Privacy Policy

Effective date: 22 August 2025
Last updated: 20 August 2026

Red Ray Capital Management Consultancy LLC (“Red Ray Capital”, “we”, “us” or “our”) respects your privacy and is committed to handling personal data responsibly and transparently.

This Privacy Policy explains how we collect, use, disclose, store and protect personal data when you:

  • Visit www.redraycapital.com
  • Contact us by email, WhatsApp, telephone, website form or social media
  • Request a consultation
  • Enquire about property, investment or citizenship-by-investment services
  • Become a prospective or existing client
  • Provide documents or information in connection with our services
  • Interact with our advertising or website analytics

This Privacy Policy should be read together with our Cookie Policy and Website Terms and Disclaimer.

Using our website does not constitute consent to every form of data processing. Where consent is legally required, including for certain advertising, analytics or marketing activities, we will request it separately.

1. Who We Are

The organisation responsible for the personal data covered by this Privacy Policy is:

Red Ray Capital Management Consultancy LLC
RS 22, Ground Floor, Zone 3
Schon Business Park, DIP 1
Dubai, United Arab Emirates

Email: contact@redraycapital.com
WhatsApp: +971 50 719 4407
Website: www.redraycapital.com

Red Ray Capital will generally act as the data controller for personal data collected and used for its own business activities.

Independent banks, lawyers, government authorities, property professionals and other service providers may act as separate data controllers for information provided to them.

2. Personal Data We May Collect

The personal data we collect depends on how you interact with us and the services you request.

Contact and enquiry information

We may collect:

  • Full name
  • Email address
  • Telephone or WhatsApp number
  • Country of residence
  • Nationality
  • Preferred communication method
  • Information included in your enquiry
  • Consultation preferences
  • Records of communications with our team

Service and eligibility information

If you request an assessment or engage our services, we may collect information about:

  • Investment objectives
  • Preferred investment route
  • Proposed investment amount
  • Property preferences
  • Family composition
  • Intended applicants and dependants
  • Citizenship and residence history
  • Travel or relocation objectives
  • Professional and business background
  • Previous application history
  • Information required for a preliminary eligibility assessment

Identity and application documents

Where necessary for a client engagement, due-diligence review or application, we may receive:

  • Passport or identity-document information
  • Date and place of birth
  • Nationality and citizenship information
  • Residential address
  • Proof of address
  • Photographs
  • Birth, marriage, divorce or family-status documents
  • Police-clearance or background-check documents
  • Education or employment records
  • Immigration or travel records
  • Information relating to spouses, children or other dependants

Please do not submit passports, bank statements, passwords, security codes or other sensitive documents through an ordinary website form or public social-media message.

When documents are required, our team may provide appropriate instructions for transferring them.

Financial and compliance information

Depending on the service requested, we may collect:

  • General investment capacity
  • Source-of-funds and source-of-wealth information
  • Bank statements or transaction evidence
  • Property ownership or property-sale records
  • Business ownership information
  • Company documents
  • Employment or business-income evidence
  • Payment and invoicing records
  • Tax-related information
  • Due-diligence or sanctions-screening information
  • Information required by banks, advisers or government authorities

We do not ask clients to provide online-banking passwords, card security codes or authentication codes.

Website and technical information

When you visit our website, certain technical information may be collected automatically, including:

  • Internet Protocol address
  • Browser and device type
  • Operating system
  • Approximate location derived from an IP address
  • Pages visited
  • Time spent on pages
  • Referring website or campaign
  • Links or buttons clicked
  • Advertising and analytics identifiers
  • Cookie preferences
  • Website performance and diagnostic data

Marketing information

We may record:

  • Whether you agreed to receive marketing
  • Your preferred communication channels
  • Your interactions with advertisements or marketing messages
  • Your cookie and advertising preferences
  • Requests to unsubscribe or withdraw consent

3. How We Collect Personal Data

We may collect personal data:

  • Directly from you
  • Through website forms
  • Through email, WhatsApp, telephone or social media
  • During consultations or meetings
  • Through documents you provide
  • Through a family member or representative acting with appropriate authority
  • From lawyers, banks, property professionals or other parties involved in a requested service
  • From government or official sources where legally permitted
  • From publicly available corporate, professional, sanctions or compliance sources
  • Automatically through cookies, pixels and similar technologies

If you provide information concerning another person, you should ensure that you are authorised to provide it and that the individual has been informed about how their data may be used.

4. How We Use Personal Data

We may use personal data to:

  • Respond to enquiries
  • Arrange consultations
  • Understand your objectives and circumstances
  • Conduct preliminary eligibility assessments
  • Provide requested consultancy or coordination services
  • Prepare service proposals, quotations or engagement documents
  • Verify identity and supporting information
  • Conduct due-diligence, sanctions or fraud-prevention checks
  • Coordinate with lawyers, banks, property developers and authorised professionals
  • Assist with investment, property, residence or citizenship-related procedures
  • Review applications and supporting documents
  • Communicate service updates
  • Process invoices and maintain business records
  • Operate, maintain and protect our website
  • Measure website and advertising performance
  • Improve our content, services and user experience
  • Deliver or measure advertising, subject to consent and applicable law
  • Send marketing communications where permitted
  • Establish, exercise or defend legal claims
  • Comply with legal or government requirements
  • Prevent fraud, misuse or unauthorised access

We will not use personal data for a materially incompatible purpose without providing appropriate notice or obtaining consent where required.

5. Legal Bases for Processing

Depending on applicable law and the circumstances, we may process personal data on the following bases:

Consent

We may rely on consent for:

  • Non-essential cookies
  • Advertising and analytics technologies
  • Certain marketing communications
  • Processing sensitive information where explicit consent is required
  • Other optional activities explained when consent is requested

You may withdraw consent at any time. Withdrawal does not affect processing that was lawful before consent was withdrawn.

Contractual necessity

We may process information when necessary to:

  • Take steps at your request before entering an agreement
  • Provide services under an engagement
  • Manage an existing client relationship
  • Fulfil contractual and administrative obligations

Legal obligations

We may process information where necessary to comply with:

  • Applicable corporate and tax requirements
  • Court orders or lawful government requests
  • Fraud-prevention requirements
  • Identity-verification, due-diligence or anti-money-laundering requirements where applicable
  • Record-keeping and professional obligations

Legitimate interests

Where permitted, we may process information for legitimate business purposes, including:

  • Responding to genuine enquiries
  • Managing client and professional relationships
  • Protecting our website and business
  • Preventing fraud and misuse
  • Maintaining appropriate business records
  • Improving website functionality and services
  • Measuring general business and advertising performance
  • Establishing or defending legal rights

We consider whether these interests are proportionate and whether they may be overridden by your rights.

6. Sensitive Personal Data

Documents used in investment-migration, financial-review or due-diligence processes may contain sensitive personal information.

We process such information only where reasonably necessary and where we have an appropriate legal basis, such as explicit consent, compliance with a legal obligation, establishment or defence of legal claims, or another basis recognised under applicable law.

Access to sensitive documents is intended to be limited to authorised personnel and relevant professional or institutional recipients.

7. Cookies and Similar Technologies

Our website uses cookies and similar technologies for different purposes.

Necessary cookies

Necessary cookies support essential website functions, security and the storage of cookie preferences.

Functional cookies

Functional cookies may support optional website features, user preferences, embedded content or third-party functionality.

Analytics cookies

When enabled, analytics technologies may help us understand:

  • Website traffic
  • Page performance
  • Visitor interactions
  • Traffic sources
  • Campaign performance
  • General usage patterns

Advertising cookies

When enabled, advertising technologies may be used to:

  • Measure conversions
  • Understand advertising performance
  • Build advertising audiences
  • Limit repeated advertising
  • Deliver or personalise advertising where permitted
  • Attribute enquiries to advertising campaigns

Managing cookie preferences

Our cookie banner allows visitors to:

  • Accept all cookies
  • Reject non-essential cookies
  • Customise cookie categories
  • Change previously selected preferences

Non-essential analytics and advertising technologies are used according to your consent choices and applicable law.

The technologies currently enabled on the website may change as our website and advertising activities develop. Current categories and available choices are displayed through our cookie-consent tool.

You may also manage cookies through your browser. Blocking some cookies may affect website functionality.

8. Google Services

Our website may use Google services for analytics, advertising and conversion measurement. Depending on the tools enabled, these may include Google Analytics, Google Ads and Google Tag Manager.

Subject to your consent choices and Google’s settings, Google may receive:

  • Cookie or advertising identifiers
  • IP address
  • Browser and device information
  • Pages visited
  • Website events
  • Approximate location
  • Advertising interactions
  • Conversion information

We do not intentionally send passport details, financial documents, passwords or application documents to Google through website advertising tags.

You can learn more about how Google processes information received from businesses using Google services through Google’s Business Data Responsibility page.

9. Meta and Social Media Technologies

Our website may use Meta technologies, including the Meta Pixel, when enabled for advertising measurement and audience creation.

Subject to your consent settings, Meta may receive information such as:

  • Browser and device information
  • Cookie identifiers
  • Page views
  • Website events
  • Advertising interactions

Our website also contains links to social platforms such as Facebook, Instagram, LinkedIn and X.

When you visit an external social platform, that platform may independently collect and process information under its own privacy policy. Red Ray Capital does not control how independent social platforms process personal data.

10. Sharing Personal Data

We may share personal data only where reasonably necessary and legally permitted.

Recipients may include:

  • Website-hosting and technical-support providers
  • Cloud-storage and cybersecurity providers
  • Email, WhatsApp and communication providers
  • Cookie-consent and website-management providers
  • Google, Meta and other analytics or advertising providers
  • Lawyers and professional advisers
  • Banks and financial institutions
  • Property developers, sellers or property professionals
  • Authorised investment or programme professionals
  • Due-diligence and identity-verification providers
  • Translation, legalisation, document-processing or courier providers
  • Government departments, citizenship units or immigration authorities
  • Accounting, audit or tax professionals
  • Courts, regulators or law-enforcement bodies where legally required
  • A purchaser or successor involved in a legitimate corporate transaction, subject to appropriate protections

Banks, lawyers, government authorities and other independent organisations may process information under their own privacy policies and legal responsibilities.

We do not sell personal data for monetary consideration. Certain advertising technologies may, however, be treated as “sharing” under some privacy laws. You can manage these technologies through our cookie controls.

11. International Transfers

Red Ray Capital is based in the United Arab Emirates, while clients, professional advisers, technology providers, banks and relevant authorities may be located in other countries.

Personal data may therefore be transferred to or processed in:

  • The United Arab Emirates
  • Türkiye
  • The country offering the relevant programme or service
  • The country where a bank, lawyer, adviser or service provider operates
  • Countries where cloud, analytics or communication providers operate

Data-protection standards may differ between countries.

Where required, we use appropriate measures intended to protect international transfers, such as contractual protections, confidentiality obligations or other recognised legal mechanisms.

12. Data Retention

We retain personal data only for as long as reasonably necessary for the purpose for which it was collected.

General enquiry information is retained only for as long as reasonably necessary to:

  • Respond to the enquiry
  • Continue relevant communication
  • Maintain appropriate business records
  • Protect against fraud, misuse or legal disputes

If an individual becomes a client, relevant enquiry information may become part of the client record.

Client, transaction, due-diligence and application records may be retained for longer where necessary because of:

  • An ongoing client engagement
  • Application or investment timelines
  • Contractual obligations
  • Corporate, accounting or tax requirements
  • Compliance and fraud-prevention requirements
  • Government or professional record-keeping obligations
  • The establishment or defence of legal claims

Marketing information may be retained until you unsubscribe, withdraw consent or the information is no longer reasonably required.

We may retain a limited record of an unsubscribe request to ensure that the individual is not added back to a marketing list.

Cookie and analytics information is retained according to the settings and retention periods of the relevant technologies and our cookie-consent tool.

When personal data is no longer reasonably required, we may delete, securely destroy or anonymise it.

13. Data Security

We use reasonable administrative, organisational and technical measures designed to protect personal data against:

  • Unauthorised access
  • Accidental loss
  • Misuse
  • Alteration
  • Unauthorised disclosure
  • Destruction

Measures may include access restrictions, confidentiality controls, secure systems, staff awareness, vendor assessment, backups and appropriate document-transfer procedures.

No website, communication platform or storage system can be guaranteed to be completely secure.

Please do not send passwords, authentication codes or highly sensitive documents through unsecured channels.

If we become aware of a personal-data breach, we will assess it and take notification or remedial steps where required by applicable law.

14. Your Privacy Rights

Depending on your location and applicable law, you may have the right to:

  • Be informed about the processing of your data
  • Request access to personal data held about you
  • Request correction of inaccurate or incomplete information
  • Request deletion where there is no continuing lawful reason to retain the data
  • Request restriction of certain processing
  • Object to processing based on legitimate interests
  • Object to direct marketing
  • Request data portability where applicable
  • Withdraw consent
  • Request information about international transfers
  • Raise a concern with an appropriate data-protection authority
  • Request human review of certain solely automated decisions

These rights are not absolute and may be subject to legal exceptions.

To exercise a privacy right, email contact@redraycapital.com with the subject line “Privacy Request”.

We may request reasonable information to verify your identity before responding. We will respond within the period required by applicable law.

15. Marketing Communications

Where legally permitted, we may contact you about:

  • Relevant property or investment opportunities
  • Citizenship or residence programme updates
  • Educational resources
  • Consultations
  • Events or service announcements

You may unsubscribe at any time by:

Withdrawing from marketing does not prevent us from sending necessary contractual, service, security or administrative communications.

16. Automated Processing and Advertising Audiences

Advertising and analytics platforms may use cookies and identifiers to include website visitors in general advertising or interest-based audiences.

Red Ray Capital does not use solely automated website profiling to make final decisions about eligibility for an investment, citizenship, residence or immigration programme.

Any preliminary assessment remains subject to human review, supporting documentation, professional due diligence and the authority of the relevant government or institution.

17. Children and Dependants

Our website and services are intended primarily for adults.

We do not knowingly collect information directly from children for independent marketing purposes.

Where an application includes a child or dependant, we may process that person’s information when it is provided by a parent, legal guardian or appropriately authorised representative and is necessary for the requested service.

18. Third-Party Websites

Our website may link to government resources, professional advisers, banks, property websites and social media platforms.

We do not control the privacy, security or content practices of independent third-party websites. You should review the relevant privacy policy before providing personal information to an external website.

19. Changes to This Privacy Policy

We may update this Privacy Policy to reflect:

  • Changes to our services
  • Changes to website technologies
  • New service providers
  • Changes in applicable data-protection requirements
  • Changes to our analytics or advertising activities
  • Operational or security developments

The updated version will be published on this page with a revised effective date.

Material changes may also be communicated through the website or cookie banner where appropriate.

20. Contact Us

For privacy questions, requests or complaints, contact:

Red Ray Capital Management Consultancy LLC
RS 22, Ground Floor, Zone 3
Schon Business Park, DIP 1
Dubai, United Arab Emirates

Email: contact@redraycapital.com
WhatsApp: +971 50 719 4407
Website: www.redraycapital.com

Please use the subject line “Privacy Request” when contacting us by email about personal data.