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Privacy Policy for AKD Real Estate

1. Introduction & Scope

This Privacy Policy outlines the practices of AKD Real Estate (referred to as “the business,” “we,” “us,” or “our”) concerning the collection, utilization, storage, sharing, and protection of personal data when individuals engage with our services, website, or interact with us. The business is committed to upholding transparency and ensuring compliance with all applicable data protection laws. This commitment extends specifically to the Digital Personal Data Protection Act (DPDPA) 2023 in India and Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (PDPL) in the UAE.

AKD Real Estate operates as a prominent real estate agency, specializing in both residential and commercial properties across India and the UAE. These markets are characterized by dynamic growth, propelled by rapid urbanization, strategic government initiatives, and continuous technological advancements. For instance, India’s real estate sector is poised for significant expansion, with its contribution to GDP projected to increase from 7% to 15% by 2030, driven by factors like urbanization and policy interventions such as RERA and Smart Cities Mission. Similarly, the UAE real estate market remains highly attractive to global investors, benefiting from strong economic growth, investor-friendly government policies, and a strategic location that fuels demand for diverse property types.

The provisions of this Privacy Policy apply to all individuals whose personal data the business processes, irrespective of their geographical location. It is specifically structured to meet the legal requirements for processing digital personal data within India, encompassing data initially collected in non-digital form but subsequently digitized. Furthermore, it extends its applicability to the processing of personal data outside India if such processing is linked to the offering of goods or services to individuals within India. Concurrently, this policy addresses personal data processing within the UAE and applies to foreign businesses that process the data of UAE residents, even if the processing occurs outside the country. This dual focus highlights a sophisticated operational framework, acknowledging that the business’s activities are not confined to a single regulatory environment but span multiple, interconnected legal landscapes. The explicit inclusion of both DPDPA and PDPL from the outset signals that the business navigates a complex operational environment, necessitating a policy that harmonizes or addresses the nuances of both regulatory frameworks. This approach goes beyond a simple listing of applicable laws; it demonstrates an understanding of how these laws interact and where they might differ or overlap, indicating a comprehensive approach to legal adherence.

By clearly defining key terms and stating its commitment to dual compliance upfront, the policy aims to foster trust and demonstrate a proactive stance on legal adherence. This is particularly vital in the real estate sector, which has historically faced challenges related to transparency and trust, especially in India. The introduction of regulations like RERA in India, for instance, was a direct response to inefficiencies, a lack of transparency, and a prevailing distrust among stakeholders. Therefore, a comprehensive and clearly articulated privacy policy serves as a strategic tool for reputation building and enhancing customer confidence. It conveys that the business not only meets its legal obligations but also regards data privacy as a fundamental operational principle, which can provide a significant competitive advantage in the market.

Key Definitions:

Personal Data: Any information pertaining to an identifiable individual, whether directly or indirectly. This encompasses, but is not limited to, an individual’s name, address, contact information, location data, date of birth, gender, online browsing history, and biometric data. In the UAE, this definition is further expanded to include elements such as voice, image, identification number, electronic identifier, and various physical, physiological, economic, cultural, or social characteristics that can identify a natural person.
Sensitive Personal Data: Under the UAE PDPL, this category specifically refers to data that directly or indirectly reveals a natural person’s family, racial origin, political or philosophical opinions, religious beliefs, criminal records, biometric data, or any data related to their health. While India’s DPDPA applies broadly to all personal data, this specific distinction for sensitive data is critical for ensuring full compliance with UAE regulations.
Data Principal/Data Subject: The individual to whom the personal data pertains.
Data Fiduciary/Controller: The entity, in this case, our real estate business, that determines the purpose and means of processing personal data.
Data Processor: An entity that processes personal data on behalf of a Data Fiduciary.
Processing: Any operation or set of operations performed on digital personal data, which includes a wide range of activities such as collection, storage, recording, organization, adaptation, retrieval, use, sharing, disclosure by transmission, dissemination or otherwise making available, restriction, erasure, or destruction.

2. Information We Collect

2.1. Types of Personal Data Collected

The business collects various categories of personal data to effectively provide and continually enhance its real estate services. This data is essential for facilitating property transactions, offering personalized experiences, and ensuring regulatory compliance. The types of personal data collected include:

Contact Information: This includes fundamental details such as first and last names, mailing address, physical address, email address, and telephone numbers. Such information is typically gathered when individuals interact with the business, for example, by filling out contact forms or registering for services.
Financial Information: Given the nature of real estate transactions, the collection of financial data is critical. This encompasses bank account details, credit card information (though processed via secure third-party payment tools and not directly stored by the business), loan details, closing costs, and other financial data pertinent to transactions. This information is indispensable for managing the high-value aspects of real estate dealings.
Property-Related Information: To deliver tailored real estate services, the business collects extensive data related to properties. This includes an individual’s home search history, properties viewed, saved listings, and specific property preferences. It also covers transaction records, such as sale prices, dates of transactions, and any pricing adjustments. Furthermore, detailed property characteristics like size, features, amenities, location, and the number of bedrooms or bathrooms are collected. Information on ownership history and property valuation data is also gathered. This comprehensive property data is vital for personalizing home search results for clients and for conducting thorough market analysis.
Identification Data: For compliance with legal and regulatory obligations, particularly Know Your Client (KYC) and Anti-Money Laundering (AML) protocols, the business collects various identification documents. These include passport copies, visa details, Emirates ID (for UAE residents), Permanent Account Number (PAN) card (which is mandatory for financial transactions in India), Driver’s License, and Social Security Number (if applicable for specific transactions or KYC requirements). The collection of such data is particularly relevant in the UAE, where enhanced due diligence is mandated for high-risk buyers, including foreign investors, requiring full verification of buyer identities and their sources of funds.
Technical & Usage Data: When individuals interact with the business’s digital platforms, technical and usage data is automatically collected. This includes IP addresses, geolocation data, browser type, device type, model, manufacturer, operating system, date and time stamps, and unique identifiers. Information on pages visited, links clicked, advertisements viewed, purchase processes, and other similar actions is also gathered. This data is typically collected through automated technologies to understand user activity, preferences, and to enhance service delivery.
Sensitive Personal Data: The business generally refrains from collecting sensitive personal data unless it is explicitly required for a particular service or mandated by a legal obligation. Should such data be collected (e.g., biometric data for secure access to specific facilities), it will be done with the individual’s explicit consent and in strict adherence to relevant laws, such as the UAE PDPL, which provides a clear definition for sensitive personal data.

2.2. How We Collect Information

The business employs a variety of channels to collect personal information, ensuring that data acquisition methods are aligned with the purposes of processing and legal obligations:

Directly from Individuals: Information is collected directly when individuals interact with the business through various means. This includes instances when a user registers for an account, completes contact forms, submits inquiries or questions via web forms, phone calls, or chat features, or provides feedback. Direct engagement for real estate services also falls under this category of collection.
Automatically: The business’s website and online services automatically collect certain data through the use of various technologies. These include cookies, web beacons, pixels, embedded scripts, mobile SDKs, and location-identifying technologies. This automated collection helps the business understand user activity, track preferences, and continuously improve the services offered.
From Third Parties: Information may also be obtained from external sources. This includes public records, Multiple Listing Service (MLS) systems, integrations with Customer Relationship Management (CRM) platforms, and affiliated service providers. For example, property listing data entry and market research often involve compiling data from diverse third-party sources to provide comprehensive insights.

The extensive requirement for identification and financial data, as detailed above, directly reflects the stringent Know Your Client (KYC) and Anti-Money Laundering (AML) regulations prevalent in the real estate sector, particularly within the UAE. This collection is not merely for facilitating service provision but is a fundamental legal mandate. The UAE, for instance, has significantly expanded its oversight and controls over its real estate sector, requiring enhanced due diligence for high-risk buyers, which includes foreign investors from jurisdictions with weaker anti-money laundering controls. KYC protocols in the UAE explicitly require full verification of buyer identities and their sources of funds, and corporate purchasers must disclose their ultimate beneficial owners. This means that the collection of such sensitive personal data is not discretionary but a direct legal obligation for any real estate business operating in the UAE, and by extension, for cross-border transactions involving Indian investors. This regulatory imperative directly dictates the scope and depth of the data collected.

While the collection of data is essential for regulatory compliance, it also serves a strategic purpose for the business. The policy indicates that data is used to “personalize home search results,” for “market analysis,” and to gain “competitive insights”. This dual role underscores that the business must carefully balance leveraging data for growth with the significant compliance burden imposed by strict data protection laws like DPDPA and PDPL. In a highly competitive market, characterized by substantial growth drivers in both India and the UAE, data is a valuable asset for understanding market trends, optimizing business strategies, and securing a competitive advantage. However, the same data, particularly sensitive financial and identification information, also presents a considerable compliance challenge under the prevailing data protection frameworks. Therefore, the business must invest in robust data governance practices to transform this compliance obligation into a strategic asset. This involves ensuring the accuracy, security, and ethical handling of data while adhering to legal mandates, necessitating a sophisticated approach to data management that extends beyond mere legal adherence.

Table 1: Types of Personal Data Collected and Their Purposes

Data Category	Specific Examples	Purpose of Collection
Contact Information	Name, Email, Phone Number, Physical Address	Account registration, communication, service delivery, lead generation, marketing communications
Financial Information	Bank Account Details, Credit Card Information, Loan Details, Source of Funds	Processing transactions, managing payments, verifying financial eligibility, anti-money laundering (AML) compliance
Property-Related Information	Home Search History, Saved Listings, Property Preferences, Transaction Records (sale prices, dates), Property Characteristics (size, features, amenities, location), Ownership History, Valuation Data	Personalizing home search results, providing real estate services, market analysis, property valuation, record-keeping, competitive insights
Identification Data	Passport Copies, Visa Details, Emirates ID, PAN Card, Driver’s License, Social Security Number	Identity verification, Know Your Client (KYC) compliance, anti-money laundering (AML) compliance, legal reporting obligations
Technical & Usage Data	IP Address, Geolocation Data, Browser Type, Device Type, Operating System, Unique IDs, Pages Visited, Clicks, Ads Viewed	Website functionality, service improvement, analytics, understanding user behavior, targeted advertising (with consent)
Sensitive Personal Data	Biometric Data, Health Data, Racial Origin, Criminal Records	Only collected with explicit consent when legally required for specific services (e.g., secure access, medical emergencies), or for public interest purposes, in strict compliance with UAE PDPL

3. How We Use Your Information

The personal data collected by the business is utilized for a range of specific, legitimate, and transparent purposes, all aimed at providing comprehensive real estate services, enhancing user experience, and ensuring legal and regulatory compliance.

3.1. Providing Real Estate Services

The primary use of collected data is to deliver the core real estate services offered by the business. This includes creating and managing user accounts, which often involve collecting account identifiers, usernames, and passwords to authenticate access and maintain account integrity. Personalizing home search results is a key service, where property-related information and preferences are used to tailor listings to individual needs. The business also uses data to facilitate property sales and rentals, communicate leads and services, and share relevant property listings with interested parties. This involves processing contact information, property preferences, and transaction details to ensure seamless interactions between buyers, sellers, and agents.

3.2. Internal Operations & Business Improvement

Beyond direct service provision, personal data supports the business’s internal operations and continuous improvement initiatives. This includes conducting market research and analysis to understand trends, such as pricing fluctuations, demand-supply dynamics, and neighborhood developments. This analysis is crucial for accurate property valuation and identifying lucrative investment opportunities, especially in rapidly evolving markets like India and the UAE. Data also aids in developing competitive insights by tracking competitors’ listings and pricing strategies. Furthermore, technical and usage data is analyzed to improve website functionality, enhance user experience, and optimize the overall digital platform. The business also uses data for internal record-keeping, financial tracking, and managing client databases, which are fundamental for efficient lead generation and nurturing strong customer relationships.

3.3. Communication and Marketing

Personal data is used to communicate with individuals regarding their inquiries, services, and relevant updates. This includes responding to questions, providing assistance, and sending periodic emails, newsletters, or market updates, provided consent has been obtained where required. Marketing communications are tailored based on user preferences and property search history, aiming to provide relevant information about new listings, investment opportunities, or market trends.

3.4. Legal and Regulatory Compliance

A significant portion of data usage is dedicated to fulfilling legal and regulatory obligations. This includes complying with Know Your Client (KYC) and Anti-Money Laundering (AML) regulations, which require thorough verification of buyer identities and sources of funds, particularly for high-value transactions and foreign investors in the UAE. The business also uses data to satisfy legal reporting obligations, prevent fraud, and manage potential legal disputes. This involves maintaining accurate records, ensuring data validation in contracts, and adhering to specific industry compliance standards, such as those set by RERA in India or the Dubai Land Department in the UAE.

3.5. Research and Development

Anonymized or aggregated data may be used for research and development purposes to identify broader market trends, develop new services, or enhance existing offerings without identifying individual users. This contributes to strategic optimization and competitive advantage within the real estate sector.

4. Legal Basis for Processing

The processing of personal data by the business is founded on specific legal bases, ensuring compliance with both the Digital Personal Data Protection Act (DPDPA) 2023 in India and Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (PDPL) in the UAE.

4.1. Consent

The primary legal basis for processing personal data is the explicit consent of the Data Principal. Consent must be freely given, specific, informed, unconditional, and unambiguous, demonstrated by a clear affirmative action. Before seeking consent, a notice is provided to the Data Principal, detailing the personal data to be collected and the purpose of processing. Data Principals have the right to withdraw their consent at any time through an accessible, transparent, and interoperable platform, and upon withdrawal, the business must cease processing that data unless another legal basis applies. For individuals under 18 years of age, consent is obtained from a parent or legal guardian. The DPDPA does not require granular consent for each processing purpose, allowing for general consent for various uses like marketing, advertising, and analytics, provided it is freely given and accompanied by an up-to-date privacy notice.

4.2. Legitimate Uses (India – DPDPA)

Under the DPDPA, personal data may be processed without prior consent for certain “legitimate uses”. These include:

Voluntary Provision of Data: If a Data Principal voluntarily provides their personal data to the business for a specific purpose (e.g., to a real estate broker for finding a rental property), the business may process that data for the stated purpose. However, if the individual subsequently withdraws their request, the business must cease processing the data.
Provision of Benefits or Services by the State: This applies when the individual has already consented to the processing of their personal data by the State or its instrumentalities for subsidies, benefits, services, certificates, licenses, or permits, or when such data is available in government databases.
Compliance with Legal Judgments or Orders: Processing is permissible if necessary for compliance with any judgment, decree, or order issued under Indian law, or any judgment or order related to contractual or civil claims under laws outside India.
Medical Emergencies: Processing is allowed when there is an immediate threat to an individual’s life or health.
Employment Purposes: Data processing necessary for employment purposes is also considered a legitimate use.

Any processing under these legitimate uses must be conducted lawfully, with data minimization principles applied, and with reasonable security measures in place to prevent misuse.

4.3. Exceptions to Consent (UAE – PDPL)

The UAE PDPL also outlines specific circumstances where processing personal data without the Data Subject’s consent is permitted. These exceptions include:

Public Interest: When processing is necessary to protect the public interest.
Publicly Available Data: If the personal data has been made public by the Data Subject.
Legal Claims and Procedures: When processing is necessary to establish any legal claim or defense of rights, or is related to judicial or security procedures.
Contractual Obligations: If processing is necessary to perform a contract to which the Data Subject is a party, or to take steps at the Data Subject’s request prior to entering into a contract.
Protection of Data Subject’s Interests: When processing is necessary to protect the vital interests of the Data Subject.
Compliance with Other Laws: If processing is necessary to fulfill obligations imposed by other laws of the UAE on Controllers.

These legal bases ensure that all data processing activities are conducted within a robust legal framework, balancing individual privacy rights with the operational needs of the business and its compliance obligations.

5. Data Security and Retention

The business prioritizes the security and confidentiality of personal data, implementing robust measures to protect against unauthorized access, disclosure, alteration, or destruction. This commitment extends to defining clear data retention periods to ensure data is not held longer than necessary.

5.1. Data Security Measures

The business employs a comprehensive set of technical and organizational safeguards to protect personal data throughout its lifecycle. These measures are designed to preserve the confidentiality, integrity, and availability of information. Key practices include:

Encryption and Pseudonymization: Sensitive documents are encrypted before being uploaded to cloud services, and pseudonymization techniques are used to conceal the identity of Data Subjects when data is retained beyond its original processing purpose.
Access Controls: Strict role-based access controls are implemented, limiting access to personal data only to authorized personnel who require it for their specific roles. This ensures that only individuals with a legitimate need can view or process sensitive information.
Network and Device Security: The business utilizes strong, unique, and complex passwords for all devices, accounts, and Wi-Fi networks, often managed through secure password managers. Two-factor authentication (2FA) is enabled for critical accounts, adding an extra layer of security. Firewalls and antivirus software are deployed to protect devices and networks from malware and unauthorized access. Public Wi-Fi networks are avoided for accessing sensitive data.
Physical Security: For physical documents containing sensitive information, secure filing systems, such as locked cabinets or safes, are utilized, with access restricted to authorized personnel.
Regular Updates and Monitoring: Operating systems, antivirus software, and applications are regularly updated to patch security vulnerabilities. The business also monitors for suspicious activity on bank accounts or software platforms and sets up alerts for unusual transactions.
Data Backup and Disaster Recovery: Important files are regularly backed up to secure external storage or reliable cloud providers, often with multiple backups, to ensure continued data processing in case of data loss or compromise.
Employee Training: All employees and partners are trained in cybersecurity best practices and data protection protocols. This education is crucial as many data breaches can be attributed to human error.
Secure Communication: Digital signature tools are used for contracts to ensure authenticity and encryption during transmission. Email accounts are separated for personal, business, and investment-related communications to mitigate risks like phishing.

The DPDPA in India mandates Data Fiduciaries to implement reasonable security safeguards to prevent personal data breaches. Similarly, the UAE PDPL requires Controllers to implement necessary standards for the protection and security of personal data, preserving confidentiality and privacy, and ensuring data is not breached, damaged, altered, or tampered with.

5.2. Data Retention

Personal data is retained only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable laws and regulations. The business adheres to specific data retention timelines:

General Personal Data: Data is ceased to be retained as soon as it is reasonable to assume that the purpose for which it was collected is no longer being served, or upon withdrawal of consent from the Data Principal, unless retention is necessary under other laws.
Real Estate Transaction Documents (UAE): For real estate transaction documents, a minimum retention period of 15 years is recommended in the UAE.
Corporate Tax Records (UAE): Financial statements and supporting documentation for Corporate Tax returns must be retained for a minimum of 7 years following the end of the relevant tax period.
VAT Records (UAE): Standard VAT records must be kept for a minimum of 5 years from the end of the relevant tax period, with capital asset records (machinery, equipment) requiring 10 years.
Employment and Payroll Records (UAE): These records should be retained for at least 7 years after employment termination, extending to 10 years in cases of workplace incidents or disputes.
Business and Legal Records (UAE): Contractual agreements are kept for a minimum of 7 years after completion, while commercial licenses, permits, and property ownership records are retained permanently.

The DPDPA in India requires Data Fiduciaries to erase personal data when it is no longer needed for the specified purpose or upon withdrawal of consent. The UAE PDPL prohibits keeping personal data after the purpose for its processing has ended, unless the identity of the Data Subject has been concealed using appropriate pseudonymization techniques.

The business also implements systematic document destruction procedures for expired records and maintains a log of such destructions. Regular compliance reviews are conducted to ensure adherence to changing regulations and to update document retention policies accordingly. Failure to maintain proper records can result in significant financial penalties, additional tax assessments, and difficulties in dispute resolution.

6. Data Sharing and Disclosure

The business may share and disclose personal data with third parties under specific circumstances, always ensuring that such sharing is necessary for the provision of services, compliance with legal obligations, or with the explicit consent of the Data Principal.

6.1. Sharing with Third-Party Service Providers

Personal data may be shared with trusted third-party service providers who perform functions on behalf of the business, such as payment processing, IT services, marketing, analytics, and property management. For example, third-party payment tools are used to process and store payment information, though the business itself does not store credit card numbers or bank account information directly. When engaging Data Processors, the business ensures that they are fully compliant with relevant data privacy requirements, and contractual agreements specify the limited purpose for sharing and obligate the third parties to uphold the same level of privacy protection. The business also verifies that any sub-processors meet the required standards.

6.2. Sharing with Affiliated Entities

Personal data may be shared with affiliated entities or partners within the business’s corporate group to provide integrated services, streamline operations, and enhance customer experience. Such sharing is governed by internal data protection policies consistent with this Privacy Policy.

6.3. Legal and Regulatory Requirements

The business may disclose personal data if required to do so by law, court order, or governmental regulation, or if such disclosure is necessary to protect the rights, property, or safety of the business, its customers, or the public. This includes responding to lawful requests from public authorities, complying with anti-money laundering (AML) regulations, and addressing property acquisition issues or land disputes. For instance, Data Fiduciaries in India can use a Data Principal’s personal data to meet any legal obligations that require sharing information with the government or its agencies.

6.4. Business Transfers

In the event of a merger, acquisition, sale of assets, or other business transaction, personal data may be transferred to the acquiring entity as part of the assets. In such cases, the business will ensure that the acquiring entity adheres to this Privacy Policy or provides a comparable level of data protection.

6.5. International Data Transfers

Given the business’s operations in both India and the UAE, personal data may be transferred across borders. Both the DPDPA in India and the PDPL in the UAE have specific regulations concerning international data transfers.

India (DPDPA): The DPDPA allows cross-border transfer of personal data to any country unless specifically restricted by the central government through notification. This framework is more permissive than earlier localization proposals but introduces regulatory uncertainty through the government’s power to blacklist countries.
UAE (PDPL): Personal data may be transferred outside the UAE to jurisdictions that have legislation for the protection of personal data, including provisions relating to the conditions and rules for protecting privacy and confidentiality. This “adequacy” can be established either through the country’s own privacy laws or its participation in binding international agreements. In the absence of an adequacy decision, transfers are permitted using standard contractual clauses (SCCs) or binding corporate rules (BCRs), which ensure the recipient upholds privacy protections aligned with UAE law. Transfers are also permitted with explicit consent from the Data Subject (provided it doesn’t conflict with public and security interests), to fulfill contractual obligations, or to comply with international judicial assistance requests. However, certain sensitive data, like banking and health records, may be subject to localization rules and require Central Bank approval and customer consent for transfer abroad.

The business ensures that any international data transfers comply with these respective legal frameworks, utilizing appropriate mechanisms such as consent, standard contractual clauses, or transfers to countries deemed to have adequate protection levels.

7. Your Data Protection Rights

Individuals whose personal data is processed by the business possess specific rights concerning their data, in accordance with the DPDPA in India and the PDPL in the UAE. The business is committed to facilitating the exercise of these rights.

7.1. Rights of Data Principals (India – DPDPA)

Under the DPDPA, Data Principals have the right to:

Right to Obtain Information: To receive information about the processing activities concerning their personal data. This includes an itemized description of the personal data and the specified purpose of processing.
Right to Correction and Erasure: To seek correction or updating of inaccurate personal data and to request the erasure of personal data when it is no longer needed for the specified purpose or upon withdrawal of consent.
Right to Grievance Redressal: To exhaust the opportunity of redressing their grievance through the established mechanism before escalating it to the Data Protection Board of India.
Right to Nominate: To nominate another person to exercise their rights in the event of death or incapacity.

Data Principals also have duties, including not registering false or frivolous complaints and ensuring they do not suppress any material information when providing personal data. Violations of these duties can incur penalties.

7.2. Rights of Data Subjects (UAE – PDPL)

The UAE PDPL grants Data Subjects a range of rights, including:

Right to Access: To request access to their personal data held by the business.
Right to Rectification: To correct inaccurate personal data.
Right to Erasure: To request the erasure of their data in specific circumstances.
Right to Restrict Processing: To restrict how their data is processed.
Right to Object: To object to processing for direct marketing or other specific cases.
Right to Data Portability: To receive their personal data in a structured, commonly used, and machine-readable format, and to transmit that data to another controller.

The business provides clear ways for users to request data access or deletion, typically through dedicated web forms or a toll-free number. Identity verification procedures are in place to ensure that requests are legitimate.

7.3. Children’s Privacy

The business does not knowingly collect personal data from individuals under the age of 18. If it is discovered that personal data of a child has been collected without verifiable parental consent, measures will be taken to delete such information promptly.

India (DPDPA): The DPDPA sets specific rules for processing children’s data, requiring verifiable consent from a parent or lawful guardian. It prohibits processing that is likely to have a detrimental effect on a child’s well-being, including restrictions on tracking, behavioral monitoring, or targeted advertising aimed at children. Exemptions may apply for healthcare and educational purposes.
UAE (PDPL): While the UAE PDPL does not contain specific provisions regulating the processing of a child’s personal data or parental consent, the broader legal framework, including Wadeema’s Law (Federal Law No. 3 of 2016 On Child Rights) and the Cybercrime Law (Federal Law No. 34 of 2021), underscores the importance of protecting children’s privacy and safeguarding them from online exploitation. The business recommends using clear and plain language in privacy policies when providing information to children, making it child-appropriate and easily understandable.

8. Cookies and Tracking Technologies

The business utilizes cookies and various tracking technologies on its website and online services to enhance user experience, analyze website traffic, and personalize content and advertising.

8.1. Use of Cookies

Cookies are small data files stored on an individual’s computer, while other related technologies include web beacons, pixels, embedded scripts, and mobile SDKs. These technologies help the business understand how users interact with its platforms, track their activity, and remember their preferences. This information is used for purposes such as personalizing home search results, providing real estate services, and delivering targeted advertisements.

8.2. Cookie Consent Requirements

Compliance with cookie consent requirements varies by jurisdiction:

India (DPDPA): The DPDPA requires that consent for data collection via cookies must be freely given, unconditional, informed, and unambiguous, demonstrated by a clear affirmative action (e.g., clicking an “ACCEPT COOKIES” button). Consent must not be tied to conditions, such as denying access to public website sections if cookies are declined. Privacy notices must be written in plain language, easy to understand, and in a readable font size. Unlike some other data privacy laws, the DPDPA does not require specific consent for each processing purpose, allowing for general consent for various cookie types (marketing, advertising, analytics, preferences), provided the overall consent is valid. The business must not allow the use of cookies before obtaining consent or assume consent through mere website browsing.
UAE (PDPL): The UAE PDPL requires clear, explicit consent from individuals before processing their personal data, which includes data collected via cookies. Consent should be unambiguous and recorded, ensuring the data subject understands what data is being collected and for what purpose. Businesses must be able to demonstrate that consent has been obtained, as it can be withdrawn at any time.

The business implements a cookie management system that includes a consent banner, allowing users to adjust cookie settings and providing a clear “Do Not Sell or Share My Personal Information” link where applicable. User preferences regarding cookies are saved and respected. A detailed cookie policy lists all cookies used, explains their purpose, specifies data retention periods, and highlights any third-party cookies involved.

9. Contact Information and Policy Updates

9.1. How to Contact Us

For any questions, concerns, or requests regarding this Privacy Policy or the business’s data practices, individuals may contact the business through the following channels:

Mailing Address:
Phone Number:
Email Address:
Online Contact Form:

The business is committed to providing clear ways for users to request data access or deletion and has established dedicated request channels, such as a web form specifically for privacy requests and a toll-free number for inquiries. Identity verification is implemented to ensure the security of these requests.

9.2. Changes to This Privacy Policy

The business reserves the right to update or modify this Privacy Policy periodically to reflect changes in its data practices, legal requirements, or market developments. Any revisions will be effective immediately upon posting the updated policy on the business’s website. Individuals are encouraged to review this Privacy Policy regularly to stay informed about how their personal data is being handled. The business is committed to keeping its privacy policies updated, as regulations continuously evolve.

10. Conclusions

This Privacy Policy for AKD Real Estate reflects a comprehensive approach to data governance, meticulously designed to navigate the intricate legal landscapes of both India and the UAE. The detailed exposition of data collection, usage, security, and individual rights underscores a commitment that extends beyond mere regulatory compliance.

The policy’s upfront declaration of adherence to both India’s DPDPA and the UAE’s PDPL highlights a crucial operational reality: for a real estate business operating across these dynamic markets, data privacy is not a monolithic challenge but a complex, interconnected regulatory endeavor. The explicit mention of dual compliance from the outset serves to set the correct legal context for all stakeholders, including clients and regulatory bodies. This proactive stance in articulating a harmonized approach to data protection is a strategic imperative. In a sector that has historically grappled with issues of transparency and trust, particularly evident in India’s journey towards regulatory reforms like RERA, a robust and clearly articulated privacy policy becomes a foundational element for building and maintaining client confidence. It positions the business as a trustworthy entity that values and safeguards personal data as a core operational principle, thereby fostering a competitive advantage.

Furthermore, the extensive detailing of identification and financial data collection within the policy is a direct consequence of stringent Know Your Client (KYC) and Anti-Money Laundering (AML) regulations, particularly pronounced in the UAE real estate market. The necessity for enhanced due diligence, especially for foreign investors, transforms what might appear as burdensome data collection into a non-negotiable legal obligation. This regulatory mandate dictates the depth and breadth of information acquired. Simultaneously, the policy’s articulation of data usage for purposes such as “personalizing home search results,” “market analysis,” and “competitive insights” reveals a dual perspective. While compliance with data protection laws demands significant investment and rigorous adherence, the very data collected for these purposes also serves as a strategic asset. In the high-growth real estate markets of India and the UAE, leveraging this data for informed decision-making, optimizing strategies, and gaining market advantage is paramount. This necessitates a sophisticated data management framework that not only mitigates compliance risks but also transforms data into a valuable resource for business expansion and innovation.

In essence, this Privacy Policy is more than a legal document; it is a testament to the business’s commitment to ethical data handling, operational excellence, and strategic positioning within a globally interconnected real estate ecosystem. By meticulously outlining its practices and empowering individuals with clear rights, the business aims to cultivate enduring trust and ensure sustainable growth in an increasingly data-driven world.