Privacy Policy

1. Who controls personal data

Cleora is the operating name of CLEORA WEB DEVELOPMENT SERVICES, a sole proprietorship registered in the Philippines. Cleora is responsible for personal data collected through this website and through direct business communications with clinics and prospective clinics.

2. What data we collect

Cleora collects business contact and service information that clinics provide directly:

• name, role, and clinic name
• email, phone, and WhatsApp number
• website URL and project details
• billing and customer details handled by the payment provider
• communications and support messages
• limited analytics and device data where analytics is enabled

3. What we do not collect

Cleora does not intentionally collect patient health information, medical records, diagnosis details, treatment histories, insurance documents, Emirates ID numbers, or patient appointment records through this website.

If a clinic accidentally sends sensitive patient data to Cleora, Cleora may delete it, ask the clinic to remove or redact it, or process it only as necessary to return or secure it.

4. How we use data

Cleora uses the information provided to:

• respond to enquiries and proposals
• provide services and deliverables
• manage subscriptions and renewals
• process payments through the active payment provider
• send service communications
• maintain website performance and security
• improve the site and the services
• comply with legal, accounting, and tax obligations

5. Legal bases for processing

Where applicable law requires a legal basis, Cleora relies on contract performance, legitimate interests (such as running and improving the services), legal obligation, and consent where consent is the appropriate basis. Clients may withdraw any consent given to Cleora at any time without affecting the lawfulness of processing already carried out.

6. Payment processing

Payments may be processed by PayPal or another approved payment provider. The payment provider handles checkout, billing, tax calculation where applicable, fraud screening, and receipts under its own privacy policy.

Cleora does not store full card numbers or CVV codes. Cleora may keep limited records of the transaction (such as plan, amount, date, and last four digits of the card) provided by the payment provider.

7. Healthcare and patient data

Clients are responsible for ensuring that any patient-related materials supplied to Cleora, including doctor credentials, treatment images, testimonials, and any before-and-after content, are legally collected, properly consented, and suitable for publication under applicable healthcare advertising rules.

Cleora's standard website architecture is static and database-free and is not designed to store patient records, treatment data, or other sensitive health information.

8. WhatsApp and third-party messaging

Where WhatsApp workflows are configured, they are operated through the clinic's own WhatsApp Business account, Meta Business account, or approved messaging provider. Cleora may help configure templates, routing, and website links, but does not own the clinic's WhatsApp number, patient conversations, or messaging account. Third-party platform and messaging fees are billed separately to the clinic unless otherwise agreed in writing.

9. Analytics and cookies

cleora.ae uses privacy-preserving analytics where enabled. If analytics or marketing tools that rely on cookies are introduced, Cleora will update this policy and provide appropriate notice or consent controls where required by law.

The site does not use third-party advertising trackers, Facebook Pixel, or marketing cookies, and does not sell personal data to third parties.

10. Third-party providers

Cleora uses reputable third-party providers to deliver and operate the services. By category these include:

• hosting and CDN: Cloudflare
• analytics and search: Google Analytics and Google Search Console where enabled
• scheduling: Calendly
• payments: PayPal or another approved payment provider
• email: the active email service provider
• messaging: the clinic's own WhatsApp Business or approved messaging provider
• domain and DNS: the relevant registrar and Cloudflare

Each third-party provider processes personal data under its own privacy policy and terms.

11. International transfers

Because Cleora serves clients internationally and uses global cloud providers, personal data may be processed outside the United Arab Emirates. Cleora uses reputable providers and takes reasonable steps to protect data during cross-border processing.

12. Retention

• Enquiries that do not become clients: typically retained for up to 24 months.
• Client and project records: retained for the duration of the relationship plus up to five (5) years for legal, accounting, and business record purposes.
• Payment records: retained by the payment provider and by Cleora as required by law.
• Analytics records: retained according to the analytics tool's own settings.

13. Security

• HTTPS in transit
• access controls on internal systems
• reputable hosting, analytics, and payment providers
• no storage of full card numbers or CVV
• static, database-free client website architecture where applicable

No system can be guaranteed completely secure. Cleora takes reasonable steps to protect personal data but cannot promise perfect security.

14. Your rights

Subject to applicable law, clients and visitors may request to:

• access the personal data Cleora holds about them
• correct inaccurate or incomplete data
• delete personal data, subject to legal retention obligations
• restrict or object to certain processing where applicable
• withdraw consent where consent is the basis for processing
• receive a copy of their data in a portable format where applicable
• complain to a relevant data protection authority where applicable

To exercise any of these rights, contact contact@cleora.ae.

15. Children

cleora.ae is a business-to-business service for clinic operators. It is not directed at children and Cleora does not knowingly collect personal data from children.

16. Changes to this policy

Cleora may update this Privacy Policy from time to time. Material changes will be posted on this page with an updated effective date and, where appropriate, communicated to active clients by email.

17. Contact

For privacy questions or to exercise any of the rights above, contact contact@cleora.ae.