Privacy Policy

1. Who we are

This website is operated by:

For the purposes of applicable personal-data-protection law, Aframena Real Estate Broker LLC is the controller of personal information collected directly through the Aframena Properties website, unless another party is identified as the controller in a particular context.

2. Scope of this policy

This Privacy Policy applies to personal information collected through:

• The Aframena Properties website
• Aframena Stays
• Property sales, rental and investment enquiries
• Short-stay enquiries
• Owner and operator applications
• Partnership enquiries
• Contact forms
• Consultation requests
• Newsletter subscriptions
• Email, telephone and WhatsApp communications
• Property submissions
• Documents supplied during application or onboarding
• Website analytics, cookies and security logs

This policy does not govern the independent privacy practices of property owners, operators, developers, agents, booking providers, payment providers or other third parties.

3. Information we may collect

Depending on how you interact with us, we may collect the following information.

3.1 Identity and contact information

This may include:

• Full name
• Email address
• Telephone number
• WhatsApp number
• Residential or business address
• Country of residence
• Company name
• Job title
• Preferred method of communication

3.2 Property and commercial information

This may include:

• Property name
• Property address or location
• Property type
• Number of bedrooms
• Guest capacity
• Property features and amenities
• Pricing
• Availability
• Minimum-stay information
• Ownership details
• Operator or management details
• Property descriptions
• Photographs and videos
• Floor plans
• Brochures
• External listing links
• Portfolio information
• Licence or registration information
• Marketing and partnership preferences
• Information about whether a property may also be available for sale

3.3 Application and verification information

Where you apply to join Aframena Stays or enter another commercial relationship with us, we may request:

• Evidence that you own, manage or are authorised to represent the property
• Property licence or registration documents
• Company details
• Operator information
• Proof of authority
• Supporting brochures or marketing material
• Other information needed to assess the application

Please do not submit unnecessary identity documents, payment-card information, bank details or sensitive personal information unless Aframena specifically requests the information through an authorised and secure process.

3.4 Enquiry and communication information

This may include:

• Property enquiry details
• Messages sent through our website
• Consultation requests
• Email correspondence
• WhatsApp messages
• Call or meeting notes
• Communication preferences
• Responses supplied by owners, operators, agents or developers

3.5 Technical and usage information

This may include:

• Internet Protocol address
• Browser type
• Device type
• Operating system
• Referring website
• Pages visited
• Time spent on the website
• Cookie identifiers
• Approximate location derived from an IP address
• Server logs
• Security and fraud-prevention data

3.6 Marketing information

This may include:

• Newsletter preferences
• Marketing consent
• Campaign engagement
• Email opens and link interactions where enabled
• Records of unsubscribe or objection requests

3.7 Transaction and payment information

Aframena Stays does not currently process guest booking payments through the Aframena Stays website.

Where a prospective guest proceeds with a booking, the relevant owner or operator may arrange payment directly under its own booking and payment terms.

Aframena may collect billing or payment-related information in connection with separately agreed advertising, listing, partnership, brokerage or professional services. Payment handling may be performed through an independent payment provider.

Aframena does not intend to store complete payment-card details on its own website systems.

4. How we collect information

We may collect information:

• Directly from you
• Through website forms
• Through property enquiries
• Through application and partnership forms
• By email
• By telephone
• Through WhatsApp
• During meetings or consultations
• From property owners or operators
• From developers, agents and referral partners
• From publicly available property or professional sources
• Through cookies, analytics and server logs
• Through third-party platforms or service providers where lawful

Where someone submits information about another person, that person must have authority to provide the information.

5. How we use personal information

We may use personal information to:

• Respond to property enquiries
• Respond to partnership and application enquiries
• Review whether a property is suitable for Aframena Stays
• Verify authority to submit or represent a property
• Create and maintain accepted listings
• Connect prospective guests with relevant owners or operators
• Connect prospective buyers or investors with relevant owners, developers, agents or advisers
• Provide brokerage or advisory services where separately agreed
• Administer partnership arrangements
• Communicate about applications and listings
• Maintain accurate property and partner records
• Send service-related communications
• Send marketing communications where permitted
• Improve our website and user experience
• Measure website and campaign performance
• Monitor security
• Detect or prevent fraud and abuse
• Maintain legal, accounting and administrative records
• Comply with legal and regulatory requirements
• Establish, exercise or defend legal claims

We will not use personal information for an unrelated purpose without an appropriate legal basis or additional notice where required.

How and why we use personal information

Scroll horizontally to see the full table.

The appropriate processing ground may vary depending on the service, the person's location and the circumstances. Aframena does not rely on consent where another lawful ground is more appropriate.

6. Legal grounds for processing

Depending on the circumstances and applicable law, we may process personal information on one or more of the following grounds:

• Your consent
• Taking steps requested by you before entering into a contract
• Performing a contract with you
• Complying with legal obligations
• Pursuing legitimate business interests where permitted
• Preventing fraud or protecting security
• Establishing, exercising or defending legal claims

Where processing is based on consent, you may withdraw that consent at any time. Withdrawal does not affect processing carried out lawfully before the withdrawal.

7. Property and short-stay enquiries

When you enquire about a property, we may share your name, contact details and enquiry information with the relevant:

• Property owner
• Property operator
• Developer
• Agent
• Broker
• Authorised representative

This is necessary so that the relevant party can respond to the enquiry.

The recipient may process the information as an independent controller and may have its own privacy policy.

Aframena is not responsible for how an independent recipient handles personal information after receiving it, although we expect business partners to handle information responsibly and lawfully.

8. Marketing communications

We may send relevant property updates, newsletters, market information or promotional communications where:

• You have consented
• You have requested the information
• We are otherwise permitted to do so under applicable law

Marketing consent is separate from communications necessary to:

• Respond to an enquiry
• Process an application
• Administer a partnership
• Provide a requested service
• Communicate about an existing commercial relationship

You may unsubscribe using the link in a marketing email or by contacting: sales@aframena.com

Withdrawing from marketing does not prevent us from sending necessary service or administrative communications.

We will not use pre-ticked consent boxes for optional marketing.

9. Who we may share information with

We may share personal information with:

• Aframena employees
• Authorised consultants and contractors
• Property owners
• Property operators
• Developers
• Agents and brokers
• Referral partners
• Website hosting providers
• Email providers
• Form providers
• Customer relationship management providers
• Cloud-storage providers
• Analytics providers
• Security and anti-spam providers
• Newsletter and communications providers
• Professional advisers
• Lawyers
• Accountants
• Auditors
• Insurers
• Government bodies
• Courts
• Regulators
• Law-enforcement authorities where legally required
• A prospective purchaser or successor to all or part of Aframena's business, subject to appropriate confidentiality measures

We do not sell personal information as a standalone commercial product.

We may receive commercial fees, commissions or referral payments arising from property, marketing, brokerage or partnership activities. Such arrangements do not permit a recipient to use personal information for unrelated purposes.

10. International transfers

Aframena operates internationally.

Personal information may be processed, stored or accessed in:

• The United Arab Emirates
• South Africa
• Mauritius
• The United Kingdom
• Other countries where our technology, hosting, email, cloud, analytics or professional service providers operate

Privacy protection may differ between countries.

Where required by applicable law, Aframena will take reasonable steps to use appropriate contractual, organisational or legal safeguards for international transfers of personal information.

We do not claim that every country receiving information has been formally recognised as providing equivalent privacy protection.

11. Data retention

We retain information only for as long as reasonably necessary for the purpose for which it was collected, including legal, regulatory, tax, accounting, security and dispute-resolution purposes.

Unless a longer or shorter period is required in the circumstances, our intended retention framework is:

• General property enquiries: up to 24 months after the last meaningful interaction
• Unsuccessful Aframena Stays applications: up to 12 months after the application decision
• Accepted owner and operator records: for the duration of the relationship and up to six years afterwards
• Contracts, invoices and financial records: for the period required under applicable UAE law
• Marketing records: until withdrawal, objection, unsubscribe or an inactivity review
• Consent and unsubscribe records: for as long as reasonably needed to demonstrate compliance
• Security and server logs: according to the technical and security requirements of the relevant service
• Legal and complaint records: for the applicable claim or limitation period

Information may be retained longer where:

• Required by law
• Required by a regulator or court
• Necessary for an investigation
• Necessary to establish or defend a legal claim
• Needed to prevent repeated fraud or misuse

12. Information security

We use reasonable technical and organisational measures intended to protect personal information.

These may include:

• Access controls
• User permissions
• Password controls
• Encryption in transit
• Secure hosting
• System monitoring
• Backups
• Confidentiality obligations
• Security updates
• Anti-spam or fraud controls
• Incident-response procedures
• Restricted access to application documents

No internet transmission or electronic-storage system is completely secure.

We cannot guarantee absolute security.

13. Your privacy rights

Depending on applicable law and the circumstances, you may have rights relating to:

• Access to personal information
• Correction of inaccurate information
• Deletion
• Restriction of processing
• Objection to certain processing
• Withdrawal of consent
• Data portability where applicable
• Information about how data is processed
• Protection from certain solely automated decisions
• Complaint to a competent authority

Some rights are subject to legal conditions and exceptions.

To exercise a privacy right or raise a concern, contact: sales@aframena.com

Please use the subject line “Privacy Request” when contacting us about access, correction, deletion, objection, consent withdrawal or another privacy matter.

We may request information reasonably necessary to verify your identity before responding.

14. Automated decision-making

Aframena does not currently make property-application or partnership-acceptance decisions solely through automated processing that produces legal or similarly significant effects.

Applications are intended to be reviewed by a person.

We may use automated tools to:

• Filter spam
• Detect security risks
• Organise enquiries
• Support website analytics
• Assist administrative workflows

15. Cookies and similar technologies

Our website uses cookies and similar technologies to support essential functionality, security, preferences and website measurement.

We currently use Google Analytics to understand general website usage and Google reCAPTCHA to protect forms against spam and misuse. Some property pages may also provide a click-to-WhatsApp contact function.

Where required, non-essential analytics or marketing technologies will only be activated in accordance with the applicable consent requirements.

Users may manage cookies through the website's cookie controls, where available, and through their browser or device settings. Disabling certain cookies may affect website functionality.

We may update the technologies used from time to time and will update this Privacy Policy or Cookie Policy where appropriate.

16. Third-party websites

Our website may link to third-party websites including:

• Property-owner websites
• Operator websites
• Developer websites
• Agent websites
• Booking services
• Payment providers
• Social-media platforms
• Mapping services
• External property portals

Aframena does not control the privacy practices of those sites.

Users should review the privacy policies of third-party services before providing information.

17. Children

The Aframena Properties website and Aframena Stays property-partnership services are not directed at children.

We do not knowingly invite children to submit owner, operator, investment or property applications.

Where information about a child is relevant to a legitimate booking or property enquiry, the responsible adult should provide only the information reasonably required.

18. Complaints

We encourage you to contact us first so that we can try to resolve a privacy concern.

Contact: sales@aframena.com

Depending on your location and the circumstances, you may also have the right to complain to a competent data-protection or regulatory authority.

We do not identify one authority as having exclusive jurisdiction over every user.

19. Changes to this Privacy Policy

We may update this Privacy Policy to reflect:

• Changes to our services
• Changes to technology
• Changes to legal requirements
• Changes to our business operations

The updated version will display a revised "Last updated" date.

Where required, we will provide additional notice of material changes.

20. Contact us

For privacy questions, requests or complaints, contact: