Privacy Policy
Last updated: 31 May 2026 - Version 1.0
1. Who we are (Data Controller)
The controller of your personal data is WL Group Management Consultancy L.L.C-FZ, a Free Zone company incorporated in the United Arab Emirates, Trade Licence No. 2416549.01, registered office Meydan Grandstand, 6th floor, Meydan Road, Nad Al Sheba, Dubai, U.A.E. ("we", "us").
Email: legal@w-l.group.
EU representative (GDPR Art. 27): GRACE srl, Via del Progresso 410, 88046 Lamezia Terme (CZ), Italy, contact: legal@w-l.group.
We have not appointed a Data Protection Officer, as we are not required to do so under Article 37 GDPR.
2. What data we collect, why, and on what legal basis
(a) Contact by email. If you email us or use a contact link, we process your name, email address and the content of your message. Purpose: to respond to your enquiry. Legal basis: our legitimate interest in responding to enquiries and, where your message concerns a possible engagement, the taking of steps at your request prior to entering a contract (Art. 6(1)(f) and Art. 6(1)(b) GDPR).
(b) Booking a call (Calendly). When you book a call we process your name, email address, the selected time slot, and any other information you enter in the booking form. Purpose: to schedule and hold the meeting you requested. Legal basis: the taking of steps at your request prior to entering a contract (Art. 6(1)(b) GDPR). Bookings are handled by Calendly (see Section 6).
(c) Website analytics. We use Plausible Analytics, a privacy-friendly analytics tool that does NOT use cookies, does NOT collect personal data and does NOT create persistent identifiers or cross-site profiles. Data is aggregated and processed on EU-based servers and is not transferred outside the EEA. Because no personal data is processed and no information is stored on or read from your device, no consent is required and we display no cookie banner for analytics. Legal basis: our legitimate interest in understanding aggregate site traffic (Art. 6(1)(f) GDPR), to the extent any data is personal.
(d) Newsletter (optional). If you subscribe, we process your name and email address to send you our newsletter. Legal basis: your consent (Art. 6(1)(a) GDPR), collected via the signup form (single opt-in). You can unsubscribe at any time via the link in every email or by emailing us; withdrawal does not affect prior processing. Our newsletter is sent via Brevo (Sendinblue), a provider headquartered in France with data hosted in the EU.
3. Retention periods
- Email/contact enquiries: kept for as long as needed to handle your request and then for up to 24 months, unless an ongoing relationship or legal claim requires longer.
- Calendly booking data: kept for the duration of the scheduling relationship and deleted or anonymised within 12 months of the meeting unless it forms part of a client relationship.
- Analytics: Plausible, aggregated, no personal data retained at individual level.
- Newsletter: kept until you unsubscribe or withdraw consent, after which your address is removed from the active list within 30 days (a suppression record may be kept to honour your opt-out).
4. Your rights
Under the GDPR you have the right to: access your data (Art. 15); rectification (Art. 16); erasure (Art. 17); restriction of processing (Art. 18); data portability (Art. 20); and to object to processing based on legitimate interests (Art. 21). Where processing is based on consent, you may withdraw consent at any time without affecting the lawfulness of prior processing (Art. 7(3)). To exercise any right, email us at legal@w-l.group. We will respond within one month.
5. Right to lodge a complaint
You may lodge a complaint with a supervisory authority, in particular in the EU Member State of your residence or where the alleged infringement occurred. For users in Italy: Garante per la protezione dei dati personali, Piazza Venezia 11, 00187 Roma, www.garanteprivacy.it. Given that our founder is resident in Poland, the Urzad Ochrony Danych Osobowych (UODO), ul. Stawki 2, 00-193 Warszawa, uodo.gov.pl, may also be a competent authority.
6. Third-party processors and recipients
- Calendly LLC (USA), scheduling. Privacy notice: https://calendly.com/legal/privacy-notice. Transfers to the US are governed by Calendly's Data Processing Addendum, which relies on the EU-US Data Privacy Framework and incorporates the EU Standard Contractual Clauses (Module 2) as a fallback.
- Plausible Insights OU (Estonia, EU), analytics, EU-hosted (servers in Germany); no transfer outside the EEA. Privacy: https://plausible.io/privacy.
- Brevo (Sendinblue SA, France, EU), newsletter, EU-hosted.
- Lovable (Lovable Cloud), EU region, website hosting.
7. International transfers
We are established in the United Arab Emirates. The UAE is not covered by a European Commission adequacy decision under Article 45 GDPR. Where your personal data is transferred to us in the UAE, the transfer is made under appropriate safeguards within the meaning of Article 46 GDPR, namely the EU Standard Contractual Clauses. You may obtain a copy of the safeguards by contacting us at legal@w-l.group. Transfers to US-based processors (if any) rely on their EU-US Data Privacy Framework certification and/or SCCs as described in Section 6.
8. Cookies and consent
This website uses only strictly necessary technical cookies required for the site to function, which do not require consent. We do not use profiling or advertising cookies. Our analytics tool (Plausible) does not use cookies. We therefore do not display a cookie-consent banner.
9. Changes to this policy
We may update this policy. The current version and its date appear at the top. Material changes will be notified on this page.
