Effective Date: 14 August 2026
Last Updated: 14 August 2026
ASTRO WALLENIUS L.L.C-FZ (“Astro Wallenius”, “we”, “us” or “our”) respects your privacy and is committed to protecting personal data entrusted to us.
This Privacy & Data Protection Policy explains how we collect, use, store, disclose and protect personal data when you visit www.astrowallenius.com (the “Website”), subscribe to our newsletter, contact us, or otherwise interact with us through the Website.
This Policy is intended to reflect applicable data-protection requirements in the United Arab Emirates, including Federal Decree-Law No. 45 of 2021 concerning the Protection of Personal Data (“UAE PDPL”), and, where applicable to our activities, Regulation (EU) 2016/679 (“GDPR”).
This Policy is a notice concerning our processing of personal data. Your use of the Website does not constitute consent to every form of processing described below. Where consent is required, we will request it separately.
For the purposes of this Policy, the principal data controller is:
ASTRO WALLENIUS L.L.C-FZ
Meydan Free Zone Company
Meydan Grandstand, 6th Floor
Meydan Road, Nad Al Sheba
Dubai, United Arab Emirates
Email: contact@astrowallenius.com
The Website also contains information relating to ASTRO WALLENIUS BUYING AND SELLING OF REAL ESTATE L.L.C, a separate mainland company in the Emirate of Dubai.
Where personal data is collected specifically in connection with activities carried out by that separate entity, that entity may act as a separate data controller for the relevant processing.
Depending on how you interact with us, we may collect the following categories of personal data.
This may include:
your name;
email address;
telephone number, where provided;
company or organisation details;
information included in messages or enquiries sent to us;
newsletter subscription information;
records of marketing consent or withdrawal of consent; and
any other information you voluntarily provide.
If a relationship with Astro Wallenius develops beyond ordinary Website interaction, we may separately request additional information where reasonably necessary for contractual, compliance, regulatory, accounting or legal purposes. Any such information will be processed in accordance with applicable law.
When you visit the Website, certain technical information may be collected automatically, including:
IP address;
browser type and version;
device type;
operating system;
approximate geographic information derived from your IP address;
Website pages visited;
date and time of access;
referring pages or websites;
Website interaction and performance information; and
cookie and consent preferences.
Some of this information may constitute personal data under applicable law.
We may collect personal data:
directly from you when you contact us;
when you subscribe to our newsletter;
through forms available on the Website;
automatically through cookies and similar technologies;
through our Website hosting, security and analytics systems; or
from service providers acting on our behalf.
Where appropriate and permitted by law, we may also receive business contact information from publicly available sources or from professional or commercial contacts.
We may process personal data for the following purposes:
operating, maintaining and securing the Website;
responding to enquiries and requests;
communicating with prospective or existing business contacts;
administering newsletter subscriptions;
sending marketing communications where you have consented to receive them or where otherwise permitted by law;
recording and managing consent preferences;
understanding how visitors use the Website;
improving Website functionality, security and user experience;
preventing misuse, fraud, cyber incidents or unauthorised access;
maintaining business and administrative records;
complying with applicable legal, regulatory, accounting and compliance obligations;
establishing, exercising or defending legal rights; and
carrying out legitimate corporate operations.
We will not use personal data for materially incompatible purposes without providing appropriate notice and, where required, obtaining consent.
Where the GDPR applies to a particular processing activity, we process personal data on one or more of the following legal bases:
We may rely on your consent for activities such as:
newsletter subscriptions;
certain direct-marketing communications; and
non-essential cookies or tracking technologies where consent is required.
You may withdraw your consent at any time. Withdrawal does not affect the lawfulness of processing carried out before consent was withdrawn.
We may process information where necessary to respond to a request made by you before entering into a business relationship or to perform obligations under an agreement with you.
We may process personal data where necessary for legitimate business interests, provided those interests are not overridden by your fundamental rights and freedoms.
These interests may include:
operating and improving the Website;
protecting our systems and Website from misuse or security threats;
responding to business enquiries;
maintaining appropriate business records; and
protecting our legal and commercial interests.
We may process information when necessary to comply with applicable laws, regulations, court orders or lawful requests from competent authorities.
You may voluntarily subscribe to the Astro Wallenius newsletter by providing your name and email address and giving the requested marketing consent.
Where marketing is based on consent, you may withdraw that consent at any time.
You can unsubscribe by:
using the unsubscribe link contained in a marketing email; or
contacting us at contact@astrowallenius.com.
After you unsubscribe, we may retain limited information necessary to record your opt-out and ensure that further marketing communications are not sent contrary to your preference.
Withdrawing marketing consent does not prevent us from sending administrative or transactional communications where these are otherwise necessary and lawful.
The Website uses cookies and similar technologies.
Cookies may include:
These cookies are required for essential Website functionality, security, consent management or other services specifically requested by the visitor.
Where enabled, analytics technologies help us understand Website traffic, visitor interactions and Website performance.
These may remember preferences or provide enhanced Website functionality.
Where used, these technologies may help measure campaigns or provide relevant communications or advertising.
Where applicable law requires consent, non-essential cookies will only be activated after you have provided the relevant consent through our cookie-consent mechanism.
You may accept, reject or manage non-essential cookies through the Website’s cookie settings.
Withdrawing cookie consent will not affect the lawfulness of processing that occurred before consent was withdrawn.
Browser settings may also allow you to delete or block cookies, although doing so may affect Website functionality.
We do not sell your personal data.
We may disclose personal data where reasonably necessary to:
Website hosting and infrastructure providers;
IT, cybersecurity and technical-support providers;
email and newsletter service providers;
analytics and Website measurement providers;
professional advisers such as lawyers, accountants, auditors and consultants;
companies providing administrative or business-support services;
competent courts, regulators, law-enforcement agencies or governmental authorities where disclosure is legally required;
potential purchasers, investors, counterparties or professional advisers in connection with a legitimate corporate transaction; or
other persons where you have requested or authorised the disclosure.
Service providers processing personal data on our behalf are expected to process it only for authorised purposes and to apply appropriate confidentiality and security protections.
Astro Wallenius is established in the United Arab Emirates, and personal data submitted through the Website may therefore be processed in the UAE.
Some of our technology or service providers may process information in other countries.
Where international transfers of personal data are subject to legal restrictions, we will take reasonable measures required by applicable data-protection law.
Where the GDPR applies to a transfer requiring safeguards, these measures may include, where appropriate:
an applicable adequacy decision;
European Commission Standard Contractual Clauses;
contractual and organisational safeguards;
supplementary technical measures; or
another lawful transfer mechanism permitted under the GDPR.
We retain personal data only for as long as reasonably necessary for the purposes for which it was collected and to satisfy applicable legal, regulatory, contractual, accounting or dispute-resolution requirements.
Retention periods depend on the nature and purpose of the information.
For example:
newsletter information may be retained for as long as you remain subscribed;
marketing opt-out records may be retained as necessary to respect your preference;
Website enquiries and correspondence may be retained for a reasonable period after the enquiry has been resolved;
technical and analytics information is retained according to the applicable cookie or service configuration; and
legal, contractual or compliance records may be retained for longer periods where required or justified by applicable law.
When personal data is no longer required, we will take reasonable steps to delete, anonymise or otherwise securely dispose of it.
Depending on the applicable law and circumstances, you may have rights concerning your personal data.
These may include the right to:
request information about how your personal data is processed;
request access to personal data held about you;
request correction of inaccurate or incomplete information;
request deletion of personal data in appropriate circumstances;
request restriction of processing;
object to certain forms of processing;
withdraw consent where processing is based on consent;
request transfer or portability of personal data where applicable;
object to certain automated processing or profiling where applicable; and
lodge a complaint with an appropriate data-protection authority.
These rights are not absolute and may be subject to legal exceptions.
To exercise a privacy right, please contact:
Please include sufficient information for us to identify the relevant records and understand your request.
We may request reasonable proof of identity before responding in order to protect personal data from unauthorised disclosure.
Where the GDPR applies to our processing of your personal data, you may have the rights provided under Articles 15–22 of the GDPR, including rights of:
access;
rectification;
erasure;
restriction;
portability;
objection; and
protection in relation to certain solely automated decisions.
Where we rely on legitimate interests for processing, you may have the right to object based on circumstances relating to your particular situation.
Where personal data is processed for direct marketing purposes, you may object to such processing at any time.
You also have the right to lodge a complaint with the competent data-protection supervisory authority in your EU or EEA country of residence, place of work or the place of an alleged infringement.
We encourage you to contact us first if you have a concern so that we can attempt to resolve it promptly.
The Website is not intended to make decisions about visitors based solely on automated processing that produce legal effects or similarly significant effects.
If this changes, we will provide any additional information required under applicable law.
We take reasonable technical and organisational measures designed to protect personal data against:
unauthorised access;
loss;
misuse;
alteration;
accidental destruction; and
unauthorised disclosure.
Measures may include access controls, system-security protections, secure communications, backups, authentication procedures and appropriate restrictions on access to personal information.
However, no online system or method of electronic storage can be guaranteed to be completely secure.
The Website may contain links to websites, platforms or services operated by third parties.
We do not control the privacy practices of independent third parties and this Policy does not apply to their websites or services.
We recommend reviewing the privacy information provided by those third parties before providing them with personal data.
The Website and the services promoted through it are intended for adults and are not directed toward children.
We do not knowingly seek to collect personal data from persons under 18 through the Website.
If we become aware that personal information concerning a child has been collected inappropriately, we will take reasonable steps to delete or otherwise address that information in accordance with applicable law.
We may update this Privacy & Data Protection Policy from time to time to reflect:
changes to our Website;
changes to our processing activities;
changes to service providers;
changes to applicable law or regulatory guidance; or
operational or security requirements.
The latest version will be published on this page together with the date on which it was last updated.
Where a change materially affects how personal data is processed, we will provide additional notice where required by law.
Questions, concerns or requests concerning personal data or this Privacy & Data Protection Policy may be sent to:
ASTRO WALLENIUS L.L.C-FZ
Meydan Grandstand, 6th Floor
Meydan Road, Nad Al Sheba
Dubai, United Arab Emirates
Email: contact@astrowallenius.com
