Scope of this Policy. This Privacy Policy explains how Aperion for Artificial Intelligence Solutions (“Aperion”, “we”, “our”, or “us”) collects, uses, discloses, and protects personal data of visitors to our website at aperion.ae and of people who submit inquiries or request a diagnostic session through our website.
This Policy is governed by the UAE Personal Data Protection Law(Federal Decree-Law No. 45 of 2021, the “PDPL”) and associated regulations.
This Policy does NOT cover the processing of personal data we carry out on behalf of a client under a signed Engagement — that processing is governed by the Data Processing Agreement (DPA)attached to each client's Service Terms & Conditions, in which our client is the Data Controller and we are the Data Processor.
1. Who We Are
Aperion for Artificial Intelligence Solutions is a sole establishment registered in Abu Dhabi, United Arab Emirates, under Economic Licence No. CN-6434191, with its principal place of business in Abu Dhabi, UAE. Aperion is wholly owned by Mr. Ali Naser Ali Naji Alhemeiri.
For the purposes of this Policy, Aperion is the Data Controller in respect of personal data collected through aperion.ae.
Contact for data-protection and privacy matters:
- Email: operations@aperion.ae
- Postal address: Abu Dhabi, United Arab Emirates
- Response time: we respond to data-protection requests within thirty (30) calendar days of receipt, as required under the PDPL.
2. What Personal Data We Collect
2.1 Information you provide directly
When you submit the “Get Diagnostic” inquiry form on aperion.ae, we ask you to provide:
- your name;
- your email address;
- your phone number;
- your company name;
- a description of the problem or use-case you are interested in exploring with us.
Providing this information is voluntary, but if you do not provide the required fields, we will not be able to schedule a diagnostic session or contact you.
2.2 Information collected automatically
When you visit aperion.ae, our website technology automatically collects limited technical information, including:
- your IP address (which may reveal your approximate geographic location);
- your browser type and version, operating system, and device type;
- pages viewed, time spent on each page, and referring URL;
- date and time of your visit.
We use Vercel Analytics (or equivalent privacy-respecting analytics tooling) to collect this technical information. Vercel Analytics does not use third-party cookies and does not track users across websites.
2.3 Cookies
As at the date of this Policy, aperion.ae does not use any marketing, advertising, or tracking cookies. We may use strictly-necessary cookies that are essential for the website to function (for example, to maintain session state). If we introduce cookies that require consent in the future, we will update this Policy and publish a cookie consent mechanism on the website.
2.4 We do not record diagnostic sessions
Diagnostic sessions conducted via video, phone, or in person are not recorded. If we wish to record a specific session for any reason in the future, we will obtain your express consent before recording.
2.5 The Pre-Diagnostic Brief
If APERION shares a private link inviting you to complete the Pre-Diagnostic Brief — the longer questionnaire we use to prepare for a Diagnostic Session — we additionally collect:
- your business legal name, trade name, sector, headcount, and turnover range;
- your role and decision-making authority, and if you are not the decision-maker, the name and role of the decision-maker;
- your operational answers across §3–§7 of the brief — workflow, AI use today, goals, constraints, decision process, and the investment range you would consider reasonable;
- optional sector-specific answers in §8;
- your three consent confirmations and typed signature in §9, together with the server timestamp at submission.
Processing of this information is governed by APERION's Service Terms (Clause 13.6 — confidentiality), the APERION Data Processing Agreement, and PDPL Article 5 — Data Subject consent. The consent recorded in §9.1 is the lawful basis for processing the brief. It informs the Diagnostic Session only and is not shared externally.
If you submit the brief and do not subsequently sign an Engagement, your submission is retained for twelve (12) months from the date of submission and then deleted, in line with §6 below.
3. How We Use Your Personal Data
We process the personal data described in Clause 2 for the following purposes, based on the following lawful bases under the PDPL:
| Purpose | Data used | Lawful basis (PDPL) |
|---|---|---|
| Responding to your inquiry and scheduling a diagnostic session | Name, email, phone, company name, problem description | Necessary for the performance of a contract or to take steps at your request before entering into a contract (PDPL Art. 5(1)(b)) |
| Communicating with you about your inquiry | Name, email, phone | Necessary for the performance of a contract or pre-contract steps (PDPL Art. 5(1)(b)) |
| Understanding website traffic and improving the website | IP address, browser type, pages viewed, referring URL, timestamp | Legitimate interest in operating and improving our website (PDPL Art. 5(1)(e)) |
| Protecting the security and integrity of our website | IP address, technical logs | Legitimate interest in ensuring the security of our systems (PDPL Art. 5(1)(e)) |
| Meeting legal, regulatory, or compliance obligations | Any relevant data | Compliance with a legal obligation (PDPL Art. 5(1)(c)) |
We do not send marketing emails to people who submit the inquiry form, unless and until they sign an Engagement with us and affirmatively opt in to receive Aperion updates. We do not sell or rent your personal data to anyone.
4. Who We Share Your Personal Data With
We share personal data only with the following categories of recipients, and only where sharing is necessary for the purposes set out in Clause 3:
(a) Service providers (processors) acting on our instructions, including:
| Provider | Purpose |
|---|---|
| Website hosting provider (e.g., Vercel) | Hosting aperion.ae |
| Analytics provider (e.g., Vercel Analytics) | Website traffic analytics |
| Email service provider (e.g., Google Workspace) | Receiving and responding to inquiry submissions; business email |
| Calendar/scheduling tool | Scheduling diagnostic sessions |
Each provider is bound by its own data-protection terms and acts on our documented instructions.
(b) Aperion's founders and authorised personnel — Ali Alhemeiri and Khalifa Al-Suwaidi (and any authorised personnel or professional advisors on a need-to-know basis).
(c) Regulatory and law-enforcement authorities — where we are required to disclose personal data to comply with a legal obligation, court order, or regulatory requirement, or to protect our legal rights.
We do not share your personal data with third parties for their own marketing purposes.
5. Cross-Border Transfers
Some of our service providers (such as website hosting and analytics) are located outside the United Arab Emirates, including in the United States and the European Union. Where your personal data is transferred outside the UAE, we rely on one or more of the following legal bases under PDPL Art. 22:
- the transfer is necessary for the performance of a contract between you and us, or for steps taken at your request prior to entering into a contract;
- appropriate safeguards are in place, including data-processing addenda with our service providers;
- the destination jurisdiction is on the UAE Data Office's list of adequate jurisdictions (where such a list has been published); or
- your explicit consent, where required.
6. How Long We Keep Your Personal Data
We retain personal data only for as long as necessary for the purposes set out in Clause 3, unless a longer retention period is required by applicable law.
| Category | Retention period |
|---|---|
| Inquiry form submissions and Pre-Diagnostic Briefs from people who did not proceed to an Engagement | Twelve (12) months from the date of submission, then deleted |
| Inquiry form submissions and Pre-Diagnostic Briefs from people who proceeded to an Engagement | For the duration of the Engagement plus the retention period set out in the applicable DPA (currently 12 months after the Engagement ends) |
| Website analytics data (aggregated / anonymised) | Retained indefinitely in aggregated or anonymised form; individual IP-level data retained for no more than twelve (12) months |
| Email correspondence | Twelve (12) months from the last communication, unless retention is required for legal, tax, audit, or dispute-related purposes |
After the retention period expires, we delete or anonymise the personal data, save for records we are required to retain for legal, tax, audit, or dispute-related purposes.
7. How We Protect Your Personal Data
We implement appropriate technical and organisational measures to protect your personal data, including:
- restricted access to inquiry submissions and customer communications (only authorised personnel);
- encryption of data in transit (TLS 1.2 or higher) on aperion.ae;
- secure credential management;
- reasonable monitoring for unauthorised access;
- prompt response to any identified security incident.
No website or data-storage system can guarantee absolute security. We will not charge you for any reasonable data-protection measure required by the PDPL.
8. Your Rights Under the PDPL
Subject to the PDPL (Arts. 13–20), you have the following rights in respect of your personal data:
- Right of access — request confirmation of whether we process your personal data, and request a copy;
- Right of correction — ask us to correct inaccurate or incomplete personal data;
- Right of erasure — ask us to delete your personal data, subject to retention required by law;
- Right to restrict processing — ask us to limit how we process your personal data in specific circumstances;
- Right of objection — object to our processing of your personal data where the basis is our legitimate interest;
- Right of data portability — request your personal data in a structured, commonly used format;
- Right to withdraw consent — where we rely on your consent, withdraw it at any time (withdrawal does not affect the lawfulness of processing before withdrawal).
How to exercise your rights. Please contact us at operations@aperion.ae. We will respond within thirty (30) calendar days of receiving your request, or within any shorter period required by the PDPL. We may need to verify your identity before acting on your request.
Complaints. If you believe we have not handled your personal data in accordance with the PDPL, you have the right to lodge a complaint with the UAE Data Office or any successor regulatory authority.
9. Children's Data
aperion.ae is a B2B website intended for adults and for people acting on behalf of businesses. We do not knowingly collect personal data from individuals under the age of 18. If you believe we have inadvertently collected personal data from a minor, please contact us at operations@aperion.ae and we will delete it.
10. Third-Party Links
aperion.ae may contain links to websites and services operated by third parties. This Policy does not apply to those third-party websites. We are not responsible for the privacy practices of third-party websites — please review their own privacy policies before providing personal data to them.
11. Changes to This Policy
We may update this Privacy Policy from time to time. The updated Policy will be published on aperion.ae with a revised effective date. For material changes, we will take reasonable steps to notify you (for example, by a website banner or, if you have an active inquiry or Engagement, by email). Your continued use of aperion.ae after the updated Policy's effective date constitutes your acknowledgment of the update.
12. Contact Us
For any questions about this Privacy Policy or our processing of your personal data:
- Email: operations@aperion.ae
- Postal address: Aperion for Artificial Intelligence Solutions, Abu Dhabi, United Arab Emirates
- Website: https://aperion.ae