EG Elite Property L.L.C. – PRIVACY POLICY
Policy Number: 1
Effective Date: July 30, 2025
Version: 1.0 (Bilingual)
1. PURPOSE & SCOPE
1.1. This Privacy Policy (“Policy”) sets out the purposes, legal bases, conditions, and procedures for processing personal data of natural persons (“Personal Information”) by EG Elite Property L.L.C., duly registered in the Emirate of Dubai, United Arab Emirates, licensed under the Real Estate Regulatory Agency (RERA) and operating in accordance with applicable law (“Company”).
1.2. The Company affirms its commitment to safeguarding the rights and freedoms of data subjects—regardless of citizenship, residency, language, legal status, or jurisdiction—and implements all reasonable, lawful, technical and organizational measures to ensure fair, transparent, lawful, and secure processing of Personal Information under UAE Federal Decree‑Law No. 45 of 2021 (PDPL), as well as other mandatory UAE regulations and applicable international obligations.
1.3. This Policy applies whenever the Company collects, records, structures, stores, uses, discloses, transfers, blocks, deletes or destroys Personal Information in any form—whether oral, written, digital, electronic, paper-based, visual or voice-based—including communications via messaging apps, website forms, CRM systems, audio‑video calls. Informal or uncontrolled channels are used only upon confirmed consent or to fulfill pre-contractual obligations.
1.4. The Company acts as the data controller under PDPL, responsible for ensuring proper processing, storage, protection and deletion of Personal Information. The Company may also comply with other jurisdictions when explicitly required by an international agreement, client contract, or regulator.
1.5. The Policy covers, without limitation: categories of data processed; processing purposes, scope, and legal bases; data sources; storage conditions; third‑party disclosures; cross‑border transfers; interaction with authorities; use of external providers/processors; automated processing; marketing; video/biometric/sensitive data; data subject rights and enforcement mechanisms; client legal obligations; applicable law and jurisdiction; update process; legal validity and precedence in case of conflicts.
1.6. The Company may unilaterally amend the Policy by publishing it on its official website or via electronic notice. Re‑consent is requested only when legally required. Clients are responsible for monitoring updates and accept legal force of amendments from publication date.
1.7. This Policy constitutes a standalone legal document and may be used by the Company in disputes, complaints, audits or claims as evidence of compliance with PDPL, RERA or other UAE regulations. It operates alongside other corporate documents (e.g. KYC, AML/CFT, risk policies, client service terms).

2. DEFINITIONS & TERMS
2.1. Company – EG Elite Property L.L.C., a legal entity registered in the UAE engaged in real estate, serving as Data Controller for purposes of this Policy.
2.2. Client – any natural person whose Personal Information is processed by the Company in connection with real estate, marketing, advisory or related services, including buyers, tenants, sellers, investors, representatives of legal entities, trustees, or other individuals who voluntarily provide data.
2.3. Personal Data (Personal Information) – any information relating to an identified or identifiable natural person, including but not limited to: name, date of birth, contact details, identity document data, residential address, nationality, marital status, property details, payment data, business/education information, digital footprints (e.g. IP address, cookies), audio/video images, and any other information that identifies the data subject.
2.4. Special (Sensitive) Categories of Personal Data – data requiring heightened protection under PDPL and applicable laws, including racial or ethnic origin, religious or philosophical beliefs, health status, political opinions, sexual orientation, criminal history, genetic or biometric data, or any other data classified as sensitive by law.
2.5. Processing – any operation performed on Personal Data, whether automated or manual, including collection, recording, organization, storage, retrieval, use, disclosure, dissemination, anonymization, blocking, deletion, or destruction.
2.6. Third Parties – individuals or entities (including governmental bodies, partners, contractors or platforms) not part of the Company but receiving access to Personal Data under contract, law or other legitimate basis, in a scope necessary to fulfill obligations or protect the Company’s interests.
2.7. Policy – this Privacy Policy, including all its editions, annexes and updates, binding on all Company personnel.
2.8. Data Subject Consent – a voluntary, specific, informed and unambiguous expression of will by which a data subject gives permission for processing and transfer of their data in accordance with this Policy. Consent can be withdrawn under applicable law.
2.9. Cross‑Border Transfer – the transfer of Personal Information outside the UAE or granting access to such data to third parties abroad, including via cloud storage, CRM systems or hosting, subject to PDPL and regulatory compliance.
2.10. Data Controller – the legal entity (including the Company) that determines the purposes and means of data processing and bears responsibility for compliance with data protection laws.
2.11. Data Processor – an individual or entity processing Personal Data on behalf of the Company under a Data Processing Agreement (DPA), without using data for its own purposes.

3. CATEGORIES OF COLLECTED DATA
3.1. The Company collects identification data, including full name, nationality, gender, date and place of birth, identity document details (passport, Emirates ID, driver’s license, or other recognized documents), and photo/video images of the face where necessary for client identification, verification, regulatory compliance, or protection of the Company’s legitimate interests.
3.2. The Company processes contact data voluntarily provided by the Client or obtained during business interactions, including phone numbers (mobile/landline), email addresses, mailing and physical addresses, as well as messenger, social media, or other digital contact identifiers used to communicate with the Company.
3.3. To comply with KYC (Know Your Customer), AML (Anti-Money Laundering), CFT (Countering the Financing of Terrorism) and other regulations, the Company collects and processes supporting documents and information, including proof of residence (utility bills, lease agreements, bank statements), employment details, source of income and funds, tax residency, status as a Politically Exposed Person (PEP), and records of sanctions, criminal or legal risks.
3.4. The Company may process information regarding potential conflicts of interest, including family, business, or other relations between the Client and Company personnel if such relations may affect compliance, internal policy adherence, or service impartiality.
3.5. Based on service nature, client requests, and applicable legislation, the Company may collect additional data necessary for contract performance, including client preferences regarding location, budget, purchase/rental goals, investment intentions, or transaction conditions.
3.6. Processing of special categories of Personal Data, including health status, criminal records, racial/ethnic origin, religious/philosophical/political beliefs, biometric and sexual orientation data, is carried out only with a legal basis and the subject’s informed consent, limited to the scope necessary to achieve the legally defined purpose.
3.7. In cases of digital interaction (via website, forms, messaging apps, CRM, mobile apps, or platforms), the Company may collect technical and digital data, such as IP address, device type, OS version, language, browser version, session timestamps, cookies, logs, geolocation, and navigation behavior, to ensure security, service performance, analytics, and service quality.
3.8. The Company may collect and process other data not explicitly listed in this section if provided voluntarily by the Client or necessary to fulfill contractual, legal, or protective obligations.
3.9. The Company does not request or process data unrelated to the stated purposes and adheres to the principles of data minimization, necessity, and proportionality.
3.10. If the Client refuses to provide mandatory information required by law or contract, or submits false/incomplete data, the Company may refuse services, suspend interactions, or require additional verification.
4. LEGAL BASES FOR DATA PROCESSING
4.1. The Company processes Personal Data based on the data subject’s prior, free, specific, informed, and unambiguous consent. Consent may be expressed in writing, electronically, or through other reliable means. Withdrawal of consent is permitted at any time but does not affect the legality of processing prior to withdrawal.
4.2. The Company may process Personal Data without separate consent if required for the conclusion, performance, or modification of a contract to which the data subject is a party or beneficiary, or at the request of the data subject prior to entering such contract.
4.3. The Company processes Personal Data where necessary to fulfill legal obligations under applicable law, including but not limited to: Federal Decree-Law No. 45 of 2021 (PDPL), Decree-Law No. 20 of 2018 (AML/CFT), Central Bank regulations, DLD and RERA requirements, tax/corporate regulations, reporting obligations, and government requests.
4.4. The Company may process Personal Data without consent where necessary to protect the life, health, freedom, property, or other vital interests of the data subject or others, particularly in emergencies, force majeure, or when consent cannot be obtained in advance.
4.5. The Company may rely on legitimate interest for processing if it does not override fundamental rights and freedoms. Legitimate interests include: ensuring information and physical security, fraud prevention, legal rights protection, internal control/audit, service improvement.
4.6. Data may be processed in the public interest or when the Company acts under legal authority, including cooperation with authorities, legal defense, crime prevention, or international commitments of the UAE.
4.7. If the data subject refuses to provide required data or withdraws consent without another legal basis, the Company may suspend services, limit communication, or terminate agreements after notification.

5. PURPOSES OF PERSONAL DATA PROCESSING
5.1 Preparation, conclusion, and execution of real estate transactions. Personal data is processed for concluding, performing, amending, and supporting transactions, including purchase and sale, leasing, booking of properties, conducting viewings, legal representation, and settlements, as well as for fulfilling contractual obligations or upon client request.
5.2 Identification and verification of legal status. Data is used for verifying the client’s identity, authenticating documents, and confirming rights to the property (including powers of attorney, court decisions, inheritance documents, etc.) for the purpose of preventing legal violations and protecting the rights of all parties.
5.3 Operational communication with the client. Contact details are used for interaction with the client regarding ongoing transactions, offers, organizing viewings, agreeing on terms, sending documents, notifications, and responding to inquiries.
5.4 Transfer of data to third parties. The Company transfers personal data strictly within the scope necessary for contract execution, legal compliance, provision of related services, or protection of lawful interests, including transfers to notaries, realtors, developer representatives, lawyers, CRM and IT providers.
5.5 Compliance with legal requirements. Processing is carried out to fulfill obligations related to AML/CFT, tax reporting, corporate regulation, providing information to government authorities, document storage, prevention of offenses, and responding to requests.
5.6 Internal control and protection of rights. The Company processes data to ensure security, internal audit, prevention of conflicts of interest, protection of lawful rights, reputation, and interests of all involved parties.
5.7 Assessment of reliability and solvency. If necessary, the Company may engage third-party agencies (for example, KYC/AML providers) to evaluate legal capacity, sources of funds, and legal risks.
5.8 Administrative and operational purposes. Data is processed for maintaining the client database, process automation (including via CRM), supporting digital services, systematizing documentation, and optimizing operational activities.
5.9 Marketing notifications. The Company has the right to use client data to send its own notifications, promotions, and services relevant to the client’s interests. The client has the right to unsubscribe from such mailings at any time.
5.10 Personnel management. The Company processes data of employees, contractors, and job candidates for contract conclusion, visa and permit processing, compliance with labor, immigration, and corporate legislation.
5.11 Service personalization. The Company uses the provided information for personalized selection of real estate considering preferences, marital status, income, purchase goals, and other factors.
5.12 Business restructuring. In case of merger, sale of the business or part thereof, transfer of assets or investments, personal data may be transferred subject to confidentiality obligations and applicable law.
5.13 Assessment of data completeness. The Company has the right to suspend service provision if required data is refused or found inaccurate until violations are resolved.
5.14 Content notifications and thematic mailings. Upon subscription, the client may select topics and professional areas of interest. The Company uses this data to improve content personalization.
5.15 Documentation for legal protection. The Company has the right to process and store documents, correspondence, and other data to form an evidentiary base in case of disputes, claims, and proceedings.

6. DATA SUBJECT CONSENT
6.1 The data subject voluntarily, specifically, knowingly, and unambiguously provides the Company with consent for collection, storage, use, transfer, processing, systematization, archiving, and other actions with their personal data to the extent, purposes, and conditions set forth in this Privacy Policy. Such consent may be expressed by signing a document, ticking a box in electronic form, submitting data via digital channels, or other methods allowing reliable recording of the subject's will.
6.2 The consent covers any forms of personal data processing, including oral, written, electronic, digital, automated and non-automated processing, carried out through messengers, forms, correspondence, contracts, CRM systems, cloud storage, calls, meetings, and other channels used by the Company in its operational activities.
6.3 The data subject confirms that they are familiar with the provisions of this Policy, including the purposes, legal grounds, categories of processed data, methods and terms of storage, conditions of cross-border transfer, rights of the subject, and possible consequences of refusal. In the case of transfer to third parties (for example, representatives, relatives, trustees), the data subject guarantees the presence of their consent to processing and undertakes to notify them of the fact and conditions of such transfer.
6.4 The data subject has the right to withdraw consent at any time by sending a written notification to the Company’s email: galuevaproperty@gmail.com. The Company ceases processing data from the moment of receiving the notification, unless there are other legal grounds for continuing processing (for example, contract execution, compliance with AML/CFT requirements, legitimate interests, legal proceedings, or obligations under other laws).
6.5 The data subject understands and confirms that withdrawal of consent or refusal to provide personal data may limit or make it impossible to provide services, fulfill contractual obligations, or comply with regulatory requirements, due to which the Company has the right to suspend or terminate service provision.
6.6 By providing personal data via website, forms, messengers, email, phone channels, or other digital means, the data subject confirms that they have read this Policy before submitting data, received explanations, fully understand it, accept processing conditions, including possible transfer to third parties and outside the UAE, and express their voluntary, full, and legally significant consent. Any action aimed at data submission (for example, clicking the “Send”, “Agree”, “Request” button, etc.) is equated to the data subject’s handwritten signature.
6.7 This consent remains legally valid indefinitely until withdrawn according to the procedure established by this Policy. Withdrawal of consent does not affect the lawfulness of actions performed based on it before the withdrawal date.

7. TRANSFER AND DISCLOSURE OF PERSONAL DATA TO THIRD PARTIES
7.1 The Company may transfer or disclose personal data to third parties solely within the purposes provided by this Policy, and only to the extent necessary for: (1) performance of contractual obligations to the data subject; (2) compliance with UAE legislation, including but not limited to AML/CFT regulations; (3) ensuring informational and legal security, protection of lawful rights, business reputation, and interests of the Company, its clients, employees, and partners. Transfer is carried out exclusively on lawful grounds and is accompanied by technical, legal, and organizational protection measures.
7.2 The Company does not sell clients’ personal data and does not transfer it to third parties for advertising, commercial, or marketing purposes not explicitly provided by this Policy. Any processing of personal data outside the approved purposes is prohibited, including attempts to resell, disclose, or retransmit without proper legal grounds.
7.3 The categories of third parties to whom information may be transferred include:
a) legal, financial, and tax consultants, auditors, banks, and other professional organizations;
b) notaries, lawyers, reliability verification agencies, AML/KYC providers, insurance companies, and other transaction participants;
c) contractors, IT service providers, cloud providers, technical and service companies, including CRM, analytics, call centers;
d) government authorities, regulatory and quasi-governmental bodies, courts, prosecutor’s office, police, DLD, RERA, and other authorized structures if disclosure is required by law, court order, mandate, or official investigation.
7.4 The Company may disclose personal data within its organizational structure (including branches, offices, subsidiaries, affiliated legal entities, employees, agents, representatives, and contractors) strictly on a need-to-know basis and in compliance with internal confidentiality policies.
7.5 All third parties receiving access to personal data from the Company are obliged to ensure a level of protection not lower than provided by this Policy and to use the information solely for the purposes for which it was provided. The Company requires such parties to sign NDAs, data protection agreements, or include corresponding provisions in contracts. In cases where a third party acts as an independent data controller, the Company informs the data subject, except where restricted by law or official mandate.
7.6 In the event of business sale, merger, reorganization, asset transfer, or involvement of investors or partners, the Company has the right to transfer personal data to the relevant parties, provided that such parties undertake obligations to comply with this Policy and do not use the data beyond agreed purposes.
7.7 The Company is not responsible for actions of third parties who received access to personal data not from the Company but directly from the data subject or as a result of actions by the data subject, including independent transfer of data to third parties without notification or agreement with the Company.

8. TRANSFER OF DATA OUTSIDE THE UAE
8.1 The Company has the right to transfer, store, or otherwise process personal data outside the United Arab Emirates (UAE) for the purposes of fulfilling contractual obligations, providing services, using cloud, digital and technological solutions, engaging external consultants, ensuring IT infrastructure operation, fulfilling international obligations, as well as complying with local and cross-border legal requirements.
8.2 Such cross-border transfers may occur in jurisdictions where the level of data protection may not meet the standards established by UAE legislation. In these cases, the Company ensures the legality and security of the transfer based on one or more of the following conditions:
– conclusion of cross-border data transfer agreements including provisions on confidentiality, technical and organizational protection, legal guarantees, and data return procedures;
– ensuring contractual obligations to prevent unauthorized access, alteration, or loss of data;
– use of services and infrastructures certified according to international data protection standards (e.g., ISO/IEC 27001, SOC 2, GDPR);
– transfer of the minimum necessary volume of data, strictly within the stated purposes and legal grounds.
8.3 Cross-border transfer may be made to external providers acting on behalf of the Company and based on contractual obligations, including:
– cloud storage, server and hosting platforms;
– CRM systems, email distribution, communication and client platforms;
– analytics, advertising, marketing, payment and other services;
– legal, financial, accounting, and other professional consultants, provided that security requirements and prohibition on further data transfer are observed.
8.4 Transfer of personal data outside the UAE does not exempt the Company from compliance with mandatory provisions of the PDPL and other applicable UAE laws. All cross-border processing is regulated by the Company’s internal policies and procedures, as well as accompanied by ensuring continuous confidentiality, integrity, and availability of data.
8.5 By giving consent to the processing of personal data under this Policy, the data subject explicitly confirms their consent to the possibility of cross-border transfer of their personal data for the purposes specified above, including transfer to countries with different regulatory levels, provided that the principles of this Policy are observed and all reasonable and sufficient measures are taken to protect the information.

9. RIGHTS OF THE DATA SUBJECT
9.1 The data subject has the right to receive complete, accurate, and understandable information about the purposes, legal grounds, scope, and methods of processing their personal data, including the content of this Policy, the list of processed data, sources of its collection, as well as information about the transfer of data to third parties or outside the UAE.
9.2 The subject has the right to request from the Company confirmation of the fact of processing their personal data and obtain access to the following information: the fact of processing, categories of personal data, purposes and legal grounds of processing, storage periods, data recipients (including third parties and international recipients).
9.3 The subject has the right to demand correction, updating, or clarification of their personal data if it is inaccurate, incomplete, outdated, or misleading. The Company undertakes to make the appropriate changes within a reasonable time after receiving a justified request.
9.4 The subject has the right to request deletion of personal data if the purposes of processing have ceased; if consent has been withdrawn and there are no other legal grounds; if the subject objects to processing based on legitimate interest; if the data was processed unlawfully; or if deletion is necessary to comply with obligations.
9.5 The subject has the right to request restriction of data processing in cases of: contesting the accuracy of data (during verification); unlawful processing while refusing deletion; lack of necessity of processing but need for data by the subject; or awaiting assessment of legal grounds after objection.
9.6 The subject has the right to data portability, including receiving their data in a structured, machine-readable format and transferring it to another operator, if technically feasible and not infringing on the rights of third parties.
9.7 The subject has the right to object to processing of their data carried out on the basis of legitimate interest or performance of a task in the public interest. The Company will cease processing unless it demonstrates overriding legitimate grounds.
9.8 The subject has the right not to be subject to decisions based solely on automated processing (including profiling) that have legal effects or similarly significant impact, except where expressly permitted by law or agreed by the subject.
9.9 The subject has the right to file a complaint with the authorized supervisory authority of the UAE if they believe their rights have been violated as a result of unlawful data processing.
9.10 To exercise the stated rights, the subject may send a written request to the Company’s email: galuevaproperty@gmail.com. The Company undertakes to consider the request within established timeframes and provide a reasoned written response. To protect data, the Company may request a document confirming the identity of the applicant.

10. DATA PROTECTION MEASURES
10.1 The Company applies adequate technical, organizational, and legal measures to protect personal data from unauthorized access, use, disclosure, alteration, loss, damage, destruction, or other unlawful forms of processing. These measures correspond to the nature of the processed information, the level of risk, the Company’s capabilities, and the requirements of UAE data protection legislation.
10.2 Personal data is stored in digital information systems (including CRM and cloud platforms) protected by multi-layered security measures. Access to such systems is granted only to authorized employees and representatives who have undergone training, are admitted on a need-to-know basis, and possess documented rights. All actions are subject to audit and logging.
10.3 Paper media containing personal data are stored in safes or cabinets with restricted access. Admission is granted only to trusted employees specified by internal regulations. Storage, copying, transfer, and destruction of such documents are carried out strictly according to internal rules.
10.4 All digital data is hosted on protected servers and cloud platforms certified to international standards and equipped with measures to prevent unauthorized access, loss, or modification. Access is provided on a minimal necessary basis; actions are logged and analyzed as needed.
10.5 The Company may use external digital services, including cloud solutions outside the UAE, provided such providers comply with security and confidentiality requirements. The Company assesses such providers and enters into agreements containing data protection provisions. The data subject consents to such cross-border processing under this Policy.
10.6 The Company ensures mandatory training for employees with access to personal data, including information security, confidential information protection, internal access, and incident response. Such employees undertake to comply with the Policy and bear responsibility for violations.
10.7 The Company regularly reviews and updates protection measures, including technical tools, procedures, and internal regulations. Upon identifying new threats or changes in legislation, the Company implements appropriate updates.
10.8 In the event of an incident involving data compromise (leakage, damage, destruction, etc.), the Company promptly conducts an investigation, takes measures to mitigate consequences, notifies regulatory authorities if necessary, and informs the data subject if there is a significant risk to their rights.
11. TERMS AND PROCEDURE FOR PERSONAL DATA STORAGE
11.1 The Company stores personal data for the period necessary to achieve the processing purposes set forth in this Policy, as well as for periods provided by applicable legislation of the United Arab Emirates, regulatory acts, licensing and compliance requirements, the Company’s internal regulations, and/or provisions of contracts concluded with clients, counterparties, or employees. If there are justified legal or operational grounds, the storage period may be extended.
11.2 The specific duration of storage is determined taking into account the category of data, the nature of the services provided, the role of the subject (e.g., client, partner, candidate), the grounds for processing, and the level of risk regarding protection of the Company’s rights and interests. In some cases, personal data may be retained after the completion of service provision if necessary to comply with legislation, maintain reporting, taxation, protect the Company’s rights, resolve disputes, or fulfill obligations to government authorities.
11.3 The Company may, at its own discretion and subject to lawful grounds, retain personal data for a reasonable period after termination of contractual, employment, or other relations with the data subject. Such storage may be necessary to respond to regulatory inquiries, conduct audits, settle claims, maintain archives, provide evidentiary support, analyze complaints, and other lawful purposes.
11.4 Upon expiration of the storage period determined in accordance with clauses 11.1–11.3, the Company carries out reliable deletion, destruction, or anonymization of personal data, except in cases where continued storage is required or permitted by law, official requests of government bodies, or within judicial or administrative procedures. Deletion is carried out in compliance with the Company’s internal policies and standards for confidentiality and data security protection.
11.5 In the event of a data subject’s request for deletion of information before the expiration of the mandatory storage period, the Company may refuse full deletion if there is a valid legal or contractual obligation to retain it. In such cases, the Company undertakes to temporarily restrict processing of such information to only minimally necessary actions aimed at fulfilling these obligations. This restriction shall not be interpreted as an obligation of the Company to delete the data prematurely.

12. LIABILITY AND CONTACT INFORMATION FOR DATA MATTERS
12.1 The Company acts as the personal data controller and bears full responsibility for ensuring the legality, security, transparency, and lawfulness of processing, storage, protection, and transfer of personal data in accordance with the applicable legislation of the United Arab Emirates, including Federal Decree-Law No. 45 of 2021 (Personal Data Protection Law, PDPL), as well as in accordance with this Policy. All processing activities are carried out within the UAE or within the framework of permissible cross-border transfer compliant with applicable legal requirements and the Company’s internal policies.
12.2 In case of questions, comments, objections, or intent to exercise rights provided by legislation and this Policy, the data subject has the right to send a written request to the Company at the email address: galuevaproperty@gmail.com. All requests are processed by authorized representatives of the Company subject to proper identification of the applicant. The Company may request documents or additional information confirming the identity and legitimacy of the applicant. A response is provided within the timeframe established by applicable legislation or within a reasonable period if no specific timeframe is set.
12.3 The Company prioritizes out-of-court resolution of any disputes, complaints, or claims related to personal data processing and undertakes to diligently and promptly consider all received requests in the prescribed manner.
12.4 The data subject undertakes, prior to contacting government authorities including the UAE Data Office, to send a corresponding notification to the Company and provide a reasonable period for remedying violations, clarifying positions, or providing responses. This procedure is a mandatory preliminary step before an official complaint.
12.5 If the situation cannot be resolved out of court, the data subject retains the right to file a complaint with the UAE Data Office or another competent government authority in the relevant jurisdiction, provided such processing is regulated by applicable law.

13. POLICY REGARDING CHILDREN
13.1 The Company does not intentionally collect, store, or otherwise process personal data of children under the age of 18, except in strictly limited cases where such processing is necessary in connection with providing services to clients acting in the interests of the minor. Any such processing is carried out to the minimum extent necessary to achieve the lawful purpose, in accordance with applicable legislation of the United Arab Emirates, including the requirements of Federal Decree-Law No. 45 of 2021 (PDPL), and accompanied by the mandatory obtaining of confirmed and documented consent from the child's legal representative.
13.2 In cases where personal data of a minor is provided within real estate transactions (e.g., for visa support, rights registration, confirmation of family composition), the Company may request official documents confirming the child's age and the authority of the person acting on their behalf, including birth certificates, kinship documents, notarized powers of attorney, court decisions, or other legally recognized grounds. The Company is not responsible for consequences arising from the provision of incomplete, inaccurate, or forged documents.
13.3 The Company is not responsible for instances where personal data of a child was provided without the consent, knowledge, or authorized participation of their legal representatives. Upon identification of such facts, the Company has the right to immediately suspend data processing, require documentary proof of authority, and, if necessary, delete the specified data if further processing contradicts legislation or internal policies.
13.4 The Company applies technical, organizational, and legal measures aimed at preventing unauthorized or unintended processing of children's personal data, as well as reducing possible risks related to minors’ involvement. The Company does not use children's personal data for direct marketing, advertising, profiling, behavioral analytics, automated decision-making, or cross-border transfer, except in cases explicitly permitted by law and only with documented consent of the legal representative.
13.5 Responsibility for the legality of transfer, accuracy, and completeness of minors’ personal data fully lies with clients providing such data. Clients must ensure the availability of appropriate consents and legal grounds for processing the child's data on their behalf.

14. USE OF COOKIES AND TRACKING TECHNOLOGIES
14.1 For the proper functioning of the website, enhancement of information security, analysis of user activity, content personalization, interface optimization, conducting marketing campaigns, and improving the quality of services provided, the Company uses cookies and other tracking technologies, including but not limited to: pixels, web beacons, JavaScript, local storage, analytical scripts, advertising identifiers, and third-party plugins.
14.2 Upon first visiting the website, the user receives a notification with the option to consent to the use of cookies, except for strictly necessary cookies without which the website cannot function technically properly. The user has the right to change or withdraw their consent at any time via browser settings, the banner interface on the site, or by submitting a written request to the Company. The Company is not responsible for possible website functionality limitations caused by disabling cookies.
14.3 Cookies may be set both directly by the Company and by third parties — service providers (e.g., web analytics, hosting, CRM, retargeting, marketing automation) acting on behalf of the Company. In such cases, technical information may be processed: IP address, geolocation, device type, OS version, browser settings, interface language, date and time of visit, navigation, session duration, clicks, link transitions, and other anonymized metadata.
14.4 The Company provides users with the ability to manage cookie settings via a special banner and/or browser. Refusal of non-essential cookies does not affect the use of strictly necessary cookies. The user has the right to change their decision at any time, including withdrawing previously given consent.
14.5 The user understands that by refusing cookies other than necessary ones, certain functions, interfaces, content, or personalized site options may be unavailable or operate with limitations. The Company is not responsible for possible errors, delays, or decreased quality of user experience caused by limitations imposed by the user.
14.6 By continuing to use the website without changing cookie settings or not expressing refusal via available mechanisms, the user is considered to have consented to the use of cookies and other tracking technologies within the purposes set forth in this Privacy Policy. Upon written request, the Company provides information about categories of cookies, storage periods, purposes, and providers.
14.7 The Company applies reasonable technical, organizational, and contractual measures to ensure the protection of data collected through cookies and requires all engaged providers to comply with information security and data confidentiality legislation.

15. CHANGES AND UPDATES TO THE POLICY
15.1 The Company reserves the right to make amendments, additions, or completely revise the provisions of this Privacy Policy at any time if such actions are necessary in connection with:
– changes in legislation, regulatory requirements, or regulatory practice;
– clarifications from government authorities;
– judicial practice;
– internal changes in data processing procedures;
– the need to enhance the level of personal data protection or transparency of processing.
15.2 All changes come into effect from the moment they are approved by the Company and the new version of the Policy is officially published on the Company’s official website, or the information is communicated by other permissible means: by email, through messengers, paper media, digital platform interfaces. The Company may refrain from sending individual notifications unless otherwise required by law or obligations to a specific data subject.
15.3 If changes affect the conditions of personal data processing for which consent was previously given, and the law requires obtaining new consent, the Company suspends processing of the affected data until the proper, confirmed consent is obtained, except in cases explicitly provided by law.
15.4 The data subject has the right at any time to request the current version of the Privacy Policy from the Company in writing or by email. At the same time, the data subject undertakes the obligation to independently monitor changes in the Policy, unless otherwise provided by individual service terms, agreement, or contract.
15.5 Use of the website, services, or continued interaction with the Company by the client after the changes come into force is considered as confirmation of acquaintance with the new version of the Policy and acceptance of its terms, except in cases where the law requires separate, explicit consent.
15.6 The data subject understands and accepts that the Company may make changes to this Policy without prior individual notification, except in cases explicitly established by law. Continued use of the website, services, or other forms of interaction with the Company after publication of changes constitutes acquaintance with the current version and acceptance of its provisions.

16. JURISDICTION AND APPLICABLE LAW
16.1 This Privacy Policy is governed by and shall be interpreted exclusively in accordance with the legislation of the United Arab Emirates, including but not limited to: the provisions of Federal Decree-Law No. 45 of 2021 "On Personal Data Protection" (PDPL), Federal Decree-Law No. 20 of 2018 (AML/CFT), normative acts of the Central Bank of the UAE, DLD, RERA, as well as other applicable regulatory legal acts in force within the territory of the Emirate of Dubai.
16.2 All disputes, claims, disagreements, demands, losses, and legal consequences arising in connection with the processing of personal data, interpretation, effect, performance, or violation of this Policy, as well as the actions of the Company to protect personal information, shall be subject to the exclusive jurisdiction of the competent civil courts of the Emirate of Dubai, United Arab Emirates, unless otherwise explicitly provided by law or a written agreement between the parties. Such courts are deemed to have contractual jurisdiction.
16.3 This Policy may be used by the Company as independent evidence of proper notification of the data subject, obtaining consents, fulfillment of data protection obligations, as well as a legal basis for protecting the interests of the Company, its employees, clients, and contractors within pre-trial, administrative, arbitration, and judicial proceedings in any jurisdiction, provided compliance with applicable law.
16.4 The parties recognize the legal force of this Policy in both paper and electronic form, including posting on official digital resources, sending via email, messengers, digital platforms, and CRM systems. The signature of the data subject under a separate consent form confirms that the terms of the Policy have been fully communicated and accepted without objections.
16.5 In the event of any discrepancies between the Russian and English versions of this Policy, the English version shall prevail. It is applied as the official version and shall be interpreted exclusively in accordance with the legislation of the United Arab Emirates.

17. DISCLAIMER
17.1 This Privacy Policy is provided solely for informational purposes and does not constitute a contract, public offer, or legal obligation beyond the duties established by the applicable legislation of the United Arab Emirates. No provisions of this Policy may be interpreted as creating additional obligations for the Company, except in cases explicitly provided by law or a written agreement between the parties.
17.2 The Company is not responsible for any losses, damages, regulatory consequences, fines, damage to business reputation, or legal consequences arising from the provision by the client or third parties of inaccurate, incomplete, outdated, or misleading information, as well as in cases of the client’s violation of the provisions of this Policy, terms of service, applicable law, or instructions communicated to the client.
17.3 The Company does not guarantee complete technical or legal invulnerability of information systems and is not liable for damages caused by unauthorized access, cyberattacks, malicious software, technical failures, vulnerabilities, data leaks, communication interruptions, equipment failures, actions of third parties, or other circumstances beyond the Company’s reasonable control, including force majeure.
17.4 The Company is not responsible for actions, omissions, breaches, or other events caused by third-party providers of cloud or digital services, advertising platforms, consultants, or other contractors acting as independent controllers or under their own policies and terms of service, even if such parties were mentioned, recommended, or used by the Company.
17.5 The Company is not liable for any consequences of unlawful, illegal, unauthorized, or erroneous actions by the client, their representatives, agents, or third parties, including actions violating confidentiality, misleading, infringing third-party rights, or breaking legal norms, except in cases where such consequences are directly caused by confirmed violations on the part of the Company.

18. OBLIGATIONS OF THE PERSONAL DATA SUBJECT
18.1 The personal data subject is obliged to provide the Company with accurate, complete, up-to-date, and legally correct information necessary for the fulfillment of service provision conditions and for achieving the purposes of processing specified in this Policy. In case of any changes to such information, the subject must promptly notify the Company in writing or through official communication channels. The Company shall not be liable for any losses, consequences, or service limitations resulting from the subject’s failure to timely update information.
18.2 The personal data subject undertakes not to provide the Company with personal data of third parties without their prior, explicit, and documented consent, or without another lawful basis provided by applicable law. In case of breach of this obligation, the subject bears full legal, administrative, and civil liability for all consequences, including sanctions, claims, and damages caused to the Company or third parties.
18.3 The personal data subject is not entitled to use forms, electronic communication means, messengers, e-mail, digital platforms, or other channels of interaction with the Company to transmit false, distorted, forged, fraudulent, defamatory, unlawful, or misleading information. Upon reasonable suspicion of false information or violation of applicable law, the Company reserves the right to suspend personal data processing, refuse to provide services, and report the information to competent authorities.
18.4 The personal data subject undertakes to refrain from any actions aimed at interfering with data processing, undermining information security measures, unauthorized access to the Company’s protected systems, hacking attempts, dissemination of personal data obtained during interactions with the Company without legal grounds, or other actions violating confidentiality, integrity, or lawfulness of personal data processing.
18.5 In the event the personal data subject submits a request to exercise their rights under the laws of the United Arab Emirates or this Policy (including requests for access, correction, deletion, restriction, withdrawal of consent, or data transfer), they must confirm their identity and authority according to procedures established by the Company by providing all necessary official documents. The Company reserves the right to refuse the request if there are no legal grounds or if there is suspicion of abuse of rights.
18.6 The personal data subject acknowledges and accepts that they bear personal, unconditional, and full responsibility for complying with all provisions of this Policy and the laws of the United Arab Emirates, including responsibility for any actions carried out on their behalf using their contact details, digital identifiers, devices, or accounts.

19. POLICY REGARDING BIOMETRIC AND SENSITIVE DATA
19.1 The Company reserves the right, in exceptional, justified, and documented cases, to process special categories of personal data, including but not limited to: information on racial or ethnic origin, religious or philosophical beliefs, health status, biometric data, criminal records, sexual orientation, and other sensitive information. Such processing is carried out strictly in accordance with the requirements of the applicable legislation of the United Arab Emirates, including Federal Decree-Law No. 45 of 2021, solely based on one of the lawful grounds and only to the extent necessary to achieve a specific and legitimate purpose.
19.2 The processing of biometric data, including facial images, fingerprints, iris scans, photo and video images, as well as other unique identifiers, is permitted exclusively in cases explicitly provided by law or justified by the necessity to verify identity, fulfill KYC/AML obligations, ensure internal security, prevent fraud, and only with separate, voluntary, informed, and documented consent of the data subject or other legal basis provided by UAE legislation.
19.3 The Company applies enhanced technical, procedural, and organizational safeguards for the protection of sensitive and biometric data, including personalized access, cryptographic protection, isolated storage, mandatory logging of all operations involving such data, prohibition of use without approval from an authorized official, as well as regular internal audits. These measures comply with the principles of necessity, minimization, legality, transparency, accountability, and confidentiality.
19.4 The data subject confirms that biometric and sensitive data is provided on their own initiative, to the extent necessary to fulfill contractual and regulatory obligations, including identification and verification. The data subject is warned that refusal to provide such data may result in the inability to receive certain services, including those requiring legally significant identification, financial compliance, or identity verification under the law.
19.5 The Company does not engage in automated decision-making, including profiling, evaluation of behavior, business reputation, creditworthiness, or other characteristics of the data subject based on sensitive and biometric information, except in cases explicitly provided by law or clearly agreed with the data subject in writing. Transfer of such data to third parties is prohibited except where explicitly required by law, upon official requests from government authorities, or with the appropriate written consent of the data subject.
19.6 All sensitive and biometric data processed by the Company is used exclusively for the purposes for which it was collected, is not transferred to other jurisdictions without sufficient legal basis, and is stored only for the strictly necessary period. Upon expiration of such period, the data is subject to complete destruction or anonymization in accordance with the Company’s internal policies and procedures, ensuring irreversible loss or removal of identifying properties.
20. POLICY ON COOPERATION WITH GOVERNMENT AUTHORITIES
20.1 The Company interacts with government, quasi-governmental, regulatory, and law enforcement authorities of the United Arab Emirates, as well as other countries where it operates, strictly within the forms and scope permitted by applicable national and international laws, including but not limited to: anti-money laundering and counter-terrorism financing regulations (AML/CFT), personal data protection legislation (PDPL), corporate, immigration, tax, land, and other special regulatory regimes.
20.2 The Company reserves the right to disclose personal data of data subjects exclusively upon the request of competent government or judicial authorities in cases where such disclosure is necessary to comply with official orders, court rulings, regulatory or law enforcement requests, or for the purposes of mandatory KYC procedures, tax reporting, due diligence, or compliance with AML/CFT rules, strictly limited to the minimum necessary scope and within the requested information.
20.3 All personal data disclosed to government authorities is transmitted solely through official, verified, and secure communication channels, with mandatory registration in the Company’s internal registry of disclosures, including details on the disclosure fact, content of the request, scope of transmitted information, and legal basis for transfer. The Company ensures ongoing audits, internal controls, and compliance of such actions with security requirements and applicable UAE legislation.
20.4 Upon receipt of an official request from government authorities, the Company conducts mandatory verification of the requester’s authority, legal basis, and compliance of the request content with applicable legislation. Responses are prepared in accordance with internal regulations, taking into account the principle of proportionality and balancing the interests of the Company, the lawful rights of data subjects, and the requirements of supervisory authorities.
20.5 The Company may withhold notification to data subjects regarding the disclosure or transfer of their information to government authorities if such notification is expressly prohibited by applicable legal norms, may interfere with official investigations, contradict the objectives of law enforcement requests, or impede compliance with orders, including within criminal, administrative, fiscal, or other legal procedures.
20.6 All employees, contractors, representatives, and other authorized persons of the Company are required to strictly adhere to internal regulations governing interactions with government authorities, including procedures for verification, registration, documentation, reporting, and to ensure compliance with principles of confidentiality, information security, professional ethics, and lawful responses to inquiries and orders.
20.7 In cases of reasonable doubt regarding the legitimacy of a request from a government authority or risk of violation of data subject rights, the Company reserves the right to suspend disclosure of information until receiving an official clarification, additional legal opinion, confirmation of the legitimacy of the demand, or independent consultation from a professional legal advisor.

21. CONSENT CONFIRMATION
21.1 By signing this document, the data subject confirms that they have received complete, accurate, and clear information regarding the purposes, grounds, scope, duration, and procedures of processing their personal data, including cross-border transfers, disclosure to third parties, use of biometric and sensitive data, application of digital systems, as well as information about their rights and methods of exercising them under the legislation of the United Arab Emirates.
21.2 By signing this Policy, the data subject provides explicit, specific, unambiguous, and voluntary consent to the processing, storage, transfer, disclosure, and other lawful actions with their personal data for the purposes set forth in this Policy, in accordance with Federal Decree-Law No. 45 of 2021 of the United Arab Emirates (PDPL), as well as other applicable legal regulations in the jurisdictions of the Company's operations.
21.3 The data subject confirms that they have carefully read the provisions of this Policy, understands the legal consequences of providing or refusing to provide data, is informed about their rights and obligations, and voluntarily accepts the terms of processing, including potential service access restrictions in case of refusal.
21.4 The consent provided by the data subject remains valid for the entire duration of processing, including storage, within the limits established by law, the Company’s internal regulations, or contractual obligations, and may be withdrawn only in writing, addressed to the official contact of the Company. The data subject acknowledges that withdrawal of consent may result in the inability to receive some or all services provided by the Company.
21.5 Signing this Policy confirms that the data subject acknowledges the legal force of this document and its admissibility as evidence of consent, notification, awareness, and voluntariness in any administrative, claim-related, or judicial procedure, including for the protection of the interests of the Company, its employees, and/or clients.

22. RELATIONSHIP WITH OTHER POLICIES AND PROCEDURES
22.1 This Privacy Policy forms an integral part of the Company’s internal regulatory framework and is applied in conjunction with other applicable policies, procedures, and agreements, including but not limited to: Anti-Money Laundering and Counter-Terrorism Financing Policy (AML/CFT), Customer Identification Policy (“Know Your Customer” / KYC), Information Security Policy, Employee Personal Data Protection Policy, Customer Complaints Handling Procedures, internal ethics and compliance standards, as well as all contracts and agreements entered into with clients, contractors, or employees, whether oral, written, or electronic.
22.2 In the event of discrepancies, contradictions, or differences between versions of this Policy translated into different languages, the official English version shall prevail and have legal force. The English version shall be applied and interpreted in accordance with the laws of the United Arab Emirates and used in any judicial, administrative, arbitration, or regulatory proceedings in jurisdictions where the Company operates.
22.3 The Company reserves the right to apply the provisions of this Policy together with other internal acts, local and international standards, and current law enforcement practices to ensure proper compliance with its legal, regulatory, contractual, and ethical obligations, transparency, risk management, and protection of the rights and interests of all parties involved.

23. PROCEDURE FOR EXERCISING DATA SUBJECT RIGHTS
23.1 The data subject has the right to submit a written request to the Company for the exercise of their rights under this Policy and applicable law, including but not limited to: the right of access, rectification, deletion, restriction of processing, withdrawal of consent, objection to processing, and data portability. Requests may be submitted via email, postal address, or other official communication channels specified by the Company in the current version of the Policy.
23.2 The Company commits to diligently and individually consider each request within the timeframe established by the applicable legislation of the United Arab Emirates, including Federal Decree-Law No. 45 of 2021 (PDPL). If objectively necessary, the timeframe may be extended with prior notification to the data subject.
23.3 To prevent unauthorized access and ensure proper identification, the Company may require verification of the requester’s identity. Such verification may include a copy of an identity document (passport or Emirates ID), information on previous interactions, or documents confirming authorization if the request is made on behalf of another person.
23.4 The Company shall not refuse to exercise the data subject’s rights without sufficient, reasonable, and lawful grounds explicitly provided by applicable law. Refusal may be justified if: (a) fulfilling the request affects the rights and freedoms of third parties; (b) the request impedes investigations, justice, or official procedures; (c) disclosure of the requested data violates legally protected confidential information, trade secrets, or other restrictions.
23.5 In case of refusal, the Company shall provide the applicant with a reasoned written response, containing specific grounds for denial, references to applicable legal provisions, and information about possible further actions, including the right to file a complaint with the UAE Data Office.
23.6 Exercising data subject rights is free of charge. However, if the request is manifestly unfounded, excessive, or repetitive, the Company reserves the right to: (a) charge a reasonable administrative fee covering actual costs, or (b) reject the request, provided there is a legal basis and the data subject is notified accordingly.
23.7 The Company maintains mandatory internal records and audit trails of all requests related to the exercise of data subject rights, including date of receipt, content, actions taken, grounds for refusal (if any), and date of fulfillment. Such information is retained in accordance with legal requirements and internal procedures and may be used in inspections, audits, or legal proceedings.

24. USE OF DATA FOR MARKETING AND ADVERTISING PURPOSES
24.1 The Company may use personal data of data subjects, including name, contact information, preference details, interaction, and behavioral data, to send information about products, services, special offers, promotions, events, surveys, research, updates, news, and other materials that, in the Company’s reasonable opinion, may be of interest, useful, or relevant to the data subject. Such use is carried out based on prior consent obtained or under the Company’s legitimate interest, within the limits expressly permitted by applicable law.
24.2 The Company may conduct such communications through any lawful channels, including but not limited to: email, telephone calls, messengers, push notifications, SMS messages, targeted and contextual advertising, online chats, personalized banners, social media posts, and other electronic communication means.
24.3 The data subject has the right to opt out of receiving marketing and advertising messages at any time by using the appropriate function in the message (e.g., an “unsubscribe” link) or by sending a written request to the Company via the official communication channels provided. The Company will cease sending such messages to the specific data subject within a reasonable period, but no later than required by law, provided the request is properly received.
24.4 The Company does not disclose personal data to third parties for their own marketing purposes without the prior, separate, and explicit consent of the data subject. In the case of joint marketing campaigns, processing and data transfer are allowed only in compliance with the purposes, scope, and conditions agreed with the data subject and subject to contractual and legal confidentiality guarantees with the relevant partners.
24.5 The Company may use anonymized, aggregated, or statistical data that do not directly or indirectly identify the data subject for internal analytics, segmentation, personalization, testing, automation, and optimization of advertising and marketing activities, including the use of external platforms and contractors, provided such actions do not violate applicable laws and do not require additional consent.

25. AUDIO AND VIDEO RECORDING POLICY
25.1 The Company may carry out audio and video recording of telephone calls, digital communications, online consultations, negotiations, in-person meetings, events, as well as any other interactions involving data subjects that occur within the framework of service provision, contractual obligations, marketing activities, internal control, quality assurance, compliance with legislation, or regulatory requirements.
25.2 Such recordings may be used for dispute resolution and claims, confirmation of agreements reached, protection of the Company’s rights and interests, monitoring and evaluation of employee performance, adherence to corporate standards, as well as internal investigations, audits, or upon requests from competent authorities, including but not limited to: DLD, RERA, Central Bank of UAE, law enforcement agencies, or courts.
25.3 All recordings are stored on technically secured physical or cloud media using reliable encryption mechanisms and access restrictions based on the “need-to-know” principle. The retention period is determined according to the processing purposes but does not exceed the terms established by UAE legislation, the Company’s internal regulations, or contract conditions. After the retention period, recordings are securely deleted or destroyed.
25.4 The Company ensures confidentiality of all audio and video recordings, including prohibition of unauthorized access, copying, transmission, or use by third parties, except in cases expressly provided by law, court order, or written agreement with the data subject.
25.5 Audio and video recordings may be used as evidence in administrative, pre-trial, and judicial proceedings, as well as for protecting the interests of the Company, its employees, or clients, including but not limited to: breaches of contracts, disciplinary offenses, attempts of fraud, violations of professional ethics, or applicable laws.

26. TERMS REGARDING REMOTE SERVICES AND CLOUD PROVIDERS
26.1 The Company may use remote digital services, cloud storage, SaaS, PaaS, and IaaS platforms, as well as external technological solutions for storing, processing, analyzing, and transferring personal data strictly within the scope necessary to fulfill contractual obligations, ensure business continuity, comply with regulatory requirements, and protect the legitimate interests of the Company.
26.2 All third-party providers of cloud and remote services to whom the Company grants access to personal data are required to comply with applicable data protection legislation, including Federal Decree-Law No. 45 of 2021 (PDPL), as well as international security standards (including but not limited to: ISO/IEC 27001, SOC 2, GDPR — if applicable), unless otherwise provided by contract or law.
26.3 Prior to transferring personal data to such providers, the Company conducts comprehensive legal, technical, and operational due diligence, including mandatory verification of Data Processing Agreement terms, assessment of security mechanisms, backup procedures, physical and logical access segregation, provisions on cross-border data transfers and localization, as well as breach notification requirements.
26.4 Access to personal data stored on remote or cloud resources is granted exclusively to authorized employees or representatives of the Company, in accordance with the principle of least privilege (need-to-know) and internal approval. The Company implements strict access controls, logging, multi-factor authentication, encryption of data at rest and in transit, and security monitoring.
26.5 In cases where cloud storage or services are located outside the jurisdiction of the UAE, the Company commits to ensuring an equivalent or higher level of personal data protection than that mandated by UAE law. Such cross-border transfer is conducted solely on a lawful basis, including explicit consent of the data subject, recognition of adequacy of the recipient country’s legislation, or other legally provided safeguards.

27. TERM AND REVIEW OF THE POLICY
27.1 This Policy shall come into effect from the date of its approval by the authorized official of the Company and shall remain in force until it is officially replaced, revoked, or declared invalid in the prescribed manner. The Company reserves the unconditional right to review, amend, or supplement the Policy unilaterally in order to comply with changes in legislation, regulatory requirements, internal procedures, data processing practices, or service provision conditions.
27.2 The Policy shall be reviewed at least once every twelve (12) months or immediately following the entry into force of significant regulatory changes, including the adoption of new laws, decrees, resolutions, or official clarifications by regulatory authorities affecting personal data processing.
27.3 The updated version of the Policy shall take effect from the moment of its publication, provision to the data subject, posting on the Company’s official resources, or other means of notification to the data subject. In the case of material changes to the scope, purposes, or legal grounds for processing, the Company may require separate confirmation of the data subject’s consent to the new version of the Policy.
27.4 Data subjects bear sole responsibility for familiarizing themselves with the current version of the Policy. Upon the client’s first request, the Company shall provide the latest approved version in written or digital form, as well as upon signing documents related to the provision of services.
27.5 Effective date of this version: July 15, 2025. All previous versions of this Policy shall be considered null and void as of the specified date, except in cases where their application is required for legal assessment of actions performed during their period of validity.

28. CONTACT INFORMATION
For all questions related to personal data processing, exercising data subject rights, as well as for submitting requests, notifications, and inquiries, the data subject may contact the Company at the following details:
EG Elite property L.L.C.
Business Bay,
Mobile Phone: +971 50 778 78 41
Email: galuevaproperty@gmail.com