Privacy Policy - CNTXT

Last Updated: October 22, 2025

1. Introduction

This CNTXT Privacy Policy ("Policy") explains how CNTXT FZCO. and its affiliates and subsidiaries operating under the 'CNTXT' brand ("CNTXT", "we", "our" or "us") collect, store, use, disclose and otherwise process information about you when you interact with our www.cntxt.tech ("Website") and our services, or products. This Policy also sets out more information about your privacy rights.

2. Acceptance of Terms

By using CNTXT's services and website, users accept the terms outlined in this Data Privacy Policy.

3. Scope of Privacy Policy

This Policy explains and describes when this Policy applies. Below are the following Sections of this Policy:

4. Legislation & Guidance

This Policy aims to meet the requirements of the General Data Protection Regulation (Regulation (EU) 2016/679), the ADGM Data Protection Regulations of 2021, and Federal Decree Law No. 45/2021 on the Protection of Personal Data of the United Arab Emirates.

5. Definitions

Personal Data means any data relating to an identified natural person, or a natural person who can be identified, directly or indirectly, through the linking of data, by reference to an identifier such as his name, voice, image, identification number, online identifier, geographical location, or one or more physical, physiological, economic, cultural or social characteristics.

Process or Processing means anything done to personal data, such as collecting, recording, organizing, structuring, storing, adapting, altering, retrieving, using, disseminating, erasing or destroying. Processing can be automated or manual.

Unless otherwise specified in this Policy, terms shall have the meanings assigned to them under the ADGM Data Protection Regulations. If a term is not defined in the ADGM Data Protection Regulations, it shall have the meaning ascribed to it under the laws of Abu Dhabi, the United Arab Emirates, or the General Data Protection Regulation (GDPR), in that order of precedence. If no specific definition exists within these frameworks, the term shall be interpreted based on generally accepted principles of data protection law.

6. Scope

This Privacy Policy applies to the personal information we collect when you use our website and our products, services, and applications (collectively, the "Services"), when you attend a CNTXT event, or otherwise interact with us. This information may include the information below:

Personal Information You Provide Directly

We collect personal information that you voluntarily share with us when interacting with our website or Services. This information is used to deliver, enhance, promote, and secure the Services, protect our legitimate interests, or comply with legal obligations. While providing this information is optional, it may be necessary for specific activities, such as account registration. Failure to provide this information could prevent CNTXT from offering the requested Services.

Personal Information Collected Automatically

We automatically collect certain information, which may include personal data, using standard tools such as log files, cookies, pixel tags, and similar technologies as you navigate our Services or engage with our emails. For further details, please refer to our Cookie Policy.

Personal Information Collected Through Third Parties

We may obtain personal data from third-party sources, such as authentication providers and public databases, for purposes like user verification and marketing. For example, if you log in to your account using Google credentials, we may access your name and email address for authentication purposes.

7. Types of Personal Data We Collect

The types of personal data we collect may include without limitation:

8. How We Use Your Personal Data

We will use your personal data for the following purposes:

The principles of Lawfulness, fairness and transparency are the pillars of processing your Personal Data. We process your personal data based on the following legal grounds:

10. Disclosure of your personal information by us

We may disclose your information to our third-party service providers, agents and subcontractors for the purposes of providing services to us or directly to you on our behalf, including to provide transcription, insights, and detailed notes etc.

We only disclose your personal information outside our business in limited circumstances. If we do, we will put in place a contract that requires recipients to protect your personal information, unless we are legally required to share that information. Any contractors or recipients that work for us will be obliged to follow our instructions and the data shall be deleted on completion of processing. We do not sell your personal information to third parties.

11. Data Security and Protection

12. Data Retention

13. CONFIDENTIALITY

13.1 Confidential Information means all confidential information (however recorded or preserved) disclosed by a party or its Representatives (as defined below) to, or obtained by, the other party and that party's Representatives whether before or after the date of the Agreement in connection with the Agreement, including but not limited to:

13.1.1 the terms of the Agreement or any agreement entered into in connection with the Agreement;

13.1.2 any information that would be regarded as confidential by a reasonable business person relating to:

13.1.2.1 the business, assets, affairs, customers, clients, suppliers, or plans, intentions, or market opportunities of the disclosing party (or of any Affiliate of the disclosing party); and

13.1.2.2 the operations, processes, product information, know-how, designs, trade secrets or software of the disclosing party (or of any Affiliate of the disclosing party);

13.1.3 any information developed by the parties in the course of carrying out the Agreement and the parties agree that:

13.1.3.1 details of the Services, and the results of any performance tests of the Services, shall constitute CNTXT Confidential Information; and

13.1.3.2 Customer Data shall constitute Customer Confidential Information.

"Representatives" means, in relation to a party, its employees, officers, contractors, subcontractors, representatives and advisers.

13.2 The provisions of this clause shall not apply to any Confidential Information that:

13.2.1 is or becomes generally available to the public (other than as a result of its disclosure by the receiving party or its Representatives in breach of this clause);

13.2.2 was available to the receiving party on a non-confidential basis before disclosure by the disclosing party;

13.2.3 was, is or becomes available to the receiving party on a non-confidential basis from a person who, to the receiving party's knowledge, is not bound by a confidentiality agreement with the disclosing party or otherwise prohibited from disclosing the information to the receiving party;

13.2.4 the parties agree in writing is not confidential or may be disclosed; or

13.2.5 is developed by or for the receiving party independently of the information disclosed by the disclosing party.

13.3 Each party shall keep the other party's Confidential Information secret and confidential and shall not:

13.3.1 use such Confidential Information except for the purpose of exercising or performing its rights and obligations under or in connection with the Agreement (Permitted Purpose); or

13.3.2 disclose such Confidential Information in whole or in part to any third party, except as expressly permitted by this clause 13.

13.4 A party may disclose the other party's Confidential Information to those of its Representatives who need to know such Confidential Information for the Permitted Purpose, provided that:

13.4.1 it informs such Representatives of the confidential nature of the Confidential Information before disclosure; and

13.4.2 at all times, it is responsible for such Representatives' compliance with the confidentiality obligations set out in this clause.

13.5 A party may disclose Confidential Information to the extent such Confidential Information is required to be disclosed by applicable law, by any governmental or other regulatory authority (including, without limitation, any relevant securities exchanges) or by a court or other authority of competent jurisdiction provided that, to the extent it is legally permitted to do so, it gives the other party as much notice of such disclosure as possible and, where notice of disclosure is not prohibited and is given in accordance with this clause 13.5, it takes into account the reasonable requests of the other party in relation to the content of such disclosure.

13.6 Each party reserves all rights in its Confidential Information. No rights or obligations in respect of a party's Confidential Information other than those expressly stated in the Agreement are granted to the other party, or are to be implied from the Agreement.

13.7 On termination or expiry of the Agreement, each party shall:

13.7.1 destroy or return to the other party all documents and materials (and any copies) containing, reflecting, incorporating or based on the other party's Confidential Information;

13.7.2 erase all the other party's Confidential Information from computer and communications systems and devices used by it, including such systems and data storage services provided by third parties (to the extent technically and legally practicable); and

13.7.3 certify in writing to the other party that it has complied with the requirements of this clause, provided that a recipient party may retain documents and materials containing, reflecting, incorporating or based on the other party's Confidential Information to the extent required by law or any applicable governmental or regulatory authority. The provisions of this clause shall continue to apply to any such documents and materials retained by a recipient party, subject to clause 16 (Termination).

13.8 CNTXT may refer to the Customer by name as a customer in respect of the Services for the purpose of promoting or marketing CNTXT and its services.

13.9 Except as expressly stated in the Agreement, no party makes any express or implied warranty or representation concerning its Confidential Information.

13.10 The above provisions of this clause 13 shall continue to apply after termination or expiry of the Agreement.

14. Cookies and Tracking Technologies

15. Google Workspace APIs and Artificial Intelligence

15.1. Any data accessed through Google Workspace APIs is not and will not be used for:

15.2. Scope of Data Usage

Data accessed through Google Workspace APIs is strictly limited to:

15.3. User Rights and Transparency

Users can be assured that:

16. Your Rights

Individuals have the right to:

17. Training

All our employees receive data protection training as part of their induction process. Data protection will also form part of continuing professional development where changes to legislation, guidance, or our processes make it necessary.

18. Changes to the Privacy Policy

We may periodically update this Data Privacy Policy. Changes will be reflected on our Website with the updated date. Any changes to this Privacy Policy will become effective when we post the revised Privacy Policy on the Website.

19. Contact Information

For questions, concerns, or requests related to this Data Privacy Policy, please contact us at support@cntxt.tech.

20. Governing Law

This Data Privacy Policy is governed by the laws of the Abu Dhabi Global Market, United Arab Emirates.