Privacy Policy

1. Introduction & Who We Are

This Privacy Policy explains how Menataur FZ-LLC (“Menataur,” “we,” “us,” or “our”), the operator of the “Business Strategy as Code” consultancy and advisory programme and the website strategyascode.org (together, the “Service”), collects, uses, discloses, and protects personal data belonging to visitors, prospective participants, and participants (“you”).

Menataur FZ-LLC is the data controller responsible for the personal data described in this Policy. We are a Free Zone company registered with the Ras Al Khaimah Economic Zone (RAKEZ), with our registered address at RAKEZ Compass Coworking Centre, Al Shohada Road, Al Hamra Industrial Zone-FZ, Ras Al Khaimah, United Arab Emirates. You can reach us at any time using the contact details in Section 13 below.

Our participants and website visitors are located around the world, including the European Union, European Economic Area, and United Kingdom (where the General Data Protection Regulation, “GDPR,” applies) and the United Arab Emirates (where Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data, the “UAE PDPL,” applies). This Policy is designed to meet the requirements of both frameworks, and of other applicable data protection laws.

2. Information We Collect

We collect the following categories of personal data:

• Information you submit through our “Request a Call” form: your name, phone number, email address, and any optional message you include. This information is transmitted to us via WhatsApp, a messaging service operated by Meta Platforms, Inc. (“Meta”), so that we can respond to your enquiry.
• Registration and payment information: when checkout is enabled and you join the programme, we collect the information necessary to process your registration (such as your name and email address) and, where card payment is used, payment is processed directly by our payment processor, Stripe. We do not store your full card details on our own systems — Stripe handles this in accordance with its own security standards and privacy policy.
• Scheduling information: where used, session or call scheduling is handled through Calendly, which may collect your name, email address, and time-zone information to arrange bookings.
• Technical and usage data: when you browse our website, our hosting provider (Netlify) and, if and when enabled, an analytics tool loaded via Partytown may automatically collect information such as IP address, browser type, device type, pages visited, and general usage patterns. Currently, we do not run any third-party advertising cookies or analytics scripts on the site; if and when we enable analytics or similar tracking, we will do so only in a privacy-respecting manner and, where legally required, only after obtaining your consent.
• Correspondence: if you email us, message us, or otherwise communicate with us directly, we keep a record of that correspondence, including your contact details and the content of the communication.

3. How We Use Your Information

We use the personal data described above for the following purposes:

• To respond to enquiries submitted through the “Request a Call” form and to follow up with prospective participants.
• To process your registration, manage payments and installment plans, and administer your participation in a cohort.
• To schedule calls or sessions, and to send confirmations, reminders, and related communications.
• To deliver the programme itself, including session materials, recordings (where applicable), and access to the CODE-REGISTRY and other programme resources.
• To communicate with you about your registration, respond to support requests, and provide customer service.
• To maintain, secure, and improve our website and the Service, including diagnosing technical issues.
• To understand, in aggregate, how visitors use our website, if and when analytics are enabled.
• To comply with our legal, tax, and accounting obligations.
• To detect, prevent, and address fraud, unauthorized access, or other misuse of the Service.

4. Legal Bases for Processing (GDPR)

Where the GDPR applies to our processing of your personal data, we rely on the following legal bases:

• Performance of a contract: to process your registration, take payment, and deliver the programme you have purchased or are in the process of purchasing.
• Consent: where we ask for your explicit agreement, for example before enabling optional analytics or marketing communications; you may withdraw consent at any time.
• Legitimate interests: to respond to enquiries, operate and secure our website, improve the Service, and communicate with prospective and existing participants, provided these interests are not overridden by your own rights and freedoms.
• Legal obligation: where we must retain or disclose information to comply with tax, accounting, or other applicable law.

5. Cookies & Tracking Technologies

Our website currently uses only essential, strictly necessary technical mechanisms required for the site to function correctly; we do not currently run third-party advertising cookies or analytics scripts.

If and when we enable product or usage analytics — for example via Partytown, which is designed to run third-party scripts off the browser’s main thread in a privacy-respecting way — we will do so only in compliance with applicable law, and, where legally required (such as under the GDPR’s ePrivacy rules), only after obtaining your prior consent through an on-site consent mechanism. You will always be able to decline non-essential cookies and tracking, and you can control or delete cookies at any time through your browser settings.

6. Third Parties We Share Data With

We do not sell your personal data. We share personal data only with service providers (“processors”) who process it on our behalf and under our instructions, strictly to operate the Service:

• Meta (WhatsApp): receives and transmits the information you submit through our “Request a Call” form so that we can contact you.
• Stripe: processes payment and billing information when checkout is enabled; Stripe acts as an independent controller for certain payment-related data under its own privacy policy.
• Calendly: processes scheduling information when used to book calls or sessions.
• Netlify: hosts our website and processes technical data necessary to serve web pages to you.
• Analytics providers: if and when enabled, an analytics provider loaded via Partytown may process usage data as described in Section 5.

We may also disclose personal data where required to comply with applicable law, regulation, legal process, or governmental request, or to protect the rights, property, or safety of Menataur, our participants, or others.

7. International Data Transfers

Menataur FZ-LLC is based in the United Arab Emirates, and the service providers listed in Section 6 may process personal data in the UAE, the United States, the European Union, and other countries in which they or their sub-processors operate. This means your personal data may be transferred to, stored, and processed in countries outside your own, including outside the European Economic Area and the United Kingdom.

Where we transfer personal data originating in the EEA or UK to a country that has not been recognized as providing an adequate level of data protection, we rely on appropriate safeguards, such as Standard Contractual Clauses or equivalent mechanisms offered by our service providers, to ensure your data continues to be protected in accordance with this Policy and applicable law.

8. Data Retention

We retain personal data only for as long as necessary to fulfil the purposes described in this Policy, including to deliver the programme you joined, respond to your enquiries, satisfy our legal, tax, and accounting obligations, and resolve any disputes. Enquiry and lead information from the “Request a Call” form that does not lead to registration is retained for a reasonable period to allow follow-up and is then deleted or anonymized. Registration and payment records are retained for as long as required by applicable tax and accounting law. When personal data is no longer needed, we delete or anonymize it.

9. Your Rights

If the GDPR applies to you, you have the right to:

• Access the personal data we hold about you;
• Request rectification of inaccurate or incomplete data;
• Request erasure of your personal data, subject to certain exceptions;
• Request restriction of processing in certain circumstances;
• Receive your data in a structured, commonly used, machine-readable format and have it transmitted to another controller (data portability);
• Object to processing carried out on the basis of legitimate interests;
• Withdraw consent at any time, where processing is based on consent, without affecting the lawfulness of processing before withdrawal; and
• Lodge a complaint with your local data protection supervisory authority.

If the UAE PDPL applies to you, you have broadly equivalent rights, including the right to be informed of and object to the processing of your personal data, the right to obtain and access your personal data, the right to correct or erase inaccurate data, and the right to restrict or stop processing in certain circumstances.

To exercise any of these rights, please contact us using the details in Section 13. We will respond to verified requests within the timeframe required by applicable law.

10. Security

We take reasonable technical and organizational measures designed to protect your personal data against unauthorized access, loss, misuse, or alteration, including relying on reputable service providers (such as Stripe, Netlify, Calendly, and Meta) that maintain their own industry-standard security practices. However, no method of transmission over the internet or electronic storage is completely secure, and we cannot guarantee absolute security.

11. Children

The Service is intended for business professionals and is not directed to, nor knowingly used by, anyone under the age of 18. We do not knowingly collect personal data from individuals under 18. If you believe a child has provided us with personal data, please contact us so that we can delete it.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, the Service, or applicable law. We will post the updated Policy on this page with a revised “Last updated” date. We encourage you to review this Policy periodically.

13. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at: