PRIVACY POLICY
Effective Date: 16 October 2026
1. Introduction
The Sapphire Circle respects the privacy of its website visitors, membership applicants, members, event participants, business partners and other individuals who interact with our services. As an international business community, we recognize that confidentiality and responsible handling of personal information are essential to maintaining trusted professional relationships.
This Privacy Policy explains how personal information is collected, used, stored, processed, disclosed and protected in connection with our website, membership application process, community services, events, communications and associated business activities.
The Sapphire Circle is a brand operated by Dunevia Global Marketing Management LLC, a company registered in Dubai, United Arab Emirates (the “Operator”, “we”, “us” or “our”). Unless otherwise indicated, the Operator is the controller responsible for determining the purposes and means of processing personal information collected through The Sapphire Circle.
We process personal information in accordance with applicable data protection requirements, including relevant legislation of the United Arab Emirates and, where applicable, the European Union General Data Protection Regulation (GDPR), the UK GDPR and other applicable privacy laws.
This Privacy Policy explains how personal information is collected, used, stored, processed, disclosed and protected in connection with our website, membership application process, community services, events, communications and associated business activities.
The Sapphire Circle is a brand operated by Dunevia Global Marketing Management LLC, a company registered in Dubai, United Arab Emirates (the “Operator”, “we”, “us” or “our”). Unless otherwise indicated, the Operator is the controller responsible for determining the purposes and means of processing personal information collected through The Sapphire Circle.
We process personal information in accordance with applicable data protection requirements, including relevant legislation of the United Arab Emirates and, where applicable, the European Union General Data Protection Regulation (GDPR), the UK GDPR and other applicable privacy laws.
2. Personal Information We Collect
We may collect personal information when individuals visit our website, submit membership enquiries or applications, communicate with our representatives, register for events or participate in community activities.
This information may include full names, email addresses, telephone numbers, countries of residence, company names, professional titles, industries, business interests, professional backgrounds and other details voluntarily provided through website forms, membership applications or correspondence.
For applicants and members, we may also process information relating to application status, membership categories, membership activation dates, participation history, communication preferences, invoices, bank transfer payment confirmations and relevant records of interactions with our team.
Where reasonably necessary and legally permitted, we may request additional information for identity verification, professional eligibility assessment, compliance or the provision of specific services.
Our website may collect technical information, including IP addresses, browser and device characteristics, website interactions and information obtained through cookies or similar technologies where used.
We aim to collect only personal information that is reasonably necessary for specific, legitimate and disclosed purposes.
This information may include full names, email addresses, telephone numbers, countries of residence, company names, professional titles, industries, business interests, professional backgrounds and other details voluntarily provided through website forms, membership applications or correspondence.
For applicants and members, we may also process information relating to application status, membership categories, membership activation dates, participation history, communication preferences, invoices, bank transfer payment confirmations and relevant records of interactions with our team.
Where reasonably necessary and legally permitted, we may request additional information for identity verification, professional eligibility assessment, compliance or the provision of specific services.
Our website may collect technical information, including IP addresses, browser and device characteristics, website interactions and information obtained through cookies or similar technologies where used.
We aim to collect only personal information that is reasonably necessary for specific, legitimate and disclosed purposes.
3. Membership Applications and Enquiries
When an individual submits an application or enquiry through The Sapphire Circle website, the information provided is used to review the submission, assess eligibility, understand professional interests and determine whether membership may be appropriate.
Our authorized representatives may contact applicants by email, telephone or other suitable channels to clarify application details, discuss membership categories, explain relevant conditions and communicate the outcome of the review.
Submitting an application does not guarantee acceptance into The Sapphire Circle and does not automatically establish a membership relationship. Personal information relating to unsuccessful or incomplete applications may be retained for an appropriate period where supported by a valid purpose and legal basis.
The processing of information for application review and related communications is separate from optional direct marketing activities. Submission of an application does not constitute unrestricted consent to unrelated marketing communications.
Our authorized representatives may contact applicants by email, telephone or other suitable channels to clarify application details, discuss membership categories, explain relevant conditions and communicate the outcome of the review.
Submitting an application does not guarantee acceptance into The Sapphire Circle and does not automatically establish a membership relationship. Personal information relating to unsuccessful or incomplete applications may be retained for an appropriate period where supported by a valid purpose and legal basis.
The processing of information for application review and related communications is separate from optional direct marketing activities. Submission of an application does not constitute unrestricted consent to unrelated marketing communications.
4. How We Use Personal Information
We may process personal information to assess membership applications, verify eligibility, contact applicants, confirm membership status, administer memberships, arrange events, provide member privileges, coordinate requested business introductions and respond to enquiries.
We may also use information to maintain professional relationships, manage records, administer invoices and bank transfer confirmations, coordinate with authorized partners, improve our services, maintain website security and comply with applicable legal requirements.
Where permitted by applicable law and supported by the necessary consent or another lawful basis, personal information may be used to communicate newsletters, invitations, community news, relevant business updates, events and information about The Sapphire Circle’s services and opportunities.
Information may also be processed for legitimate internal administration, legal compliance, fraud prevention, dispute management and the establishment, exercise or defence of legal claims where legally permitted.
We may also use information to maintain professional relationships, manage records, administer invoices and bank transfer confirmations, coordinate with authorized partners, improve our services, maintain website security and comply with applicable legal requirements.
Where permitted by applicable law and supported by the necessary consent or another lawful basis, personal information may be used to communicate newsletters, invitations, community news, relevant business updates, events and information about The Sapphire Circle’s services and opportunities.
Information may also be processed for legitimate internal administration, legal compliance, fraud prevention, dispute management and the establishment, exercise or defence of legal claims where legally permitted.
5. Legal Basis for Processing
The legal basis for processing personal information depends on the nature of the information, the specific processing purpose and the legislation applicable to the relevant activity.
Where permitted by applicable law, personal information may be processed when necessary to take steps requested before entering into a membership agreement, perform contractual obligations, comply with legal requirements, pursue recognized legitimate interests subject to appropriate safeguards, or carry out processing otherwise expressly permitted by law.
Where consent is legally required, including for certain direct marketing or optional tracking activities, we will request valid consent before undertaking the relevant processing.
Individuals may withdraw consent at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal or processing that remains permitted or necessary under another applicable legal basis.
Where permitted by applicable law, personal information may be processed when necessary to take steps requested before entering into a membership agreement, perform contractual obligations, comply with legal requirements, pursue recognized legitimate interests subject to appropriate safeguards, or carry out processing otherwise expressly permitted by law.
Where consent is legally required, including for certain direct marketing or optional tracking activities, we will request valid consent before undertaking the relevant processing.
Individuals may withdraw consent at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal or processing that remains permitted or necessary under another applicable legal basis.
6. Marketing Communications and Newsletters
The Sapphire Circle may provide website visitors, applicants and members with the opportunity to subscribe to newsletters and receive community updates, invitations to selected events, news and information concerning relevant activities and business opportunities.
Where required by applicable law, promotional communications will be sent only after valid consent has been obtained. Consent is voluntary and is not a condition of submitting a membership application or obtaining services that do not require such communications.
Individuals may withdraw marketing consent at any time by using an unsubscribe mechanism included in our marketing emails or by contacting [email protected].
We may maintain records of consent, communication preferences and withdrawal requests to ensure that marketing activities reflect individual choices and applicable legal requirements.
Withdrawal of marketing consent does not prevent us from sending communications necessary to review a pending application, administer an active membership, confirm an event registration or respond to a service request.
Marketing communications conducted independently by another affiliated company will be subject to that entity’s own applicable transparency and lawful-basis requirements, including any additional consent required by law.
Where required by applicable law, promotional communications will be sent only after valid consent has been obtained. Consent is voluntary and is not a condition of submitting a membership application or obtaining services that do not require such communications.
Individuals may withdraw marketing consent at any time by using an unsubscribe mechanism included in our marketing emails or by contacting [email protected].
We may maintain records of consent, communication preferences and withdrawal requests to ensure that marketing activities reflect individual choices and applicable legal requirements.
Withdrawal of marketing consent does not prevent us from sending communications necessary to review a pending application, administer an active membership, confirm an event registration or respond to a service request.
Marketing communications conducted independently by another affiliated company will be subject to that entity’s own applicable transparency and lawful-basis requirements, including any additional consent required by law.
7. Customer Relationship Management — Bitrix24
The Sapphire Circle uses Bitrix24, including version 26.0.0, as a customer relationship management (CRM) system to organize and administer membership applications, enquiries, professional contacts, communications, membership records and other related operational activities.
Information submitted through our website may be transmitted to and stored within our CRM system so that authorized representatives can review applications, manage communications, record membership decisions and administer relevant services.
Our CRM platform and its applicable hosting, infrastructure or technology service providers may process information in connection with these services, subject to relevant contractual, confidentiality, security and data protection arrangements.
Access to CRM records is restricted according to authorized business responsibilities and legitimate processing purposes.
The location of data hosting and processing depends on the actual Bitrix24 deployment and service arrangements. Where personal information is processed internationally, the relevant legal requirements and transfer safeguards will apply.
Information submitted through our website may be transmitted to and stored within our CRM system so that authorized representatives can review applications, manage communications, record membership decisions and administer relevant services.
Our CRM platform and its applicable hosting, infrastructure or technology service providers may process information in connection with these services, subject to relevant contractual, confidentiality, security and data protection arrangements.
Access to CRM records is restricted according to authorized business responsibilities and legitimate processing purposes.
The location of data hosting and processing depends on the actual Bitrix24 deployment and service arrangements. Where personal information is processed internationally, the relevant legal requirements and transfer safeguards will apply.
8. Sharing Information with Service Providers and Affiliated Entities
We may share relevant personal information with authorized service providers, professional advisers, event organizers, selected commercial partners and affiliated business entities where necessary for legitimate, disclosed purposes and permitted by applicable law.
Such purposes may include membership administration, customer relationship management, website operations, technology support, event coordination, professional services, business communications and requested member introductions.
Personal information may be processed by affiliated entities involved in relevant administrative, operational or technical support. Such access does not automatically authorize those entities to use the information for independent marketing or unrelated purposes.
Where an individual requests access to a third-party service, partner privilege, event or business introduction, relevant personal information may be disclosed to the provider or participant to the extent necessary to facilitate that request.
We may also disclose personal information to professional advisers, auditors, legal representatives or competent public authorities where such disclosure is legally required or otherwise permitted.
We apply appropriate contractual, organizational and technical safeguards to the sharing of personal information where required. Where another organization acts as an independent or joint controller, its identity, processing purposes and other legally required information will be made available through appropriate privacy notices.
Such purposes may include membership administration, customer relationship management, website operations, technology support, event coordination, professional services, business communications and requested member introductions.
Personal information may be processed by affiliated entities involved in relevant administrative, operational or technical support. Such access does not automatically authorize those entities to use the information for independent marketing or unrelated purposes.
Where an individual requests access to a third-party service, partner privilege, event or business introduction, relevant personal information may be disclosed to the provider or participant to the extent necessary to facilitate that request.
We may also disclose personal information to professional advisers, auditors, legal representatives or competent public authorities where such disclosure is legally required or otherwise permitted.
We apply appropriate contractual, organizational and technical safeguards to the sharing of personal information where required. Where another organization acts as an independent or joint controller, its identity, processing purposes and other legally required information will be made available through appropriate privacy notices.
9. Corporate Transactions and Business Transfers
Personal information may be disclosed or transferred where reasonably necessary in connection with an actual or proposed merger, acquisition, restructuring, financing arrangement, transfer of business activities or sale of relevant business assets.
Any such disclosure or transfer will be conducted in accordance with applicable data protection requirements, confidentiality obligations and appropriate safeguards.
Where a business transaction materially changes how personal information will be used, affected individuals will receive any additional notice or choices required by law. Additional consent will be obtained where necessary.
The transfer of business activities does not automatically authorize the recipient to use personal information for unrelated marketing or other incompatible purposes.
We do not sell personal information as an independent marketing database without an appropriate legal basis and compliance with applicable privacy and direct marketing requirements.
Any such disclosure or transfer will be conducted in accordance with applicable data protection requirements, confidentiality obligations and appropriate safeguards.
Where a business transaction materially changes how personal information will be used, affected individuals will receive any additional notice or choices required by law. Additional consent will be obtained where necessary.
The transfer of business activities does not automatically authorize the recipient to use personal information for unrelated marketing or other incompatible purposes.
We do not sell personal information as an independent marketing database without an appropriate legal basis and compliance with applicable privacy and direct marketing requirements.
10. International Data Transfers
The Sapphire Circle operates internationally and may use technology providers, professional advisers, business partners and affiliated entities located in different jurisdictions.
Accordingly, personal information may be accessed, stored or processed outside the United Arab Emirates depending on the systems, providers and services used.
Where international transfers are subject to legal restrictions, we will implement the required safeguards or rely on another legally permitted transfer mechanism. These may include appropriate contractual arrangements, recognized adequacy mechanisms or other legally accepted protections.
Further information concerning relevant international transfer arrangements may be requested through our contact details.
Accordingly, personal information may be accessed, stored or processed outside the United Arab Emirates depending on the systems, providers and services used.
Where international transfers are subject to legal restrictions, we will implement the required safeguards or rely on another legally permitted transfer mechanism. These may include appropriate contractual arrangements, recognized adequacy mechanisms or other legally accepted protections.
Further information concerning relevant international transfer arrangements may be requested through our contact details.
11. Data Security and Confidentiality
We take reasonable technical and organizational measures designed to protect personal information against unauthorized access, accidental loss, alteration, unlawful disclosure and misuse.
Access to information is limited to authorized personnel and service providers who require access for legitimate business or operational purposes. Appropriate confidentiality and security safeguards are applied according to the nature of the information and the processing activities involved.
Although reasonable precautions are taken, no electronic communications system or storage environment can be guaranteed to be completely secure.
Where a personal data security incident occurs, we will take the actions and provide any notifications required by applicable law.
Access to information is limited to authorized personnel and service providers who require access for legitimate business or operational purposes. Appropriate confidentiality and security safeguards are applied according to the nature of the information and the processing activities involved.
Although reasonable precautions are taken, no electronic communications system or storage environment can be guaranteed to be completely secure.
Where a personal data security incident occurs, we will take the actions and provide any notifications required by applicable law.
12. Data Retention
We retain personal information only for as long as reasonably necessary to fulfil the purposes for which it was collected, administer membership relationships, respond to enquiries, maintain relevant business records and satisfy applicable legal, accounting or regulatory requirements.
Retention periods may vary depending on the type of information, the status of a membership application, the duration of membership, the nature of the relationship and any applicable legal or contractual requirements.
Information relating to unsuccessful or incomplete membership applications will not be retained indefinitely without a lawful purpose. Where an individual withdraws marketing consent, we will stop the relevant communications and may retain limited records necessary to demonstrate compliance and prevent further unwanted contact.
When personal information is no longer required, it will be securely deleted, anonymized or otherwise handled in accordance with applicable law.
Retention periods may vary depending on the type of information, the status of a membership application, the duration of membership, the nature of the relationship and any applicable legal or contractual requirements.
Information relating to unsuccessful or incomplete membership applications will not be retained indefinitely without a lawful purpose. Where an individual withdraws marketing consent, we will stop the relevant communications and may retain limited records necessary to demonstrate compliance and prevent further unwanted contact.
When personal information is no longer required, it will be securely deleted, anonymized or otherwise handled in accordance with applicable law.
13. Cookies and Website Analytics
Our website may use cookies and similar technologies to support essential functionality, website security, performance measurement and improvements to the user experience.
Certain technologies may be provided by third-party hosting, analytics or other website service providers. Information collected through these technologies may include technical identifiers, website usage information and browser or device characteristics.
Where required by applicable law, non-essential cookies and tracking technologies will be activated only after the required information and consent have been provided.
Visitors may manage available cookie preferences through website controls or compatible browser settings. Further information about the technologies actually used may be provided through a separate Cookie Notice or consent management interface.
Certain technologies may be provided by third-party hosting, analytics or other website service providers. Information collected through these technologies may include technical identifiers, website usage information and browser or device characteristics.
Where required by applicable law, non-essential cookies and tracking technologies will be activated only after the required information and consent have been provided.
Visitors may manage available cookie preferences through website controls or compatible browser settings. Further information about the technologies actually used may be provided through a separate Cookie Notice or consent management interface.
14. Individual Privacy Rights
Depending on applicable law, individuals may have the right to request access to personal information, correction of inaccurate or incomplete records, deletion, restriction of certain processing activities, withdrawal of consent or objection to direct marketing.
Additional rights may include data portability, obtaining information concerning certain disclosures or international transfers, and submitting complaints to a competent data protection authority.
Requests relating to personal information may be submitted to [email protected]. We may request reasonable verification of identity before responding to certain requests and will respond within the periods required by applicable law.
Certain requests may be subject to lawful exceptions, including obligations to retain information, comply with regulations or protect legitimate legal rights.
Additional rights may include data portability, obtaining information concerning certain disclosures or international transfers, and submitting complaints to a competent data protection authority.
Requests relating to personal information may be submitted to [email protected]. We may request reasonable verification of identity before responding to certain requests and will respond within the periods required by applicable law.
Certain requests may be subject to lawful exceptions, including obligations to retain information, comply with regulations or protect legitimate legal rights.
15. Member Privacy and Professional Confidentiality
The Sapphire Circle recognizes that discretion and confidentiality are important within a trusted international business community.
Membership applications, individual membership status, personal contact details and private business information will not be made publicly available merely because an individual has submitted an application or has been accepted as a member.
Member information may be used to administer appropriate community services and facilitate requested interactions, subject to applicable privacy requirements and individual choices.
Where member directories, public profiles, testimonials, photography, video recordings or promotional materials are offered, appropriate notices and permissions will be obtained where required.
Members and participants are expected to respect the privacy of others and refrain from unauthorized disclosure or commercial use of information obtained through private community activities.
Membership applications, individual membership status, personal contact details and private business information will not be made publicly available merely because an individual has submitted an application or has been accepted as a member.
Member information may be used to administer appropriate community services and facilitate requested interactions, subject to applicable privacy requirements and individual choices.
Where member directories, public profiles, testimonials, photography, video recordings or promotional materials are offered, appropriate notices and permissions will be obtained where required.
Members and participants are expected to respect the privacy of others and refrain from unauthorized disclosure or commercial use of information obtained through private community activities.
16. Third-Party Websites and Services
Our website and communications may contain links to external websites, event platforms, partner businesses and other third-party services.
Independent providers may collect and process information according to their own terms and privacy policies.
Their independent data processing activities are not governed by this Privacy Policy. We encourage individuals to review the applicable privacy information before submitting personal details to external services.
Independent providers may collect and process information according to their own terms and privacy policies.
Their independent data processing activities are not governed by this Privacy Policy. We encourage individuals to review the applicable privacy information before submitting personal details to external services.
17. Children’s Privacy
The Sapphire Circle is intended for individuals aged 18 or older and does not knowingly solicit membership applications from minors.
Where we become aware that personal information has been collected from a minor without an appropriate lawful basis, we will take reasonable steps to address the matter in accordance with applicable law.
Where we become aware that personal information has been collected from a minor without an appropriate lawful basis, we will take reasonable steps to address the matter in accordance with applicable law.
18. Changes to This Privacy Policy
We may periodically update this Privacy Policy to reflect changes in our membership services, operational processes, technology systems, data protection requirements or other relevant activities.
The latest version will be published on our official website with its effective date. Where changes materially affect how personal information is processed, we will provide any additional notice or obtain any consent required under applicable law.
The latest version will be published on our official website with its effective date. Where changes materially affect how personal information is processed, we will provide any additional notice or obtain any consent required under applicable law.
19. Contact and Privacy Enquiries
For questions concerning this Privacy Policy, the processing of personal information, marketing preferences or requests to exercise applicable privacy rights, please contact:
The Sapphire Circle
Operated by Dunevia Global Marketing Management LLC
Office No. 1709, Malk Samar Mohammed Al Ad, Business Bay, Bur Dubai, Dubai, United
Arab Emirates
Trade Licence Number: 1000768
VAT Registration Number (TRN): 104173600800003
Email: [email protected]
Telephone: +971 58 805 7060
Website: www.thesapphirecircle.com
Where applicable, individuals may also contact the competent data protection supervisory
authority.
THE SAPPHIRE CIRCLE
Based in Dubai. Connected globally.
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