Privacy Policy

1. Who We Are

Smart Learning Academy ("we", "us", "our") operates the e-learning platform at smartacademy.ae. This Privacy Policy explains how we collect, use, store, and protect your personal data in compliance with UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (PDPL).

2. Data We Collect

We may collect the following categories of personal data:

• Identity data: full name, date of birth, and profile photo.
• Contact data: email address and phone number.
• Account data: username, password (hashed), and account preferences.
• Payment data: billing address and transaction records (card details are not stored by us).
• Usage data: courses accessed, progress, quiz results, and login timestamps.
• Technical data: IP address, browser type, device information, and cookies.

3. How We Use Your Data

We use your personal data to:

• Create and manage your account and course enrolments.
• Process payments and issue receipts or refunds, where payment services are enabled.
• Provide customer support and respond to enquiries.
• Send transactional emails (receipts, course updates, password resets).
• Send promotional communications — only with your consent, which you may withdraw at any time.
• Comply with our legal obligations under UAE law.

We do not currently use any analytics or tracking platform on the Platform. If this changes, this Policy will be updated to describe it before it is enabled — see our Cookie Policy.

4. Legal Basis for Processing

We process your data on the basis of: (a) contract performance — to deliver the services you have purchased; (b) legitimate interests — to improve and secure the Platform; (c) consent — for marketing communications; and (d) legal obligation — where required by UAE law.

5. Data Sharing

We do not sell your personal data. We may share data with trusted third parties solely to operate our services, including:

• Payment processors — only for transactions where a payment gateway is enabled and used; no payment processor receives your data otherwise.
• Cloud hosting providers for Platform infrastructure.
• Email service providers for transactional and, where you have consented, marketing communications.

All third-party processors we do use are contractually bound to handle data securely and in accordance with applicable law. We do not currently share data with any analytics platform (see Cookie Policy).

6. Data Retention

We retain your personal data for as long as your account remains active, and for a minimum of five (5) years thereafter to comply with UAE commercial and tax law requirements. You may request deletion of your data, subject to legal retention obligations.

7. Your Rights

Under UAE PDPL, you have the right to:

• Access the personal data we hold about you.
• Correct inaccurate or incomplete data.
• Request deletion of your data (subject to legal exceptions).
• Withdraw consent for marketing at any time.
• Lodge a complaint with the UAE Data Office.

To exercise your rights, contact us at: smart-learning@smartacademy.ae

8. Data Security

We implement appropriate technical and organisational measures to protect your data, including SSL encryption, secure servers, access controls, and regular security reviews. However, no internet transmission is entirely secure, and we cannot guarantee absolute security.

9. Children's Privacy

The Platform is not directed at children under 13. If we become aware that we have collected personal data from a child under 13 without parental consent, we will delete it promptly.

10. Privacy Enquiries & Complaints

For privacy enquiries or complaints, contact us at: smart-learning@smartacademy.ae. No formal Data Protection Officer has been appointed at this time; enquiries are handled by our support team.