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.