- INTRODUCTION
This Privacy Policy explains how Royce Properties L.L.C., a real estate brokerage company duly licensed and operating in Dubai, United Arab Emirates (together “Royce Real Estate”, the “Company”, “we”, “us” or “our”), collects, uses, discloses, stores and protects personal data.
This Privacy Policy is issued in accordance with Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (the PDPL), its implementing regulations, and other applicable UAE laws.
By engaging our services, accessing our website or digital platforms, communicating with us, or otherwise providing personal data to us, you acknowledge that you have read, understood and agree to be bound by this Privacy Policy. If you do not agree to this Privacy Policy, you should not provide us with any personal data.
- DATA CONTROLLER
For the purposes of the PDPL, Royce Properties L.L.C. acts as the data controller in respect of personal data processed in connection with its brokerage and related activities. Where the Company acts as a data processor on behalf of third parties, separate processing agreements shall govern such arrangements.
- SCOPE OF THIS PRIVACY POLICY
This Privacy Policy applies to personal data relating to:
- clients, buyers, sellers, landlords and tenants;
- investors and prospective clients;
- website and digital platform users;
- business partners and professional contacts; and
- any individual whose personal data is processed in the course of our business operations.
This Privacy Policy applies regardless of whether personal data is collected online, offline, verbally, in writing, or through electronic or digital means.
- CATEGORIES OF PERSONAL DATA
We may collect and process the following categories of personal data:
4.1 Identification Data
- full name;
- nationality;
- date of birth (where legally required);
- passport, Emirates ID or other identification details (where required for compliance).
4.2 Contact Data
- mobile and landline telephone numbers;
- email addresses;
- residential or correspondence addresses.
4.3 Transaction and Property Data
- property requirements and preferences;
- transaction history and records;
- viewing schedules and communications;
- contractual and mandate-related information.
4.4 Compliance and Regulatory Data
- information required for anti-money laundering, know-your-customer and sanctions screening;
- source of funds information, where required by law.
4.5 Technical and Usage Data
- IP address;
- browser type and device information;
- website usage, analytics and interaction data.
- LEGAL BASIS FOR PROCESSING
Personal data is processed on one or more of the following lawful bases under the PDPL:
(a) performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract;
(b) compliance with a legal or regulatory obligation to which the Company is subject;
(c) the legitimate interests pursued by the Company or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject;
(d) the data subject has given explicit consent to the processing of their personal data for one or more specific purposes; or
(e) processing is necessary to protect the vital interests of the data subject or of another natural person.
- PURPOSES OF PROCESSING
Personal data is processed for the following purposes:
- provision of real estate brokerage and related services;
- identifying and marketing suitable off-plan and secondary market opportunities;
- facilitating property viewings, negotiations and Transactions;
- compliance with UAE laws, RERA regulations, DLD requirements and regulatory authorities;
- communication with clients regarding enquiries, Transactions and service updates;
- internal record-keeping, risk management and business administration; and
- direct marketing communications, subject to obtaining the data subject’s prior explicit consent in accordance with UAE PDPL Article 4(1)(d) and applicable telecommunications regulations, including the right to withdraw such consent at any time.
- DATA SHARING AND DISCLOSURE
We do not sell or trade personal data. However, personal data may be disclosed to:
- developers, sellers, landlords and counterparties involved in Transactions;
- banks, mortgage providers and financial institutions;
- legal advisers, auditors, insurers and professional consultants;
- government authorities, regulators and law enforcement agencies where required by law; and
- service providers supporting IT, hosting, analytics, communications or operational functions.
The Company shall ensure that all recipients of personal data are subject to appropriate contractual obligations, including obligations of confidentiality and data protection, and that such recipients process personal data only in accordance with the Company’s documented instructions and applicable data protection laws.
- INTERNATIONAL DATA TRANSFERS
Personal data shall not be transferred outside the UAE except in accordance with UAE PDPL Article 22 and where: (a) the destination country has been determined by the UAE Data Office to provide an adequate level of protection; (b) appropriate safeguards have been implemented, including standard contractual clauses approved by the UAE Data Office or binding corporate rules; or (c) one of the derogations specified in Article 22(3) of the PDPL applies. The Company shall document the legal basis for any international transfer and make such documentation available to data subjects upon request.
- DATA RETENTION
Personal data shall be retained only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law. Retention periods are determined based on:
- compliance with legal and regulatory obligations;
- contractual and mandate requirements; and
- legitimate business needs.
Once personal data is no longer required for the purposes for which it was collected and there is no legal obligation to retain it, the Company shall securely delete or destroy such personal data, or render it anonymous in an irreversible manner, in accordance with the Company’s data retention and deletion policy and applicable law.
- DATA SECURITY
The Company implements and maintains appropriate administrative, technical and organisational security measures in accordance with UAE PDPL Article 7 to protect personal data against:
- unauthorised access or disclosure;
- loss, misuse or alteration; and
- accidental destruction; and
(d) any other form of unlawful processing.
Access to personal data is restricted to authorised personnel on a strict need-to-know basis, and all such personnel are subject to appropriate confidentiality obligations.
- MARKETING COMMUNICATIONS
Where permitted by applicable law, we may send marketing communications relating to property opportunities, market insights and promotional offers.
Data subjects have the right to withdraw their consent to receive marketing communications at any time, without affecting the lawfulness of processing based on consent before its withdrawal. Data subjects may exercise this right by using the unsubscribe mechanism provided in each communication or by contacting the Company through the contact details provided in Clause 15 below. The Company shall process any opt-out request within 5 business days of receipt.
- DATA SUBJECT RIGHTS
Subject to the PDPL and applicable law, data subjects may have the right to:
- request access to their personal data;
- request correction or updating of inaccurate data;
- request deletion or restriction of processing, where applicable;
- withdraw consent where processing is consent-based; and
- object to certain processing activities.
Requests to exercise data subject rights must be submitted in writing to the contact details specified in Clause 15 below. The Company shall respond to such requests within 30 days of receipt, or such other period as may be prescribed by the UAE Data Office. The Company may request additional information to verify the identity of the data subject making the request. Where a request is refused, the Company shall inform the data subject of the reasons for refusal and their right to lodge a complaint with the UAE Data Office.
- COOKIES AND TRACKING TECHNOLOGIES
The Company’s website and digital platforms use cookies and similar tracking technologies. Certain cookies are strictly necessary for the operation of the website, while others are used to enhance functionality, analyse usage and improve user experience. Where required by applicable law, the Company shall obtain the user’s prior consent before deploying non-essential cookies. Users may manage their cookie preferences through browser settings
- AMENDMENTS TO THIS PRIVACY POLICY
The Company reserves the right to update or amend this Privacy Policy from time to time to reflect changes in law, regulation or business practices. Where material changes are made that affect the processing of personal data, the Company shall notify affected data subjects through appropriate means, which may include email notification or prominent notice on the Company’s website. The updated Privacy Policy shall become effective on the date specified in the notice, which shall be no less than 30 days from the date of notification for material changes. Continued use of the Company’s services following the effective date shall constitute acceptance of the updated Privacy Policy.
- CONTACT INFORMATION
For enquiries, requests or concerns regarding this Privacy Policy or the processing of personal data, please contact Royce Real Estate through its official communication channels.
