Privacy Policy

Last updated: 29 October 2026

This policy explains what personal information the Biological Upgrade Program ("we", "us", "our") collects, why we collect it, who we share it with, and the choices you have. It covers our website (biological-upgrade.com), our client app and questionnaire (app.biological-upgrade.com), our enquiry forms on Facebook and Instagram, and the messages, calls and emails we have with you.

1. Who we are

The Biological Upgrade Program is operated by Haya Tech FZ-LLC, a free zone limited liability company licensed in Dubai Internet City, Dubai, United Arab Emirates (licence number 107656), of Premises HD01A, First Floor, In5 Tech, Dubai Internet City, Dubai, United Arab Emirates.

We are the "controller" of your personal information. We follow the UAE Personal Data Protection Law and, where we serve clients in the United Kingdom, the European Union or elsewhere, the data protection laws that protect them, including the UK GDPR and the EU GDPR.

Contact us about anything in this policy at: derek@biological-upgrade.com

2. What we collect

When you enquire (for example through a form on Facebook or Instagram, or on our website):

• Your name, email address, phone number and the city and state or country where you live
• Your answers to our enquiry questions, such as what you would like to improve and which best describes your work

When you complete our questionnaire or become a client:

• Your date of birth, sex at birth, height, weight and estimated body fat
• Your health history: medical conditions, medications, supplements, allergies, injuries, training level and goals
• Blood test results and other health reports you upload or send us
• Notes from your calls and consultations, your Longevity Index reports, and your progress through the program

When you talk to us:

• Messages you send us by WhatsApp, email or social media, and your call bookings

Automatically, when you use our website or app:

• Basic technical information such as your browser type, device and pages visited, and the information needed to keep you signed in to the app

3. Health information

Health information, including blood test results, is sensitive personal data under the UAE Personal Data Protection Law and "special category" data under UK and EU law, and we treat it with extra care. We only collect it with your explicit consent, which you give when you complete our questionnaire or send us your results. We use it only to assess whether the program is right for you, to produce your Longevity Index report and to deliver your program. You can withdraw your consent at any time by emailing us. This won't affect anything we did before you withdrew it, but we may not be able to continue your assessment or program without it.

The Biological Upgrade Program provides health optimisation coaching and naturopathic guidance. It does not replace care from your own doctor.

4. Why we use your information, and our legal basis

• To reply to your enquiry and book your assessment call (our legitimate interests, and steps you ask us to take before entering a contract)
• To assess your health information and deliver the program you sign up for (performance of our contract with you, and your explicit consent for health information)
• To take payment and keep business and tax records (performance of a contract and legal obligation)
• To send you follow-up messages about your enquiry or program (legitimate interests; you can ask us to stop at any time)
• To measure and improve our advertising, for example counting how many enquiries come from an ad (legitimate interests)
• To keep our website and app secure and working (legitimate interests)

We never sell your personal information and never use your health information for advertising.

5. Who we share it with

We share your information only with people who need it to run the program, and only as much as they need:

• Our program team, including Dr Nira, our naturopathic doctor, who reviews health information and blood work as part of your assessment and program, and our operations and medical coordinator, who manages client records and scheduling
• Service providers who host and run our systems for us, such as website and app hosting (Netlify), our database provider (Supabase), Google (call booking through Google Calendar, and client files and intake forms in Google Drive and Google Forms), WhatsApp, and our email provider
• AI tools that help our team summarise notes and automate administrative tasks. We only use providers whose terms do not allow them to train their models on your information
• The training app we use to deliver your exercise program, which receives only the details needed for your training plan
• Meta Platforms (Facebook and Instagram), when you send us an enquiry through a Meta form, and our advertising contractor who manages our ads and can see enquiry form answers (never your questionnaire or health information)
• Payment providers, when you pay for the program
• Authorities, where the law requires it

Each service provider may only use your information to provide its service to us.

6. International transfers

Our business is registered in the United Arab Emirates, but our team works from other countries too (including Mexico and Serbia), and some of our service providers store data in the United States and elsewhere. When your information moves between countries, we use safeguards recognised by the applicable law, such as standard contractual clauses, the UK International Data Transfer Agreement or Addendum, or a provider's certification under the UK-US Data Bridge, and we share only what is needed.

7. How long we keep it

• Enquiries that don't become clients: up to 12 months after our last contact, then deleted
• Client records, including health information and reports: for the length of your program and up to 6 years after it ends, so we can answer questions about your care and meet our legal obligations, unless you ask us to delete them sooner and the law allows it
• Payment and tax records: as long as tax law requires (7 years in the UAE)

8. Your rights

You have the right to:

• Ask for a copy of the personal information we hold about you
• Ask us to correct information that is wrong or incomplete
• Ask us to delete your information
• Ask us to limit how we use it, or object to how we use it
• Ask us to send your information to you or someone else in a usable format
• Withdraw your consent at any time, where we rely on it
• Stop follow-up and marketing messages at any time

If you live in the United States, you may have similar rights under your state's privacy law (for example California, Colorado, Connecticut, Texas, Virginia or Washington), including the right to know, delete and correct your information, and the right to opt out of its sale. We do not sell personal information or share it for cross-context behavioural advertising.

To use any of these rights, email derek@biological-upgrade.com. We will reply within one month. We may need to confirm who you are first.

If you are unhappy with how we handle your information, please tell us first so we can put it right. You can also complain to the UAE Data Office, to the UK Information Commissioner's Office if you live in the UK (ico.org.uk) or the data protection authority where you live.

9. Security

We keep your information in secure, access-controlled systems. Only the people who need your health information can see it. No system is completely secure, so if we ever learn of a breach that affects you, we will tell you and the authorities as the law requires.

10. Cookies and similar technologies

Our app stores small amounts of information in your browser so you can stay signed in. If we add analytics or advertising tools to our website, such as the Meta Pixel, we will update this policy and, where the law requires it, ask for your consent first.

11. Children

The program is for adults. We do not knowingly collect information from anyone under 18.

12. Changes to this policy

We may update this policy from time to time. The date at the top shows when it last changed. If a change significantly affects how we use your information, we will let you know before it takes effect.

13. Contact

Biological Upgrade Program
Operated by Haya Tech FZ-LLC, licence number 107656
Premises HD01A, First Floor, In5 Tech, Dubai Internet City, Dubai, United Arab Emirates
derek@biological-upgrade.com