PRIVACY POLICY
PRAMER REAL ESTATE L.L.C Trade License No. 1605263Effective Date: 8 April 20261. INTRODUCTION
PRAMER REAL ESTATE L.L.C ("Pramer," "we," "our," or "us"), a company licensed and operating in the United Arab Emirates (Trade License No. 1605263), is committed to protecting the privacy and personal data of all individuals who interact with us — including clients, prospective buyers and tenants, landlords, website visitors, and business partners.This Privacy Policy explains how we collect, use, store, share, and protect your personal information in accordance with: Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (PDPL) — the UAE's primary federal data protection legislation; Federal Decree-Law No. 20 of 2018 on Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT) and its implementing regulations; Applicable regulations of the Dubai Land Department (DLD) and the Real Estate Regulatory Agency (RERA); Any other applicable UAE laws and regulations.By using our website, CRM channels, submitting inquiries or your data through portals (Property Finder, Bayut, Meta Ads, Google Ads), or engaging our real estate services, you acknowledge that you have read and understood this Privacy Policy.2. WHO WE ARE (DATA CONTROLLER)
For the purposes of the UAE PDPL, PRAMER REAL ESTATE L.L.C acts as the Data Controller responsible for your personal data.Registered Address: PRAMER REAL ESTATE L.L.C Citadel Tower, Business Bay, Dubai, UAEData & Privacy Inquiries: info@pramer.ae3. PERSONAL DATA WE COLLECT
We may collect and process the following categories of personal data, limited to what is necessary for the specific purpose of collection (data minimisation principle):3.1 IDENTITY & CONTACT INFORMATION
Full name, date of birth, nationality, gender Emirates ID, passport number, UAE residency visa details Email address, phone number, postal/residential address3.2 PROPERTY & TRANSACTION INFORMATION
Properties you own, are seeking to purchase or sell Property specifications, title deed details, Ejari registration data Transaction history, purchase/sale agreements, tenancy contracts Trakheesi permit details and advertising references3.3 FINANCIAL INFORMATION
Payment details and banking information Source of funds and source of wealth (required under AML/CFT regulations) Credit history and financial statements where relevant to property transactions Virtual asset transaction details where applicable3.4 KYC & COMPLIANCE INFORMATION
Ultimate Beneficial Owner (UBO) information Corporate documentation for legal entities Sanctions screening results and risk assessment data Any information required for goAML/FIU reporting obligations3.5 MARKETING PREFERENCES, COMMUNICATIONS & INTERACTION DATA
By submitting your data, you consent to: Records of emails, phone calls, WhatsApp messages, and in-person meetings Correspondence related to property inquiries, property recommendations, promotional campaigns, retargeting ads via Meta and Google, offers, and negotiations, feedback, complaints, and survey responses Your communication preferences and consent status for marketingYou may opt out at any time via:Unsubscribe linksDirect request3.6 WEBSITE & DIGITAL USAGE DATA
IP address, browser type, device information Pages visited, time spent on site, referral source Essential cookies, Cookie data (please see our Cookie Policy for details) Analytics (Google Analytics), Advertising pixels (Meta Pixel, Google Ads) Interactions with our property listings and search features4. HOW WE COLLECT YOUR PERSONAL DATA
We collect personal data through the following means: Directly from you: when you submit an inquiry form, register on our website, visit our office, sign a brokerage agreement, or communicate with our agents; Automatically: via cookies and similar tracking technologies when you browse our website; From third parties: property portals (Bayut, Property Finder, Dubizzle), developers, financial institutions, government databases (DLD, RERA/Trakheesi), and referral partners — where permitted by law; From public sources: publicly available registries, court records, or information you have made publicly available.5. LEGAL BASIS FOR PROCESSING
In accordance with the UAE PDPL, we process your personal data on the following lawful grounds:Your Consent: Marketing communications, use of non-essential cookies, sending newslettersPerformance of a Contract: Processing your property transaction, preparing tenancy agreements, facilitating purchase/sale
Legal Obligation: AML/CFT compliance, KYC verification, goAML reporting to the FIU, data retention required by UAE Ministry of Economy and DLD
Protection of Public Interest: Reporting suspicious transactions, fraud prevention, regulatory compliance
Legitimate Business Interests: Improving our services, website analytics, internal record-keeping, business developmentWhere we rely on your consent, you have the right to withdraw it at any time without affecting the lawfulness of processing carried out before withdrawal.
6. PURPOSES OF PROCESSING
We use your personal data for the following purposes:6.1 Real Estate Services To facilitate property search, listings, viewings, negotiations, purchase, sale, and lease transactions; to prepare and execute brokerage agreements, MOUs, tenancy contracts, and related documentation; and to register transactions with DLD/RERA.6.2 AML/CFT Compliance To conduct customer due diligence (CDD) and enhanced due diligence (EDD) where required; to verify the identity of clients and beneficial owners; to screen against sanctions and PEP lists; and to file Real Estate Activity Reports (REARs) via the goAML platform with the UAE Financial Intelligence Unit (FIU), as required under Federal Decree-Law No. 20 of 2018.Pursuant to the UAE Ministry of Economy circular, we are legally required to retain records and transaction data for a minimum of five (5) years.6.3 Communication & Customer Support To respond to your inquiries; to provide updates on your transactions; to send appointment confirmations; and to deliver post-transaction support.6.4 Marketing & Promotions To send property recommendations, market reports, promotional materials, and newsletters — only with your prior consent, and with the option to unsubscribe at any time.6.5 Legal & Regulatory Compliance To comply with DLD, RERA, UAE Ministry of Economy, and any other applicable regulatory requirements; to respond to lawful requests from authorities; and to protect our legal rights.6.6 Analytics & Service Improvement To analyse how our website and services are used, identify trends, and improve user experience and service quality.7. DATA SHARING & DISCLOSURE
We do not sell your personal data. We may share your data only in the following circumstances:7.1 With Service Providers (Processors) Third-party suppliers who provide services on our behalf — including IT and CRM platforms, marketing agencies, payment processors, legal advisors, and translation services — under strict data processing agreements ensuring PDPL compliance.7.2 With Government & Regulatory Authorities Dubai Land Department (DLD), Real Estate Regulatory Agency (RERA), UAE Ministry of Economy, Financial Intelligence Unit (FIU/goAML), UAE Data Office, law enforcement agencies, and courts — where required by law or to comply with a legal obligation.7.3 With Property Developers & Financial Institutions Developers, banks, and mortgage providers involved in property transactions in which you participate — only to the extent necessary to complete the transaction.7.4 With Property Portals Property listing platforms such as Bayut, Property Finder, and Dubizzle — to advertise properties in accordance with Trakheesi/RERA advertising regulations.7.5 In Business Transfers In the event of a merger, acquisition, or sale of business assets, your data may be transferred as part of the transaction. You will be notified of any such change.7.6 Cross-Border Transfers If your data is transferred outside the UAE, we ensure that appropriate safeguards are in place in accordance with Article 22 of the UAE PDPL, including contractual protections or transfers to jurisdictions with adequate data protection standards.8. DATA SECURITY
We implement robust technical and organisational measures to protect your personal data against unauthorised access, loss, alteration, or disclosure. These measures include: End-to-end encryption of data in transit and at rest Access controls limiting data access to authorised personnel only Firewall protection and secure server environments Regular security audits and staff privacy training Incident response procedures — in the event of a data breach that may affect your privacy, we will notify the UAE Data Office and, where required, affected individuals, in accordance with UAE PDPL obligations9. DATA RETENTION
We retain your personal data only for as long as necessary to fulfil the purposes outlined in this Policy, subject to the following minimum retention periods required by UAE law: Real estate transaction records: minimum 5 years from transaction date (UAE Ministry of Economy circular, AML/CFT regulations) KYC/CDD documentation: minimum 5 years from the end of the business relationship Tenancy and brokerage agreements: for the duration of the contract plus 5 years Marketing data: until consent is withdrawn or you opt out Website analytics data: up to 2 yearsUpon expiry of applicable retention periods, personal data is securely deleted or anonymised.10. YOUR RIGHTS UNDER THE UAE PDPL
In accordance with Federal Decree-Law No. 45 of 2021, you have the following rights regarding your personal data:Right of Access: Request a copy of the personal data we hold about you, free of chargeRight to Rectification: Request correction of inaccurate or incomplete data
Right to Erasure: Request deletion of your data where it is no longer necessary for the original purpose (subject to our legal retention obligations)
Right to Restriction: Request that we restrict processing of your data in certain circumstances
Right to Data Portability: Request that your data be provided in a structured, commonly used format
Right to Withdraw Consent: Withdraw consent for marketing or non-essential processing at any time
Right to Object: Object to processing based on legitimate interestsTo exercise any of these rights, please contact us at https://pramer.ae with the subject line "Data Subject Request." We will respond within a reasonable timeframe in accordance with PDPL requirements.Please note that some requests may be limited where processing is required to comply with our legal obligations (e.g., AML/CFT retention requirements).