Privacy Policy

Last Updated: 25 April 2026

Introduction

1. Contrafly FZCO is a limited liability freezone company registered with the Dubai International Economic Zones Authority with its registered address at DSO-IFZA, IFZA Properties, Dubai Silicon Oasis(the Company, we or us). Contrafly provides a secure AI platform that provides human-in-the-loop contract review, interrogation and drafting functionality to augment user productivity (the Services). 

2. This privacy policy (Policy) sets out how the Company uses and protects data relating to an identifiable individual (referred to as personal data) through your use of this website and in our other interactions with you. We recommend you read this policy in full so that you understand how we collect and use your personal data. If you have any questions please contact us, details of how you can do so by contacting Contrafly by email at privacy@contrafly.com.

3. This Policy does not apply to any input or output of our Services, the use of our Services and the collection, use and storage of data inputted or outputted from our Services is governed by the relevant agreement between Contrafly and you in connection with the Services.

4. For the purposes of applicable data protection law, the Company is typically the “data controller” of any personal information provided to us.

What information do we collect?

5. We may collect information about you from different sources as detailed below.

• Information you give us:

  • you may give us information about yourself when you respond to a communication from us or by filling in forms (both online and offline), over the telephone and through written correspondence with us.  The personal data that we might collect and process about you may include:

    • your name and contact details (for example, your address, phone number and email address) – this may occur when, for example, you request information from us in connection with our products or services;

    • other personal information such as demographic details (age, nationality, etc.) or work-related information (job, title, seniority, etc.);

    • your opinions and views about your industry, your company, our products and services; and

    • such other information as we may deem to be reasonably required or desirable in connection with your use of this Website and/or our products or services from time to time.

• Information we receive and collect from other sources:

  • We may collect certain types of personal data from you when you visit or use our website, for example by using cookies and similar technologies. This may include technical information about you which is automatically generated (for example, information about your IP address, your browser identity, and any relevant referring website that directed you to our website).  When visitors leave comments on the Website, we may also collect the data shown in the comments form, and the visitor’s IP address and browser user agent string to help spam detection.

  • We may receive information about you from other websites operated by us or from the other services that we provide.

How do we use your personal information?

6. We use your personal data to operate, administer and personalize your experience on this Website, and in accordance with this Policy and the purposes for which we collected the personal data. For example, we may use your personal data to:

• send you updates by way of email, provide information and/or deliver our newsletters, if you have subscribed for this;

• contact you to schedule a meeting or discussion about our products or services, if you have requested this;

• customise the experience of visiting our website to make it more valuable and enjoyable, including processing of information in order to keep our website safe and secure and protect against fraudulent or illegal activity such as cyber-attacks;

• improve our products and services to deliver a better service to you or customers with a similar profile;

• comply with legal requirements and exercise or defend legal claims;

• keep an up-to-date suppression list where you have asked not to be contacted, so we do not inadvertently re-contact you;

• or such other purposes as we may deem to be reasonably required or desirable in connection with your use of this Website and/or our products or services from time to time.

7. We may share your personal data with our affiliated or group companies and with third parties to whom we have outsourced certain activities and with whom we have signed relevant non-disclosure and/or data processing agreements.

8. In order to fulfil the purposes for processing your personal data as described in this Policy, from time to time we may transfer your personal data to other countries.  If we do so, we will rely on certain legal bases to transfer your personal data in this manner (as further described below), and which may include your consent and our reliance on model contractual clauses which establish certain privacy protections and security standards.

9. Some countries where we might transfer your personal data may have privacy and data protection laws and regulations that are different from (and may be less stringent than) the laws of your home country.

Our use of cookies and related technologies

10. Our website uses “cookies”, which are small files that may be placed on your device by a web server.  There are different types of cookies, and they may be used for different purposes.  For example, a cookie might remember certain preferences or settings chosen by a site visitor, such as choice of language or home country, so that the same preferences are offered to the visitor the next time he or she accesses the site.  Cookies may also be used to facilitate targeted advertising and site analytics.

11. It is in your discretion whether or not you choose to accept or reject cookies on our website.  However, not allowing certain cookies may impact on your ability to access or use certain features of the Website.  If you wish to manage your cookie preferences, you can do so via your browser settings.

What is the legal basis for us processing your information?

12. We may rely on different reasons to establish the basis for processing your personal data.  These may include:

    • we have a legal obligation;

    • we have a vital interest, or the processing is necessary to protect your interests;

    • we need it to perform a public task or protect public interest;

    • we have a contractual obligation;

    • we have a legitimate interest; and/or

    • your consent.

13. You may remove your consent at any time by contacitng us using the email address above.

Where do we store your personal information?

14. The personal information that we collect from you will be stored in the UAE, although it could be transferred to any other company owned by us regardless of geographic location, in the process of our business operations. We will take all steps that are reasonably necessary to ensure that your personal information is treated securely and in accordance with this Policy and applicable data protection laws.

15. It may also be necessary for us to share your personal information with third parties around the world, who provide services to us (including data storage facilities or online storage located within or outside the United Arab Emirates, which may be operated by independent service contractors). Where such transfers occur, we ensure appropriate safeguards, including as appropriate to the jurisdiction in question, the use of standard contractual clauses, limiting transfers to jurisdictions recognised as having at least equivalent data protection legislation and regulations as well as specific contractual and technical protections.

Security of personal information

16. All information you provide to us via our website is stored on our secure servers.

17. We have taken steps to safeguard the integrity of our communications and computing infrastructure, which includes implementing adequate security measures and standards to protect against unauthorised use or disclosure. Security measures have been integrated into the design, implementation, and day-to-day operations of this website as part of our continuing commitment to the security of electronic content and the electronic transmission of information. Despite our best efforts unfortunately the transmission of information via the internet is not completely secure. Although we have strict procedures and security measures in place, we cannot guarantee the security of your data transmitted to our website.

Third-party websites and apps

18. Our website may contain links to and from third party websites.  Please note that if you follow a link to any of these websites, these websites will have their own terms of use and privacy policies and that we do not accept any responsibility or liability for these policies.  Please check these policies before you submit any personal data to these websites.

What rights do you have related to your personal information?

19. Under applicable data protection laws and regulations, you have certain rights in relation to your personal information.  These rights may include:

• your right of access – You have the right to ask us for copies of your personal information;

• your right to rectification – You have the right to ask us to correct personal information you think is inaccurate. You also have the right to ask us to complete personal information you think is incomplete;

• your right to erasure – You have the right to ask us to erase your personal information in certain circumstances;

• your right to restriction of processing – You have the right to ask us to restrict the processing of your personal information in certain circumstances;

• your right to object to processing – You have the right to object to the processing of your personal information in certain circumstances; and

• your right to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.

20. You may contact us at any point using the details below to exercise these rights.

How long do we keep your personal information?

21. Your personal information is stored by us and/or our third-party service providers, strictly to the extent necessary for the performance of our obligations and strictly for the time necessary to achieve the purposes for which the information is collected, in accordance with applicable data protection laws. 

22. When we no longer need to use your information, we will remove it from our systems and records and/or take steps to properly anonymise it so that you can no longer be identified from it (unless we need to keep your information to comply with legal or regulatory obligations to which we are subject).

Changes to this policy

23. We may update this policy from time to time in response to changing legal, regulatory or operational requirements. Any changes will be updated on our website.  Your continued use of our website and/or products or services after any such updates take effect will constitute acceptance of those changes.