1. General Provisions (UAE)
1.1. This Personal Data Processing Policy (the "Policy") has been developed in accordance with the requirements of Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (the "PDPL") and the applicable Executive Regulations issued by the UAE Data Office.
1.2. This Policy governs the procedures for collecting, using, storing, disclosing, and protecting personal data of users of Papa Dubai digital services, including websites, booking systems, loyalty programs, CRM systems, and related platforms (collectively, the “Platform”).
1.3. For the purposes of this Policy, the data controller and operator of personal data processing is:
SINEMA BEY LOUNGE HOSPITALITY SERVICES L.L.C.
A limited liability company duly incorporated and existing under the laws of the United Arab Emirates.
Legal Type: Limited Liability Company (LLC)
Licensing Authority: Department of Economic Development, Dubai
Commercial License No.: 1020341
DCCI Membership No.: 664097
Commercial Registration No.: 2755737
Registered Address: P.O. Box 346-481, Dubai, United Arab Emirates
License Valid Until: 19/01/2027
(Hereinafter referred to as the “Operator” or “Data Controller”)
1.4. The Operator recognizes the protection of personal data as a fundamental right and undertakes to ensure that personal data is processed lawfully, fairly, and transparently, in accordance with the PDPL and this Policy.
1.5. This Policy applies to all personal data collected through the Platform, including but not limited to:
online forms and reservations;
loyalty programs and memberships;
CRM systems and integrations;
marketing communications and subscriptions;
direct communications via email, messaging applications, or other digital channels.