Who the data controller is
The controller of your personal data is:
| Controller | Real Lux Prime Properties L.L.C |
|---|---|
| Trade licence | No. 1496086, issued by the Dubai Department of Economy and Tourism (DET) |
| Activity | Real Estate Buying & Selling Brokerage |
| Address | Al Ameri Tower, 19th floor, Atelier Business Center, Dubai (United Arab Emirates) |
| Contact | [email protected] · WhatsApp +971 54 352 0551 |
In this policy, “Lux Prime”, “we” or “the agency” means Real Lux Prime Properties L.L.C, which trades under the Lux Prime Estate brand.
Which law applies
We process your data under UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (PDPL) and other applicable regulations in Dubai.
If you live in the European Union or in another country with its own data protection law, we also respect the rights that law gives you, to the extent it applies to our relationship with you.
What data we collect
Data you give us
- Contact details: first name, surname, phone, email and country of residence.
- Details of your investment search: property type, areas, approximate budget, payment method, timing and the project or property you are interested in.
- Your account details for the Lux Prime Club and the Lux Prime Academy: username, password (encrypted) and course progress.
- Messages you send us by form, email, WhatsApp, phone or video call.
- Transaction documents if you buy or sell with us: passport, ID document, proof of address, source of funds and the details needed for the contract, the DLD and the developer.
Data collected automatically
- Technical browsing data: IP address, device and browser type, pages visited, date and time, and the page you came from.
- Data from cookies and similar technologies. We explain this in our cookie policy.
We do not ask for special category data (health, religion, ethnic origin, political opinions, etc.). Please do not send it to us.
What we use your data for
| Purpose | Legal basis |
|---|---|
| Answering your enquiries and requests for information, brochures, floor plans or yield studies. | Your consent and the steps you ask us to take before a possible transaction. |
| Advising you on finding, reserving, buying, selling or renting a property, and handling the transaction with developers, owners, the DLD and other parties. | Performance of our service and of any contract we sign with you. |
| Creating and maintaining your Lux Prime Club and Lux Prime Academy account and giving you access to its content. | The terms of use you accept when you register. |
| Sending you, by WhatsApp or email, opportunities, market news and Academy content that match your profile. | Your consent, which you can withdraw at any time. |
| Meeting legal obligations, in particular the anti-money-laundering and customer identification (KYC) rules that apply to real estate brokers in the UAE. | Compliance with a legal obligation. |
| Improving the website, measuring its use and protecting it from abuse. | Our legitimate interest in a website that works well and is secure. |
We do not make decisions about you based solely on automated processing that produce legal effects or significantly affect you.
Who we share your data with
We do not sell your data. We only share it when necessary to provide our service or to comply with the law:
- Our team of advisers, who only access the data they need to help you.
- Developers, owners and other agencies involved in the transaction you are interested in, when you ask us to move forward with it.
- Official bodies such as the Dubai Land Department (DLD) and the Real Estate Regulatory Agency (RERA), banks, escrow trustees and authorities where the law requires it.
- Providers who work for us: website hosting and CRM (LeadConnector / HighLevel), messaging (WhatsApp, by Meta), email and video-call tools. They may only use your data on our instructions.
- External professionals such as lawyers, agents or tax advisers, when you ask us to or when the transaction requires it.
Transfers outside the UAE
Some of our providers (for example the CRM and messaging) store data on servers outside the United Arab Emirates, mainly in the United States and the European Union. When this happens, we do so in the cases permitted by the PDPL and require those providers to apply appropriate security measures.
As many of our clients live outside the UAE, it is also normal for us to contact you and send you documents in your country of residence.
How long we keep your data
- Enquiries and contacts that do not lead to a transaction: while you remain interested and for no more than 3 years from our last contact, unless you ask us to delete them sooner.
- Club and Academy account: while you keep it active. If you close it, we delete it within a reasonable period.
- Transaction and customer identification (KYC) data: for as long as UAE regulations require, which for anti-money-laundering purposes is at least 5 years from the end of the relationship.
Your rights
Under the PDPL, you can ask us at any time for:
- Access: to know what data of yours we process and to get a copy.
- Rectification: to correct inaccurate or incomplete data.
- Erasure: to delete your data when it is no longer needed, unless the law requires us to keep it.
- Restriction: to stop using it temporarily in certain cases.
- Objection: to our using your data to send you marketing communications.
- Portability: to receive your data in a structured format to take to another provider.
- Withdraw your consent at any time, without affecting what we did before.
To exercise these rights, email [email protected] stating which right you wish to exercise. We may ask you to prove your identity. We will reply within the time limits set by law.
To stop receiving marketing messages you can also reply “STOP” to our WhatsApp messages or use the unsubscribe link in our emails.
If you believe we have not handled your data properly, you can complain to the UAE Data Office or to the data protection authority in your country.
Security
We apply reasonable technical and organisational measures to protect your data: encrypted connections (HTTPS), CRM access restricted by username and password, and team access limited to what is necessary. No system is infallible, but if we detect a security breach that affects you, we will act and notify you where the law requires.
Minors
Our services are intended for people aged 18 or over. We do not knowingly collect data from minors. If you believe a minor has given us their data, write to us and we will delete it.
Changes to this policy
We may update this policy to reflect legal changes or changes to our services. The current version, with its update date, will always be published on this page. If the change is significant, we will let you know by email or WhatsApp.