with the original purpose without notifying you and, where required, obtaining your consent.

4. Data Sharing & International Transfers

We do not sell or rent your personal information. We may share data in the following circumstances:

• Service Providers: Trusted vendors supporting hosting, analytics, payments, communications, and similar operations. They are contractually bound to process data only under our instructions and to protect it appropriately.
• Legal Requirements: Where necessary to comply with laws, regulations, court orders, or lawful governmental requests.
• Business Transfers: In connection with a merger, acquisition, or asset sale, your information may be transferred to the new entity; we will provide notice where required.

If we transfer personal data outside the DIFC, we will do so only to jurisdictions recognized as providing an adequate level of protection or under appropriate safeguards (e.g., standard contractual clauses or binding agreements) as required by Articles 26–27 of the DIFC DP Law.

5. Data Retention

We retain personal data only for as long as necessary to fulfil the purposes described in this Policy, including to meet legal, accounting, or reporting requirements. We determine retention periods based on the nature of the data, the length of our relationship with you, applicable legal obligations, and our operational needs. When data is no longer required, we will delete, anonymize, or securely store it until deletion is possible.

6. Security of Your Information

We implement administrative, technical, and physical safeguards designed to protect personal data against unauthorized access, loss, misuse, or disclosure. However, no method of transmission or storage is 100% secure.

7. Your Data Protection Rights

Subject to conditions and exceptions under the DIFC DP Law, you may have the right to:

• Access your personal data.
• Rectify inaccurate or incomplete data.
• Erase personal data (“right to be forgotten”) in certain circumstances.
• Restrict processing in specific situations.
• Data Portability where technically feasible.
• Object to processing based on legitimate interests, including objecting to direct marketing.
• Withdraw Consent at any time where processing is based on consent.

To exercise your rights, contact us using the details below. We aim to respond within one (1) month in accordance with the DIFC DP Law.

8. Children’s Privacy

Our services are not directed to individuals under 13. We do not knowingly collect personal data from children. If we learn that a child has provided personal data, we will promptly delete it.

9. Changes to This Privacy Policy

We may update this Policy from time to time. Any changes will be posted on this page with an updated “Last Updated” date. Please review this Policy periodically to stay informed.

10. Contact Us (Controller / DPO)

If you have questions about this Privacy Policy, our data handling practices, or your rights, please contact:

Data Protection Officer

ResoluteX Technology Labs Ltd.

Address: Unit 05, Level 3, DIFC Innovation One, Dubai AI Campus, DIFC, Dubai, United Arab Emirates

Email: info@cyborgnetwork.io

11. When We Provide This Notice

Where we collect personal data directly from you, we provide this information at the time of collection (Article 29). Where we obtain personal data from another source, we provide this information within the timeframe set out above (Article 30).