Information about the processing of personal data at www.davituru.com.
DAVITURU MARKETING SOLUTIONS — FZCO DSO-IFZA, IFZA Properties, Dubai Silicon Oasis Dubai, United Arab Emirates Registration number: DSO-FZCO-37952 · Commercial licence no. 40072 Email: info@davituru.com DAVITURU MARKETING SOLUTIONS — FZCO is the controller of the personal data collected through www.davituru.com and the other channels described in this policy. The Company operates commercially under the brands Davituru and Shadow Operator.
This policy applies to the processing of personal data of: • Visitors to the website • Persons requesting information or downloading free resources • Persons interacting with the Company through social media messaging • Clients of professional services • Students of training programmes It does not apply to the websites or platforms of third parties to which the Company may link, which are governed by their own policies.
The Company collects personal data through the following channels: 3.1 Website. Contact, subscription and resource download forms, as well as cookies and similar technologies. 3.2 Advertising and lead generation forms. Campaigns on advertising platforms and contact forms integrated into those platforms. 3.3 Automated direct messaging on social media. The Company uses conversation automation tools that send a direct message to people who comment a specific keyword on a post, reply to a story or write to the profile. By performing that interaction, the person voluntarily starts a conversation with the Company. The data from their public profile on the platform, the content of the conversation and the record of the interaction are processed in order to handle the request, deliver the offered resource and, if they give their consent, send subsequent commercial communications. The conversation history is also kept as a record of the origin of the contact for internal commercial management purposes. 3.4 Messaging and direct communications. Communications by email, WhatsApp or other messaging channels initiated by the interested person or consented to by them. 3.5 Contracting and service provision. Data provided during the purchase process, registration on the training platform, support sessions and execution of professional engagements.
• Identifying data: name, surname, company name, social media username • Contact data: email address, phone number • Commercial data: services or products requested, history of contacts and interactions, content of messaging conversations • Billing data: data necessary to issue and retain proof of payment. The Company does not store complete card data; payment is processed directly by the relevant gateway • Technical data: IP address, browser type, operating system, device information • Usage data: pages visited, session duration, interactions, progress within the training platform • Marketing data: consent records and communication preferences
• Provide the contracted services and manage access to training programmes • Respond to information requests and enquiries • Manage subscriptions, registrations and delivery of free resources • Maintain the commercial relationship with current and potential clients • Send commercial communications and promotional content, where the corresponding consent is obtained • Run advertising, segmentation and remarketing campaigns • Issue invoices and comply with accounting and tax obligations • Improve services and the user experience • Ensure site security and prevent fraud and abuse • Comply with applicable legal and regulatory obligations
• Consent: commercial communications, non-essential cookies, initiation of automated messaging conversations • Performance of a contract or pre-contractual measures: provision of services, access to training programmes, handling of requests • Legitimate interest: website security, fraud prevention, service improvement, management of the relationship with existing clients • Legal obligation: retention of accounting, tax and billing records Where processing is based on consent, the data subject may withdraw it at any time by writing to info@davituru.com or through the unsubscribe link included in communications. Withdrawal of consent does not affect the lawfulness of processing carried out previously.
The Company does not sell personal data. Data may be disclosed to trusted providers acting as processors, under contract and subject to confidentiality obligations: • Messaging automation and conversation management — Manychat, Inc. (USA) — https://manychat.com/legal/privacy • Hosting, delivery of training programmes and student community — Whop, Inc. (USA) — https://whop.com/privacy/ • Payment processing and marketing of digital products — Hotmart (Brazil) — https://hotmart.com/es/legal/privacidad-de-datos • CRM, marketing automation and email communications — HighLevel LLC — GoHighLevel (USA) — https://www.gohighlevel.com/privacy-policy • Live training sessions and videoconferencing — Zoom Communications, Inc. (USA) — https://www.zoom.com/en/trust/privacy/privacy-statement/ • Advertising, messaging and social media — Meta Platforms (Facebook, Instagram, WhatsApp) — https://www.facebook.com/privacy/policy/ · https://privacycenter.instagram.com/policy/ Data may also be disclosed to professional advisers, financial institutions and public authorities where there is a legal obligation to do so.
The Company is established in the United Arab Emirates. Personal data may be processed or transferred outside the European Economic Area, in particular to the United Arab Emirates, the United States and Brazil, where the providers listed in the previous section are located. When data relating to persons located in the European Union are transferred, such transfers are carried out with the appropriate safeguards provided for in applicable legislation, including: • Standard Contractual Clauses approved by the European Commission • The EU–US Data Privacy Framework framework, where applicable • Contractual agreements ensuring an adequate level of protection
The Company uses cookies and similar technologies to ensure the operation of the site and to deliver personalised advertising and remarketing campaigns, mainly through the tracking pixels of the advertising platforms listed in section 7. The Company does not use its own web analytics tools. Non-essential cookies — including advertising and tracking cookies — are only activated with the express consent of the user, which may be withdrawn at any time from the site's cookie settings panel. Detailed information on the cookies used, their retention periods and how to manage them is available in the Cookie Policy at www.davituru.com.
• Information requests and unconverted contacts — 12 months from the last interaction • Messaging conversations — 24 months from the last interaction • Marketing data and consents — Until consent is withdrawn • Student data — During the programme access period and, thereafter, the legal limitation periods • Contractual, accounting and billing data — During the relationship and the retention periods required by applicable law in the UAE • Cookie data — As indicated in the Cookie Policy Once the periods have elapsed, the data are deleted or irreversibly anonymised.
Any data subject may exercise the following rights: • Access their personal data • Request rectification of inaccurate data • Request erasure of data that are no longer necessary • Request restriction of processing • Object to processing • Request data portability • Withdraw consent at any time To exercise them, simply write to info@davituru.com, indicating the right you wish to exercise. The Company may request additional information to verify the identity of the requester. Persons located in the European Union also have the right to lodge a complaint with the supervisory authority of their country. In Spain, the competent authority is the Agencia Española de Protección de Datos (AEPD). The list of European authorities is available at https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm
The Company's services and products are aimed exclusively at persons over the age of 18. The Company does not knowingly collect personal data from minors through its forms, campaigns or messaging channels. If it is detected that data from a minor have been collected without the corresponding authorisation, they will be deleted. Anyone who becomes aware of such a situation may report it to info@davituru.com. When, exceptionally, a minor is admitted to a training programme, the express and verifiable consent of the person holding parental authority or guardianship will be required in advance, as well as the identification of that person as the contracting party.
The Company uses automated tools for audience segmentation, advertising optimisation and remarketing campaigns. Decisions based solely on automated processing that produce legal effects or significantly affect data subjects are not taken without human intervention.
The Company applies appropriate technical and organisational measures to protect personal data against unauthorised access, alteration, loss or disclosure, including secure hosting environments, access controls, encryption where appropriate and internal confidentiality policies. Access to data is limited to staff and collaborators who need it for the performance of their duties, subject to confidentiality obligations.
The Company may amend this Privacy Policy to adapt it to legislative, technical or operational changes. Amendments shall take effect from their publication on the website. It is recommended to review it periodically.
This Privacy Policy is governed by the legislation of the United Arab Emirates, in particular Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (PDPL), and, where applicable in relation to persons located in the European Union, by the General Data Protection Regulation (GDPR).
Davituru Marketing Solutions — FZCO
DSO-IFZA, IFZA Properties, Dubai Silicon Oasis, Dubai, United Arab Emirates
info@davituru.com
Last updated: August 2026