Privacy Policy

Effective Date: 11th October 2025

Last Updated: 11th October 2025

Your Privacy Matters: This Privacy Policy explains how Elite Byblos Hotel (“we,” “us,” “our,” or “the Hotel”) collects, uses, stores, and protects your personal data when you use our Wi-Fi captive portal, website, and social sign-in services (Facebook and Instagram Login via Meta).

1. Who We Are

Elite Byblos Hotel

Address: Behind Mall of the Emirates, Al Barsha 1, Dubai, United Arab Emirates

Contact: info@elitebybloshotel.com

Website: elitebybloshotel.com

2. Data We Collect

2.1 Wi-Fi Captive Portal & Social Sign-In (Meta/Facebook/Instagram)

When you sign in to access our hotel Wi-Fi network using Facebook or Instagram Login, we collect:

• Name: Your full name as provided by Meta/Facebook
• Email Address: Your email address associated with your Facebook or Instagram account

Purpose: To authenticate your access to the hotel Wi-Fi network and to send you promotional messages, special offers, and marketing communications about our hotel services.

Note: Our Meta app only requests your name and email. We do not collect profile pictures, friends lists, posts, or any other Facebook/Instagram data.

2.2 Automatically Collected Website Data

When you visit our website or use the captive portal, the following data is automatically collected via analytics tools:

• IP address
• Device type and model
• Browser type and version
• Operating system
• Referring URLs (the website you came from)
• Pages visited and time spent on each page
• Clickstream data and user interactions

Tools Used: Google Analytics and Microsoft Clarity

Purpose: To analyze website performance, understand user behavior, improve user experience, and optimize our website and Wi-Fi portal.

3. Legal Basis for Processing

We process your personal data under the following legal bases as required by the UAE Personal Data Protection Law (Federal Decree-Law No. 45 of 2021) and, where applicable, the EU General Data Protection Regulation (GDPR) for guests from the European Union:

• Consent: By signing in via Facebook/Instagram and accepting this Privacy Policy, you explicitly consent to our collection and use of your name and email address.
• Legitimate Interests: Processing is necessary for our legitimate business interests in operating a secure Wi-Fi network, improving our services, and marketing our hotel offerings, provided your rights and freedoms are not overridden.
• Legal Obligation: We may process data to comply with applicable UAE laws and regulations.

4. How We Use Your Data

We use your personal data for the following purposes:

• Wi-Fi Access: To authenticate and provide you with internet access during your stay
• Marketing Communications: To send you promotional emails, special offers, newsletters, and information about our hotel services, events, and packages
• Service Improvement: To analyze usage patterns and improve our Wi-Fi network, website, and guest experience
• Security: To maintain the security and integrity of our network and prevent unauthorized access
• Legal Compliance: To comply with legal obligations and respond to lawful requests from authorities

5. Data Retention

Storage Period: We retain your name and email address for 2 years from the date of collection or your last interaction with our services, whichever is later.

After 2 Years: Your data will be automatically deleted or anonymized unless we are required by law to retain it for a longer period.

Analytics Data: Google Analytics data is retained for 26 months, and Microsoft Clarity data is retained according to their default retention policies (typically 30-90 days for session recordings).

6. Third-Party Services & Data Sharing

6.1 Meta/Facebook/Instagram

When you use Facebook or Instagram Login, Meta provides us with your name and email. Your interaction with Meta is governed by Meta’s Data Policy.

6.2 Google Analytics

We use Google Analytics to track and analyze website usage. Google may collect cookies and usage data. Learn more: Google Privacy Policy

Opt-Out: Install the Google Analytics Opt-out Browser Add-on

6.3 Microsoft Clarity

We use Microsoft Clarity to understand how users interact with our website through session recordings and heatmaps. Microsoft may collect behavioral data and device information. Learn more: Microsoft Privacy Statement

Opt-Out: Adjust your preferences via Microsoft’s privacy controls or use browser settings to block tracking cookies.

6.4 Other Third Parties

We do not sell, rent, or trade your personal data to third parties. We may share your data with:

• Service Providers: Trusted vendors who assist with email marketing, IT support, and analytics (under strict confidentiality agreements)
• Legal Authorities: When required by law, court order, or governmental regulation

7. International Data Transfers

Your personal data may be transferred to and processed in countries outside the UAE, including:

• United States: Google (Analytics) and Meta (Facebook/Instagram) are based in the U.S.
• European Union: Microsoft (Clarity) processes data in EU data centers.

Safeguards: These companies participate in recognized data protection frameworks (e.g., EU-U.S. Data Privacy Framework, Standard Contractual Clauses) to ensure adequate protection. Where data is transferred to countries without adequate protection under UAE PDPL, we rely on your explicit consent or other appropriate safeguards.

8. Your Data Subject Rights

Under the UAE Personal Data Protection Law and GDPR (for EU residents), you have the following rights:

• Right to Access: Request a copy of the personal data we hold about you
• Right to Rectification: Request correction of inaccurate or incomplete data
• Right to Erasure (Right to be Forgotten): Request deletion of your personal data (see Section 9 below)
• Right to Restriction: Request that we limit how we use your data
• Right to Data Portability: Receive your data in a structured, machine-readable format
• Right to Object: Object to processing based on legitimate interests, including marketing communications
• Right to Withdraw Consent: Withdraw your consent at any time (this does not affect the lawfulness of processing prior to withdrawal)
• Right to Lodge a Complaint: File a complaint with the UAE Data Office or your local supervisory authority (for EU residents)

To Exercise Your Rights: Email us at info@elitebybloshotel.com or visit our Data Deletion Instructions page.

Response Time: We will respond to your request within 30 days.

9. Data Deletion Requests (Facebook/Instagram Users)

If you signed in via Facebook or Instagram and wish to delete the data we received from Meta, you can:

1. Go to your Facebook Settings → Apps and Websites → Remove EBH
2. Or visit our dedicated Data Deletion Instructions page for detailed steps

What Gets Deleted: Your name and email address collected via Meta Login will be permanently deleted within 30 days.

10. Cookies & Tracking Technologies

We use cookies and similar technologies to:

• Remember your consent preferences
• Enable social sign-in functionality
• Collect analytics data (Google Analytics, Microsoft Clarity)

Cookie Consent: When you first visit our website, you will see a cookie consent banner. By clicking “I Agree,” you consent to our use of cookies as described in this policy.

Managing Cookies: You can control or delete cookies through your browser settings. Note that disabling cookies may affect website functionality.

11. Data Security

We implement appropriate technical and organizational measures to protect your personal data from unauthorized access, loss, misuse, or alteration, including:

• Secure HTTPS encryption for data transmission
• Access controls and authentication mechanisms
• Regular security assessments and updates
• Secure storage and limited access to personal data

Data Breach Notification: In the event of a data breach that poses a risk to your rights, we will notify you and the UAE Data Office within 72 hours as required by UAE PDPL.

12. Children’s Privacy

Our services are not directed to individuals under the age of 18. We do not knowingly collect personal data from children. If we become aware that we have collected data from a child, we will delete it promptly.

13. Marketing Communications & Opt-Out

We may use your email address to send you promotional messages, special offers, and newsletters about our hotel services.

How to Opt-Out:

• Email us at info@elitebybloshotel.com with the subject line “Unsubscribe”
• Contact the front desk during your stay

Important: Even if you opt out of marketing emails, we may still send you service-related communications (e.g., Wi-Fi access confirmations, security alerts).

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or technology. The “Last Updated” date at the top of this page indicates when the policy was last revised.

How We Notify You: Significant changes will be communicated by displaying a prominent notice on this page.

15. Governing Law & Jurisdiction

This Privacy Policy is governed by the laws of the United Arab Emirates, specifically the UAE Personal Data Protection Law (Federal Decree-Law No. 45 of 2021). For guests from the European Union, GDPR provisions shall also apply where relevant.

Dispute Resolution: Any disputes arising from this Privacy Policy shall be resolved in the courts of Dubai, UAE.

16. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or how we handle your personal data, please contact us:

Elite Byblos Hotel
Behind Mall of the Emirates, Al Barsha 1,
Dubai, United Arab Emirates
Email: info@elitebybloshotel.com
Phone: +971 4 455 4800