Legal

Privacy Policy

Last updated: [DATE]

Draft for legal review. This document is a thorough working draft prepared to be accurate to MonikaSphere’s actual data practices. It must be reviewed by a UAE-qualified lawyer familiar with the Personal Data Protection Law (PDPL) and health-data handling before it governs real users. Bracketed placeholders below must be completed before launch.

This Privacy Policy explains how [REGISTERED COMPANY NAME] (“MonikaSphere”, “we”, “us”, or “our”), a company registered in the Ras Al Khaimah Economic Zone (RAKEZ), United Arab Emirates (licence no. [LICENCE NUMBER]), collects, uses, stores, and protects your personal information when you use the MonikaSphere platform, website, and coaching services (the “Service”).

We take your privacy seriously — particularly because some of the information you share with us relates to your health and wellbeing. Please read this policy carefully.

1. Who we are

MonikaSphere is a premium fitness and wellness coaching platform for women in midlife, founded and led by coach Monika. The Service provides personalised training programs, coaching, progress tracking, and supportive tools.

Data controller: [REGISTERED COMPANY NAME], RAKEZ, Ras Al Khaimah, UAE.
Contact for privacy matters: info@monikasphere.com

2. The information we collect

We collect the following categories of information:

Information you provide directly:

Information collected automatically:

3. How we use your information

We use your information to:

We do not sell your personal information. We do not use your health information for advertising.

4. How we use artificial intelligence (AI)

MonikaSphere uses AI to support — never to replace — your coach. Being transparent about this matters to us:

5. Sensitive (health) information — special handling

Because MonikaSphere is a wellbeing service, some information you share is health-related and therefore sensitive. We apply heightened protections:

Important disclosure about your coach’s visibility: to coach you effectively, your coach (Monika) can see the information relevant to your coaching, including your intake, your daily logs, your progress, and the AI-generated summaries of your progress. Your progress summaries are visible to your coach as part of the coaching relationship. Your private conversations with the in-app assistant (“Ask”) remain private to you unless you choose to share a specific conversation with your coach.

By using the Service and providing health-related information, you consent to our processing of it for the purposes described in this policy. You may withdraw consent by closing your account, though this may mean we can no longer safely provide the Service.

6. The legal basis for processing (UAE PDPL)

We process your personal data on the following bases, consistent with the UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (PDPL):

7. Third parties who process data for us

We use trusted third-party service providers (“processors”) to run the Service. Each processes data only as needed to provide their function:

Some of these providers may process or store data outside the UAE. Where data is transferred internationally, we take steps consistent with the PDPL to ensure it remains protected.

8. How long we keep your information

We keep your information for as long as your account is active and as needed to provide the Service. If you close your account, we retain certain information only as long as necessary for legitimate business, legal, or safety purposes, after which it is deleted or anonymised.

9. Your rights

Under the UAE PDPL, subject to its conditions and exceptions, you have the right to:

You can exercise many of these directly in the app (for example, requesting a copy of your data, or deleting your account in your account settings). For any request, contact us at info@monikasphere.com. We will respond within the timeframes required by law.

10. Security

We protect your information using industry-standard measures, including encryption in transit, strict access controls (so that, for example, one client can never access another client’s data), server-side handling of secrets and API keys, and deliberate minimisation of sensitive data sent to third parties. No system is perfectly secure, but we take our responsibility to protect your information seriously.

11. Children

The Service is intended for adults (18+) and is designed for women in midlife. It is not directed at children, and we do not knowingly collect data from anyone under 18.

12. Changes to this policy

We may update this policy from time to time. If we make material changes, we will notify you through the Service or by email. The “Last updated” date at the top shows when it was last revised.

13. Contact us

For any privacy questions or to exercise your rights, contact:
[REGISTERED COMPANY NAME]
RAKEZ, Ras Al Khaimah, United Arab Emirates
Email: info@monikasphere.com