Privacy Policy

Effective date: 20 March 2026

Acumen Advertising DMCC (“Company”, “we”, “us”), a company registered in the Dubai Multi Commodities Centre free zone, United Arab Emirates (Registration No. JLT3208), operates the Anabel AI executive assistant platform (“Service”). This Privacy Policy explains how we collect, use, store, and protect your personal data.

1. Data We Collect

We collect the following categories of data:

• Account data: Name, email address, company name, and billing information provided during registration.
• Service data: Data from connected third-party integrations (email content, calendar events, CRM records, documents) that you authorise the Service to access on your behalf.
• Usage data: Message counts, feature usage, login timestamps, and session metadata for billing and service improvement.
• Technical data: IP address, browser type, device information, and cookies collected automatically when you access the platform.

2. How We Use Your Data

We use your data to:

• Provision and operate your dedicated Anabel instance.
• Process your instructions and deliver AI-powered outputs.
• Process payments and manage your subscription.
• Send transactional communications (billing receipts, security alerts, service updates).
• Monitor and improve the performance, security, and reliability of the Service.
• Comply with legal obligations.

We do not use your business data to train AI models. Your data is processed solely to deliver the Service.

3. Data Isolation

Each customer receives a dedicated, isolated cloud instance. Your data is logically and architecturally separated from all other customers. No other customer or their AI instance can access your data.

4. Third-Party Services

We share data with the following categories of third parties, strictly as needed to operate the Service:

• Payment processor: Our merchant of record processes billing data (name, email, payment method) to handle subscriptions and tax compliance.
• AI model providers: Your messages are processed by AI model providers (Anthropic) to generate responses. These providers process data under their enterprise terms and do not use your data for model training.
• Cloud infrastructure: Your instance runs on cloud infrastructure providers with SOC 2-aligned security controls.
• Connected integrations: When you connect third-party services (Google, HubSpot, etc.), data flows between those services and your Anabel instance according to the permissions you grant.

We do not sell your personal data to third parties.

5. Data Security

We implement the following security measures:

• Encryption in transit (TLS 1.2+) and at rest (AES-256).
• Dedicated instance isolation per customer.
• Access controls and audit logging.
• Regular security assessments and monitoring.
• Prompt injection defences and canary token monitoring.

6. Data Retention

• Active subscription: Your data is retained for the duration of your subscription.
• After cancellation: Your data is available for export for 30 days following cancellation, after which it is permanently deleted.
• Billing records: Transaction and invoice data may be retained for up to 7 years to comply with tax and accounting obligations.

7. Your Rights

You have the right to:

• Access the personal data we hold about you.
• Correct inaccurate or incomplete data.
• Delete your personal data (subject to legal retention requirements).
• Export your data in a portable format.
• Withdraw consent for optional data processing at any time.

To exercise any of these rights, contact us at privacy@getanabel.ai.

8. Cookies

We use essential cookies to maintain your session and preferences. We do not use advertising or tracking cookies. Analytics cookies, if used, are anonymised and do not identify individual users.

9. International Data Transfers

Your data may be processed in jurisdictions outside the UAE where our infrastructure providers operate. We ensure appropriate safeguards are in place, including data processing agreements with our providers that meet internationally recognised standards.

This Privacy Policy also reflects our obligations under the UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (PDPL). If you are located in the UAE, you have the rights described above and may direct enquiries to privacy@getanabel.ai.

10. Data Processing Agreements

If you are an enterprise customer and require a formal Data Processing Agreement (DPA) setting out our obligations as Data Processor under GDPR or UAE PDPL, please contact us at privacy@getanabel.ai. We will provide a pre-signed DPA within 2 business days.

11. Children

The Service is not intended for individuals under 18 years of age. We do not knowingly collect data from children.

12. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes via email or through the Service. The effective date at the top of this page indicates the latest revision.

13. Contact

For privacy-related enquiries, contact us at:

Acumen Advertising DMCC
Unit 805, Tiffany Towers
Jumeirah Lakes Towers, Dubai, UAE
privacy@getanabel.ai