1. Introduction and Scope

Al Marwan Real Estate Development L.L.C. is committed to protecting personal data in accordance with the provisions of Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data in the United Arab Emirates (PDPL), the European Union General Data Protection Regulation (GDPR), the United Kingdom General Data Protection Regulation (UK GDPR), and relevant international standards.

This Privacy Policy applies to all users of our website (https://almarwandevelopments.com), mobile applications, and all related services and businesses, regardless of the user's location. By using our services, you acknowledge that you have read this Privacy Policy and agree to the data processing practices described herein.

2. Collection of Personal Data

2.1 Categories of Data Collected We may collect the following categories of personal data:

Contact and Identity Information: Name, email address, phone number, nationality, address, and any other contact details you provide to us.
Investment Information: Property preferences, budget range, investment goals, and related real estate interests you share with us.
Technical Information: Internet Protocol (IP) address, browser type, device information, operating system, and usage data collected via standard web technologies.
Communication Records: Records of consultations, inquiries, and commercial correspondence with our team.
Application Data: Information collected through mobile applications and Customer Relationship Management (CRM) systems.

2.2 Methods of Data Collection Personal data may be collected through the following:

Contact forms and consultation requests via the website.
Use of mobile applications and registration processes.
Direct communications and consultations.
Customer Relationship Management systems (including Microsoft Dynamics CRM).
Standard web technologies including cookies and analytics tools (including Google Analytics).
Business meetings and property viewings.

3. Legal Basis and Purposes of Processing

3.1 Legal Basis for Data Processing We process personal data based on the following legal grounds:

Legitimate Business Interests: To operate our real estate development business, provide consultancy services, and maintain client relationships, where such processing is necessary and proportionate. Our legitimate interests include service improvement, market trend analysis, and ensuring digital platform security.
Contract Performance: To fulfill service agreements, process real estate transactions, and deliver requested services.
Consent: In cases where you provide explicit consent for specific processing activities, such as marketing communications or non-essential cookies.
Legal Compliance: To comply with applicable laws, regulations, and legal requirements.

3.2 Purposes of Processing Personal data may be used for the following purposes:

Providing real estate consultancy and advisory services.
Managing client relationships and real estate interests.
Processing property inquiries and investment opportunities.
Providing personalized property recommendations.
Improving our services and digital platforms.
Managing business communications and customer support.
Complying with legal and regulatory requirements.
Any other purposes consistent with our legitimate business interests.

4. Data Sharing and Transfer

4.1 Data Sharing We may share personal data with the following entities:

Service Providers: Third-party service providers who support business operations, technical services, and customer support, including Google Analytics and Microsoft Dynamics CRM, under appropriate data protection agreements.
Real Estate Sector Partners: Property developers, agents, and related professionals when necessary to execute services and complete real estate transactions.
Legal and Regulatory Authorities: When required by law, regulations, or legal proceedings, or to protect our rights and interests.
Corporate Transactions: In the context of mergers, acquisitions, or other business transactions, subject to appropriate confidentiality and protection measures.

4.2 International Data Transfer Personal data may be transferred to countries outside the United Arab Emirates for business purposes, particularly to serve international clients and investors, including transfers to the United States for the use of Google Analytics and other service providers. When making such transfers, we implement appropriate safeguards as required by applicable laws, including Standard Contractual Clauses approved by the European Commission, and adequacy assessments in accordance with the requirements of the UAE Personal Data Protection Law (PDPL), in addition to applying encryption technologies during data storage and transfer.

5. Data Subject Rights

In accordance with applicable laws, you may have the following rights:

Right of Access: To request information about the personal data we hold about you.
Right to Rectification: To request the correction of any inaccurate or incomplete personal data.
Right to Erasure: To request the deletion of personal data under specific circumstances.
Right to Restriction of Processing: To request the restriction of processing of personal data in certain cases.
Right to Object: To object to data processing based on legitimate interests or for direct marketing purposes.
Right to Data Portability: To request the transfer of personal data in a structured, machine-readable format, where technically feasible.
Withdrawal of Consent: To withdraw consent for processing that is based on consent, without affecting the lawfulness of prior processing. You may withdraw your consent for marketing or cookies through the consent banner on the website or by contacting us directly.

To exercise any of these rights, please contact us using the contact details provided below. We will respond to requests within one month, which may be extended by two additional months in complex cases, in accordance with Article 12(3) of the GDPR.

Right to File a Complaint: You have the right to file a complaint with the UAE Data Office, the competent supervisory authority in the European Union, or the Information Commissioner’s Office (ICO) in the United Kingdom.

6. Data Retention and Security

6.1 Data Retention We retain personal data only for as long as necessary to fulfill the purpose for which it was collected or to meet legal obligations, after which it is securely deleted or irreversibly anonymized. Current retention periods are as follows:

Contact and Commercial Data: For 5 years after the last interaction or as required by law.
Technical and Usage Data: For 2 years for analysis purposes.
Marketing Data: Until consent is withdrawn.
Other Data: As dictated by legal compliance requirements and business purposes.

These periods may be updated in the event of changes to UAE laws, and the longest applicable mandatory retention period will always be applied.

6.2 Data Security We implement appropriate technical and organizational measures to protect personal data from unauthorized access, alteration, disclosure, or destruction. However, no security system can be completely immune, and we cannot guarantee the absolute security of personal data.

7. Cookies and Tracking Technologies

Our website and mobile applications use cookies and similar technologies to enhance user experience, analyze usage patterns, and provide customized services. These categories include:

Essential Cookies: Necessary for the website and applications to function correctly.
Analytical Cookies: Used to track usage patterns and analyze performance (e.g., Google Analytics).
Marketing Cookies: Enable the sending of targeted marketing communications (with your consent).
Personalization Cookies: Used to customize property recommendations and content according to your interests.

You may provide consent for the use of marketing or non-essential cookies through the consent banner on our website. To withdraw consent, you may use the "Manage Preferences" link on the site or contact us directly. Please note that essential cookies necessary for the operation of the site and services cannot be disabled without affecting the service's performance and core functions.

8. Privacy Policy Updates

We may update this Privacy Policy from time to time to reflect any changes in our practices or applicable laws and regulations. Updated versions will be posted on our website and mobile applications with an indication of their effective date. Your continued use of our services following the posting of any updates constitutes your acceptance of the revised Privacy Policy.

9. Contact Information

For inquiries regarding privacy or to exercise your data protection rights, please contact us at:

Al Marwan Real Estate Development L.L.C. Email: [---------] Address: [---------] Data Protection Officer: [---------] (For all privacy-related matters)