Privacy Policy
1. Introduction
DvanB Management Consultancy FZCO or ARAYA Hospitality ("ARAYA", "we", "us", or "our") is a boutique hotel investment firm headquartered in the United Arab Emirates. We are committed to protecting the personal data of visitors to our website at araya-hospitality.com (the "Website") and of individuals who contact us through it.
This Privacy Policy explains what personal data we collect, how we use it, with whom we share it, and what rights you have in relation to it. It applies to all users of our Website, regardless of location.
Please read this policy carefully. By using our Website, you acknowledge that you have read and understood its terms.
2. Applicable Legal Framework
As a UAE-based entity, ARAYA Hospitality is subject to:
• Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (UAE PDPL) and its implementing regulations;
• The General Data Protection Regulation (EU) 2016/679 (GDPR), to the extent we process personal data of individuals located in the European Economic Area (EEA).
Where GDPR applies, ARAYA acts as a data controller. Our legal bases for processing are set out in Section 5 below.
3. Personal Data We Collect
3.1 Data you provide directly
When you use our contact form or send us an enquiry, we collect:
• Your name
• Your email address
• The content of your message
• Any additional information you voluntarily include
3.2 Data collected automatically
When you visit our Website, we and our service providers may collect:
• IP address and approximate geographic location
• Browser type and version
• Device type and operating system
• Pages visited, time spent on pages, and referring URLs
• Cookie identifiers and analytics data (see Section 7)
4. How We Use Your Personal Data
We use the personal data we collect for the following purposes:
• To respond to your enquiries and communicate with you
• To assess potential investment or business relationships
• To send you updates or information about ARAYA Hospitality where you have subscribed to receive these
• To analyse how our Website is used and improve its performance
• To comply with our legal and regulatory obligations
• To protect our legitimate business interests
5. Legal Basis for Processing (GDPR)
Where GDPR applies, we rely on the following legal bases:
• Consent — for newsletter communications and non-essential cookies. You may withdraw consent at any time.
• Legitimate interests — for responding to enquiries, improving our Website, and protecting our business.
• Legal obligation — where processing is required to comply with applicable law.
6. Third-Party Services and Data Sharing
6.1 Google Workspace
We use Google Workspace (provided by Google LLC) to manage our email communications. Enquiries submitted via our contact form are received and processed using Google Workspace. Google acts as a data processor on our behalf and processes data in accordance with Google's Data Processing Addendum.
6.2 Squarespace Analytics
Our Website is hosted and built on Squarespace (provided by Squarespace, Inc.). Squarespace Analytics collects aggregated data about Website visits, including page views, traffic sources, and visitor behaviour. This data is used solely to improve our Website and is processed by Squarespace as a data processor on our behalf.
6.3 No sale of personal data
We do not sell, rent, or trade your personal data to any third party for their own marketing purposes.
6.4 Other disclosures
We may disclose your personal data where required by law, by a court order, or to protect the rights and safety of ARAYA Hospitality or others.
7. Cookies and Tracking Technologies
Our Website uses cookies and similar tracking technologies. Cookies are small text files placed on your device when you visit a website. We use the following types of cookies:
• Essential cookies — necessary for the Website to function correctly. These cannot be disabled.
• Analytics cookies — used by Squarespace Analytics to collect aggregated, anonymised information about how visitors use our Website. These are only placed with your consent where required by law.
You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the Website.
8. International Data Transfers
As a UAE-based business using service providers including Google (USA) and Squarespace (USA), your personal data may be transferred to and processed in countries outside the UAE and the EEA.
Where such transfers occur, we ensure that appropriate safeguards are in place, including:
• Standard Contractual Clauses (SCCs) approved by the European Commission, where GDPR applies;
• Data processing agreements with all relevant service providers.
9. Data Retention
We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law. In practice:
• Contact form enquiries are retained for up to 3 years from the date of last contact.
• Newsletter subscriber data is retained until you unsubscribe.
• Analytics data is retained in accordance with Squarespace's data retention policies.
10. Your Rights
Depending on your location and applicable law, you may have the following rights in relation to your personal data:
• Right of access — to request a copy of the personal data we hold about you
• Right to rectification — to request correction of inaccurate or incomplete data
• Right to erasure — to request deletion of your personal data in certain circumstances
• Right to restrict processing — to request that we limit how we use your data
• Right to data portability — to receive your data in a structured, machine-readable format
• Right to object — to object to processing based on legitimate interests
• Right to withdraw consent — where processing is based on consent, to withdraw it at any time
To exercise any of these rights, please contact us at the details set out in Section 12. We will respond within 30 days. We may need to verify your identity before processing your request.
11. Data Security
We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, destruction, or alteration. These include:
• Secure transmission via HTTPS/SSL encryption
• Access controls limiting who within ARAYA can access personal data
• Use of reputable, security-certified service providers (Google, Squarespace)
However, no method of transmission over the internet is entirely secure. While we strive to protect your data, we cannot guarantee absolute security.
12. Contact Us
If you have any questions about this Privacy Policy, wish to exercise your rights, or wish to make a complaint, please contact us:
ARAYA Hospitality
Email: info@araya-hospitality.com
Website: www.araya-hospitality.com
Jurisdiction: United Arab Emirates
If you are located in the EEA and believe we have not handled your data in accordance with GDPR, you have the right to lodge a complaint with your local data protection supervisory authority.
13. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. We will post the updated policy on this page with a revised effective date. We encourage you to review this policy periodically.