Privacy Policy

Last Updated September 2026

1. Introduction

We at F/CXO MENA, operated by The CXOnsiglieri Company (“our Company”), provide you with a directory of fractional leadership resources through our website at www.fcxomena.com (“our Site”).

In order to serve you better, we may collect information from you and/or your organisation, some of which may be considered personal data pertaining to individuals or confidential information of your organisation respectively. We understand the importance of the privacy and security of your information, and we have therefore set out in detail below how we collect and use your information. Kindly review the terms and conditions of this Privacy Policy so that you may be reassured that we take data protection seriously.

Please note that your access to and use of our Site is subject to our Company’s Terms of Use, as well as the terms and conditions set out in this Privacy Policy. Accordingly, by accessing our Site, you are agreeing to our collection of your information pursuant to this Privacy Policy. Should you disagree with any clause in our Terms of Use and/or this Privacy Policy, please discontinue use of our Site.

In order for you to maximise the utility of our Site, access our services, request information from us, or receive our marketing materials, newsletters or updates regarding our services, our products and other related matters (collectively, our “Updates”), your Personal Data (as defined in clause 2.2 below) and/or your Confidential Information (as defined in clause 2.4 below) has to be provided to us, and we will need to keep and use your Personal Data and/or Confidential Information in order to fulfil the purpose for which you have contacted us, subscribed to our Site, Updates and/or services.

For expediency and for compliance with any changes in the law, we reserve the right to amend this Privacy Policy at our sole discretion at any time without prior notice to you, and you agree that your continued access to our Site and/or desire to receive our Updates constitutes your unconditional acceptance of the amended Privacy Policy. You agree that it is your sole responsibility to keep yourself updated of any amendments by reviewing this Privacy Policy on our Site regularly.

2. Types of Data Collected

2.1 When you visit our Site, sign up for any of our Updates, register a profile, and/or email us, we collect Personal Data and Anonymised Data.

2.2 “Personal Data” refers to information, whether true or otherwise, with personal identifiers that can be used separately or collectively to identify an individual, such as name, address, Emirates ID, passport number or other national identification number, mobile number, email address, birthdate, gender, professional background, income range, residency status, and payment card details.

2.3 “Anonymised Data” refers to information that is not associated with or linked to your Personal Data and cannot be used to identify individual persons.

2.4 “Confidential Information” refers to sensitive or proprietary information of an organisation (incorporation, partnership, or other similar form of legal entity) that is not available in the public domain.

3. Collection of Anonymised Data

3.1 When you access our Site and/or email us, we may collect Anonymised Data about you via the application of generally accepted web technologies including but not limited to web beacons, cookies, clear GIFs, widgets, online evaluations, surveys, HTML5, and third party web analytics such as Google Analytics (collectively, “Acceptable Technologies”). This automatic collection of non-personal information includes, without limitation, collection of your IP address, the web browser software you used, your sign-ups for any Updates or information via our Site, the specific pages of our Site viewed by you, and third party websites that you may have visited prior to our Site. Our purpose for this collection is to understand the preferences of our visitors and users so as to enhance and facilitate the ease with which you are able to access or use our Site.

3.2 As part of the Anonymised Data that we collect, when you access our Site via your mobile device, we will also collect information regarding the type of mobile device you are using so that our Site can provide you with the version best suited for access via your device.

3.3 If you do not consent to our collection of Anonymised Data, please adjust the settings on your computer, tablet and mobile device to block or disable our use of the Acceptable Technologies. In the event that you choose to access our Site without blocking, disabling or opting out of the Acceptable Technologies, such access constitutes your consent to our use of the Acceptable Technologies and our collection of information thereby.

3.4 To better assist you in understanding the generally accepted technology used in our collection of Anonymised Data:

• “IP Address” refers to a number automatically assigned to your computer when you access the Internet. Under certain circumstances, your IP address remains the same from browser session to browser session; where a consumer Internet access provider is used, your IP address will likely vary from session to session. We track IP addresses solely in conjunction with session cookies to analyse the flow of webpages on our Site.
• “Cookies” refer to small pieces of data that a website transfers to your computer’s hard drive or mobile device’s internal storage while you are viewing the website. Our Site uses both session cookies (which expire the moment your browser is closed) and persistent cookies (which remain until you actively delete them) to provide you with a more personalised and interactive experience. By changing the options in your browser and adjusting the settings on your device, you can control whether to accept or decline cookies.
• “Clear GIFs” refer to clear electronic images used to track your opening of webpages on our Site and your browsing patterns, for the purpose of assessing the attractiveness of our content and the flow of webpages and layouts that appeal to you. Clear GIFs are also commonly known as web beacons and generally work in conjunction with cookies to identify users and user behaviour. Some of our HTML based emails may also use Clear GIFs so we can assess how emails we sent have been opened and acted upon. Clear GIFs collect only limited data, such as a cookie number, the time and date a particular webpage is accessed, and a description of the webpage on which the Clear GIF resides.
• “Third party web analytics” refer to services provided by third party providers for the assessment, analysis, measurement and reporting of visitor behaviour on a website, in order to assess and improve the website’s effectiveness. One of the most well known third party analytics services is Google Analytics.
• “HTML5 local storage” refers to caching services using primarily a cache manifest file, which allows for storage of your preferences offline, updated and synchronised when you go online.

4. Your Consent to our Collection, Retention and Use of Personal Data and Confidential Information

4.1 In order for our Company to provide you with our services and products, you agree and consent to our Company collecting, using and retaining your Personal Data and/or Confidential Information as follows:

• When you sign up for our Updates, register a profile on our Site, or email us with any queries, you will be required to provide us with your Personal Data and/or Confidential Information in order for us to add you to our mailing list, publish and maintain your directory profile as applicable, or respond to your queries.
• When you sign up for any Updates, register for any account, enrol in any membership or other promotional campaign that we provide, we will require your Personal Data and/or Confidential Information in order to keep a record of and provide you with the benefits that accompany our membership programme and/or promotional campaigns. Unless you withdraw from our membership programme or promotional campaigns, or the relevant campaign ends, we will keep your Personal Data for as long as you are still part of the programme or campaign (whichever is later) so that we can provide you with the relevant benefits. In relation to your Confidential Information, we will retain it for as long as we are of the reasonable opinion that your organisation may still be interested in our Company’s services, so that our Company can be expeditious in providing our services whenever you seek our assistance.
• When you click on any of our Company’s online advertisements for more information regarding our services or our Site, we collect the Personal Data and/or Confidential Information that you provide in order to follow up with you on your interest.

4.2 In addition, we will retain your Personal Data and/or Confidential Information where necessary and for such duration as may be required in order for our Company to comply with applicable laws and regulations, assist in any legal investigations, meet the demands of any regulatory or law enforcement bodies, for use in legal proceedings, minimising fraud, collection of debts, resolving disputes, identifying issues, enforcing contractual breaches and/or claiming damages.

5. Disclosure of Personal Data and Confidential Information

5.1 We may need to disclose your Personal Data and/or Confidential Information to:

• Third party service providers, in order for us to facilitate your access to and use of our Site, contact you as you may have requested, maintain and update your records, respond to your queries, follow up on any consultations you may have requested, operate the directory platform, and provide you with any other benefits accompanying your participation in our membership programme and/or promotional campaigns. These third party service providers have a contract with us to perform the services necessary for you to use our Site and receive Updates, and include but are not limited to our technology platform provider, web hosting companies, website maintenance companies, database storage companies, payment service providers, and companies that assist with mailing on our behalf.
• Our bookkeepers, accounting firms, audit firms, law firms and/or other professional advisory firms who maintain our records in accordance with legal requirements.
• Governmental, regulatory or law enforcement bodies who have a legal right to demand your Personal Data and/or Confidential Information.
• Credit bureaus, credit rating agencies and fraud prevention companies for the purpose of minimising fraudulent activity.
• Our affiliated or related companies and/or third parties with whom we may engage in a transaction involving some or all of our Company’s assets (which may include your Personal Data), in the course of a corporate divestiture, restructuring, merger, acquisition, joint venture, bankruptcy, dissolution, reorganisation or any other similar transaction or proceeding.

5.2 Except as provided above, we do not sell, rent, licence or otherwise disclose your Personal Data and/or Confidential Information to third parties or our affiliated companies. We are careful in our selection of third party service providers, and all such providers and affiliated companies are bound by obligations of data protection, pursuant to contracts and/or applicable laws, similar to the obligations in this Privacy Policy.

6. Transferring Personal Data out of the United Arab Emirates

6.1 Pursuant to the purposes and activities set out in sections 3, 4 and 5 above, it may be necessary for us to transfer your Personal Data outside the United Arab Emirates, including to our technology platform provider and other service providers located abroad. You hereby agree and consent to such transfer, on the understanding that the recipients of such Personal Data are subject to applicable laws or contractual obligations providing a standard of protection comparable to that under UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data.

7. Accurate and Complete Personal Data and Confidential Information

7.1 In order for us to provide you with access to our Site and all its associated functions and services, and to perform the activities set out in sections 3, 4 and 5 above, you warrant that the Personal Data and/or Confidential Information you provide to us is accurate, and that all Personal Data and/or Confidential Information relevant for the particular purpose or circumstance has been provided.

8. Marketing Communications

8.1 We respect your selections in relation to the channels via which you wish to receive our Updates. We do not engage in telemarketing activities. If you wish to withdraw your consent for us to contact you, please contact our Data Protection Officer at concierge@fcxomena.com.

9. Withdrawal of Consent

9.1 You may at any time withdraw your consent to our use, retention, disclosure or transfer of your Personal Data and/or Confidential Information pursuant to this Privacy Policy by emailing our Data Protection Officer at concierge@fcxomena.com. However, please note that any such withdrawal of consent may result in us being unable to continue providing our services or fulfilling our contractual obligations to you, including but not limited to termination of your access to our Site, removal of your directory profile, termination of any membership benefits that would otherwise have been available to you, inability to provide you with the opportunity to participate in promotions, inability to fulfil any request for information that you may have submitted, and potentially the inability of third parties to provide you with their services or products as you might have contracted with them through our Site. Accordingly, your withdrawal of consent may also lead to the termination of any contracts you may have with our Company, as well as any contracts with third parties engaged through our Site, for which our Company expressly reserves its rights and remedies. Our Data Protection Officer will further advise you on the consequences that may follow should you contact us to withdraw your consent.

9.2 Should you wish to unsubscribe from our Updates, please respond to any of our emails and we will remove you from our mailing list. Please note that this may result in us being unable to make available to you updates on our services, your benefits under our membership programme, and any ongoing promotions.

10. Access and Correction of Personal Data and Confidential Information

10.1 Should you wish to access, update or make corrections to your Personal Data and/or Confidential Information held with us, or if you wish to receive further clarification on your Personal Data and/or Confidential Information held with us, please email our Data Protection Officer at concierge@fcxomena.com.

10.2 There will be no administrative fees or other charges levied for any request to correct or update your Personal Data and/or Confidential Information. However, for other requests, such as accessing records of when you accessed our Site or the dates of your requests for information, a reasonable administrative fee may be levied depending on the request, as time and resources will be spent in accommodating it.

10.3 Should you have any queries or complaints pertaining to this Privacy Policy, our Terms of Use, your Personal Data and/or Confidential Information as registered with us, or in relation to our Company’s use, retention, disclosure or transfer of your Personal Data and/or Confidential Information, or should you wish to learn more about our data protection policies and security measures, please email our Data Protection Officer at concierge@fcxomena.com.

11. Minors

11.1 Our Site, our Updates and our services are not meant for persons who may be defined as minors under applicable law. We do not knowingly collect Personal Data from minors; however, through the internet, we may not be able to ascertain whether an individual is a minor. It is the responsibility of parents or guardians to ensure that minors do not access our Site, email us, or provide us with Personal Data without parental or guardian consent. If a parent or guardian becomes aware that a minor has accessed our Site or provided us with Personal Data without consent, they should promptly contact our Data Protection Officer at concierge@fcxomena.com. If we become aware that a person under 18 has provided us with Personal Data without parental or guardian consent, we will delete such information from our records.

12. Security Measures for Protection of Personal Data and Confidential Information

12.1 We ensure that our Site is protected by reasonable security measures afforded by current technology, and that all our data hosts and servers are similarly protected.

12.2 Your Personal Data and Confidential Information is kept securely and protected against unauthorised access and disclosure. We use security means such as, without limitation, password protection, encryption, and locked and restricted access. We have strict policies in place restricting access to Personal Data and Confidential Information to authorised personnel on a need-to-know basis.

12.3 We will take practical steps to ensure that your Personal Data is not kept longer than as set out in this Privacy Policy, or for as long as is necessary for fulfilling the purposes for which you have entrusted us with your Personal Data, or as may be required for legitimate business or legal purposes, whichever is the latest.

13. Third Party Sites and Social Network Sites

13.1 Our Site may contain hyperlinks to websites operated by third parties. Such third party websites are not governed by our Privacy Policy or Terms of Use. We are not responsible for the privacy policies or data security of such third party websites, even if they are co-branded with our Company name or logo, or our Site displays products or services that originate from such third parties. We urge you to learn about the privacy policies of these third party websites before accessing or using them, and to be careful about providing any Personal Data and/or Confidential Information to them. We seek your understanding that we are not liable for any acts or omissions, or any loss or damage that you may suffer, due to your use of or access to such third party websites.

13.2 Our Company may use reputable social media and network sites, including but not limited to LinkedIn, Instagram, YouTube and X (collectively, the “Social Media Sites”), to connect with your social networks. In order to generate interest in our Site and services among the contacts in your networks and to allow you to share your interest in our Site and services, we provide access to our Site to third party Social Media Sites, and there may be links on our Site to such Social Media Sites. This association does not constitute any endorsement or recommendation of any Social Media Site by our Company, nor vice versa. Kindly review the terms of use and privacy policies of the Social Media Sites before you use or access them in conjunction with our Site.

13.3 The association of our Site with the Social Media Sites may make available certain features which, when used by you, may result in information being made available from your accounts with the Social Media Sites to our Company. Such information constitutes public information available in the general domain because it was made publicly available by the Social Media Sites. Should you prefer that we do not collect your information from the Social Media Sites, please do not use the features or links that associate our Site with the Social Media Sites, and adjust the settings in your accounts with the Social Media Sites to prevent the sharing of your information. Please note that our Company cannot control, and is not responsible for, the sharing of your information by the Social Media Sites with third parties.

13.4 Where sharing or endorsement features provided by Social Media Sites are used in relation to our Site or our services, information about our Site and services may be made known to your network via the methods employed by the relevant Social Media Site, and your information may be displayed alongside services you have endorsed. If you are not agreeable to this, please adjust your account settings with the relevant Social Media Site. We are not obliged to display any of your information on our Site or related webpages, and where any of your information or endorsements appear, we reserve the right at our sole discretion to remove them.

14. Governing Law and Jurisdiction

14.1 The terms and conditions of this Privacy Policy are governed by the laws of the United Arab Emirates as applied in the Emirate of Dubai. In the event of any dispute arising from this Privacy Policy and your use of our Site, you must first contact our Data Protection Officer at concierge@fcxomena.com regarding your concern and use your best endeavours to settle the dispute amicably in good faith. We will likewise use our best endeavours to settle your concerns amicably and in good faith. However, if no amicable resolution is reached within 30 days, you agree to submit to the exclusive jurisdiction of the Courts of Dubai, United Arab Emirates.