Draft for legal review. Prepared for BioMax and the partner clinic to review with UAE counsel before publication. Highlighted text in brackets needs to be completed or confirmed.
Your health information is personal. This policy explains what we collect, why, who we share it with, how long we keep it, and your rights.
1. Who we are
BioMax is operated by [legal entity name] (“BioMax”, “we”). For your consultation and prescriptions, [partner clinic name] and [pharmacy name] are also responsible for the records they keep. You can contact our data protection lead at [privacy email].
2. What we collect
- Identity and contact details: name, date of birth, sex at birth, email, mobile number, delivery address and, where needed, Emirates ID details to confirm your identity
- Health information: your assessment answers, medical history, medicines, allergies, uploaded blood test results, consultation notes and prescriptions
- Order and payment information: what you ordered and paid for. Card details are handled by our payment provider, not stored by us.
- Communications: messages with our care team and physicians
- Technical information: device, browser, IP address and how you use the website, including through cookies
3. How we use it
- To run the assessment and show protocols that may match your goals
- To let a physician assess you, consult with you and decide whether to prescribe
- To have prescriptions dispensed and delivered, and to take payment
- To send you service messages, such as booking confirmations and refill reminders
- To keep the service safe, prevent fraud and meet our legal and regulatory obligations
- With your consent, to send you news and offers. You can opt out at any time.
We do not use your health information for advertising, and we never sell your personal data.
4. Our legal basis
We process your health information with your explicit consent, which you give in the assessment declaration, and as needed to provide healthcare and meet our obligations under UAE law. Health information has its own rules in the UAE, so these laws apply: [Federal Law No. 2 of 2019 on the Use of Information and Communications Technology in Health Fields], [Federal Decree-Law No. 45 of 2021 on Personal Data Protection], and [the Dubai Health Authority's health data protection and confidentiality requirements]. [Counsel to confirm.]
6. Where your data is stored
Health information is stored on servers located in the United Arab Emirates. We do not transfer your health information outside the UAE. [Counsel to confirm any exceptions.]
7. How long we keep it
Medical records are kept for as long as UAE law requires, [currently understood to be at least 25 years from your last treatment; counsel to confirm]. Other information is kept only as long as needed for the purposes above, then deleted or anonymised.
8. Your rights
Subject to UAE law, you can:
- ask for a copy of the personal data we hold about you
- ask us to correct inaccurate information
- ask us to delete information we no longer need. Medical records we are required to keep cannot be deleted early.
- withdraw consent to marketing at any time
- object to or restrict certain uses
To make a request, email [privacy email]. If you are unhappy with how we handle your data, you can complain to [the UAE Data Office or relevant authority].
9. How we protect it
We use encryption in transit and at rest, access controls so only people involved in your care can see your health information, and regular security reviews. No system is completely secure, so please keep your password private.
11. Children
BioMax is for adults only. We do not knowingly collect information from anyone under 18.
12. Changes to this policy
We will post any changes here with a new date and tell you about significant changes by email.

