1. Introduction

This Cookie Policy describes how Zenway International FZ-LLC, operating under the brand name ZenVisa International ("Company," "we," "us," or "our"), uses cookies and similar tracking technologies on our website at https://www.zenvisa.net (the "Website").

This Cookie Policy is designed to provide you with clear and comprehensive information about the cookies we use, the purposes for which we use them, and the choices you have regarding their use. It should be read together with our Privacy Policy and Terms of Use, which are incorporated herein by reference.

By accessing or using the Website, you acknowledge that you have read, understood, and agree to the use of cookies and similar technologies as described in this Cookie Policy. If you do not agree to our use of cookies, you must adjust your browser settings accordingly or discontinue use of the Website.

2. Company Identity

The entity responsible for the use of cookies and similar tracking technologies on the Website is:

We act as the Data Controller for personal data collected through cookies and similar tracking technologies, in accordance with UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (PDPL) and, where applicable, the General Data Protection Regulation (GDPR) and UK GDPR.

3. Scope of this Cookie Policy

This Cookie Policy applies to all cookies and similar tracking technologies placed on your device when you access or use the Website, including all subdomains, pages, features, and functionality.

This Cookie Policy covers:

• First-party cookies placed directly by us;

• Third-party cookies placed by our service providers and partners;

• Web beacons, pixel tags, tracking pixels, and similar technologies;

• Local storage, session storage, and similar browser-based storage technologies;

• Fingerprinting and device recognition technologies.

This Cookie Policy does not apply to cookies or tracking technologies used by third-party websites or services that are linked from our Website. We encourage you to review the cookie policies of any third-party websites you visit.

4. Definitions

The following terms, when used in this Cookie Policy with initial capital letters, shall have the meanings ascribed below:

"Applicable Law": means all laws, regulations, and regulatory requirements applicable to the use of cookies and processing of personal data, including the PDPL, GDPR, UK GDPR, UAE Consumer Protection Law, UAE Electronic Transactions Law, and the ePrivacy Directive 2002/58/EC (as amended).

"Cookie": means a small text file consisting of letters and numbers that is placed on your device (computer, tablet, smartphone, or other internet-enabled device) when you visit a website. Cookies are stored by your browser and transmitted back to the originating website on subsequent visits.

"Data Controller": has the meaning ascribed to it in the PDPL, GDPR, and UK GDPR.

"Device": means any computer, tablet, smartphone, or other internet-enabled device used to access the Website.

"Fingerprinting": means a technique that collects information about a device's configuration (such as screen resolution, installed fonts, browser plugins, and time zone) to create a unique identifier for that device without using cookies.

"First-Party Cookie": means a cookie placed on your device directly by the Website you are visiting.

"PDPL": means UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data, as amended.

"Persistent Cookie": means a cookie that remains on your device for a specified period or until you manually delete it.

"Session Cookie": means a cookie that is automatically deleted when you close your browser.

"Similar Technologies": means technologies that store or access information on your device, including but not limited to web beacons, pixel tags, tracking pixels, local storage, session storage, indexed databases, and device fingerprinting.

"Third-Party Cookie": means a cookie placed on your device by a domain other than the Website you are visiting, typically by third-party service providers integrated into the Website.

"User": means any natural person who accesses, browses, or uses the Website.

"Website": means the website operated by the Company and accessible at https://www.zenvisa.net, including all subdomains, pages, content, features, and functionality.

5. What Cookies Are

Cookies are small text files that websites place on your device when you visit them. They are widely used to make websites work efficiently, to improve user experience, and to provide information to website owners. Cookies enable a website to recognize your device and remember your preferences and actions over time.

Cookies typically contain the following information:

• The name of the website that placed the cookie;

• A unique identifier (a randomly generated string of characters);

• An expiration date indicating how long the cookie will remain on your device;

• Optional values or flags set by the website.

In addition to cookies, we use similar tracking technologies that perform comparable functions. These include web beacons (small graphic images placed on web pages or in emails), pixel tags (tiny pieces of code that track user activity), local storage (which allows websites to store data in your browser beyond the capacity of cookies), and device fingerprinting (which creates a unique identifier based on your device's characteristics).

Throughout this Cookie Policy, references to "cookies" include all similar tracking technologies unless otherwise specified.

6. Why Cookies Are Used

We use cookies and similar technologies for the following purposes:

• To enable the essential functionality of the Website and provide the services you request;

• To remember your preferences, settings, and choices to enhance your browsing experience;

• To analyze Website traffic, user behavior, and performance metrics;

• To monitor and improve the security and integrity of the Website;

• To detect and prevent fraud, unauthorized access, and other security threats;

• To deliver relevant advertising and marketing communications;

• To measure the effectiveness of our advertising campaigns;

• To enable social media features and content sharing;

• To understand how users interact with the Website and to identify areas for improvement;

• To comply with legal obligations and regulatory requirements.

7. Categories of Cookies

The cookies we use fall into the following categories. Each category serves different purposes and has different legal bases for processing.

Strictly Necessary Cookies are essential for the operation of the Website and do not require your consent. All other categories of cookies require your consent before they are placed on your device.

8. Strictly Necessary Cookies

Strictly Necessary Cookies are essential for the Website to function properly. They enable core features such as security, network management, session management, accessibility, and fraud prevention. Without these cookies, the Website cannot operate correctly, and certain services you have requested cannot be provided.

Strictly Necessary Cookies are used to:

• Authenticate users and maintain secure login sessions;

• Enable navigation between pages and access to secure areas of the Website;

• Prevent fraudulent use of user accounts;

• Maintain Website security and protect against cyberattacks;

• Ensure the stability and proper loading of Website content;

• Comply with legal and regulatory security requirements.

Strictly Necessary Cookies do not store any personally identifiable information. They are session-based or expire shortly after your visit ends. These cookies are placed automatically and cannot be disabled through the cookie consent banner, as doing so would prevent the Website from functioning. You may block these cookies through your browser settings, but this will prevent you from accessing and using the Website.

9. Functional Cookies

Functional Cookies enable the Website to provide enhanced functionality and personalization. They may be set by us or by third-party providers whose services we have integrated into the Website.

Functional Cookies are used to:

• Remember your preferences and settings, such as language selection, region, and font size;

• Store information you have entered into forms so that you do not need to re-enter it;

• Enable live chat functionality and customer support features;

• Remember your login details if you choose the "Remember Me" option;

• Enable embedded content from third-party platforms;

• Store your cookie consent preferences.

Functional Cookies may be either session-based or persistent. If you do not allow these cookies, some features of the Website may not function properly, and your preferences will not be remembered between visits.

10. Preference Cookies

Preference Cookies allow the Website to remember choices you have made in the past and to customize the Website according to your preferences. These cookies improve your browsing experience by making the Website more relevant to you.

Preference Cookies are used to:

• Remember your display preferences, such as light mode or dark mode;

• Store your preferred communication channels and frequency;

• Remember your privacy and consent settings;

• Customize the layout and content presentation based on your preferences.

Preference Cookies are disabled by default and are placed only after you have provided your consent. You may change your preference settings at any time through the cookie consent banner or your browser settings.

11. Performance Cookies

Performance Cookies collect information about how visitors use the Website, including which pages are visited most frequently, how users navigate between pages, and whether they encounter error messages. This information is aggregated and anonymized.

Performance Cookies are used to:

• Monitor Website loading times and identify performance bottlenecks;

• Track page load errors and broken links;

• Analyze user navigation patterns to improve Website structure;

• Measure server response times and uptime;

• Test different versions of Website content to optimize user experience.

Performance Cookies help us identify and fix technical issues, improve Website speed and reliability, and ensure a smooth user experience. The data collected is used only for internal analysis and is not shared with third parties for marketing purposes.

12. Analytics Cookies

Analytics Cookies collect detailed information about how you use the Website, including the pages you visit, the links you click, the time you spend on each page, and the actions you take. This data helps us understand user behavior and improve the Website.

Analytics Cookies are used to:

• Track user journeys through the Website;

• Identify the most and least popular pages and content;

• Analyze traffic sources and referral patterns;

• Measure conversion rates for specific actions and goals;

• Generate demographic and interest reports (where available);

• Understand device and browser usage patterns.

We use third-party analytics providers, including Google Analytics, to process analytics data. These providers may combine the data collected on our Website with data from other websites to build a profile of your online activities. Where required by law, we obtain your consent before placing analytics cookies. You can opt out of analytics tracking through the cookie consent banner or by using the opt-out tools provided by the relevant analytics providers.

13. Statistical Cookies

Statistical Cookies collect aggregated data about Website usage for the purpose of generating statistical reports. Unlike analytics cookies, which track individual user journeys, statistical cookies focus on aggregate patterns and trends.

Statistical Cookies are used to:

• Count the total number of visitors to the Website;

• Calculate bounce rates, session durations, and page views per session;

• Track trends in Website traffic over time;

• Generate reports on user demographics, geography, and technology;

• Support business planning and resource allocation decisions.

The data collected through Statistical Cookies is aggregated and anonymized wherever possible. Individual users cannot be identified from statistical reports alone.

14. Advertising Cookies

Advertising Cookies are used to deliver advertisements that are relevant to your interests. They track your browsing habits across different websites and build a profile of your interests to show you targeted advertisements.

Advertising Cookies are used to:

• Deliver personalized advertisements based on your browsing history and interests;

• Measure the effectiveness of advertising campaigns;

• Limit the number of times you see the same advertisement;

• Track conversions from advertisements to Website actions;

• Build audience segments for targeted advertising;

• Enable retargeting and remarketing campaigns.

Advertising Cookies may be placed by us or by third-party advertising networks with our permission. These cookies may track your activity across multiple websites to build a profile of your interests. The data collected may be shared with advertisers, advertising networks, and data brokers.

We do not use Advertising Cookies to target children under the age of 18. You can opt out of personalized advertising by adjusting your cookie preferences or by visiting the opt-out pages of major advertising networks.

15. Marketing Cookies

Marketing Cookies support our marketing activities by tracking the effectiveness of our marketing campaigns and enabling us to deliver relevant marketing content to you.

Marketing Cookies are used to:

• Track email open rates, click-through rates, and engagement metrics;

• Identify which marketing channels drive the most traffic and conversions;

• Personalize marketing messages based on your interests and behavior;

• Attribute conversions to specific marketing campaigns;

• Build lookalike audiences for prospecting campaigns.

Marketing Cookies work in conjunction with Advertising Cookies and may share data with social media platforms, email marketing providers, and customer relationship management systems. Where required by Applicable Law, we obtain your explicit consent before placing marketing cookies.

16. Social Media Cookies

Social Media Cookies are set by social media platforms to enable content sharing, social login, and integration with social media features on the Website.

Social Media Cookies are used to:

• Enable you to share Website content on social media platforms;

• Allow you to log in to the Website using your social media credentials;

• Display embedded social media feeds and content;

• Track interactions with social media buttons and widgets;

• Enable social media platforms to track your browsing activity for advertising purposes.

When you interact with social media buttons, widgets, or embedded content on the Website, the relevant social media platform may set cookies on your device and collect information about your browsing activity, even if you do not have an account with that platform. The use of such cookies is governed by the social media platform's own cookie policy and privacy policy.

17. Third-Party Cookies

Third-Party Cookies are placed on your device by domains other than zenvisa.net. These cookies are set by third-party service providers that we engage to provide functionality, analytics, advertising, security, and other services on the Website.

Third-Party Cookies may be used by:

• Analytics providers (such as Google Analytics) to track Website usage;

• Advertising networks to deliver targeted advertisements;

• Social media platforms to enable sharing and embedded content;

• Security providers to detect and prevent malicious activity;

• Payment processors to facilitate secure transactions;

• Customer support providers to enable chat functionality.

We do not control the placement or use of Third-Party Cookies. Third-party service providers are responsible for their own cookie practices and are required to comply with Applicable Law. We encourage you to review the cookie policies of any third-party services that appear on our Website.

A list of the third-party cookies used on the Website, including their purposes, providers, and retention periods, is available through the cookie consent banner and in the cookie settings panel.

18. Google Analytics

We use Google Analytics, a web analytics service provided by Google LLC ("Google"), to analyze Website traffic and user behavior. Google Analytics uses cookies to collect information about your use of the Website, including your IP address, which may be transmitted to and stored by Google on servers in the United States.

Google Analytics collects the following types of data:

• Pages visited, time spent on each page, and navigation paths;

• Referral sources, including search engines, social media, and direct traffic;

• Device type, operating system, browser type, and screen resolution;

• Geographic location (country and city level);

• User demographics and interests (where enabled and available).

We have implemented the following privacy-enhancing measures in Google Analytics:

• IP anonymization is enabled, which truncates IP addresses within the EEA before transmission to Google;

• Data sharing with Google for advertising purposes is disabled;

• User and event data retention is set to the minimum period required for analysis;

• Google Signals is not enabled.

Google uses the collected information to evaluate Website usage, compile reports on Website activity, and provide other services relating to Website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf.

You can prevent Google Analytics from collecting your data by: (a) adjusting your cookie preferences in our cookie consent banner; (b) installing the Google Analytics Opt-out Browser Add-on at https://tools.google.com/dlpage/gaoptout; or (c) opting out of personalized advertising at https://adssettings.google.com.

19. Google Tag Manager

We use Google Tag Manager ("GTM"), a tag management system provided by Google LLC, to manage and deploy cookies and tracking scripts on the Website. GTM allows us to add, update, and remove tracking technologies without modifying the Website's source code.

GTM itself does not collect personal data. It functions as a container that loads other tags, including Google Analytics, Meta Pixel, LinkedIn Insight Tag, and conversion tracking tags. The data collected by these tags is subject to their respective privacy policies and this Cookie Policy.

When you visit the Website, GTM may load the following types of tags based on your cookie consent preferences:

• Analytics tags (loaded when you consent to analytics cookies);

• Marketing and advertising tags (loaded when you consent to marketing cookies);

• Functional tags (loaded when you consent to functional cookies);

• Essential security and performance tags (loaded automatically as strictly necessary).

GTM operates under Google's privacy policy, available at https://policies.google.com/privacy.

20. Meta Pixel (Facebook Pixel)

We use the Meta Pixel (formerly Facebook Pixel), a tracking technology provided by Meta Platforms, Inc. ("Meta"), to measure the effectiveness of our advertising campaigns on Facebook, Instagram, and other Meta platforms, and to build audiences for remarketing purposes.

The Meta Pixel is a small piece of JavaScript code that collects the following data:

• Facebook user ID (if you are logged into Facebook);

• Pages visited on the Website and actions taken;

• Device information, browser information, and IP address;

• Referrer URL and timestamp of visit;

• Conversion events, such as form submissions and quote requests.

The Meta Pixel enables us to:

• Track conversions from Meta advertisements;

• Optimize ad delivery to audiences most likely to take action;

• Build custom audiences for remarketing campaigns;

• Create lookalike audiences based on our existing customers;

• Measure cross-device conversions.

The Meta Pixel is loaded only when you provide consent for marketing cookies. Meta processes the data collected through the Meta Pixel in accordance with its Data Policy, available at https://www.facebook.com/privacy/policy. You can opt out of Meta's use of cookies for advertising purposes through your Facebook ad settings at https://www.facebook.com/adpreferences.

21. LinkedIn Insight Tag

We use the LinkedIn Insight Tag, a tracking technology provided by LinkedIn Corporation ("LinkedIn"), to measure the effectiveness of our advertising campaigns on LinkedIn and to enable website demographics and remarketing features.

The LinkedIn Insight Tag collects the following data:

• LinkedIn member ID (if you are logged into LinkedIn);

• IP address, timestamp, and page events;

• Device and browser information;

• Conversion data related to LinkedIn advertisements.

The LinkedIn Insight Tag enables us to:

• Track conversions from LinkedIn advertisements;

• Generate website demographics reports showing aggregated professional characteristics of our visitors;

• Build remarketing audiences for LinkedIn advertising campaigns.

The LinkedIn Insight Tag is loaded only when you provide consent for marketing cookies. LinkedIn processes the data collected through the Insight Tag in accordance with its Privacy Policy, available at https://www.linkedin.com/legal/privacy-policy. You can opt out of LinkedIn's use of cookies for advertising through your LinkedIn settings at https://www.linkedin.com/psettings/advertising.

22. YouTube Embedded Content

The Website may contain embedded videos from YouTube, a video sharing platform operated by Google LLC. When you visit a page containing an embedded YouTube video, YouTube may place cookies on your device and collect information about your viewing activity.

YouTube cookies may:

• Track video views, play duration, and interaction events;

• Store your video preferences, such as volume level and playback quality;

• Collect demographic and interest data for advertising purposes;

• Enable personalized video recommendations.

Where technically feasible, we use YouTube's privacy-enhanced mode ("nocookie" mode) for embedded videos. In this mode, YouTube does not place cookies on your device until you click the play button. However, YouTube may still collect certain technical information when the video player is loaded.

YouTube's use of cookies is governed by Google's privacy policy, available at https://policies.google.com/privacy. You can manage your YouTube privacy settings at https://myaccount.google.com/data-and-personalization.

23. Cloudflare and Security Cookies

We use Cloudflare, Inc. ("Cloudflare") as a content delivery network (CDN), security, and performance optimization provider. Cloudflare places cookies and uses other technologies to ensure the security, reliability, and performance of the Website.

Cloudflare cookies and technologies are used to:

• Identify and mitigate distributed denial-of-service (DDoS) attacks;

• Detect and block malicious traffic, bots, and automated threats;

• Route traffic efficiently to the nearest data center;

• Cache Website content to improve loading speed;

• Maintain security rules and rate limiting;

• Verify browser integrity through JavaScript challenges.

Cloudflare's security cookies are classified as Strictly Necessary Cookies and are placed automatically. They do not track users across websites and do not collect personally identifiable information. Cloudflare processes data in accordance with its Privacy Policy, available at https://www.cloudflare.com/privacypolicy.

24. Fraud Prevention Cookies

We use cookies and similar technologies specifically designed to detect, prevent, and mitigate fraudulent activity on the Website. These cookies are essential for maintaining the security and integrity of our Services.

Fraud Prevention Cookies are used to:

• Identify suspicious login attempts and unauthorized access;

• Detect unusual patterns of behavior indicative of fraud;

• Track device fingerprints to identify compromised accounts;

• Validate transaction authenticity and detect payment fraud;

• Maintain blacklists of known fraudulent devices and IP addresses;

• Support our AML/KYC compliance obligations.

Fraud Prevention Cookies are classified as Strictly Necessary Cookies. They are placed automatically and cannot be disabled through the cookie consent banner. Blocking these cookies through browser settings may prevent you from accessing the Website.

25. Session Cookies

Session Cookies are temporary cookies that are stored in your browser's memory and are automatically deleted when you close your browser. They do not have an expiration date and are not written to your device's storage.

Session Cookies are used to:

• Maintain your session state as you navigate between pages;

• Store temporary data required for form submissions;

• Authenticate your identity during your current visit;

• Store items in your session-based shopping cart or service selection;

• Prevent cross-site request forgery (CSRF) attacks.

Session Cookies are essential for the proper functioning of the Website and are classified as Strictly Necessary Cookies. They expire automatically when your browsing session ends.

26. Persistent Cookies

Persistent Cookies are cookies that remain on your device for a specified period after your browsing session ends. They have an expiration date set by the website and are stored on your device's hard drive or storage until that date is reached or until you manually delete them.

Persistent Cookies are used to:

• Remember your preferences and settings between visits;

• Store your cookie consent choices for future visits;

• Authenticate returning users who have selected "Remember Me";

• Track repeat visits for analytics and performance measurement;

• Enable remarketing and personalized advertising.

Persistent Cookies are placed only with your consent (except for Strictly Necessary Cookies, which are placed automatically). You can delete Persistent Cookies at any time through your browser settings. The specific retention periods for each Persistent Cookie are listed in the cookie settings panel.

27. Cookie Lifespans

The lifespan of each cookie depends on its category and purpose. The following table summarizes the typical lifespans for each category of cookies used on the Website:

The specific expiration date for each cookie is set by the provider of that cookie. You can view the exact expiration dates for all cookies currently stored on your device through your browser's cookie management interface or through the cookie settings panel on the Website.

We regularly review cookie lifespans to ensure they are no longer than necessary for the stated purpose. Where a cookie's lifespan exceeds the period required for its purpose, we will reduce the lifespan or replace the cookie with a more appropriate alternative.

28. Consent Management Platform (Cookie Banner)

When you first visit the Website, you will be presented with a cookie consent banner that allows you to manage your cookie preferences. The cookie banner provides:

• A clear explanation of the cookies we use and their purposes;

• The ability to accept or reject each category of non-essential cookies individually;

• A link to this Cookie Policy for further information;

• A link to our Privacy Policy;

• A record of your consent choices for future reference.

The consent management platform operates as follows:

• Strictly Necessary Cookies are loaded automatically and cannot be disabled;

• All other categories of cookies are blocked until you provide your consent;

• You can provide consent for all categories by clicking "Accept All";

• You can reject all non-essential cookies by clicking "Reject All";

• You can customize your preferences by clicking "Manage Preferences" and selecting individual categories;

• Your consent choices are stored in a functional cookie and remembered for future visits.

Your consent is recorded with a timestamp and is valid for twelve (12) months from the date of consent. After this period, you will be prompted to renew your consent choices. You may change your preferences at any time by clicking the "Cookie Settings" link in the footer of the Website.

Where you do not provide consent for non-essential cookies, these cookies will not be placed on your device, and the corresponding features and functionality will not be available. This will not affect your ability to access the core functionality of the Website.

29. Lawful Basis for Cookie Processing

We process personal data collected through cookies only where we have a valid legal basis under Applicable Law. The lawful bases for cookie processing are:

29.1 Legal Obligation and Legitimate Interests (Strictly Necessary Cookies)

Strictly Necessary Cookies are processed on the basis of our legitimate interests in ensuring the security, stability, and proper functioning of the Website, and where applicable, on the basis of compliance with a legal obligation (such as security and data protection requirements). These cookies do not require your consent.

29.2 Consent (All Other Cookie Categories)

Functional, Preference, Performance, Analytics, Statistical, Advertising, Marketing, and Social Media Cookies are processed on the basis of your explicit consent. You provide this consent through the cookie consent banner when you first visit the Website. You have the right to withdraw your consent at any time by adjusting your cookie preferences or contacting us at legal@zenvisa.net.

29.3 Legitimate Interests (Where Consent Is Not Required)

In certain jurisdictions where consent is not required for specific categories of cookies, we may rely on our legitimate interests in improving our Services, understanding user behavior, and delivering relevant content. Where we rely on legitimate interests, we have conducted a balancing test to ensure that our interests do not override your fundamental rights and freedoms.

29.4 Contractual Necessity

Where cookies are strictly necessary to provide a service you have explicitly requested, such as processing a service request or completing a transaction, the processing is based on contractual necessity.

30. Withdrawing Cookie Consent

You have the right to withdraw your consent to the use of non-essential cookies at any time. Withdrawing consent does not affect the lawfulness of processing based on consent before its withdrawal.

You can withdraw your cookie consent by:

• Clicking the "Cookie Settings" link in the footer of the Website and adjusting your preferences;

• Contacting us at legal@zenvisa.net with the subject line "Cookie Consent Withdrawal";

• Deleting cookies through your browser settings (see Clause 31).

Upon withdrawal of consent:

• All non-essential cookies will be deleted from your device;

• No further non-essential cookies will be placed;

• The Website will continue to function, but certain features and personalization may not be available;

• Your withdrawal will be recorded and honored on subsequent visits.

Please note that withdrawing consent for analytics cookies will not delete historical analytics data that has already been collected and aggregated. Withdrawing consent for marketing cookies will not unsubscribe you from email marketing lists; you must unsubscribe separately using the unsubscribe link in marketing emails.

31. Browser Cookie Controls

Most web browsers allow you to control cookies through their settings. You can typically configure your browser to:

• Accept all cookies;

• Reject all cookies;

• Notify you when a cookie is being placed;

• Delete existing cookies;

• Block third-party cookies while accepting first-party cookies.

Instructions for managing cookies in common browsers are available at:

• Google Chrome: https://support.google.com/chrome/answer/95647

• Mozilla Firefox: https://support.mozilla.org/kb/cookies-information-websites-store-on-your-computer

• Apple Safari: https://support.apple.com/guide/safari/manage-cookies-and-website-data-sfri11471

• Microsoft Edge: https://support.microsoft.com/help/4027947

• Opera: https://help.opera.com/en/latest/web-preferences/#cookies

Please note that disabling or deleting cookies may affect the functionality of the Website and your ability to access certain features. If you configure your browser to reject all cookies, you may not be able to use the full functionality of the Website.

32. Do Not Track (DNT)

Some browsers include a "Do Not Track" (DNT) feature that signals to websites you visit that you do not want your browsing activity tracked. There is currently no universally accepted standard for how websites should respond to DNT signals.

At this time, our Website does not respond to DNT signals from browsers. However, we respect your privacy choices through our cookie consent banner, which allows you to opt out of analytics, advertising, and marketing cookies regardless of your DNT settings.

We monitor developments in DNT standards and will update our practices as industry standards emerge. In the meantime, we recommend using the cookie consent banner or your browser's cookie settings to manage tracking preferences.

33. Cross-Border Data Transfers

Cookie data, including personal data collected through cookies, may be transferred to, stored in, or accessed from countries outside the United Arab Emirates. This occurs because many of our third-party service providers operate globally and process data in multiple jurisdictions.

The following third-party cookie providers may process data outside the UAE:

• Google LLC (Google Analytics, Google Tag Manager, YouTube) - United States;

• Meta Platforms, Inc. (Meta Pixel) - United States;

• LinkedIn Corporation (LinkedIn Insight Tag) - United States;

• Cloudflare, Inc. - United States;

• Other third-party service providers as listed in the cookie settings panel.

Where cookie-related data is transferred outside the UAE, we implement appropriate safeguards, including:

• Standard Contractual Clauses (SCCs) approved by the UAE data protection authority;

• Adequacy decisions or equivalent protections recognized under the PDPL;

• Supplementary technical measures, such as encryption and pseudonymization;

• For transfers from the EEA and UK, Standard Contractual Clauses with supplementary measures under the GDPR and UK GDPR.

By providing your consent for non-essential cookies, you consent to the transfer of cookie-related data outside the UAE as described in this Clause, to the extent required by Applicable Law.

34. Third-Party Service Providers

We engage the following categories of third-party service providers that place cookies or use similar tracking technologies on the Website:

Each third-party service provider is contractually bound to process cookie data in accordance with Applicable Law and this Cookie Policy. We conduct due diligence on all third-party providers before engaging their services and review their privacy and security practices regularly.

A complete and up-to-date list of all third-party cookies used on the Website, including their specific names, providers, purposes, and lifespans, is available through the cookie settings panel on the Website.

35. AI and Automated Technologies

We may use artificial intelligence ("AI") and machine learning technologies in connection with the data collected through cookies and similar tracking technologies. These technologies may be used for:

• Analyzing user behavior patterns to improve Website design and user experience;

• Detecting anomalies in traffic patterns that may indicate security threats;

• Optimizing content delivery and personalization based on predicted user preferences;

• Automating the classification and categorization of cookie data;

• Enhancing fraud detection and prevention capabilities.

AI processing of cookie data is conducted in compliance with the PDPL, GDPR, UK GDPR, and applicable UAE AI governance guidelines issued by TDRA and NESA. We implement appropriate safeguards to ensure that AI-driven processing is fair, transparent, and free from unlawful bias.

AI-assisted processing does not involve automated decision-making that produces legal effects concerning you or significantly affects you, unless you have provided explicit consent or such processing is required by Applicable Law. You have the right to request human review of any AI-driven decision that affects your rights.

36. Security Measures

We implement appropriate technical and organizational security measures to protect cookie data and the information collected through cookies against unauthorized access, alteration, disclosure, or destruction. These measures include:

• Encryption of cookie data in transit using Transport Layer Security (TLS) 1.2 or higher;

• Secure storage of cookie-related data on servers protected by firewalls and intrusion detection systems;

• Access controls restricting access to cookie data to authorized personnel only;

• Regular security assessments and vulnerability testing;

• Monitoring of cookie placement and usage for unauthorized or malicious activity;

• Contractual security requirements for all third-party cookie providers.

While we take reasonable steps to secure cookie data, no method of transmission over the internet or electronic storage is completely secure. We cannot guarantee the absolute security of cookie data and disclaim liability for unauthorized access beyond our reasonable control, except as prohibited by Applicable Law.

37. Children's Privacy

Our Website is not intended for children under the age of eighteen (18) years, and we do not knowingly place cookies on the devices of children under 18. We do not use advertising or marketing cookies to target children.

If we become aware that we have inadvertently collected cookie data from a child under 18, we will take immediate steps to delete that data and disable the relevant cookies.

Parents and guardians who believe that their child has interacted with our Website and that cookies have been placed on the child's device should contact us at legal@zenvisa.net so that we can take appropriate action.

38. International Users

The Website is operated from the United Arab Emirates. If you access the Website from outside the UAE, you acknowledge that your cookie data may be transferred to, stored in, and processed in the UAE and other countries as described in Clause 33.

Users accessing the Website from the European Economic Area, the United Kingdom, or other jurisdictions with specific cookie consent requirements are entitled to the rights set out in Clause 41. Where the GDPR or ePrivacy Directive applies, we obtain your prior consent before placing non-essential cookies.

Users from jurisdictions that require explicit opt-in consent for all cookies (including strictly necessary cookies in some cases) should contact us to discuss their requirements.

39. Changes to Cookie Technologies

We may update the cookies and tracking technologies used on the Website from time to time to reflect changes in technology, our business operations, or legal requirements. Such changes may include:

• Adding new cookies to support new Website features or services;

• Replacing existing cookies with more efficient or privacy-enhancing alternatives;

• Removing cookies that are no longer necessary;

• Adding or changing third-party service providers;

• Adjusting cookie lifespans or categories.

When we add new non-essential cookies or make material changes to existing cookies, we will update the cookie settings panel and, where required by Applicable Law, prompt you to review and update your consent preferences. We will not place new non-essential cookies without obtaining your consent where such consent is required.

40. Changes to this Cookie Policy

We reserve the right to modify, amend, or update this Cookie Policy at any time to reflect changes in our cookie practices, legal requirements, or business operations. Material changes will be notified to you by posting a prominent notice on the Website or by sending an email to the address associated with your account, at least fifteen (15) days before such changes take effect.

Your continued use of the Website following the posting of any changes constitutes your acceptance of the updated Cookie Policy. If you do not agree with the modified Cookie Policy, you must adjust your cookie preferences or discontinue use of the Website.

We encourage you to review this Cookie Policy periodically. The "Last Updated" date at the top of this document indicates when it was most recently revised.

41. User Rights

Under the PDPL, GDPR, UK GDPR, and other Applicable Law, you have the following rights in relation to your personal data collected through cookies:

• The right to access the personal data we hold about you, including cookie-related data;

• The right to rectification of inaccurate or incomplete personal data;

• The right to erasure of your personal data in certain circumstances;

• The right to restrict processing of your personal data;

• The right to object to processing based on legitimate interests or for direct marketing;

• The right to data portability, where processing is based on consent or contract;

• The right to withdraw consent for non-essential cookies at any time;

• The right to lodge a complaint with the relevant data protection authority.

To exercise any of these rights, please contact us using the details provided in Clause 43. We will respond to your request within thirty (30) days of receipt, or within such shorter period as may be required by Applicable Law. We may request additional information to verify your identity before processing your request.

42. Complaint Procedure

If you have a complaint about our use of cookies or our processing of your personal data through cookies, you may submit a complaint using the following procedure:

• Step 1: Contact us at legal@zenvisa.net with the subject line "Cookie Complaint," providing details of your complaint, including the nature of the issue and your preferred resolution.

• Step 2: We will acknowledge receipt of your complaint within three (3) Business Days.

• Step 3: We will investigate your complaint and provide a substantive response within fifteen (15) Business Days of acknowledgment.

• Step 4: We will provide a written final response setting out our findings and any remedial action taken.

If you are not satisfied with our response, you have the right to lodge a complaint with: (a) the UAE data protection authority; (b) the supervisory authority in your country of residence (for EEA and UK residents); or (c) the Ras Al Khaimah Economic Zone Authority (RAKEZ).

43. Contact Information

If you have any questions, concerns, or requests regarding this Cookie Policy or our use of cookies and similar technologies, please contact us:

We will use commercially reasonable efforts to respond to all inquiries within five (5) Business Days of receipt.

44. Governing Law

This Cookie Policy and any dispute, claim, or controversy arising out of or in connection with it shall be governed by and construed in accordance with the laws of the United Arab Emirates, as applied in the Emirate of Ras Al Khaimah, without regard to its conflict of law principles.

Where the GDPR, UK GDPR, or ePrivacy Directive applies to our processing of your personal data through cookies, those regulations shall also govern our obligations to the extent required by Applicable Law.

45. Jurisdiction

The courts of the United Arab Emirates, and specifically the courts of the Emirate of Ras Al Khaimah, shall have exclusive jurisdiction over any dispute arising out of or in connection with this Cookie Policy, subject to the arbitration provisions set out in our Terms of Use.

Nothing in this Cookie Policy shall prevent data subjects in the EEA or UK from lodging complaints with their local supervisory authority or seeking remedies available under the GDPR or UK GDPR.

46. Severability

If any provision of this Cookie Policy is held to be invalid, illegal, or unenforceable by a court of competent jurisdiction or arbitral tribunal, such provision shall be modified to the minimum extent necessary to make it valid and enforceable, or if modification is not possible, such provision shall be severed from this Cookie Policy.

The invalidity, illegality, or unenforceability of any provision shall not affect the validity, legality, or enforceability of the remaining provisions, which shall continue in full force and effect.

47. Entire Policy

This Cookie Policy, together with our Privacy Policy, Terms of Use, and any other data protection notices we may provide, constitutes the entire agreement between you and the Company with respect to the use of cookies and similar tracking technologies on the Website.

This Cookie Policy is incorporated into and forms part of our Privacy Policy and Terms of Use. In the event of any conflict between this Cookie Policy and the Privacy Policy or Terms of Use, the Privacy Policy shall govern with respect to data protection matters, and the Terms of Use shall govern with respect to liability limitations, indemnification, and dispute resolution.

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