Data Protection Policy

Effective Date: 28 November 2025
Zabeel Star Travel and Tourism LLC (Zabeel Travel)
Website: https://zabeeltravel.ae

1. Introduction

Zabeel Star Travel and Tourism LLC (“Zabeel Travel”, “we”, “us”, or “our”) is committed to protecting the privacy and security of personal data entrusted to us by our clients, employees, partners, and service providers. This Data Protection Policy outlines how we collect, use, store, disclose, and safeguard personal information in compliance with applicable UAE data protection laws, including the UAE Personal Data Protection Law (PDPL) and other relevant regulatory frameworks.

2. Scope

This policy applies to all personal data processed by Zabeel Travel in the course of its operations—including but not limited to:

Client data (e.g., passport details, visa applications, contact information, travel itineraries)
Employee and contractor data (including offshore staff in Kenya)
Vendor and third-party service provider information

Processing may occur manually or electronically, across our offices in Dubai and through our offshore operations.

3. Lawful Basis for Processing

We process personal data only where at least one of the following lawful bases applies:

Consent (explicitly obtained where required)
Performance of a contract (e.g., visa processing, booking services)
Legal obligation (e.g., immigration reporting, financial compliance)
Legitimate interests (e.g., fraud prevention, service improvement), provided these do not override the rights of the individual.

4. Types of Personal Data Collected

We may collect and process:

Identity information (name, nationality, date of birth, passport/ID copies)
Contact details (email, phone, address)
Travel & visa-related data (itinerary, accommodation, visa type, purpose of travel)
Financial data (payment records, bank/M-Pesa transfer details — limited to necessary transactional use)
Employment data (for staff and contractors, including contractual terms and performance records)

5. Data Security Measures

We implement appropriate technical and organizational measures to protect personal data, including:

Encryption of sensitive transmissions
Access controls and role-based permissions
Secure hosting (e.g., Cloudways with hardened configurations)
Staff training on data confidentiality and incident reporting
Contractual obligations with offshore teams (including Kenya-based staff) to uphold confidentiality and UAE-aligned standards
Regular review of data handling procedures

6. Data Retention

Personal data is retained only for as long as necessary to fulfil the purpose for which it was collected, or as required by UAE law (e.g., financial records: 5 years; visa application records: minimum 2 years post-service completion). Secure deletion or anonymisation is performed upon expiry of retention periods.

7. Data Sharing and Transfers

We do not sell personal data. Limited sharing occurs only with:

Government authorities (e.g., UAE/GCC/Saudi immigration entities) as legally mandated
Third-party service providers (e.g., airlines, hotels, visa processing agents) under strict confidentiality agreements
Offshore support teams (e.g., in Kenya), bound by contractual data protection clauses and trained on privacy obligations

Cross-border transfers (e.g., to Kenya) are conducted with safeguards ensuring an adequate level of protection, in line with UAE PDPL requirements.

8. Individual Rights

Under UAE law, individuals have the right to:

Access their personal data
Request correction of inaccurate or incomplete data
Request erasure (where no legal basis for retention exists)
Withdraw consent (where processing is consent-based)
Lodge complaints with the UAE Data Office

Requests should be submitted in writing to our Data Protection Contact (below).

9. Data Protection Contact

For enquiries, complaints, or to exercise your rights, please contact:

Data Protection Officer

Zabeel Star Travel and Tourism LLC
Email: [privacy @ zabeeltravel.ae]
Phone: +971 4 355 6700
Address: Dubai, UAE

We aim to respond within 14 business days.

10. Policy Review

This policy is reviewed annually or following material changes in operations, law, or technology. Updates will be published on https://zabeeltravel.ae.