Application Privacy Notice

Effective Date: 20 May 2026  |  Version: 1

1. Who We Are

1.1 This Application Privacy Notice explains how Silal Food And Technology L.L.C. (“Silal”, “we”, “us” or “our”) collects and processes Personal Data in connection with applications to the Unbreakable Harvest Platform. References in applicant-facing materials for this application process to Innovation Oasis, iO, the Innovation Oasis Accelerator, or similar Silal branding refer to Silal acting through its Innovation Oasis research, development, and innovation initiative or hub in connection with the Platform, and this Notice applies to Personal Data processed in connection with Applications submitted under any of those names.

1.2 For the purposes of applicable UAE personal data protection law, Silal is the controller of the Personal Data covered by this Notice.

1.3 Silal’s privacy contact for this Notice is compliance@silal.ae.

1.4 Capitalised terms used but not defined in this Notice have the meanings given in the Application Terms and Conditions. References to Applicant Submissions, Protected Material, the Application Site, the Delivery Partner, and related Platform terms are to those terms as used in the Application Terms and Conditions.

1.5 The Platform is delivered on Silal’s behalf by Ibex (the Delivery Partner), part of the Antler group. Silal remains the controller of Personal Data processed in connection with the Platform. The Delivery Partner acts as a processor on Silal’s behalf and under Silal’s instructions for the purposes described in this Notice and the Application Terms and Conditions. For the avoidance of doubt, Applicant data is not used for Antler group investment, deal-flow, portfolio, or fundraising purposes.

2. Scope

2.1 This Notice applies to Personal Data processed in connection with applications submitted to the Unbreakable Harvest Platform; supporting documents and Applicant Submissions; communications with applicants; shortlisting, verification, interviews, diligence, site visits, and evaluation; records of electronic acceptance, versioning, and submission activity for the application process; and technical operation, security, audit, and evidence records relating to the Application Site.

2.2 This Notice does not, by itself, govern later-stage participant, pilot, grant, procurement, investment, or service-delivery activities. If your Application progresses and Silal needs to process Personal Data for a later stage, Silal may provide additional privacy information.

3. Categories of Personal Data

3.1 Depending on the Application and stage of review, Silal may process:

  1. identity data, such as name, nationality, date of birth, Emirates ID or other identification details, and electronic acceptance details;
  2. contact data, such as email address, mobile number, postal address, and other contact details;
  3. business and financial data, such as company details, ownership details, licences, financial information, and business plans;
  4. application content, including proposals, presentations, attachments, images, videos, and correspondence;
  5. verification and diligence data, such as clarifications, interview notes, site-visit notes, and compliance or risk-review records;
  6. technical and usage data relating to the application process, such as submission time, IP address, browser or device information, portal activity logs, security logs, cookie identifiers, analytics identifiers where used, and version-acceptance records; and
  7. Personal Data about founders, shareholders, directors, officers, employees, contractors, advisers, customers, suppliers, referees, investors, partners, or other individuals included in or connected with an Application.

4. Why We Process Personal Data

4.1 Silal may process Personal Data for the following purposes:

  1. receiving, administering, and reviewing applications;
  2. verifying eligibility, identity, authority, and supporting information;
  3. communicating with applicants;
  4. shortlisting, evaluating, benchmarking, interviewing, and conducting diligence;
  5. arranging demonstrations, presentations, site visits, or follow-up discussions;
  6. maintaining governance, audit, compliance, fraud-prevention, security, legal-defence, and recordkeeping processes;
  7. establishing, exercising, or defending legal rights and responding to judicial, regulatory, or governmental requests;
  8. where separately agreed, using limited Personal Data for publicity, promotional, or media purposes; and
  9. operating, securing, monitoring, supporting, troubleshooting, and evidencing the Application Site and submission process.

4.2 Silal may send administrative, operational, diligence, evaluation, and Platform-related communications in connection with your Application. Silal will not use your Personal Data for unrelated direct marketing, third-party promotions, or non-Platform promotional communications unless there is a lawful basis to do so, including consent where required by applicable law.

4.3 Where used in connection with the Platform, Silal, the Delivery Partner, and evaluators may use scoring tools, evaluation criteria, forms, rankings, administrative workflows, or platform functionality to support the review of Applications. Final selection decisions are intended to be made by human reviewers or under meaningful human oversight and are not intended to be based solely on automated processing. Where any decision producing legal or similarly significant effects is based solely on automated processing, Silal will provide further information and human review where required by applicable law.

5. Legal Basis / Permitted Basis

5.1 Silal may rely on one or more grounds permitted by applicable law, including where processing is necessary to take measures at your request with a view to concluding, amending, or terminating a contract or arrangement; perform a contract or arrangement to which you are a party; comply with legal or regulatory obligations applicable to Silal; establish, exercise, or defend legal rights or claims, or in connection with judicial procedures; protect the security, integrity, and operation of the Application Site and Platform process; or where required or chosen by Silal for a specific activity, on the basis of consent.

5.2 Where Silal relies on consent for a specific activity, you may withdraw that consent in accordance with applicable law. Withdrawal will not affect processing lawfully carried out before withdrawal.

6. Sharing of Personal Data

6.1 Silal may share Personal Data, on a need-to-know basis and subject to appropriate restrictions where applicable, with:

  1. Affiliates and group entities involved in Platform administration, governance, compliance, legal review, or evaluation;
  2. the Delivery Partner, acting on Silal’s behalf and under Silal’s instructions for application intake, administration, communications, evaluation support, diligence support, reporting, and related Platform purposes;
  3. third-party application platform providers, including the relevant AcceleratorApp operating entity where used for the Application Site, and hosting providers, email service providers, support tool providers, analytics providers where enabled, security providers, and other technical service providers used to operate, administer, host, secure, support, or evidence the Application process;
  4. evaluators, reviewers, advisers, auditors, insurers, professional advisers, and consultants engaged in connection with the Platform;
  5. governmental, judicial, regulatory, or law-enforcement authorities where disclosure is required or appropriate under applicable law; and
  6. counterparties or advisers involved in a restructuring, merger, acquisition, transfer, assignment, or reorganisation affecting Silal or the Platform.

6.2 Processors and service providers engaged for the Application process must process Personal Data only for authorised Platform purposes and subject to appropriate contractual, confidentiality, security, and data protection obligations.

7. Cross-Border Transfers

7.1 Personal Data may be transferred to, stored in, accessed from, or otherwise processed in countries outside the UAE, including countries where the Delivery Partner, technical service providers, application platform providers, hosting providers, email service providers, support tool providers, evaluators, advisers, or other recipients involved in the Platform are located.

7.2 These countries currently include Singapore, Germany, the United States, Ireland, and Canada, and may also include other countries where the Delivery Partner, third-party application platform providers, hosting providers, email service providers, support tool providers, analytics providers where enabled, security providers, other technical service providers, evaluators, advisers, or their relevant support teams, systems, infrastructure, or sub-processors are located. Further information about current recipient-location categories may be requested from Silal’s Privacy Contact.

7.3 Where Silal transfers or permits access to Personal Data outside the UAE, Silal will implement transfer conditions, contractual safeguards, consent where required, or other lawful transfer mechanisms available under applicable UAE personal data protection law, including applicable executive regulations, as required in the circumstances. This Notice discloses potential transfers but does not by itself replace the need for a lawful transfer basis where one is required.

8. Cookies, Analytics, and Technical Tools

8.1 The Application Site may use cookies, pixels, tags, logs, analytics, support, monitoring, fraud-prevention, security, or similar technical tools to operate the Application Site, maintain security, support submissions, evidence acceptance, troubleshoot issues, understand usage, and improve the Application process.

8.2 Some tools may be strictly necessary for the Application Site to function. Others, such as analytics, tag-management, support, or marketing-related tools, may be used only where enabled for the Application Site and where there is a lawful basis to do so, including consent where required by applicable law. Where required, additional cookie or tool-specific notices or controls may be presented on the Application Site.

9. Retention

9.1 Silal will retain Personal Data for as long as reasonably necessary for the purposes described in this Notice, including application administration, evaluation, compliance, legal defence, audit, and recordkeeping.

9.2 Unless a longer period is required or justified by law, dispute, claim, investigation, audit, enforcement, compliance, or governance need, Silal may retain application files and supporting documents for up to seven years after the end of the relevant application cycle, and records of electronic acceptance, versioning, submission activity, and related evidence for up to seven years after the end of the relevant application cycle.

9.3 You shall not input, upload, or otherwise disclose any Silal Confidential Information into any third-party artificial intelligence, machine learning, large language model, or analytics system without Silal’s prior written consent.

10. Your Rights

10.1 Subject to applicable law and any lawful exceptions, you may have the right to request information about the types of Personal Data processed, the purposes of processing, recipients, storage standards, cross-border safeguards, and how to complain; request correction of inaccurate Personal Data or completion of incomplete Personal Data; request erasure in the cases allowed by law; request restriction of processing in the cases allowed by law; object to processing for direct marketing, including related profiling, in the cases allowed by law; object to certain automated decisions and request human review where applicable; and request transfer of Personal Data in the cases allowed by law and where technically feasible.

10.2 To exercise your rights, contact Silal using the privacy contact details set out in this Notice.

11. Security

11.1 Silal implements technical, organisational, and administrative measures designed to protect Personal Data against unlawful or unauthorised access, use, alteration, disclosure, destruction, or loss, taking into account the nature of the data and the risks involved.

12. Personal Data Breaches

12.1 Where required by applicable law, Silal will notify the competent authority and, where applicable, affected data subjects of qualifying Personal Data breaches without undue delay and in accordance with applicable legal requirements.

13. Complaints

13.1 If you believe that your Personal Data has been processed in breach of applicable law, you may contact Silal first using the privacy contact details set out in this Notice. You may also have the right to submit a complaint to the competent UAE data protection authority in accordance with applicable law.

14. Changes to This Notice

14.1 Silal may update this Notice from time to time. The version in force at the time of your submission will be identified by version number and date and applies to the processing of Personal Data for that Application, except where Silal provides updated privacy information for future stages, future applications, or material changes that Silal decides to apply to existing Applications.