1. Introduction

Elyora values your privacy and is dedicated to its protection. Therefore, we are investing great efforts to be transparent about how we collect and otherwise process your personal data.

This Privacy Notice (‘Notice’) explains the purposes for which we use your personal data, with whom we may share it, where your personal data is stored, and the measures we take to protect your security.

This Notice covers the personal data we process:

• when you interact with our website, microsites, mobile sites, and various online marketing channels, including our social media pages (‘Online Sites’), and
• when we provide you with our professional residence and/or citizenship by investment related services (‘Services’).

We may amend this Notice from time to time to keep it up to date with legal requirements and the way we operate our business. Any changes to this Notice will be effective as of the date they are published on our website.

2. Personal Data We Collect About You

Under this section, we explain the types of personal data we collect from you, how we gather it, and why it is necessary for us to do so. This includes details such as your contact information, preferences, and any data you provide when using our services.

2.1 If you are a a Visitor of our Online Sites

We may process information about you that you have provided to us directly, information that originates from your activities on the website (via cookies or other automated means) and information collected from other sources.

We may process information about you that you have provided to us directly, information that originates from your activities on the website (via cookies or other automated means) and information collected from other sources.

We may process information about you that you have provided to us directly, information that originates from your activities on the website (via cookies or other automated means) and information collected from other sources.

The data is collected directly from you whenever you: visit our website; contact us with questions or comments; sign up to our newsletters, upload content to our website or social media pages; or fill out any forms on our website or social media pages.

Information that may be provided directly by you include:

• Contact Data such as name, gender, email address, and phone number name, gender, email address, and phone number
• Marketing Data such as marketing preferences or survey responses
• Emails or Contact Forms such as electronic communications that you have sent us
• Service Reviews/Referral such as the personal data you may share while providing a service review or a referral.

Other sources from which we collect data about you:

• Your device or browser: Certain information is automatically collected from your device or browser and analysed when you visit our website, interact with our social media pages or online advertising, or open our emails
• Third Parties: We work with third parties who provide services to us such as analytics or advertising companies. Your information may be collected and processed independently in accordance with the third party’s own privacy notices. These third parties share information they have collected with us. We may combine this information with any information we collect.
• Social Media Platforms: Social media platforms share information, which is typically aggregated and doesn’t include personal information, with us. You can learn more about how social media platforms collect and use your information by reviewing their privacy policies and settings
• Cookies: We use cookies (small data files stored on your device or browser) and other similar technologies to automatically collect information when you visit our website or interact with our emails. Through the use of cookies, we may link information about your interactions with our website or emails over time. Any information collected by us or by third parties through the use of cookies or similar technologies may be linked with other information we collect about you. For more information, please find our cookie declaration.
  • Technical Data such as device type, web browser, IP address, accessibility options
  • Usage Data such as account log ins, site navigation, clicks and browsing time
  • Location Data when using the website
  • Preference Data such as products and activities you have indicated an interest in, preferred language
  • Social Media/Third Party Data such as your social media handle and activity on Social Media Pages.

2.2 If you use our services

We may process information about you that you have provided to us directly and information collected from other sources. The data is provided directly from you when you engage our Services independently. Other sources from which we collect data about you may include (i) a partner-company that you contractually entrusted to assist with acquiring your new residency and/or citizenship, (ii) specialised investigation firms that conduct background verification, involved at your and/or partner-company discretion and cost, and (iii) publicly available sources i.e. compliance databases, social media, and news outlets.
The collected information may include any information relating to and about you and if applicable your family members i.e.

• Full name, e-mail address, telephone number
• Passport details, such as passport number, citizenship(s), gender, date of birth, place of birth, place of issue, date of expiry, your identification numbers, maiden name where applicable
• Spouse/civil partner full name, including maiden name where applicable, relationship to you (date and place of marriage if applicable), date of birth, citizenship, place of birth, permanent residential address, tax residence (all applicable countries), occupational/business activities, business name, address and website
• Dependant family member full name, relationship to you, date of birth citizenship, place of birth, permanent residential address
• Previous marriages, divorces, and spouses’ names
• Parents and grandparents’ information, relationship to you, full name, date and place of birth, date and place of death, marital status, date and place of marriage, previous marriages, divorces, and spouses names
• Permanent residential address, tax residence in all applicable countries
• Employment, qualifications, skills, and career history
• Occupational/business activities, business name, address, and website
• Political exposure i.e. information on performing a public function or having immediate family member or a close associate of such person being entrusted with a public function
• Your income, assets, sources of funds, sources of wealth, indemnities, payment records, personal references, investment objectives, financial plans, credit reports and other financially related information
• Remittance information i.e. bank account, IBAN, SWIFT code, bank name and location
• Health insurance information, including information on health status
• Criminal records, information about investigations, proceedings, litigations, and any adverse information that may reflect on reputation
• Information concerning your personality, travel details, lifestyle, leisure activities, and other information of personal nature

3. Purposes and Lawful Bases for Processing Your Personal Data

Elyora will only collect, use and share your personal information where we are satisfied that we have an appropriate legal basis to do so. This is explained in more detail in the table below which sets out the purposes for which we collect personal information

4. Sharing Your Personal Data with Third Parties

We are not in the business of selling any of your data, including personal data, to other third parties.

We may disclose or otherwise share personal data collected by us to the following categories of third parties:

• Any company in Elyora
• Third party service providers and sub-contractors who provide services to us (including but not limited to IT, marketing and back-office services)
• Our business partners offering related services and promotions
• Any third party to whom we delegate the performance of any or all Services from time to time i.e. agents and local lawyers that liaise with government authorities to handle applications and submissions of relevant documents and follow ups
• Any relevant government authorities which handle applications
• Any other third party connected with the Services including but not limited to the specialised investigation firms or other platforms we may use to conduct due diligence
• Transfer of business: Elyora may, in the future, sell or otherwise transfer some or all of its assets to a third party. In such case, we might share or transfer your information to a third party. This could occur during mergers, acquisitions, financings, bankruptcies, dissolutions, transactions, or proceedings.
• We might share aggregated statistical data for improving the Services on our website. Additionally, we might share aggregated or de-identified information with third parties at our discretion.
• Any other sharing of your information will be carried out as directed by you or subject to your consent

With the exception of government authorities, we always enter into non-disclosure and confidentiality agreements with those who have access to your data to ensure the data protection. Accordingly, third parties may only use your data for the purposes and to the extent necessary to perform their contractual duties.

In exceptional circumstances, we may disclose data with law enforcement agencies, fraud prevention agencies, courts or other third parties, where we are required by law or we think it is necessary to defend our legal rights (where possible, we notify you of this type of disclosure).

5. Transferring Your Data

Elyora is a company operating globally; therefore, personal data collected by us may be transferred to other jurisdictions and stored outside of the UAE. In such cases, these transfers may be to countries that do not provide a level of data protection equivalent to that of the UAE.

We will implement appropriate measures like standard contractual clauses to ensure data security and that your personal data is subject to the same level of protection even when it is transferred outside of UAE.

We are committed to ensure that all data transfers will remain secure and under our control. We will ensure that any third parties receiving personal data from us provide sufficient guarantees to meet the requirements of applicable data protection standards.

6. Security

We have implemented technical security measures to safeguard the personal data collected online, in particular – to protect it against unauthorized access, loss, misuse and alteration. This includes, but is not limited to, use of encryption at rest and in transit, identity and access controls and malware protection software.

7. Data Retention and deletion

We will only keep personal data as long as required in respect to the purpose for which they were collected. We may use the following means of deletion: automatic and manual deletion or anonymisation.

8. Your Rights

Within the conditions/limitations set out in applicable data protection law, you can exercise the following privacy rights:

• (a) access to your personal data – request a copy of your personal data that we process about you
• (b) erase or rectify your data – request us to amend or update your personal data where it is inaccurate or incomplete or delete your personal data where it is no longer necessary for the purpose(s) for which your data was originally collected
• (c) restrict or object to the use of your data – request us temporarily or permanently to stop processing all or some of your personal data or in certain circumstances, object to us processing your personal data where it is based exclusively on our legitimate interests (see above) or for direct marketing purposes
• (d) receive or transmit your data in a machine-readable and structured format (otherwise known as “data portability”) – request the receipt or transmission of your personal data to another organisation, in a structured and machine-readable format, and
• (e) withdraw your consent – withdraw your consent at any time to the use of your personal data for a particular purpose (where we have asked you for consent to use your information for that particular purpose)
• (f) object to the processing of personal data – right to ask us to stop processing of your personal data.

If you would like to exercise any of these rights, please contact us via email at [email protected]
Subject to any overriding legal obligations, requirements and/or exemptions, we will endeavour to respond to your request within thirty (30) days of receipt, unless we require further information from you. If you feel that we do not comply with applicable data protection and privacy laws and regulations, you may lodge a complaint with a competent data protection authority.

9. Your Preferences

Email. If you prefer not to receive marketing and promotional emails from us, you can click on the “unsubscribe” link in the email to opt-out of marketing emails or directly reach out to us at [email protected]

Please be aware that even if you choose to opt-out of marketing communications, you may still receive service-related messages related to the processing of your application.
Text, WhatsApp or LinkedIn Instant Messages. We might occasionally use text, WhatsApp or LinkedIn instant messaging to get in touch with you. It is important to note that even if you decide not to receive marketing communications, you may still receive service-related messages connected to the processing of your application

10. Third-Party Sites

This Site may contain links to third party sites (including social media bookmarking buttons that enable you to share certain content on our site). Please review the cookie and privacy statements of these third-party sites to understand how they may use cookies and your personal data. Our Privacy Notice does not apply to your use of third-party sites.