Legal &
Compliance.

Data Security Policy

Effective: 25.12.2024

Creon L.L.C-FZ ("we," "our," or "us") is committed to conducting business with integrity and in compliance with UAE laws as well as protect corporate and client data through this Data Security Policy.

1. Scope and Purpose

This policy outlines the technical and organizational measures implemented by Creon L.L.C-FZ to protect corporate and client data in compliance with UAE laws, including:

• Federal Decree-Law No. 45 of 2021 (PDPL)
• UAE Cyber Crime Law
• Meydan Free Zone Dubai regulations

2. Data Classification

• Corporate Data: Internal business records, financial reports, and operational documents.
• Client Data: Information provided by B2B partners, including technical specifications, project details, and contractual agreements.
• Technical Data: IP addresses, browser types, and website analytics (non-personal).

3. Security Measures

Technical Controls

• Encryption:
  • Data in transit: SSL/TLS protocols for all communications.
  • Data at rest: AES-256 encryption for stored data.
• Access Controls:
  • Role-based access to sensitive systems (e.g., client project repositories).
  • Multi-factor authentication (MFA) for administrative accounts.
• Network Security:
  • Firewalls and intrusion detection systems (IDS).
  • Regular vulnerability scans and penetration testing.

Organizational Controls

• Employee Training:
  • Annual cybersecurity training aligned with PDPL Article 5 requirements.
  • Phishing simulation exercises to reinforce awareness.
• Data Minimization:
  • Collection limited to data necessary for B2B operations.
  • Regular audits to delete obsolete data.

4. Incident Response

• Breach Notification:
  • Report breaches to the UAE Data Office within 72 hours of detection.
  • Notify affected corporate clients if the breach poses significant risk.
• Containment and Recovery:
  • Isolate compromised systems.
  • Restore data from encrypted backups.

5. Third-Party Management

• Vendor Assessments:
  • Due diligence for all third parties handling Creon L.L.C-FZ data.
  • Contracts mandating compliance with UAE data protection laws.
• Cloud Services:
  • Use only UAE-based or GDPR-equivalent compliant providers.

6. Compliance and Audits

• Annual Audits:
  • Internal reviews of security protocols and access logs.
  • External audits by certified cybersecurity firms.
• Data Protection Impact Assessments (DPIAs):
  • Conducted for high-risk processing activities (e.g., fintech software deployments).

7. Roles and Responsibilities

• Data Protection Officer (DPO):
  • Role: Interim Manager
  • Contact: dpo@creon.ae
  • Duties: Oversee PDPL compliance, manage breach responses, and liaise with regulators.

8. Policy Updates

• Reviewed annually or following significant regulatory changes (e.g., PDPL Executive Regulations).
• Updates published on www.creon.ae under Terms & Policies > Data Security Policy.

Contact for Security Concerns

Email: security@creon.ae
Address: Meydan Grandstand, 6th floor, Meydan Road, Nad Al Sheba, Dubai, U.A.E.
Phone: +971 589 410747

This policy aligns with Creon L.L.C-FZ's B2B focus, ensuring robust protection for corporate data while adhering to UAE legal requirements.

Anti-Corruption Policy

Effective: 25.12.2024

Creon L.L.C-FZ ("we," "our," or "us") is committed to conducting business with integrity and in compliance with UAE laws through this Anti-corruption Policy.

1. Scope and Purpose

Creon L.L.C-FZ, a Meydan Free Zone Dubai-registered B2B software development and fintech consultancy company, is committed to conducting business with integrity and in compliance with UAE anti-corruption laws, including:

• Federal Law No. 31 of 2021 (UAE Penal Code)
• Federal Decree-Law No. 20 of 2018 (AML/CFT Law)
• Meydan Free Zone Dubai Compliance Guidelines

This policy applies to all employees, contractors, and third parties acting on behalf of Creon L.L.C-FZ.

2. Prohibited Conduct

Bribery and Facilitation Payments

• Offering or Accepting Bribes: Prohibited under Article 234 of the UAE Penal Code. Includes cash, gifts, favors, or any undue advantage intended to influence business decisions.
• Commercial Bribery: Prohibited under Article 237 for private-sector transactions.
• Facilitation Payments: Strictly prohibited, even if customary in certain jurisdictions.

Gifts and Hospitality

• Gifts exceeding AED 500 (or equivalent) require prior written approval from the Compliance Officer.
• Hospitality (e.g., meals, event tickets) must be infrequent, modest, and directly related to legitimate business purposes.

Conflicts of Interest

Employees must disclose any personal, financial, or familial relationships that could influence business decisions.

3. Third-Party Due Diligence

• Vendor/Partner Screening:
  • Conduct AML/CFT checks on third parties using UAE Central Bank-approved tools.
  • Verify compliance with UAE Anti-Corruption Laws through the Meydan Free Zone Dubai Business Partner Portal.
• Contract Clauses: Include anti-corruption warranties and audit rights in all agreements.

4. Reporting Violations

• Whistleblower Mechanism: Report suspected violations to compliance@creon.ae or via the anonymous hotline (+971 589 410747).
• Protection: Whistleblowers are protected under Federal Decree-Law No. 20 of 2018 from retaliation.

5. Training and Awareness

• Mandatory Training: Annual anti-corruption training for all employees, covering:
  • UAE Penal Code requirements.
  • Red flags (e.g., unusual payment requests, lack of transparency).
• Management Accountability: Senior executives must certify compliance annually.

6. Enforcement and Penalties

• Internal Investigations: Led by the Compliance Officer, with escalation to the Meydan Free Zone Dubai Authority if required.
• Consequences:
  • Employees: Termination and potential imprisonment (up to 15 years under Article 234).
  • Third Parties: Contract termination and blacklisting.
  • Corporate Fines: Up to AED 5 million under Article 66 of the UAE Penal Code.

7. Compliance Officer

• Role: Director
• Responsibilities:
  • Monitor adherence to this policy.
  • Liaise with Meydan Free Zone Dubai Authority and Federal Tax Authority (FTA).
  • Maintain records of gifts, hospitality, and due diligence checks.

8. Policy Review

Reviewed annually or after significant regulatory changes (e.g., FATF 2026 UAE evaluation). Updates published on www.creon.ae under Terms & Policies > Anti-Corruption Policy.

Contact for Compliance Queries

Email: compliance@creon.ae
Address: Meydan Grandstand, 6th floor, Meydan Road, Nad Al Sheba, Dubai, U.A.E.
Phone: +971 589 410747

This policy aligns with Creon L.L.C-FZ's B2B operations, UAE legal requirements, and FATF recommendations post-grey-list removal.

Privacy Policy

Effective: 22.05.2024

Creon L.L.C-FZ ("we," "our," or "us") respects your privacy and is committed to protecting it through this Privacy Policy. This document outlines how we collect, use, disclose, and safeguard your information when you visit our website www.creon.ae or engage with our services.

The website serves solely as an informational platform for B2B operations and does not engage in direct-to-consumer activities or online transactions.

1. Information We Collect

We do not collect personal data from individuals through our website.

However, the following types of data may be collected:

• Technical Information: IP address, browser type, operating system, and visit timestamps.
• Contact Information: Corporate details provided voluntarily via inquiry forms or email communication.

2. How We Use Your Information

The data collected is used exclusively for:

• Responding to inquiries from corporate clients.
• Improving website functionality and analyzing traffic patterns.

We do not use collected data for marketing purposes or share it with third parties.

3. Data Storage

• All data is stored securely on servers located in the UAE and is deleted once its purpose has been fulfilled.
• We ensure that no data is retained longer than necessary for operational purposes.

4. Sharing Your Information

We do not sell or rent your personal information. However, we may share information with:

• Service Providers: Third-party vendors who help us operate our business.
• Legal Authorities: When required by law, regulation, or to protect our rights.
• Business Transfers: In case of a merger, acquisition, or business restructuring.

5. Data Protection

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction.

We implement robust security measures to safeguard collected data:

• Encryption and secure transmission protocols (SSL).
• Restricted access to data by authorized personnel only.
• Regular updates to security systems to prevent breaches.

6. Your Rights and Choices

Depending on applicable laws, you may have the right to:

• Access, correct, or delete your personal data.
• Opt out of marketing communications.
• Restrict processing of your data in certain circumstances.

In compliance with Federal Law No. 45 of 2021 (UAE Personal Data Protection Law - PDPL), data subjects have the right to:

• Request access to their data.
• Demand correction or deletion of their data (if applicable).

Requests can be submitted via email at dpo@creon.ae

7. Third-Party Links

Our website may contain links to third-party websites. We are not responsible for their privacy practices, and we encourage you to review their policies.

8. Cookies and Tracking Technologies

We may use cookies and similar technologies to enhance user experience and collect data about interactions with our website.

Our website uses cookies strictly for technical purposes:

• Monitoring website traffic and usage patterns.
• Ensuring proper functionality of the website features.

You can control cookie settings through your browser.

9. Changes to Privacy Policy

Creon L.L.C-FZ reserves the right to update this Privacy Policy in line with changes in UAE legislation or company requirements. Updates will be published on www.creon.ae.

10. Contact Us

For any questions regarding this Privacy Policy, please contact us:

Address: Meydan Grandstand, 6th floor, Meydan Road, Nad Al Sheba, Dubai, U.A.E.
Email: dpo@creon.ae
Phone: +971 589 410747

This Privacy Policy complies with UAE Personal Data Protection Law (PDPL) and Meydan Free Zone Dubai regulations while addressing the specific operational needs of Creon L.L.C-FZ as a B2B company.

Client Data Management Policy

Effective: 25.12.2024

Creon L.L.C-FZ ("we," "our," or "us") is committed to conducting business with integrity and in compliance with UAE laws through this Client Data Management Policy.

1. Scope and Purpose

This policy governs the management of client data for Creon L.L.C-FZ, a Meydan Free Zone Dubai-registered B2B company specializing in AI-driven software development and fintech consultancy. It ensures compliance with UAE laws, including:

• Federal Decree-Law No. 45 of 2021 (PDPL)
• Federal Decree-Law No. 30 of 2024 (KYC Law)
• Meydan Free Zone Dubai Compliance Guidelines

2. Data Classification

• Corporate Client Data: Company names, contact details, project specifications, contractual agreements, and payment histories.
• Representative Data: Limited personal data of corporate representatives (e.g., names, email addresses) provided during B2B engagements.
• Technical Data: Non-personal data (e.g., IP addresses, browser types) collected via website analytics.

3. Data Collection and Use

• Lawful Basis:
  • Corporate client data is processed under contractual necessity to deliver services (e.g., AI/fintech solutions).
  • Representative data requires explicit consent for communication purposes.
• Data Minimization: Collect only data essential for B2B operations (e.g., company registration details for KYC checks).
• Prohibited Uses: No marketing, resale, or sharing with third parties unrelated to service delivery.

4. Security Measures

Technical Controls

• Encryption:
  • In transit: SSL/TLS protocols for all communications.
  • At rest: AES-256 encryption for stored data on UAE-based servers.
• Access Controls:
  • Role-based permissions for employees (e.g., developers vs. finance teams).
  • Multi-factor authentication (MFA) for systems handling sensitive client data.

Organizational Controls

• Employee Training: Annual PDPL and cybersecurity training, including phishing simulations.
• Audits: Quarterly reviews of access logs and data storage practices.

5. Third-Party Data Sharing

• Vendor Due Diligence:
  • AML/KYC checks for third parties via the Meydan Free Zone Dubai Business Partner Portal.
  • Contracts mandating PDPL compliance and data protection clauses.
• Cross-Border Transfers:
  • Data transferred only to jurisdictions with adequate protection (e.g., EU GDPR countries).
  • Use of Standard Contractual Clauses (SCCs) for non-approved jurisdictions.

6. Breach Response

• Notification Protocol:
  • Report breaches to the UAE Data Office within 72 hours of detection.
  • Notify affected corporate clients if the breach poses significant operational/financial risk.
• Containment: Immediate isolation of compromised systems and restoration from encrypted backups.

7. Client Rights

Corporate clients and their representatives may:

• Request access to their data via dpo@creon.ae.
• Demand corrections to inaccuracies within 30 days.
• Withdraw consent for representative data processing (does not affect contractual obligations).

8. Compliance and Roles

• Data Protection Officer (DPO):
  • Role: Director
  • Duties: Oversee PDPL/KYC compliance, manage breach responses, and liaise with the UAE Data Office.
• Assessments:
  • Data Protection Impact Assessments (DPIAs) for high-risk projects (e.g., fintech integrations).

9. Policy Updates

Reviewed annually or following regulatory changes (e.g., PDPL Executive Regulations). Updates published at www.creon.ae

Contact for Data Requests or Concerns

Email: dpo@creon.ae
Address: Meydan Grandstand, 6th floor, Meydan Road, Nad Al Sheba, Dubai, U.A.E.

This policy aligns with Creon L.L.C-FZ's B2B operations, UAE legal frameworks, and international data protection standards, ensuring transparency and trust with corporate partners.

Website Usage Policy

Effective: 25.12.2024

Creon L.L.C-FZ ("we," "our," or "us") is committed to conducting business with integrity and in compliance with UAE anti-corruption laws through this Website Usage Policy.

1. Introduction

This Website Usage Policy governs the use of the Creon L.L.C-FZ website (www.creon.ae), which serves as an informational platform for B2B operations. By accessing and using this website, you agree to comply with the terms outlined herein, as well as applicable laws and regulations in the United Arab Emirates (UAE).

2. Acceptable Use

Users agree to access and use the website for lawful purposes only. Prohibited activities include:

• Using the website to engage in illegal or fraudulent activities.
• Attempting to disrupt or harm the website's functionality, including introducing malware or viruses.
• Accessing data or areas of the website that are not intended for public use without authorization.
• Disseminating content that is unlawful, unethical, defamatory, or offensive under UAE law.

3. Intellectual Property Rights

All content on this website, including text, graphics, logos, images, and software, is owned by or licensed to Creon L.L.C-FZ and is protected by UAE intellectual property laws. Users may not:

• Copy, reproduce, distribute, or modify any content without prior written permission from Creon L.L.C-FZ.
• Use trademarks or logos displayed on the website without authorization.

4. Disclaimer of Liability

Creon L.L.C-FZ is not liable for:

• Any direct or indirect damages resulting from the use or inability to use this website.
• Temporary unavailability of the website due to technical issues beyond our control.
• Content on third-party websites linked from www.creon.ae; users access such links at their own risk.

5. External Links

The website may contain links to external websites for user convenience. Creon L.L.C-FZ does not endorse or assume responsibility for the content or practices of these third-party websites.

6. Privacy and Data Protection

Creon L.L.C-FZ respects user privacy and adheres to UAE Federal Law No. 45 of 2021 (PDPL). For details on how data is collected and used, please refer to our Privacy Policy published on www.creon.ae.

7. Governing Law

This Website Usage Policy is governed by the laws of the UAE. Any disputes arising from its breach shall be resolved in the competent courts of Meydan Free Zone Dubai.

8. Amendments

Creon L.L.C-FZ reserves the right to amend this policy at any time without prior notice.

Updates published on www.creon.ae under Terms & Policies > Website usage Policy. Continued use of the website constitutes acceptance of any changes made.

9. Contact Information

For questions regarding this policy or concerns about website usage, please contact:

Email: legal@creon.ae
Address: Meydan Grandstand, 6th floor, Meydan Road, Nad Al Sheba, Dubai, U.A.E.
Phone: +971 589 410747

This Website Usage Policy ensures compliance with UAE legislation (including Federal Decree-Law No. 5 of 2012 on Cybercrimes) and aligns with Creon L.L.C-FZ's commitment to ethical business practices in its B2B operations.

Disclaimer Policy

Effective: 22.05.2024

Creon L.L.C-FZ ("we," "our," or "us") is committed to conducting business with integrity and in compliance with UAE laws through this Disclaimer Policy.

1. General Disclaimer

The content and functionality of this website (www.creon.ae) are provided by Creon L.L.C-FZ on an "as is" and "as available" basis. While we strive to ensure the accuracy, timeliness, and completeness of the information presented, Creon L.L.C-FZ makes no warranties or representations, either express or implied, regarding the website's content, including but not limited to:

• Accuracy, reliability, or suitability for any specific purpose.
• Uninterrupted or error-free operation of the website.
• Freedom from viruses or harmful components.

Creon L.L.C-FZ disclaims all liability for any errors, omissions, or inaccuracies in the content provided on this site.

2. Limitation of Liability

By using this website, you agree that Creon L.L.C-FZ shall not be held liable under any circumstances for:

• Direct, indirect, incidental, consequential, or special damages resulting from your use of or inability to use the website.
• Losses arising from reliance on any information provided on this site.

This limitation applies even if Creon L.L.C-FZ has been advised of the possibility of such damages.

3. Third-Party Links and Content

The website may contain links to external websites or third-party content for user convenience. Creon L.L.C-FZ does not endorse or assume responsibility for:

• The accuracy or reliability of third-party content accessed via these links.
• The security or privacy practices of third-party websites.

Users access such content at their own risk and are encouraged to review the terms and policies of those external sites.

4. Intellectual Property Rights

All content on this website, including but not limited to text, images, logos, and software, is owned by or licensed to Creon L.L.C-FZ and is protected under UAE intellectual property laws and international conventions. Unauthorized use, reproduction, or distribution of this content is strictly prohibited without prior written consent from Creon L.L.C-FZ.

5. Compliance with UAE Law

This website operates in compliance with applicable UAE federal laws, including:

• Federal Decree-Law No. 34 of 2021 on Combatting Rumors and Cybercrimes: Users are prohibited from engaging in fraudulent activities or disseminating false information through this site.
• Federal Decree-Law No. 45 of 2021 (PDPL): Personal data collected through the site is managed in accordance with UAE privacy regulations (refer to our Privacy Policy).

Any misuse of this website that violates UAE law may result in civil and criminal penalties.

6. User Responsibility

By accessing this website, users agree to:

• Use the site only for lawful purposes related to B2B informational needs.
• Avoid introducing viruses, malware, or other harmful components that could disrupt the site's functionality.
• Refrain from unauthorized access to restricted areas of the site or its servers.

Violations of these terms may result in restricted access to the site and legal action as permitted by UAE law.

7. Amendments to This Policy

Creon L.L.C-FZ reserves the right to modify this Disclaimer Policy at any time without prior notice. Updates will be published on www.creon.ae, and continued use of the website constitutes acceptance of any changes made.

8. Governing Law and Jurisdiction

This Disclaimer Policy is governed by the laws of the United Arab Emirates and is subject to the exclusive jurisdiction of the courts in Meydan Free Zone Dubai.

9. Contact Information

For questions regarding this policy or concerns about website usage, please contact:

Email: legal@creon.ae
Address: Meydan Grandstand, 6th floor, Meydan Road, Nad Al Sheba, Dubai, U.A.E.

This Disclaimer Policy ensures compliance with UAE legal requirements while protecting Creon L.L.C-FZ from liability arising out of website usage by visitors and clients in its B2B operations context.

Terms of Service

Effective: 22.05.2024

1. Introduction

Welcome to Creon L.L.C-FZ. These Terms of Service ("Terms") govern your use of our website, products, and services (collectively, "Services"). By accessing or using our Services, you agree to comply with these Terms.

2. Company Information

Creon L.L.C-FZ is a legally registered entity with its office located at:

Meydan Grandstand, 6th floor, Meydan Road, Nad Al Sheba, Dubai, U.A.E.

3. Use of Services

You agree to use our Services in compliance with all applicable laws and regulations. You shall not:

• Use our Services for any unlawful purpose.
• Attempt to gain unauthorized access to our systems or data.
• Disrupt the functionality of our Services.

No online payments via our site

No services to individuals

4. Account Registration and Security

If you are required to create an account, you must provide accurate information and maintain the security of your credentials. You are responsible for all activities that occur under your account.

5. Intellectual Property

All content, trademarks, and intellectual property on our platform are owned by or licensed to Creon L.L.C-FZ. Unauthorized reproduction, distribution, or modification of any materials is strictly prohibited.

6. Payment and Fees

If applicable, you agree to pay all fees associated with our Services. Payments must be made in accordance with the billing terms provided at the time of purchase.

7. Limitation of Liability

Creon L.L.C-FZ shall not be liable for any direct, indirect, incidental, or consequential damages arising from the use of our Services. Our liability, if any, shall not exceed the total amount paid by you for the Services in the past six months.

8. Termination

We reserve the right to suspend or terminate your access to our Services if you violate these Terms or engage in any activities that may harm our business or reputation.

9. Governing Law

These Terms shall be governed by and construed in accordance with the laws of the United Arab Emirates. Any disputes shall be resolved in the competent courts of Dubai, UAE.

10. Changes to Terms

We may update these Terms from time to time. Any modifications will be posted on our website, and continued use of our Services constitutes acceptance of the updated Terms.

11. Contact Information

For any questions or concerns regarding these Terms, please contact us at:

Creon L.L.C-FZ, Meydan Grandstand, 6th floor, Meydan Road, Nad Al Sheba, Dubai, U.A.E.
Email: legal@creon.ae
Phone: +971 589 410747

Compliance Policy

Effective: 24.03.2025

Creon L.L.C-FZ ("we," "our," or "us") is committed to conducting business with integrity and in compliance with UAE laws through this Compliance Policy.

1. Scope and Purpose

Creon L.L.C-FZ, a Meydan Free Zone Dubai-registered B2B company specializing in AI-driven software development and fintech consultancy, commits to adhering to UAE laws and regulations. This policy ensures compliance with:

• Federal Decree-Law No. 47 of 2022 (Corporate Tax Law)
• Federal Decree-Law No. 45 of 2021 (PDPL)
• Federal Decree-Law No. 20 of 2018 (AML/CFT Law)
• Meydan Free Zone Dubai Compliance Guidelines
• Economic Substance Regulations (ESR)

2. Tax Compliance

Corporate Tax

• Registration: Registered with the Federal Tax Authority (FTA) under license no. 8556 with TRN 104673880100001
• Filing: Annual tax returns to be filed via EmaraTax by 30th September 2025.
• Record Retention: Financial records (invoices, ledgers, balance sheets) maintained for 7 years.

3. Anti-Money Laundering (AML) and Counter-Terrorism Financing (CFT)

• Customer Due Diligence (CDD):
  • Verify corporate client identities via the Meydan Free Zone Dubai Business Partner Portal.
  • Screen clients and third parties against UAE Central Bank's sanctions list.
• Reporting: Suspicious transactions reported to the UAE Financial Intelligence Unit (FIU) via goAML.
• Training: Annual AML/CFT training for employees, including phishing simulations.

4. Data Protection and Privacy

• PDPL Compliance:
  • Collect only essential corporate client data (e.g., company registration details).
  • Encrypt data in transit (SSL/TLS) and at rest (AES-256).
  • Report breaches to the UAE Data Office within 72 hours.
• Privacy Policy: Published on www.creon.ae, outlining data handling practices for B2B clients.

5. Economic Substance Regulations (ESR)

• Relevant Activities:
  • Distribution and Service Centre Business (fintech/AI software services).
• Compliance Tests:
  • Directed and Managed Test: Board meetings held in Meydan Free Zone Dubai.
  • Core Income-Generating Activities (CIGA): Development and consultancy services performed locally.
• Reporting: ESR notifications submitted within 6 months, and detailed reports within 12 months of the financial year.

6. Legal and Operational Disclosures

• Website Compliance:
  • Display valid licenses (Commercial License 8556/2 and Service License 8556) with QR codes for verification.
  • Include disclaimers:
    • No online payments via our site
    • No services to individuals
  • Electronic Invoicing: Prepare for mandatory e-invoicing for transactions over AED 50,000 starting July 2025.

7. Audit and Record-Keeping

• Record Retention: Maintain records for 5 years (Meydan Free Zone Dubai) or 7 years (tax purposes).

8. Roles and Responsibilities

• Compliance Officer:
  • Role: Director
  • Duties: Oversee tax/AML/ESR compliance, manage audits, and liaise with regulators.
• Employees: Complete mandatory training and report violations via compliance@creon.ae.

9. Policy Updates

Reviewed annually or after regulatory changes (e.g., UAE Corporate Tax Law amendments). Updates published on www.creon.ae under Terms & Policies.

Contact for Compliance Queries

Email: compliance@creon.ae
Address: Meydan Grandstand, 6th floor, Meydan Road, Nad Al Sheba, Dubai, U.A.E.

This policy aligns with Creon L.L.C-FZ's B2B operations, UAE legal frameworks, and international standards, ensuring transparency and mitigating regulatory risks.