Address Point Privacy Policy

 

Address Point Properties (“Company”, “We”, “Us”, “Our”) is committed to protecting your privacy and ensuring the security of your Personal Data in strict compliance with the United Arab Emirates Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (“UAE PDPL”), Cabinet Resolution No. 56 of 2024 concerning the Regulation of Telemarketing Activities, Cabinet Resolution No. 57 of 2024 (Executive Regulations), Federal Decree-Law No. 34 of 2021 on Cybercrimes, and relevant real estate regulations issued by the Abu Dhabi Department of Municipalities and Transport (DMT) and other Relevant Authorities.

 

This Privacy Policy is a comprehensive legal document explaining how we collect, use, disclose, retain, and safeguard your information. It is designed to protect both your rights and the Company’s legitimate interests. By engaging with Address Point Properties, participating in our Events & Competitions, or using our services, you acknowledge the practices described herein. IF YOU DO NOT AGREE WITH ANY PROVISION HEREIN, YOU MUST IMMEDIATELY CEASE ALL USE OF OUR SERVICES AND NOT PROVIDE ANY PERSONAL DATA TO US.

1DATA CONTROLLER AND CONTACT INFORMATION

1.1 Data Controller Identity

For the purposes of the UAE PDPL and applicable Emirate-specific laws, the Data Controller responsible for your Personal Data is:

ADDRESS POINT PROPERTIES –

SOLE PROPRIETORSHIP L.L.C.

 

1.2 Data Protection Officer (DPO) / Privacy Contact

We have designated a specialized privacy team to oversee compliance with this Policy and UAE data protection laws. You may contact us at:

Email: privacy@approperties.ae

 

2SCOPE AND APPLICABILITY

2.1 Territorial and Operational Scope

This Policy applies to all Personal Data collected, processed, stored, or transmitted by Address Point Properties across the United Arab Emirates, including but not limited to:

– Our website (www.approperties.ae), mobile applications, client portals, and digital platforms;

– Marketing communications (email, SMS, WhatsApp, social media, ads, calls);

– Telephone interactions (including call recordings and voice analytics);

– In-person engagements (offices, events, exhibitions, property viewings, seminars, contests);

– Real estate transaction processes in Abu Dhabi, Dubai, and other Emirates;

– Interactions with AI Agents (chatbots, voice bots, automated valuation models);

– Third-party data sources where we act as a Controller or Joint Controller.

2.2 Relationship with Terms and Conditions

This Privacy Policy operates in conjunction with our Terms and Conditions. In the event of any inconsistency regarding data processing purposes, consent mechanisms, or liability limitations, this Privacy Policy shall prevail to the extent of such inconsistency, subject to mandatory provisions of UAE Federal Law that cannot be derogated by contract.

2.3 Updates and Modifications

We reserve the right to update this Privacy Policy to reflect changes in our practices, technology, or UAE laws. The “Effective Date” at the top of this document will be updated accordingly.

– Material Changes: Material changes will be communicated via our website, email, or other direct channels at least seven (7) days prior to implementation, where required by law.

– Acceptance: Continued use of our services after changes constitutes acceptance of the updated Policy.

– Historical Data: Updates may apply to Personal Data collected prior to the effective date where permitted by law.

3COMPREHENSIVE CATEGORIES OF PERSONAL DATA

We may collect, generate, receive, or infer the following categories of Personal Data. This list is exhaustive but not necessarily limited to:

3.1 Identity and Contact Data

• Full name, title, salutation, nationality, residency status, birthday;
• Government Identification Numbers (Emirates ID, Passport Number, Visa Number) where required for transactions or event verification;
• Phone numbers (mobile, landline, WhatsApp), email addresses;
• Physical addresses (current, permanent, mailing), location data (GPS);
• Preferred contact language, time zone, communication preferences.

3.2 Interaction and Communication Data

• Records of your interactions with us (website visits, form submissions, email correspondence, chat logs);
• Call Recordings: Audio recordings of telephone conversations between you and our representatives (human or AI);
• Marketing Engagement Data: Records of your responses to ads, posts, reels, emails, or SMS (e.g., clicks, opens, replies, conversion events);
• Expression of Interest Records: Documentation of the specific action that constituted your Expression of Interest (timestamp, channel, IP address);
• AI Interaction Logs: Transcripts, voice prints (if applicable), or logs of interactions with our AI Agents;
• Event & Competition Data: Registration details, participation records, contest entries, lucky draw submissions, attendance logs;
• Social Media Data: Publicly available data from social media profiles if you interact with us there (e.g., LinkedIn, Instagram).

3.3 Financial and Transactional Data

• Budget ranges, financing preferences, mortgage pre-approval status;
• Transaction records, payment receipts, commission agreements, brokerage contracts;
• Bank details (IBAN, account number) only when necessary for transaction execution and processed via secure payment gateways;
• Tax identification numbers (for compliance with UAE tax laws);
• Source of funds documentation (for AML compliance).

3.4 Technical and Device Data

• IP address, browser type, version, operating system;
• Device identifiers (IMEI, MAC address, Advertising ID);
• Cookies, web beacons, pixel tags, and similar tracking technologies;
• Login credentials, authentication tokens, session data;
• Network connection data, crash reports, performance logs.

3.5 Special Categories of Data (Sensitive Data)

We generally do not seek to collect Special Categories of Personal Data (e.g., health, biometric, religious, political data) unless strictly required for a specific transaction (e.g., visa processing assistance, medical insurance for property deals) or Event participation, and only with your explicit additional written consent as required by UAE PDPL Article 8.

3.6 Third-Party and AI-Generated Data

• Data sourced from public registers (DMT, DLD, Land Departments);
• Data purchased from licensed data brokers or lead generation partners;
• Data generated by our AI systems (e.g., property valuations, investment ROI projections, behavioral profiling scores).

4EXHAUSTIVE PURPOSES OF DATA PROCESSING

We process your Personal Data only for specific, explicit, and legitimate purposes. Any use beyond these purposes will require additional consent unless permitted by law.

4.1 Service Delivery and Lead Management

• Responding to your inquiries, property requests, and Expressions of Interest;
• Qualifying leads to match you with suitable properties in Abu Dhabi, Dubai, or other Emirates;
• Scheduling property viewings, consultations, follow-up meetings, and site visits;
• Managing client relationships throughout the real estate transaction lifecycle;
• Facilitating transactions with developers, owners, government authorities, and banks.

4.2 Marketing and Communications

• Sending you property updates, market reports, promotions, and newsletters;
• Conducting customer satisfaction surveys, feedback collection, and net promoter score (NPS) analysis;
• Retargeting advertisements based on your interaction history;
• Contacting you via telephone, email, SMS, or WhatsApp in accordance with your Expression of Interest or Event Participation;w
• Inviting you to events, webinars, exhibitions, property launches, contests, or educational sessions.

4.3 Events, Competitions and Promotions

• Administering contests, competitions, lucky draws, seminars, talks, roadshows, dinners, and other events;
• Verifying eligibility, selecting winners, and distributing prizes;
• Adding participants to our marketing database (as per Section 5.3 of Terms and Conditions);
• Using participant names, images, and testimonials for publicity and marketing purposes;
• Complying with UAE regulations governing promotions and competitions.

4.4 Call Recording, Quality Assurance and AI Training

 

CRITICAL NOTICE REGARDING CALL RECORDINGS AND AI

We process call recordings and interaction data for the following specific purposes:

• Quality Assurance: Monitoring service standards, compliance with internal policies, and script adherence;
• Staff Training: Evaluating and improving the performance of our human agents, sales staff, and support teams;
• AI System Improvement: Training, refining, and enhancing our Artificial Intelligence (AI) agents, voice recognition systems, natural language processing models, and conversational interfaces to handle future inquiries more effectively, accurately, and efficiently;
• Dispute Resolution: Maintaining an accurate, tamper-evident record of agreements, instructions, complaints, or verbal contracts;
• Regulatory Compliance: Fulfilling record-keeping obligations under UAE Telemarketing Regulations (Cabinet Resolution No. 56 of 2024) and Real Estate Laws.

Consent Mechanism:

1. Prior Consent: By interacting with our marketing campaigns, submitting an Expression of Interest, or participating in Events (as per our Terms and Conditions), you grant prior consent for call recording and AI processing.
2. Verbal Notification: To comply with Article 4(7) of Cabinet Resolution No. 56 of 2024, you will be notified at the start of each recorded call. Continuing the call confirms your consent.
3. Irreversibility: You acknowledge that data used to train AI models may be anonymized and aggregated, making specific erasure of trained model weights technically impossible, though your raw Personal Data will be deleted upon request subject to legal holds.

4.5 Regulatory and Legal Compliance

• Verifying identity against UAE sanctions lists, PEP lists, or anti-money laundering (AML) requirements;
• Submitting required data to Abu Dhabi DMT, Dubai Land Department (DLD) or other authorities for transaction registration (Oqood, Tawtheeq, etc.);
• Responding to lawful requests from UAE judicial, regulatory, or law enforcement authorities;
• Compliance with UAE tax laws (VAT, Corporate Tax), economic substance regulations, and ultimate beneficial owner (UBO) reporting;
• Defending legal claims, lawsuits, or regulatory investigations.

4.6 Security and Fraud Prevention

• Detecting, preventing, and investigating fraud, security breaches, identity theft, or prohibited conduct;
• Securing our digital platforms, physical offices, and network infrastructure;
• Protecting the vital interests of our clients, employees, and the public;
• Monitoring for cyber threats and implementing incident response protocols.

4.7 Business Operations and Analytics

• Conducting data analytics, market research, and trend analysis;
• Improving website functionality, user experience, and service offerings;
• Internal auditing, risk management, and business continuity planning;
• Managing corporate transactions (mergers, acquisitions, asset sales).

5LEGAL BASIS FOR PROCESSING (UAE PDPL COMPLIANCE)

Under UAE PDPL Article 6 and Executive Regulations, we process your Personal Data based on one or more of the following lawful bases:

Legal Basis	Application & Examples
Consent	Where you have provided explicit, informed, and unambiguous consent (e.g., marketing communications, call recordings, AI training, sensitive data, Event participation). Your “Expression of Interest” constitutes valid consent under Cabinet Resolution 56/2024.
Performance of Contract	Where processing is necessary to execute a brokerage agreement, sale/purchase agreement, lease contract, or service agreement you have entered into with us.
Legal Obligation	Where we are required by UAE law (e.g., DMT/DLD regulations, AML laws, Tax laws, Cybercrime Law) to collect, retain, or disclose data.
Legitimate Interest	Where processing is necessary for our legitimate interests (e.g., network security, fraud prevention, AI improvement, service quality, direct marketing to existing clients), provided such interests do not override your rights and freedoms.
Public Interest	Where processing is necessary for public health, safety, or statutory functions performed by the Company under government authorization.
Vital Interests	Where processing is necessary to protect your life or physical safety (e.g., emergency contact during property viewing).

6DATA SHARING AND DISCLOSURE

We do not sell your Personal Data. We may share your data with the following categories of recipients under strict confidentiality and data processing agreements:

6.1 Government and Regulatory Authorities

• Abu Dhabi Department of Municipalities and Transport (DMT): For property registration, permit verification, transaction compliance, and licensing in Abu Dhabi.
• Dubai Land Department (DLD): For property registration, permit verification, transaction compliance, and Form A reporting in Dubai.
• UAE Federal Authorities: Including Ministry of Economy, TDRA (for telemarketing compliance), UAE Data Office, Ministry of Interior, Federal Tax Authority, and law enforcement agencies where required by law or court order.

6.2 Authorized Partners and Service Providers

• Developers and Property Owners: To facilitate viewings, negotiations, reservations, and transactions for specific properties.
• Partner Brokers: Where a referral is necessary to fulfill your inquiry (e.g., an Abu Dhabi-based inquiry for a Dubai property), subject to confidentiality agreements and Relevant Authority licensing.
• Technology Providers: Cloud storage providers (e.g., AWS, Azure, Google Cloud), CRM systems (e.g., Salesforce, HubSpot), telephony providers, AI service providers, website hosting partners, and cybersecurity vendors.
• Legal and Financial Advisors: Lawyers, notaries, mortgage brokers, banks, insurance companies, and valuation firms involved in your transaction.
• Event Partners: Sponsors, vendors, venues, and promotional agencies associated with Events & Competitions.
• Professional Services: Auditors, accountants, consultants, and insurers.

6.3 Cross-Emirate Data Transfers (Abu Dhabi ↔ Other Emirates)

To provide seamless service across the UAE, your Personal Data may be transferred between our offices in Abu Dhabi (headquarters), Dubai, and other Emirates. Such transfers are conducted internally under strict security protocols aligned with UAE PDPL Article 29, including binding corporate rules and internal data protection policies.

6.4 International Data Transfers

Your Personal Data is primarily stored and processed within the United Arab Emirates. In the event that data must be transferred outside the UAE (e.g., to a global cloud server provider or international partner):

• We shall ensure the destination country has adequate data protection laws approved by the UAE Data Office; OR
• We shall implement appropriate safeguards (e.g., Standard Contractual Clauses, Binding Corporate Rules) as per UAE PDPL Article 29; OR
• We shall obtain your explicit consent for the transfer; OR
• The transfer is necessary for the performance of a contract between you and us, or for implementing pre-contractual measures at your request; OR
• The transfer is necessary for important reasons of public interest.

6.5 Business Transfers and Asset Sales

In the event of a merger, acquisition, reorganization, bankruptcy, or sale of assets, your Personal Data may be transferred as part of the business assets. We will require the acquiring entity to honor this Privacy Policy or provide equivalent protection.

6.6 User-Generated Content and Public Forums

If you post information on public forums, blogs, or social media pages associated with the Company, that information may be visible to other users and the public. We are not responsible for the privacy practices of other users who view such content.

7DATA RETENTION PERIODS

We retain Personal Data only for as long as necessary to fulfill the purposes outlined in this Policy or as required by law. Retention periods are determined based on legal, regulatory, and business requirements.

Data Category	Retention Period	Legal Basis / Reason
Inquiry and Lead Data	24 months from last interaction (unless converted to client)	Legitimate Interest / Consent
Client Transaction Records	5 to 10 years	DMT/DLD Regulations & UAE Commercial Transactions Law
Call Recordings	24 months from date of call	Quality Assurance / Telemarketing Regulations
Marketing Consent Records	7 years from consent or withdrawal	Cabinet Resolution 56/2024 Compliance & Internal Policy
Event & Competition Data	7 years from event conclusion	Dispute Resolution / Tax / Audit
CCTV Footage (Offices)	30 days (unless incident reported)	Security & Safety
AI Training Data	Anonymized data may be retained indefinitely for model improvement	Legitimate Interest (Irreversible Aggregation)
Financial & Tax Records	5 to 15 years	UAE Tax Law & AML Regulations
Legal Hold Data	Indefinite (until litigation/resolution concludes)	Legal Obligation / Defense of Claims

Upon expiry of the retention period, data shall be securely deleted, anonymized, aggregated, or destroyed in accordance with UAE Data Office standards and industry best practices.

8YOUR RIGHTS UNDER UAE PDPL

Under Federal Decree-Law No. 45 of 2021 (UAE PDPL) and Executive Regulations, you possess the following rights regarding your Personal Data. These rights are subject to applicable legal exceptions and limitations.

8.1 Right to Access

You may request confirmation of whether we are processing your Personal Data and obtain a copy of such data in a concise, transparent, and intelligible format.

8.2 Right to Correction

You may request correction of any inaccurate, incomplete, or outdated Personal Data held by us. We may require evidence to verify the correct data.

8.3 Right to Erasure (“Right to Be Forgotten”)

You may request deletion of your Personal Data where:

– The data is no longer necessary for the original purpose;

– You withdraw consent (where consent was the basis);

– The processing was unlawful;

– Erasure is required to comply with a legal obligation.

Note: This right is subject to legal retention obligations (e.g., DMT/DLD transaction records, AML laws, call recording regulations, legal holds).

8.4 Right to Restriction and Objection

You may request restriction of processing or object to processing based on legitimate interests (e.g., direct marketing). If you object to direct marketing, we will cease processing for that purpose immediately.

8.5 Right to Data Portability

Where technically feasible and processed by automated means, you may request to receive your data in a structured, commonly used, machine-readable format to transfer to another controller.

8.6 Right to Withdraw Consent

You may withdraw consent for marketing or call recording at any time. Withdrawal does not affect the lawfulness of processing prior to withdrawal. Withdrawal may limit our ability to provide certain services.

8.7 Rights Regarding Automated Decision-Making

You have the right not to be subject to a decision based solely on automated processing (including profiling) which produces legal effects concerning you, unless necessary for a contract or based on explicit consent. You may request human intervention during any AI interaction.

8.8 How to Exercise Your Rights

To exercise any of these rights, please submit a written request to our Data Protection Officer at privacy@approperties.ae.

– Verification: We may request verification of your identity before processing your request to prevent unauthorized access.

– Timeline: We will respond within thirty (30) days as required by UAE PDPL. This period may be extended by another 30 days for complex requests, with notice to you.

– Fees: Requests are generally free, but we may charge a reasonable fee for manifestly unfounded or excessive requests.

9CALL RECORDING AND AI ENGAGEMENT SPECIFICS

9.1 Call Recording Consent Framework

• Prior Consent: By making an Expression of Interest or participating in Events, or interacting with our website or any of our marketing materials on any channel, you provide prior consent for call recording and processing.
• Verbal Notification: At the start of each call, you will hear: “This call may be recorded as consented to in our Terms. By continuing, you confirm your consent.” or a similar variation thereof.
• Storage: Recordings are stored on secure, encrypted servers within the UAE.
• Access: Access is restricted to authorized personnel for training, QA, compliance, and legal defense.
• Usage: Recordings may be used as evidence in disputes, regulatory investigations, or legal proceedings.

9.2 AI Agent Engagement

• Disclosure: You will be informed if you are interacting with an AI Agent.
• Human Handover: You may request to speak to a human representative at any time during an AI interaction.
• AI Training: Interactions may be used to train our AI models. We implement safeguards (e.g., anonymization, pseudonymization) to prevent the AI from memorizing or revealing sensitive Personal Data.
• Profiling: We may use AI to profile your property preferences for future interactions to give you the best service. You may opt-out of profiling for marketing purposes.

9.3 Data Localization

Call recordings and core Personal Data are stored on servers located within the United Arab Emirates to comply with data localization principles under UAE PDPL and sector-specific regulations. Cross-border transfers are only conducted with adequate safeguards.

10DATA SECURITY MEASURES AND LIMITATION OF LIABILITY

10.1 Technical and Organizational Measures

We implement appropriate technical and organizational measures to protect your Personal Data against unauthorized access, alteration, disclosure, destruction, or loss, including:

• Encryption: Data encrypted in transit (SSL/TLS) and at rest;
• Access Controls: Strict role-based access controls (RBAC), multi-factor authentication (MFA), and least-privilege principles;
• Network Security: Firewalls, intrusion detection/prevention systems (IDS/IPS), and regular vulnerability scanning;
• Secure Storage: Servers located within the UAE or in approved jurisdictions with strict access logs;
• Backup & Recovery: Regular backups and disaster recovery testing to ensure data availability.

10.2 Limitation of Security Liability

 

IMPORTANT DISCLAIMER REGARDING DATA SECURITY

While we implement industry-standard security measures, no method of transmission over the Internet or electronic storage is 100% secure. To the fullest extent permitted by UAE law:

• We cannot guarantee absolute security against sophisticated cyberattacks, force majeure, or user negligence (e.g., sharing your password);
• We shall not be liable for any indirect, incidental, special, or consequential damages arising from data processing or security breaches caused by factors beyond our reasonable control;
• We shall not be liable for data breaches caused by third-party processors who comply with their own privacy policies and our contractual requirements;
• Your failure to maintain secure credentials or devices may compromise your data, for which we shall not be held liable.

10.3 Indemnification Regarding Data Provision

You agree to indemnify, defend, and hold harmless Address Point Properties from any claims, losses, or damages arising out of:

– Your provision of false, inaccurate, or misleading Personal Data;

– Your misuse of another person’s Personal Data without their consent;

– Your violation of this Privacy Policy or applicable laws;

– Your failure to secure your own devices or credentials.

11COOKIES AND DIGITAL TRACKING

11.1 Use of Cookies

Our website uses cookies, pixels, and similar technologies to enhance user experience, analyze traffic, and support marketing efforts.

– Essential Cookies: Required for website functionality (e.g., login, security).

– Analytics Cookies: Help us understand user behavior (e.g., Google Analytics).

– Marketing Cookies: Used for retargeting and ad performance (e.g., Meta Pixel, Google Ads).

– Functional Cookies: Remember your choices (e.g., language, region).

11.2 Consent Management

You may manage cookie preferences via our website banner. Disabling certain cookies may affect website functionality.

11.3 Third-Party Tracking

We may allow third-party partners to place cookies on your device to serve relevant advertisements. These third parties are bound by their own privacy policies. We are not responsible for their practices.

11.4 Do Not Track (DNT)

Our systems may not respond to “Do Not Track” browser signals as there is no uniform standard under UAE law. We rely on cookie consent banners for tracking control.

12CHILDREN’S PRIVACY

Our services are not directed to individuals under the age of 18 years. We do not knowingly collect Personal Data from minors.

– Parental Consent: If we require data from a minor (e.g., for family visa processing related to property or Event participation), we will obtain verifiable parental consent.

– Deletion: If we become aware that we have collected data from a minor without parental consent, we will take steps to delete such information immediately.

13WEBSITE CONTENT AND DATA ACCURACY DISCLAIMER

 

As stated in our Terms and Conditions (Section 2):

– Some information processed by us (e.g., property details, valuations, ROI projections) may be AI-generated or sourced from third parties.

– We do not warrant the accuracy, completeness, or timeliness of such third-party or AI-generated data.

– You indemnify Address Point Properties from any responsibility for any actions or decisions taken by you based on such data without consulting directly with our team.

– This Policy governs how we process that data, but does not guarantee its accuracy.

14COMPLAINTS AND REGULATORY RECOURSE

14.1 Internal Complaints

If you have a complaint regarding our handling of your Personal Data, please contact our Data Protection Officer at privacy@approperties.ae. We aim to resolve complaints within thirty (30) days.

14.2 External Recourse

If you are unsatisfied with our response, you have the right to lodge a complaint with:

– UAE Data Office: For PDPL violations.

– TDRA: For telemarketing violations (DNCR, call recording).

– DMT/DLD: For real estate-specific data matters.

– Competent Courts: As per the jurisdiction clauses in our Terms and Conditions.

15GOVERNING LAW AND JURISDICTION

This Privacy Policy is governed by the Federal Laws of the United Arab Emirates.

– For Abu Dhabi-specific data matters, Abu Dhabi Courts shall have jurisdiction.

– For Dubai-specific data matters, Dubai Courts shall have jurisdiction.

– Federal authorities (UAE Data Office) have oversight nationwide.

– Nothing in this Policy limits your right to file a complaint with the UAE Data Office.

16ACKNOWLEDGMENT

 

BY ENGAGING WITH ADDRESS POINT PROPERTIES OR USING OUR WEBSITE OR ANY OTHER DIGITAL PLATFORM OF ADDRESS POINT PROPERTIES, YOU ACKNOWLEDGE THAT:

1. You have read, understood, and agreed to this Privacy Policy;
2. You consent to the collection, processing, and storage of your Personal Data as described herein;
3. You specifically consent to call recording for training, quality assurance, and AI improvement, subject to the verbal notification protocol at the start of each call;
4. You understand that participation in Events & Competitions adds you to our marketing database;
5. You understand that some data processed may be AI-generated or third-party sourced, and accuracy is not warranted as per our Terms;
6. You understand your rights under UAE PDPL and how to exercise them, subject to legal limitations;
7. You agree that your data may be transferred between our Abu Dhabi, Dubai, and other Emirate offices for service delivery;
8. You acknowledge the Limitation of Liability and Indemnification clauses in Section 10.

© 2026 Address Point Properties. All Rights Reserved. Abu Dhabi, UAE.