Terms & Conditions

1. Scope of Application

These General Terms and Conditions (GTC, also “Terms & Conditions”) apply to all contracts and services between the Client and Privacy Management Group FZ-LLC, registered in the Ras Al Khaimah Economic Zone (RAKEZ), United Arab Emirates – hereinafter referred to as “PMG.”

PMG, within the Privacy Management Group corporate structure, serves as the central point of contact for international clients. It is responsible for coordination, mandate management, and the organizational handling of services in the areas of company formation, relocation of residence, office services, visa procedures, and strategic tax consulting in various countries and jurisdictions.

All services in connection with the United Arab Emirates are provided directly by PMG. Services in Cyprus, Ireland, or other countries in which group companies of Privacy Management Group are operationally active are provided independently by such companies. In further jurisdictions, services are rendered by carefully selected cooperation partners. In all such cases, however, PMG remains the central contractual partner and first point of contact for the Client. PMG assumes further responsibility for the services of third parties only if this has been expressly agreed in writing.

PMG offers its services worldwide and serves clients from various jurisdictions, economic areas, and nationalities. These GTC therefore apply irrespective of the domicile or nationality of the Client. They take into account the international framework conditions of the respective target states as well as the specific regulatory requirements of individual countries, including outside the European Union.

PMG renders its services exclusively to Clients who are entrepreneurs within the meaning of the applicable legal definition. Contracts with consumers are generally not concluded. For this reason, consumer protection regulations do not apply. In particular, restrictions that exist in consumer protection law – for example, concerning automatic contract renewals or unilateral adjustment clauses – do not apply in business-to-business transactions.

These GTC also apply to all future business relationships with the Client, unless expressly agreed otherwise. A renewed explicit reference to these GTC for subsequent assignments is not required.

2. Subject Matter of the Contract and Description of Services

The subject of this contract is the provision of consulting, incorporation, and administrative services by PMG in connection with national and international corporate structures, relocation of residence, visa matters, as well as office and postal services.

PMG offers these services both for the United Arab Emirates and for numerous other jurisdictions. Services within the United Arab Emirates are provided directly by PMG. With respect to Cyprus, Ireland, and other countries in which group companies of the Privacy Management Group are operationally active, implementation is carried out by the respective responsible group entity. For all other jurisdictions, PMG may rely on qualified external cooperation partners. In such cases, the execution of individual services is handed over to the respective third-party provider.

The Client expressly agrees that individual service components may be performed by affiliated group companies or external cooperation partners. A separate consent is not required, provided that PMG continues to act as the Client’s contractual partner. PMG assumes further responsibility for the services of third parties only if this has been expressly agreed in writing.

The specific scope of services results from the respective individual contract, a signed offer, and/or an individually formulated service description. PMG does not guarantee any specific legal, economic, or administrative effect unless expressly assured in writing. In particular, no guarantee can be given for the granting of visas, permits, tax certificates, or the opening of bank accounts, as these decisions lie solely within the discretion of the competent authorities or institutions.

PMG is entitled to engage qualified third parties, employees, or vicarious agents to fulfill the contract. In the event that individual tasks are delegated to group companies or cooperation partners, central coordination responsibility – unless otherwise agreed – remains with PMG.

3. Duties of the Client

The Client undertakes to support PMG to the best of their ability in the execution of the commissioned services. This includes, in particular, the timely, complete, and truthful provision of all information, documents, declarations, and authorizations necessary for the performance of the contract.

PMG relies on the active cooperation of the Client to ensure proper service delivery. Delays, additional work, or disadvantages resulting from delayed, incomplete, or incorrect cooperation fall within the Client’s responsibility. In such cases, PMG is entitled to adjust deadlines or charge additional fees for the increased processing effort.

The Client is obliged to notify PMG without delay, but at the latest within seven (7) working days, in writing or electronically, of any changes to their business contact details (in particular address, telephone number, e-mail address), corporate structure, or beneficial owners.

PMG provides the Client with certain documents – including contracts, permits, tax assessments, or other declarations. The Client undertakes to examine these documents immediately upon receipt for correctness and completeness. Any discrepancies or objections must be communicated to PMG in writing within seven (7) working days. If no feedback is provided, the contents are deemed approved.

If PMG provides the Client with electronic access data (e.g. to customer portals or project platforms), such data must be treated confidentially, protected from third-party access, and regularly updated. In the event of suspected misuse, PMG must be notified without delay.

If PMG provides the Client with a business address, office service, or mail forwarding, such services may only be used within the framework of the contractually agreed purpose. Misuse or misleading use, particularly for deception regarding tax residence, economic substance, or circumvention of regulatory obligations, is prohibited and entitles PMG to terminate the contract extraordinarily.

The Client is responsible for complying with legal, tax, and regulatory deadlines in all affected jurisdictions – particularly in connection with tax returns, license renewals, or visa extensions. PMG assumes no liability for omissions, fines, default interest, or other disadvantages arising from a lack of cooperation or delayed response by the Client.

If payments are to be made by PMG to authorities or third parties on behalf of the Client (e.g. for visas, licenses, or annual fees), the full amount must be credited to the account specified by PMG no later than ten (10) working days before the due date. All transaction fees, transfer costs, or currency conversion fees shall be borne by the Client. If payment is not made on time or in full, PMG is entitled to suspend the service concerned or to perform it at the Client’s sole risk.

PMG is entitled to set binding deadlines for the submission of accounting or administrative documents. If such deadlines are not met, PMG may postpone processing or charge additional fees. Repeated breaches of cooperation duties entitle PMG to extraordinary termination for cause.

The Client is obliged to formulate all instructions to PMG clearly and comprehensibly. Changes, repetitions, or corrections must be identified as such.

PMG is not obliged to actively request missing or unclear information from the Client. The responsibility for the timely, complete, and verifiable provision of all relevant documents lies exclusively with the Client. If documents are not submitted, submitted late, or submitted incompletely, PMG is entitled to suspend or refuse service provision in whole or in part.

4. Liability and Limitation of Liability

PMG shall be liable to the Client exclusively within the framework of the following provisions. Liability is governed by the statutory provisions of the United Arab Emirates, insofar as these Terms and Conditions do not provide for a permissible and validly agreed limitation. Further liability under mandatory law – in particular for intent, gross negligence, injury to life, body, or health, or under mandatory statutory provisions – remains unaffected.

4.1 Liability for Services in the United Arab Emirates

PMG is liable without limitation for damages caused by intentional or grossly negligent conduct, as well as in the event of injury to life, body, or health.

In the event of simple negligent breach of essential contractual obligations (cardinal duties), liability is limited to the typically foreseeable damage. Liability for indirect damages, loss of profit, or financial losses is excluded, unless a mandatory statutory provision provides otherwise.

These liability provisions apply equally to PMG’s legal representatives, employees, vicarious agents, and subcontractors.

4.2 Liability for Services by Group Companies

Where PMG has services performed in whole or in part by affiliated companies within the corporate group – in particular by Privacy Management Group Ltd in the Republic of Cyprus, by affiliated units in Ireland, or in other countries where group companies operate under their own license – the execution of services is carried out under the sole legal responsibility of the respective group entity.

PMG remains the contractual partner and central coordination point in such cases, but is liable only for the careful selection and proper transfer to the responsible group company. The actual provision of services and responsibility for their substantive correctness are subject to the respective national law and regulations of the competent jurisdiction.

PMG assumes no liability for the substantive, legal, or tax quality of the services, unless expressly assumed in writing as its own obligation.

4.3 Liability in Cooperation with Third-Party Providers

Where services are performed in whole or in part by external cooperation partners or third-party providers – for example, in jurisdictions where PMG itself has no operational entity – execution of the commissioned service is under the sole legal and factual responsibility of the respective third-party provider.

PMG is liable in such cases exclusively for the careful selection and instruction of the respective cooperation partner. Any further liability – in particular for the actual execution, results, official approvals, or the economic and legal quality of services – is excluded, unless PMG has expressly assumed such responsibility in writing.

The Client acknowledges that PMG remains the contractual partner even if the execution of individual services is performed by external third-party providers operating outside the United Arab Emirates, Cyprus, Ireland, or other group regions. Liability for delays, omissions, or breaches of duty by such third-party providers does not exist unless a written assumption of responsibility by PMG has been agreed.

4.4 General Limitation of Liability

General content provided by PMG – such as on the website, in newsletters, or in introductory orientation discussions – serves solely for general information and does not constitute individual legal, tax, or financial advice. It does not give rise to any contractual obligation. Decisions by the Client based on such general information are made at their own risk. PMG assumes no liability in this respect.

PMG does not generally owe any specific economic, legal, or administrative success, unless expressly assured in writing. This applies in particular to the granting of visas, licenses, tax certificates, or the opening of bank accounts, as the decision rests solely with the competent authorities.

4.5 Exclusion of Assignment and Class Actions

The assignment of claims against PMG to third parties is excluded, unless PMG has expressly consented to the assignment in writing.

Claims against PMG may not be asserted by way of class actions, group actions, or comparable collective proceedings. Each Client is obliged to pursue their own claims individually. PMG assumes no liability for disadvantages, costs, or legal consequences resulting from impermissible assignments or collective proceedings.

4.6 Exclusion of Liability in Bank Account Openings

PMG assists the Client, upon request, in the preparation and submission of documents for the opening of a bank or financial account. The choice of the financial institution (e.g. bank, FinTech, or payment service provider) is made solely by the Client. PMG does not provide any legally binding recommendation in this context.

If the Client selects an institution on the basis of a non-binding recommendation or referral from PMG, this is done at the Client’s own risk. PMG does not conduct any creditworthiness check or legal evaluation of the respective institution. The Client is solely responsible for examining the suitability and integrity of the financial institution before submitting an application and regularly thereafter. PMG assumes no liability for later changes in creditworthiness, operational problems, economic difficulties, or measures by supervisory authorities against the provider concerned.

PMG also provides no guarantee for successful or timely account opening. The decision lies exclusively with the financial institution. This applies irrespective of whether rejection or delay is due to reasons attributable to the Client (e.g. late or incomplete documents) or to internal decisions of the financial institution. PMG is not liable for any resulting damages or delays.

4.7 Responsibility of the Beneficial Owner (BO)

The mandate relationship exists between PMG and the beneficial owner (BO) as entrepreneur as well as the company founded or managed by them. PMG provides its services exclusively within the framework of a business-to-business relationship (B2B).

PMG reserves the right to reject mandates or cooperation with persons or organizations if there is reason to believe that the true identity of the beneficial owner is being deliberately concealed.

The beneficial owner is personally and jointly liable for all obligations of their company towards PMG. This includes in particular outstanding remuneration claims, additional services, expenses, as well as all contractual or statutory claims arising from the mandate relationship.

A personal release from liability of the beneficial owner is effective only if PMG has consented in writing or if a statutory provision expressly provides for such release. A unilateral exemption by the beneficial owner is excluded.

In the event of payment arrears or serious breaches of duty, PMG is entitled to assert its claims both against the company and against the beneficial owner personally – including by judicial enforcement, where legally permissible.

5. Data Protection and Confidentiality

PMG undertakes to treat all personal data, business information, and documents transmitted or made accessible within the framework of the mandate relationship as strictly confidential and to use them exclusively for the performance of the contractually agreed services. This includes, in particular, all information concerning the Client, its beneficial owners, authorized representatives, or other affected persons.

The collection, processing, and storage of personal data by PMG takes place in compliance with the applicable data protection regulations of the United Arab Emirates (in particular Federal Law No. 45 of 2021 on the Protection of Personal Data – UAE Data Protection Law), the EU General Data Protection Regulation (GDPR), as well as the relevant laws of further affected jurisdictions, where applicable to the mandate relationship.

5.1 Data Processing and Purpose Limitation

Personal data is processed exclusively for the purpose of contract performance, client communication, processing of commissioned projects, fulfillment of regulatory obligations, and payment processing. PMG collects only such data as is necessary for these purposes (principle of data minimization).

PMG is entitled to share personal data within the corporate group – in particular with Privacy Management Group Ltd in the Republic of Cyprus or other group companies – insofar as this is necessary for the performance of the commissioned services. Separate consent is not required, provided that appropriate technical and organizational safeguards are in place and the processing is legally permissible.

In the event of cooperation with external partners or service providers outside the UAE or EU, personal data will only be transferred if:

• it is strictly necessary for contract fulfillment,
• the third-party provider demonstrates adequate data protection standards, and
• PMG is legally or contractually entitled to transfer the data.

PMG ensures that all internal and external entities entrusted with processing personal data are bound to confidentiality and act in accordance with applicable law.

5.2 Data Security and Access Protection

PMG implements appropriate technical and organizational measures to protect personal data against loss, unauthorized access, manipulation, or disclosure. These include, in particular:

• encrypted data transmission,
• password protection for digital access,
• access controls and logging,
• as well as clear internal policies on data processing and storage.

Where the Client is provided with access data to online portals or secure communication channels, they are obliged to store such access data securely, update it regularly, and protect it against unauthorized use. PMG is not liable for damages resulting from improper handling or security gaps on the part of the Client.

5.3 Retention Periods and Data Deletion

Personal data is stored by PMG only for as long as is necessary to fulfill contractual or legal obligations. The applicable retention periods are determined by the laws of the United Arab Emirates, the Republic of Cyprus, Ireland, the European Union, and other relevant jurisdictions.

After expiry of statutory retention periods or cessation of the processing purpose, the data is deleted in compliance with data protection regulations or anonymized, where technically possible. Deletion does not take place if further storage is necessary, for example, to assert, exercise, or defend legal claims.

The Client may at any time request deletion of specific data or their client account, provided that no statutory retention obligations or legitimate interests of PMG oppose such deletion.

5.4 Confidentiality

Both contracting parties undertake to treat as confidential all information received or made accessible during the course of cooperation. This applies in particular to economic, legal, tax, strategic, or personnel information – regardless of whether expressly marked as confidential.

This confidentiality obligation continues beyond termination of the contractual relationship and lapses only if:

• the information was demonstrably publicly accessible,
• there is a statutory or regulatory duty of disclosure, or
• disclosure is objectively necessary for performance of the contract.

PMG is entitled, within the framework of mandate handling – in particular in cross-border services – to share information with qualified entities within the corporate group, provided this serves the contractual purpose and is in compliance with data protection requirements.

6. Remuneration and Payment Terms

PMG renders all services on the basis of a written agreement, a signed offer, or another form of order confirmation by the Client. Unless otherwise expressly agreed, the following provisions apply.

6.1 General Remuneration Rules

All price quotations are understood, unless expressly stated otherwise, as net amounts plus any applicable statutory taxes, public levies, or official fees pursuant to the applicable provisions in the United Arab Emirates or the respective target country.

PMG determines the currency for each contractual relationship individually. Depending on the jurisdiction concerned and the performing entity, billing may be in Euro (EUR), US Dollar (USD), or UAE Dirham (AED). The currency specified in the offer or contract is binding.

The agreed remuneration covers only the contents specified in the offer or service description. Extensions, modifications, or additional services require a separate written agreement and are invoiced additionally in accordance with the applicable hourly rates or individually agreed lump sums.

Unless otherwise agreed, remuneration is due for payment immediately upon invoicing without deduction. Payment shall be deemed made only when the full amount has been irrevocably credited to the PMG account specified in the invoice.

Any bank charges, transfer fees, or currency conversion costs are borne by the Client, unless otherwise agreed in writing.

6.2 Accounting and Tax Services (Jurisdiction-Specific)

Provision of accounting and/or tax advisory services by PMG or affiliated group companies takes place only in selected countries and only where expressly indicated in the respective offer. The following rules apply:

• Cyprus: Privacy Management Group Ltd in the Republic of Cyprus is registered there as a licensed tax consultancy firm. Accounting, bookkeeping, and annual financial statements are rendered by internal departments. The applicable fees are defined on a case-by-case basis and depend on scope, corporate structure, and industry-specific requirements of the Client.
• Ireland: In Ireland, accounting and tax services are provided by carefully selected local cooperation partners. PMG coordinates the cooperation but remains the contractual partner of the Client. Remuneration includes both internal coordination and external partner services and is transparently set out in the offer.
• United Arab Emirates (UAE): In the UAE, PMG cooperates with recognized tax consultants and auditors. Services are provided by such external partners but on preferential terms negotiated by PMG for its Clients. PMG remains contractually responsible and the central point of contact. Fee structure is clearly indicated in the offer.
• Other countries: For all other jurisdictions, PMG may, upon the Client’s request, facilitate contact with external qualified providers. In such cases, PMG assumes neither service obligations nor liability for tax or accounting content, unless expressly agreed in writing.

6.3 Payment Default and Reminder Fees

If the Client defaults on due payments, PMG is entitled to charge statutory default interest and to suspend further service provision until all outstanding amounts are fully settled.

A flat reminder fee may be charged for each reminder. PMG is further entitled, in the event of continued payment default, to engage external debt collection agencies or legal counsel to enforce outstanding claims. The resulting costs are borne by the Client, to the extent legally permissible.

6.4 Rights of Retention and Release of Documents

PMG is entitled to withhold the release of documents, certificates, attestations, or other contract-related materials until all outstanding claims have been fully settled. This applies in particular to prepared annual financial statements, company documents, or official filings.

In the event of contract termination, PMG is entitled to charge a reasonable processing fee for the provision or transfer of relevant documents to third parties (e.g. new tax consultants or successor firms), unless already covered under the existing contract.

6.5 One-Off and Recurring Fees

For certain services (e.g. office services, compliance support, annual fees, or administrative support), PMG may charge both one-off setup costs and recurring fees. These will be communicated transparently in advance and clearly designated in the offer.

Termination of the contractual relationship does not release the Client from the obligation to pay fees already incurred or agreed until the date of termination taking effect. Refunds are only granted under the conditions regulated in the section “Termination of Contract.”

7. Term, Termination, and Renewal

7.1 Contract Term and Automatic Renewal

The contract term results from the signed offer or agreement. Unless otherwise specified, the term begins on the date of contract conclusion and ends upon full performance of the agreed services.

For ongoing services – in particular office services, tax support, accounting services, or compliance services – a minimum term of twelve (12) months applies, unless otherwise agreed in individual cases.

If such contract is not terminated in writing at least three (3) months before the end of the respective term, it is automatically renewed for a further twelve (12) months. This provision applies regardless of the nationality or residence of the Client and corresponds to the B2B legal framework in the United Arab Emirates, the European Union, and other international jurisdictions where PMG operates.

PMG may remind the Client before expiry of the contract term of the impending contract end and the possibility of termination. However, PMG is not obliged to give such notice.

7.2 Ordinary Termination

Ordinary termination is only possible if expressly provided for in the specific contract. In all other cases, termination is possible only by full contract performance or by extraordinary termination.

Where ordinary termination is permissible, it must be effected by giving three (3) months’ notice to the end of the respective contract term. Termination must be in writing or in text form (e.g. by e-mail), unless the contract stipulates a stricter form.

7.3 Extraordinary Termination

Both contracting parties are entitled to terminate the contract with immediate effect for good cause. Good cause exists, in particular, if:

• the Client remains in default of due payments despite reminder,
• the Client repeatedly or materially breaches duties of cooperation, disclosure, or documentation,
• PMG can no longer provide contractual services due to legal, regulatory, or economic circumstances – regardless of jurisdiction,
• the relationship of trust between the parties is permanently disrupted by serious misconduct.

PMG is further entitled to terminate the contract with immediate effect if the Client deliberately provides false information, uses licenses or addresses unlawfully, or misuses the services – regardless of the Client’s place of residence or place of service provision.

7.4 Refunds and Settlement upon Early Termination

In the event of termination – regardless of reason – there is no entitlement to reimbursement of fees already paid, insofar as the agreed services have already been wholly or partially rendered or PMG has already entered into binding obligations towards third parties in connection with the assignment.

Refunds are possible only if PMG has demonstrably and culpably (intentionally or with gross negligence) breached contractual obligations and the remaining services can therefore no longer be rendered. In such case, reimbursement is limited to the proportionate value of the unrendered services. The burden of proof lies with the Client.

7.5 Change of Provider or Consultant

The Client is entitled to switch to another service provider, tax consultant, or office provider – regardless of nationality or the domicile of the new firm. PMG will support such transition upon request for a reasonable processing fee, amounting to:

• at least EUR 1,550.00 net flat,
• plus EUR 190.00 net per hour for additional effort.

PMG is entitled to withhold documents until full settlement of all outstanding claims. Data provision is made in a standard format. There is no entitlement to special formats, individual file structures, or specific export solutions.

7.6 Retention and Transfer of Data after Termination

Upon termination of the contractual relationship, PMG is entitled either to transfer all documents to the Client or to a successor designated by them, or – insofar as legally permissible – to destroy them in compliance with data protection law.

Statutory retention obligations in the United Arab Emirates, Cyprus, Ireland, the European Union, and other affected jurisdictions remain unaffected. The respective relevant tax, commercial, or regulatory requirements apply, in particular in cases of cross-border activities.

8. Amendment of the GTC

PMG reserves the right to amend or update these Terms and Conditions at any time, in particular to adapt to legal, technical, regulatory, or economic developments, or to expand the service portfolio.

Material amendments to these GTC will be communicated to the Client at least thirty (30) calendar days before the planned effective date in text form (e.g. by e-mail). The amendment notice will contain explicit reference to the Client’s right to object and the consequences of failure to object.

If the Client does not object within the specified period and continues to use PMG’s services, the new GTC are deemed agreed. PMG will explicitly point this out in the amendment notice.

If a timely objection is raised, the previous contractual terms initially remain unchanged. PMG is, however, entitled to terminate the contractual relationship with reasonable notice if continuation under the original terms is no longer reasonable due to legal, economic, or operational reasons.

Retroactive amendments or amendments without notice period take place only if required by mandatory statutory provisions or official orders. This applies in particular in the case of immediate application of new statutory requirements in the United Arab Emirates, the European Union, or other jurisdictions where PMG operates or where Clients are resident.

9. Governing Law and Jurisdiction

For all contracts between the Client and PMG as well as for all claims arising therefrom, only the substantive law of the United Arab Emirates (UAE) applies. The application of international conventions – in particular the United Nations Convention on Contracts for the International Sale of Goods (CISG) – is expressly excluded.

Mandatory statutory provisions of other states remain unaffected, insofar as and to the extent that they are mandatorily applicable under the conflict of laws rules of the United Arab Emirates despite the choice of law. This applies in particular to mandatory consumer protection, tax, or regulatory provisions in states where the Client is domiciled or services are rendered.

The exclusive place of jurisdiction for all disputes arising out of or in connection with the contractual relationship is – to the extent legally permissible – the competent court in Ras Al Khaimah, United Arab Emirates.

PMG is, however, entitled to assert claims also before the general place of jurisdiction of the Client or before another competent court, in particular where more effective legal enforcement or execution is ensured.

This jurisdiction clause applies regardless of the nationality of the Client, the registered office of the company, or the place of service provision, and applies to all business relationships, including where such take place outside the UAE or the European Union.

10. Final Provisions

10.1 Severability Clause

Should individual provisions of these Terms and Conditions be or become wholly or partially invalid, unenforceable, or void, the validity of the remaining provisions remains unaffected. In place of the invalid or unenforceable clause, a provision shall be deemed agreed which comes as close as legally permissible to the economic purpose of the omitted clause.

10.2 Formal Requirements

All agreements, amendments, and side arrangements require text form, unless a stricter form is prescribed by law. Waiver of the text form requirement itself requires text form.

10.3 Assignment and Transfer

The Client is not entitled to transfer or assign rights or obligations from the contractual relationship to third parties without prior written consent of PMG.

PMG is entitled to transfer this contract as well as all rights and obligations arising therefrom to an affiliated company of the PMG group, provided that the Client’s legitimate interests are not impaired. In all cases, PMG remains responsible for proper performance of services.

10.4 Language and Interpretation

These Terms and Conditions have been drafted in the German language. If PMG provides the Client with translations of these Terms or of contractual documents, such translations serve solely for comprehension. For interpretation and legal effect, only the German original version is authoritative.

10.5 Tax Notice

PMG expressly points out that the Client’s income, assets, or activities may be taxable in their state of residence. The Client is solely responsible for fulfilling all tax obligations in all affected jurisdictions, irrespective of nationality, residence, or registered office.

PMG assumes no liability or warranty for tax consequences of measures taken by the Client on the basis of advice, recommendations, or general information provided by PMG. Liability is assumed only if expressly agreed in writing.

PMG further points out that any disclosure obligations under international frameworks – such as the Common Reporting Standard (CRS), the EU Directive DAC6, US tax law (FATCA), or comparable rules – fall exclusively within the Client’s responsibility, unless PMG has been expressly engaged to fulfill such obligations.

Status: August 2025