1. Introduction
Welcome to ICM Coaching. We are committed to protecting the privacy and security of your personal data, and ensuring that our processing of your personal data complies with UAE laws and regulations, including the Federal Decree-Law No. 45/2021 on the Protection of Personal Data.
By using our website (icmcoaching.com) and/or enrolling in our training, courses or coaching services, you accept the practices described in this Policy.

2. Scope
This Policy applies to all personal data (whether electronic or otherwise) collected by us as a “Controller” or “Processor” under the PDPL from individuals (data subjects) within the UAE or whose data is processed through our services.
It also covers data collected through the Website, offline interactions, email, telephone, and other channels.

3. What Information We Collect
We may collect the following categories of data:

• Identity & contact information: name, email address, postal address, telephone/mobile number, company/organization (if applicable).
• Registration/enrolment information: training programme selected, payment details, invoicing address, job title, previous certification/training background.
• Website usage information: IP address, device and browser type, pages visited, referral source, time and date of access, cookies and similar technologies.
• Communications data: any messages you send to us via contact forms, email or chat, and our replies.
• Special or sensitive personal data only if you provide it explicitly (for example health/accessibility information if relevant to a tailored training programme).

4. How We Use Your Information
We may process your personal data for the following purposes:

• To provide you the Services (coaching, training, certification, support) and to administer your account, enrolment and payment.
• To communicate with you regarding your account, changes to our Services, updates, newsletters, marketing (where you have consented) and other information we believe may interest you.
• To improve our website and the Services: analytics, usage trends, performance monitoring, security and fraud prevention.
• To fulfil legal or regulatory obligations in the UAE (including compliance with the PDPL, consumer-protection legislation, financial or tax obligations).
• Other uses with your consent or as otherwise permitted under law.

5. Legal Basis for Processing
In so far as required under law, we rely on the following bases for processing your personal data:

• Your consent (for example for direct marketing communications).
• Performance of a contract or taking steps at your request prior to contract (e.g., enrolling you in a coaching programme).
• Compliance with legal obligations.
• Our legitimate interests (for example fraud prevention, security of our website, improving our Services) provided such interests are not overridden by your rights.

6. Disclosure of Information
We may share your personal data with:

• Service providers and subcontractors who assist us (e.g., payment processors, hosting providers, email-marketing platforms) under contractual obligations of confidentiality and data protection.
• External trainers, coaches, or affiliates when you participate in programmes involving them — we will ensure you are informed of the sharing where relevant.
• Regulatory, governmental or legal authorities in the UAE when required by law or in connection with legal proceedings.
• In the event of a reorganization, merger or sale of assets, your personal data may be transferred to the successor entity, subject to similar protections.

7. International Transfers
Your personal data may be transferred to, stored or processed in jurisdictions outside the UAE. Where this occurs, we will ensure appropriate safeguards (such as contractual clauses, binding corporate rules or equivalent) are in place so that the recipient meets data protection standards comparable to those in the UAE. Under PDPL, transfer is permitted to jurisdictions with equivalent levels of protection or based on a contract or consent.

8. Data Security & Retention
We implement reasonable technical and organizational measures to protect your personal data from un authorized access, disclosure, alteration or destruction. We retain your personal data only for as long as required for the purposes for which it was collected, or as required by applicable UAE laws or legitimate business purposes (whichever is longer).

9. Cookies & Tracking Technologies
We use cookies and similar tracking technologies on our Website to:

• Authenticate and manage your login session.
• Remember your preferences and personalize your experience.
• Analyze website usage and performance to help improve our Services.
  You may choose to disable cookies through your browser settings, but please be aware this may affect certain features of our Website.

10. Your Rights
Under UAE data protection laws (including the PDPL), you have rights in relation to your personal data, including:

• The right to access the personal data we hold about you.
• The right to rectify inaccurate or incomplete personal data.
• The right to request erasure (“right to be forgotten”) of your personal data, subject to any legal or contractual retention obligation.
• The right to restrict or object to processing of your personal data (including for direct marketing).
• The right to data portability — to receive your personal data in a structured, machine-readable format.
  To exercise these rights, please contact us at the email address provided below.

11. Children’s Data
Our Services are directed at individuals aged 18 or above. We do not knowingly collect or process personal data relating to children under the age of 18. If we become aware that such data has been collected, we will take steps to delete it.

12. Changes to this Policy
We may update this Policy from time to time to reflect changes in our processing practices or legal/regulatory developments. We will notify you of any material changes (by posting the updated version on our Website and indicating the effective date). Your continued use of the Website or our Services after such changes constitutes your acceptance of the updated Policy.

13. Contact Us
If you have any questions or concerns about this Policy or our data-processing practices, please contact: [email protected]