Privacy Policy

Introduction

EliteCare Global, Inc. (“EliteCare”, “we”, “our”, or “us”) is a Delaware C-Corporation and the parent company of EliteCare Home Healthcare L.L.C, a Dubai mainland Limited Liability Company registered with the Dubai Department of Economy and Tourism (DET). We operate a specialist respiratory home healthcare service in Dubai, UAE.

We are committed to protecting the privacy, confidentiality, and security of all personal data we collect and process. This Privacy Policy explains how we collect, use, store, share, and protect your personal information when you use our website (elitecarehhcc.com), contact us, receive our services, or invest in our company.

This policy is designed to comply with:

• UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (UAE PDPL)
• Cabinet Decision No. 83 of 2022 (Executive Regulations of the UAE PDPL)
• Federal Law No. 2 of 2019 on the Use of ICT in the Health Fields (Healthcare ICT Law)
• Dubai Health Authority (DHA) data governance and NABIDH standards
• US Delaware corporate law requirements applicable to investor data

Who We Are — Data Controller

For the purposes of the UAE PDPL, the data controller for personal data collected through this website and in connection with our services is:

For investor-related data processed in connection with the Wefunder community round and SAFE agreements, the data controller is:

What Personal Data We Collect

Website Visitors

• IP address and browser type (collected automatically via server logs)
• Pages visited, time on site, and referral source (analytics)
• Name and email address if you submit an enquiry form or subscribe to updates
• Cookie data (see Cookie section below)

Patients and Families

• Full name, Emirates ID number, date of birth, nationality
• Contact details — address, email, phone/WhatsApp number
• Next of kin and caregiver contact details
• Clinical and health information — diagnosis, medications, ventilator settings, oxygen prescription, care plan, clinical visit notes, vital signs, and other medical data
• Health insurance details and policy information
• NABIDH records — clinical data shared with and received from Dubai’s unified health information network
• Payment information (processed securely through authorised payment processors)

Hospital and Clinical Partners

• Name, job title, DHA licence number, and contact details of referring clinicians
• Hospital name and department
• Patient referral information shared in the course of care coordination

Investors

• Name, email address, country of residence
• Investment amount and SAFE agreement details
• Identity verification information as required by Wefunder and applicable KYC/AML regulations
• Communication preferences

Job Applicants and Clinical Staff

• CV, professional qualifications, DHA licence details, immunisation records, and employment history
• Identity documents as required for DHA and MOHRE processing

How We Use Your Personal Data

We will never use your personal data for purposes beyond those stated above without obtaining fresh consent. We will never sell your personal data to third parties.

Sensitive Personal Data — Health Information

Health and clinical data is classified as sensitive personal data under the UAE PDPL and is subject to heightened protections. We only process your health data where:

• You have provided explicit, informed, written consent before the start of your care
• Processing is necessary for the provision of healthcare services or preventive medicine
• Processing is required by law — including DHA NABIDH reporting obligations

All clinical data is stored in our Unite+ NABIDH-compliant EMR system, which meets DHA technical security standards. Clinical data is accessible only to authorised members of your care team and the referring physician, subject to your consent.

Who We Share Your Data With

We do not sell, rent, or trade your personal data. We share data only as necessary and with appropriate safeguards in place:

International Data Transfers

EliteCare Global, Inc. is incorporated in Delaware, USA. Investor data relating to SAFE agreements may be processed and stored in the United States through Wefunder and Carta, both of which maintain appropriate data protection safeguards.

In accordance with UAE PDPL Article 22 and Cabinet Decision No. 83 of 2022, cross-border transfers of personal data are subject to adequate safeguards. We use contractual clauses and work only with processors that provide sufficient guarantees of data protection standards equivalent to the UAE PDPL.

Patient clinical data is stored within UAE-based systems (Unite+ EMR) and is not transferred internationally except where required by law or with explicit consent.

Your Rights Under the UAE PDPL

Under Federal Decree-Law No. 45 of 2021, you have the following rights regarding your personal data:

• Right to be informed — to know what data we hold about you, why, and how it is used
• Right of access — to receive a copy of your personal data in a readable format
• Right to rectification — to correct inaccurate or incomplete data
• Right to erasure — to request deletion of your data, subject to legal retention obligations
• Right to object — to object to processing for marketing purposes at any time
• Right to data portability — to receive your data in a transferable format
• Right to withdraw consent — to withdraw consent for any processing based on consent

To exercise any of these rights, contact us at info@elitecarehhcc.com. We will respond within 30 days. We may require identity verification before processing your request. Requests that are manifestly unfounded or excessive may be declined in accordance with the PDPL.

You also have the right to lodge a complaint with the UAE Data Office if you believe your data has been processed unlawfully.

Data Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, destruction, or alteration. These include:

• NABIDH-compliant encrypted EMR system (Unite+) for all clinical data
• Encrypted communications for all patient-identifiable data
• Access controls — clinical data accessible only to authorised care team members
• Secure cloud storage with UAE data residency for clinical records
• Staff training on data protection and confidentiality obligations
• Regular security assessments and NABIDH AI privacy audit compliance

In the event of a data breach that presents a significant risk of harm, we will notify the UAE Data Office and affected individuals promptly in accordance with UAE PDPL Article 26.

Data Retention

When data is no longer required for its stated purpose and no legal retention obligation applies, it will be securely deleted or anonymised.

Cookies

Our website uses cookies to improve your experience. We use:

• Essential cookies — necessary for the website to function correctly; cannot be disabled
• Analytics cookies — help us understand how visitors use the site (e.g. Google Analytics); only set with your consent
• Preference cookies — remember your language and accessibility preferences

On your first visit, you will be asked to accept or decline non-essential cookies. You can change your cookie preferences at any time using the Cookie Settings link in the footer. You can also manage cookies through your browser settings.

Children’s Data

EliteCare provides clinical services to paediatric patients. Where we process health data relating to children (under 18), we obtain explicit consent from a parent or legal guardian before processing. Parental consent is documented as part of the clinical intake process. Children’s data is held to the same security standards as adult clinical data.

Our website is not directed at children. We do not knowingly collect personal data from individuals under the age of 18 through our website without parental consent.

Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our services, legal requirements, or best practices. We will notify active patients and investors of material changes by email. The “Last Updated” date at the top of this policy reflects the most recent revision. Continued use of our website or services following notification of changes constitutes acceptance of the updated policy.

Contact Us — Privacy Enquiries

For any questions, concerns, or requests regarding this Privacy Policy or your personal data, please contact:

We will acknowledge your enquiry within 5 working days and respond fully within 30 days, as required under the UAE PDPL. If you are unsatisfied with our response, you have the right to lodge a complaint with the UAE Data Office.