Privacy Policy

This Privacy Policy explains how Pioneer Education Limited (“Pioneer Education”, “we”, “us”, or “our”) collects, uses, and protects personal data when you visit our website at pioneereducationlimited.com (the “Site”).

Pioneer Education Limited is a company registered in the Abu Dhabi Global Market (ADGM) and is the data controller responsible for your personal data. We process personal data in accordance with the ADGM Data Protection Regulations 2021 (the “Regulations”).

This policy also explains the rights you have over your personal data and how to contact us about them.

1. Scope of this policy

This policy applies only to this informational website. Our education applications and platforms, when launched, will each be governed by their own separate privacy policies.

The Site is informational. It does not use cookies, it does not sell products or take payments, and the only way to contact us through the Site is by email or our contact form.

2. Personal data we collect

Information you give us. When you contact us by email or through our contact form, we collect your name, email address, and the content of your message.

Information collected automatically. Our hosting provider (Vercel) automatically records standard technical information when you visit the Site — such as your IP address, browser type, the pages you view, access times, and the referring website — as part of the standard request logs it generates to operate and secure the Site.

We do not use cookies, website analytics, or other tracking technologies on the Site.

3. How we use your personal data and our lawful bases

We use your personal data for the purposes set out below. Each purpose is supported by a lawful basis under the Regulations:

• Respond to your enquiries and communicate with you about what you asked
  • Data used: The contact details and message content you provide
  • Lawful basis: Your request / consent, and our legitimate interest in responding to enquiries
• Operate, maintain, secure, and improve the Site
  • Data used: Technical and log data collected automatically
  • Lawful basis: Legitimate interests — running a secure, functioning website
• Detect and prevent fraud, misuse, or security incidents
  • Data used: Technical and log data collected automatically
  • Lawful basis: Legitimate interests — protecting the Site and its users
• Meet our legal and regulatory obligations
  • Data used: Any data relevant to the obligation
  • Lawful basis: Legal obligation

Where we rely on your consent, you can withdraw it at any time (see “Your rights” below).

4. Sharing and disclosure

We do not sell, rent, or trade your personal data.

We share personal data only with:

• Service providers (processors) who help us operate the Site — namely our hosting provider (Vercel) and our email provider (Proton Mail). They may process personal data only on our instructions and must keep it confidential and secure.
• Authorities or other parties where required by law — we may disclose personal data to comply with a legal obligation or legal process, to protect or defend our rights or property, or to protect the safety of users or the public.

5. International transfers

Our hosting provider (Vercel) and our email provider (Proton Mail) may process personal data on servers located outside the ADGM.

Proton Mail processes data in Switzerland, which the ADGM recognises as providing an adequate level of protection, so that transfer does not require additional safeguards.

Vercel processes data in the United States. Vercel is certified under the EU-US Data Privacy Framework and provides Standard Contractual Clauses in its data processing agreement, which serve as the safeguards for that transfer as required by the Regulations.

6. Retention

We keep personal data for as long as we need it for the purposes described in this policy.

We do not delete enquiry correspondence on a fixed schedule; we keep it until we decide it is no longer needed and then delete it manually. Automatically-collected log data is retained for as long as our hosting provider (Vercel) stores it, in line with Vercel’s own retention periods.

7. Security

We maintain reasonable administrative, technical, and physical safeguards designed to protect personal data from unauthorised access, use, disclosure, alteration, or loss. The Site is served over an encrypted connection (HTTPS/TLS). No method of transmission or storage over the internet is completely secure, and we cannot guarantee absolute security.

8. Personal data breaches

If a personal data breach occurs that is likely to result in a risk to your rights, we will notify the ADGM Office of Data Protection (the Commissioner of Data Protection) within 72 hours where required, and we will inform affected individuals where the Regulations require us to do so.

9. Your rights

Under the Regulations, you have the right to:

• access the personal data we hold about you;
• have inaccurate data corrected;
• have your data erased in certain circumstances;
• restrict or object to our processing;
• data portability; and
• where processing is based on your consent, withdraw that consent at any time (this does not affect processing carried out before withdrawal).

To exercise any of these rights, email us at support@pioneereducationlimited.com. We will respond within the time required by the Regulations.

10. Complaints

If you have concerns about how we handle your personal data, please contact us first so we can try to resolve them. You also have the right to lodge a complaint with the ADGM Office of Data Protection (the Commissioner of Data Protection).

11. Children

The Site is not directed to children under 18, and we do not knowingly collect personal data from anyone under 18. Under the Regulations, a “child” is anyone under the age of 18. If you believe a child has provided us with personal data, please contact us and we will delete it.

12. Links to other websites

The Site may contain links to third-party websites. We are not responsible for the content or privacy practices of those sites, and we encourage you to read their privacy policies before providing any personal data.

13. Changes to this policy

We may update this policy from time to time — for example, to reflect changes in our services, our data practices, or the law. The effective date below always shows the current version, and we will take reasonable steps to inform you of significant changes.

14. Contact us