Privacy Policy — NAYL نَيْل

NAYL Group ("NAYL," "we," "us," "our") takes the privacy of every visitor, prospective client, and business contact seriously. This policy explains what personal data we collect, how we use it, the legal basis for doing so, and the rights you have. In clear terms, without legal theatre.

This Privacy Policy applies to personal data processed through the website naylgroup.com and any related services we provide. It has been prepared in accordance with the United Arab Emirates Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data ("UAE PDPL") and, where relevant, with reference to international data protection standards such as the EU General Data Protection Regulation (GDPR) for visitors based outside the UAE.

01. Who We Are

NAYL Group is an advisory and intelligence firm based in Dubai, United Arab Emirates. For the purposes of data protection law, NAYL Group is the data controller of personal data collected through this website. You can reach our designated data contact at admin@naylgroup.com.

02. Personal Data We Collect

We collect only the personal data necessary to engage with you meaningfully. This may include:

Information you provide to us directly

Your full name and preferred form of address
Email address and phone or messaging number (including WhatsApp)
Nationality and country of residence, where relevant to the inquiry
Property preferences, budget range, timeline, and investment intent
Any other information you choose to share in free-text fields or direct correspondence

Information collected automatically

Technical data: IP address (truncated or anonymised where feasible), browser type, device type, operating system
Usage data: pages viewed, time on page, referring website, approximate location based on IP
Cookie data: limited to essential functionality and anonymised analytics (see Section 06)

03. How We Use Your Personal Data

Your personal data is used only for clearly defined purposes:

To respond to your inquiry: providing information, arranging advisor consultations, sending you the requested brief
To deliver our advisory services: matching you to suitable opportunities, maintaining your client record, coordinating transactions
To improve our service: analysing aggregated, non-identifying usage patterns to improve the website and our research
To meet legal and regulatory obligations: including anti-money laundering (AML), know-your-customer (KYC), and record-keeping requirements under UAE law
With your explicit consent: for any other purpose clearly communicated to you at the time of collection

04. Legal Basis for Processing

We rely on the following legal bases under the UAE PDPL:

Your consent: when you voluntarily submit information through our forms or contact channels
Contract performance: when processing is necessary to provide services you have engaged us for
Legitimate interests: where we have a reasonable business interest that does not override your privacy rights
Legal obligation: where we are required to process your data by applicable law

05. Data Sharing

We do not sell personal data. We may share your data only in the following circumstances:

With service providers we rely on to operate (hosting, email, analytics, secure messaging), all of whom are bound by confidentiality and data protection obligations
With regulators or authorities where required by UAE law or a lawful order
With property developers or third parties directly relevant to a transaction you have authorised us to pursue on your behalf, and only the minimum information needed
In the event of a business transfer: such as a merger, acquisition, or corporate restructuring, subject to the same protections described in this policy

We do not disclose your personal data to advertisers, data aggregators, or unrelated third parties.

06. Cookies and Tracking

This website uses a minimal set of cookies: strictly necessary cookies for basic site function, and (where enabled) privacy-respecting analytics cookies that help us understand how visitors engage with our content. We do not use advertising, profiling, or retargeting cookies without explicit consent.

You can control cookie preferences through your browser settings. Disabling cookies may affect certain site functionality.

07. Data Retention

We retain personal data only as long as needed for the purpose it was collected, or as required by law. As a general rule:

General inquiry data: retained for up to 24 months, then deleted or anonymised
Active client data: retained for the duration of the client relationship and for a further 7 years where required for regulatory, tax, or audit purposes
Anonymised analytics data: retained indefinitely as it cannot identify individuals

08. International Transfers

Our primary operations are in the UAE. Some of our service providers (hosting, email infrastructure, analytics) may process data in other jurisdictions. Where personal data is transferred outside the UAE, we ensure an adequate level of protection through one or more of the following: contractual safeguards with the recipient, transfers to jurisdictions with recognised adequacy, or with your explicit consent where required.

09. Your Rights

Under the UAE PDPL, you have the following rights in relation to your personal data:

Right of access: obtain confirmation of whether we hold your data, and a copy of it
Right to rectification: correct inaccurate or outdated information
Right to erasure: request deletion of your data ("right to be forgotten"), subject to legal retention obligations
Right to restrict processing: limit how we use your data in specific circumstances
Right to data portability: receive your data in a structured, machine-readable format
Right to object: to processing for direct marketing or automated profiling
Right to withdraw consent: at any time, without affecting the lawfulness of processing that took place before withdrawal

To exercise any of these rights, contact us at admin@naylgroup.com. We will respond within the timelines set by UAE law. If you believe your rights have not been respected, you may lodge a complaint with the UAE Data Office.

10. Security

We apply appropriate technical and organisational measures to protect personal data against unauthorised access, disclosure, alteration, or destruction. These measures include encrypted data transmission (HTTPS), access controls, and regular review of our infrastructure. No internet-based service can guarantee absolute security, but we commit to promptly investigating and responding to any breach in accordance with our legal obligations.

11. Children

This website is not directed to individuals under the age of 18. We do not knowingly collect personal data from minors. If you believe we have inadvertently collected such information, please contact us so we can delete it.

12. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in law, our practices, or the services we offer. Material changes will be communicated on this page with a revised "Last updated" date. Continued use of the site after changes constitutes acceptance of the updated policy.

13. Contact Us

Questions, concerns, or requests relating to this policy or to your personal data should be sent to:

NAYL Group
Dubai, United Arab Emirates
admin@naylgroup.com

This Privacy Policy constitutes the entire agreement between you and NAYL Group on the subject of personal data handling for this website. It is governed by the laws of the United Arab Emirates, and any disputes shall be subject to the exclusive jurisdiction of the UAE courts.