Privacy Policy

1. Introduction

1.1. Who We Are

Peak Trust Global Real Estate LLC ("we," "our," or "us") is a real estate company registered in Dubai, United Arab Emirates. Our registered office is located at Office No. 15th, 15th floor, Fahidi Heights, Trident Nexus Business Centre, Khalid Bin Al Waleed Road, Dubai, UAE. DED License No.: 49142, ORN: 1474329.

1.2. Purpose of This Policy and Scope

This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you:

• Visit our website peaktrust.ae
• Use our real estate services, including property listings, viewings, and transactions
• Interact with us as a client, lead, or prospective client
• Subscribe to our newsletters or marketing communications
• Contact us through any communication channel

1.3. Applicable Law

This Privacy Policy is designed to comply with the UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data ("PDPL"), which governs the processing of personal data in the United Arab Emirates. We are committed to protecting your privacy rights in accordance with this legislation and international best practices.

2. Data Controller / Contact

2.1. Details of Data Controller

Peak Trust Global Real Estate LLC is the data controller responsible for the processing of your personal data. For any privacy-related inquiries, data subject rights requests, or concerns about how we handle your personal information, please contact us:

2.2. Data Protection Officer (DPO) or Privacy Contact

For privacy-related inquiries, data subject rights requests, or to withdraw consent, please contact us using the contact information provided above. We will respond to your request within a reasonable timeframe as required by applicable law.

3. Data We Collect

3.1. Information You Provide Directly

We collect information that you provide directly to us when you interact with our services, including:

• Personal identification information: Name, email address, phone number, nationality, Emirates ID or passport number (when required for transactions)
• Property preferences and search criteria: Budget range, property type, location preferences, number of bedrooms, amenities, and other property requirements
• Feedback and survey responses: Reviews, ratings, comments, and responses to our surveys
• Correspondence: Records of communications, inquiries, requests, and interactions with our team
• Financial information: Bank account details, payment information (processed securely through third-party payment processors), and financial documentation when required for property transactions
• Contract and transaction information: Purchase agreements, rental contracts, property viewing records, and related documentation

3.2. Automatically Collected Information

When you visit our website or use our services, we automatically collect certain information about your device and how you interact with our platform, including:

• Device information: Device type, operating system, browser type and version, screen resolution, and device identifiers
• IP address and location data: Your IP address, approximate geographic location (country, city), and time zone
• Usage data: Pages visited, time spent on pages, click patterns, search queries, referring website addresses, and navigation paths
• Cookies and tracking technologies: Information collected through cookies, web beacons, pixel tags, and similar technologies (see Section 10 for details)
• Log files: Server logs, error logs, and system logs that may contain your IP address and other technical information

4. Legal Basis & Consent

4.1. Legal Bases for Processing

Under the UAE PDPL, we process your personal data based on one or more of the following legal bases:

• User Consent: When you have given clear consent for us to process your personal data for specific purposes (e.g., marketing communications, newsletter subscriptions, non-essential cookies)
• Contractual Obligation: When processing is necessary to perform a contract with you or to take steps at your request before entering into a contract (e.g., processing property inquiries, arranging viewings, managing transactions)
• Legal Compliance: When processing is necessary to comply with a legal obligation to which we are subject (e.g., tax reporting, anti-money laundering requirements, regulatory compliance)
• Legitimate Interest: When processing is necessary for our legitimate business interests, provided that such interests do not override your fundamental rights and freedoms (e.g., website analytics, fraud prevention, security, business operations, customer relationship management)

4.2. How Consent is Obtained

We obtain your consent through various means, depending on the type of processing:

• Forms and checkboxes: Explicit consent checkboxes on contact forms, inquiry forms, and registration forms
• Subscription consent: Separate consent for newsletter subscriptions and marketing communications
• Cookies consent banner: Cookie consent banner that appears when you first visit our website, allowing you to accept, reject, or customize cookie preferences
• Transaction consent: Consent obtained during the property transaction process, including terms and conditions acceptance

All consent mechanisms are designed to be clear, specific, and easy to understand. We do not use pre-checked boxes or assume consent by default.

4.3. Ability to Withdraw Consent and Opt-Out

You have the right to withdraw your consent at any time. You can withdraw consent by:

• Clicking the unsubscribe link in any marketing email
• Contacting us directly at [email protected] or +971-50-226-0017
• Using the cookie settings in the website footer to manage cookie preferences
• Submitting a data subject rights request (see Section 9)

Withdrawing consent will not affect the lawfulness of processing based on consent before its withdrawal. However, withdrawing consent may limit your ability to use certain features of our services.

5. Purpose of Use

We use your personal data for the following purposes:

• Provide and manage services: To provide property listings, arrange property viewings, facilitate communications between clients and developers, manage property transactions, and deliver our real estate services
• Process enquiries, requests, and contracts: To respond to your inquiries, process property requests, manage contracts, handle transactions, and provide customer support
• Send property listings, market updates, and newsletters: To send you relevant property listings, market updates, newsletters, and promotional materials (with your consent)
• Website analytics, improvement, and personalization: To analyze website usage, improve our website functionality, personalize your experience, and optimize our services
• Fraud detection, security, and legal compliance: To detect and prevent fraud, ensure security, comply with legal obligations, and protect our rights and the rights of our users
• Other legitimate business activities: To conduct business operations, manage customer relationships, perform data analytics, and support our business functions

6. Data Sharing & Third-Party Processors

6.1. Categories of Recipients

We may share your personal data with the following categories of recipients:

• Property developers and partners: To facilitate property viewings, transactions, and related services
• Service providers: Third-party vendors who assist with our operations, including:
  • Email service providers and marketing platforms
  • Cloud hosting and infrastructure providers
  • Payment processors and financial service providers
  • Customer relationship management (CRM) systems
  • Analytics and data analytics tools (e.g., Google Analytics)
  • IT support and maintenance providers
• Legal or regulatory authorities: When required by law, court order, or regulatory requirements, or to protect our rights and the rights of others
• Business successors: In connection with a merger, acquisition, sale of assets, or other business transfer

6.2. Purposes of Sharing

We share your personal data only for the purposes outlined in this Privacy Policy, including:

• To provide and deliver our services
• To process transactions and manage contracts
• To improve our services and user experience
• To comply with legal obligations
• To protect our rights and prevent fraud

6.3. Assurance of Confidentiality, Data-Processing Agreements, and Safeguard Measures

We take appropriate measures to ensure that third parties who process your personal data on our behalf:

• Are bound by strict confidentiality obligations
• Enter into data processing agreements that comply with applicable data protection laws
• Implement appropriate technical and organizational security measures
• Process your data only for the purposes we specify and in accordance with our instructions
• Do not use your data for their own purposes without your consent

6.4. Statement That We Do Not Sell Personal Data

We do not sell, rent, or trade your personal data to third parties for their marketing purposes.We only share your personal data as described in this Privacy Policy and in accordance with applicable laws.

7. Data Transfers Outside UAE

Your personal data may be transferred to and processed in countries outside the United Arab Emirates, including countries that may not have the same data protection laws as the UAE. This may occur when:

• We use cloud hosting services or data centers located outside the UAE
• We engage service providers or partners based in other countries
• We use analytics or marketing tools that process data internationally

Safeguards and Compliance

When we transfer your personal data outside the UAE, we ensure appropriate safeguards are in place to protect your data, including:

• Standard contractual clauses or similar contractual arrangements that ensure adequate protection
• Verification that the recipient country has adequate data protection laws or equivalent safeguards
• Implementation of technical and organizational security measures
• Regular monitoring and assessment of data transfer arrangements

By using our services, you consent to the transfer of your personal data to countries outside the UAE as described in this Privacy Policy.

8. Data Retention

We retain your personal data for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. Our data retention practices are based on:

• Purpose of processing: We retain data for as long as necessary to provide our services and fulfill the purposes for which it was collected
• Legal obligations: We may retain certain data for longer periods to comply with legal obligations, such as tax laws, anti-money laundering regulations, or real estate transaction record-keeping requirements (typically 5-10 years for financial and transaction records)
• Legitimate business interests: We may retain data for legitimate business interests, such as fraud prevention, dispute resolution, or business analytics
• Consent-based processing: For data processed based on consent, we retain it until you withdraw consent or the purpose is fulfilled

Data Deletion and Anonymization Policy

When personal data is no longer needed for the purposes for which it was collected, we will:

• Delete or anonymize the data in a secure manner
• Ensure that deleted data cannot be recovered or reconstructed
• Retain only anonymized or aggregated data for statistical or analytical purposes where appropriate

If you request deletion of your personal data (see Section 9), we will process your request in accordance with applicable law, subject to any legal obligations that require us to retain certain information.

9. Your Rights Under PDPL

Under the UAE Federal Decree-Law No. 45 of 2021 (PDPL), you have the following rights regarding your personal data:

9.1. Right to Access Personal Data

You have the right to request access to your personal data that we hold, including information about:

• The categories of personal data we process
• The purposes for which we process your data
• The recipients or categories of recipients with whom we share your data
• The retention period or criteria for retention

9.2. Right to Correct or Update Inaccurate Data

You have the right to request correction or updating of any inaccurate or incomplete personal data we hold about you.

9.3. Right to Deletion / Erasure

You have the right to request deletion of your personal data, subject to certain exceptions, such as when:

• We are required to retain the data by law
• The data is necessary for the establishment, exercise, or defense of legal claims
• The data is needed for legitimate business interests

9.4. Right to Object to Processing

You have the right to object to the processing of your personal data for certain purposes, including direct marketing and processing based on legitimate interests.

9.5. Right to Withdraw Consent

When processing is based on consent, you have the right to withdraw your consent at any time. Withdrawing consent will not affect the lawfulness of processing based on consent before its withdrawal.

9.6. Right to Data Portability

You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit that data to another controller, where technically feasible.

How to Exercise Your Rights

To exercise any of these rights, please contact us using the following methods:

• Email: [email protected] (subject line: "Data Subject Rights Request")
• Phone: +971-50-226-0017
• Post: Peak Trust Global Real Estate LLC, Office No. 15th, 15th floor, Fahidi Heights, Trident Nexus Business Centre, Khalid Bin Al Waleed Road, Dubai, UAE

Timeframe: We will respond to your request within a reasonable timeframe, typically within 30 days of receipt, as required by applicable law. We may request additional information to verify your identity before processing your request.

10. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to enhance your experience, analyze our traffic, and provide personalized content. Our cookie usage adapts based on your location to comply with applicable privacy laws, including GDPR for EU/EEA visitors and UAE PDPL.

10.1. Types of Cookies Used

10.2. Purpose of Each Cookie Category

• Essential cookies: Necessary for the website to function properly and cannot be disabled
• Analytics cookies: Help us understand website usage, improve performance, and optimize user experience
• Marketing cookies: Enable targeted advertising and measure campaign effectiveness
• Functional cookies: Remember your preferences and provide enhanced features

10.3. How Users Can Manage or Opt-Out of Cookies

You can manage your cookie preferences at any time by:

• Clicking the "Cookie Settings" link in the website footer to access our cookie preference center
• Adjusting your browser settings to block or delete cookies (instructions vary by browser)
• Using browser extensions or privacy tools for cookie management
• Opting out of specific third-party cookies through their respective opt-out mechanisms

Note: Disabling certain cookies may affect website functionality and limit your access to some features.

10.4. For EU/EEA Users: Explicit Consent Before Non-Essential Cookies

For visitors from the EU/EEA, we require explicit consent before setting non-essential cookies, in compliance with GDPR. Our cookie consent banner allows you to:

• Accept all cookies
• Reject non-essential cookies
• Customize your preferences by category

Your location is detected automatically using your IP address, and consent mechanisms are tailored accordingly.

11. Security Measures

We implement appropriate technical and organizational security measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. These measures include:

• Encryption: Use of encryption technologies (SSL/TLS) to protect data in transit and at rest
• Access control: Implementation of access controls, authentication mechanisms, and role-based permissions to ensure only authorized personnel can access personal data
• Secure storage: Secure storage of personal data using industry-standard security practices and secure data centers
• Backups: Regular backups of data with secure backup storage and recovery procedures
• Restricted access: Limiting access to personal data to employees, contractors, and agents who need to know that information to process it on our behalf, and who are subject to strict confidentiality obligations
• Security monitoring: Continuous monitoring for security threats, vulnerabilities, and unauthorized access attempts
• Employee training: Regular training of employees on data protection and security best practices
• Incident response: Procedures for detecting, reporting, and responding to security incidents

Limitations

While we strive to protect your personal data, no method of transmission over the Internet or electronic storage is 100% secure. We cannot guarantee absolute security, but we continuously work to improve our security measures and stay current with industry best practices. We encourage you to take appropriate measures to protect your personal information, such as using strong passwords and keeping your login credentials confidential.

12. Data Breach Notification

In the event of a personal data breach that is likely to result in a high risk to your rights and freedoms, we are committed to:

• Notifying affected parties: We will notify you without undue delay if a breach poses a high risk to your rights and freedoms
• Notifying authorities: We will report the breach to the relevant data protection authority in accordance with applicable law and within the required timeframe
• Providing information: Our notification will include information about the nature of the breach, the categories of data affected, the likely consequences, and the measures we are taking to address the breach

Timeframe and Method of Notification

We will notify you of a data breach as soon as reasonably possible, typically within 72 hours of becoming aware of the breach, as required by applicable law. Notifications will be sent via email to the email address we have on file, or through other appropriate communication channels if email is not available.

13. Children's Privacy

Our services are not directed to individuals under 18 years of age. We do not knowingly collect personal information from children under 18. If you are a parent or guardian and believe that your child has provided us with personal information, please contact us immediately at [email protected].

If we become aware that we have collected personal information from a child under 18 without parental consent, we will take steps to delete that information from our systems as soon as possible, in accordance with applicable law.

Age restrictions: By using our services, you represent that you are at least 18 years of age or have obtained parental consent if you are under 18.

14. Policy Updates

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make changes, we will:

• Update the "Last updated" date at the top of this page
• Post a notice on our website or send an email notification for material changes
• Display a banner or notification on our website for significant updates

How Users Are Notified About Changes

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your personal data. Your continued use of our services after any changes to this Privacy Policy constitutes your acceptance of the updated policy. If you do not agree with the changes, you may stop using our services or contact us to discuss your concerns.

For material changes that significantly affect your rights or how we use your data, we will provide more prominent notice, such as:

• Email notification to registered users
• Banner notification on our website
• In-app notifications (if applicable)

15. Contact Information

If you have questions, concerns, or requests regarding this Privacy Policy, our data practices, or to exercise your data subject rights, please contact us:

For privacy-related inquiries, data subject rights requests, or to withdraw consent, please use the contact information above. We will respond to your request within a reasonable timeframe as required by applicable law.