Relationship to the EU template
The EU GDPR DPA applies in its entirety with the following adaptations:
| EU term | UAE equivalent |
|---|---|
| ”GDPR" | "UAE PDPL” (+ DIFC / ADGM where applicable) |
| “Supervisory Authority” | UAE Data Office (federal) / DIFC DP Commissioner / ADGM OCDP |
| ”EU Standard Contractual Clauses” | UAE-approved cross-border transfer mechanism (TIA + adequacy or SCC-equivalent) |
Cross-border transfer
A UAE workspace is hosted in Processor’s EU cell, on AWS in Frankfurt (eu-central-1), where its application servers, database, file storage and backups stay.
PDPL Art. 22 restrictions apply. Processor transfers to countries with a UAE Data Office adequacy decision, or with explicit Data Subject consent, or under SCC-equivalent clauses with the upstream vendor.
Free-zone carve-outs
DIFC and ADGM have their own DP regimes. Where the Customer is established in DIFC or ADGM, the respective regime takes precedence and this DPA is interpreted accordingly.
Governing law
Federal law of the UAE. DIFC-based Customers: DIFC courts. ADGM-based Customers: ADGM courts.
Signatures per the EU DPA template. Contact legal@lydira.com for the executable version.