Privacy Policy

1. Introduction and Scope of This Policy

Infinity Realty Real Estate LLC (“Company”, “we”, “us”, or “our”), a duly licensed real estate brokerage incorporated and operating under the laws of the United Arab Emirates, is committed to safeguarding the privacy and confidentiality of personal data entrusted to us by individuals who access, browse, or otherwise interact with our digital platforms, physical offices, and associated service channels.

This Privacy Policy (“Policy”) applies to all natural persons (“Data Subjects”, “you”, or “your”) whose personal data is processed by the Company in connection with the provision of real estate consultancy, property marketing, listing aggregation, investment advisory, and related ancillary services (“Services”). This Policy applies to all digital properties operated by the Company, including the website located at infinityrealty.ae, this landing page and any associated subdomains, mobile applications, or API integrations.

This Policy is issued in compliance with applicable data protection legislation, including Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (“UAE PDPL”) and any implementing regulations issued thereunder. Where the Company processes personal data of individuals located in the European Economic Area, the General Data Protection Regulation (EU) 2016/679 (“GDPR”) shall apply concurrently to the extent required by law.

2. Identity of the Data Controller

For the purposes of applicable data protection legislation, the Data Controller in respect of personal data processed pursuant to this Policy is Infinity Realty Real Estate LLC, a limited liability company incorporated and operating under the laws of the United Arab Emirates and licensed by the Real Estate Regulatory Agency (RERA). Contact details for the Data Controller are set out in Section 14 of this Policy.

3. Categories of Personal Data Collected

The Company may collect, receive, and process the following categories of personal data, depending on the nature of your interaction with our Services:

• Identity Data: full legal name, nationality, date of birth, Emirates ID number, passport number, and similar government-issued identification particulars.
• Contact Data: postal address, email address, telephone number(s), and preferred communication channel.
• Property Preference Data: property type preferences, budget ranges, desired locations, investment objectives, and transaction timeline.
• Financial Data: indicative budget or financing status, mortgage pre-approval information, and payment history where relevant to a concluded or ongoing transaction.
• Technical Data: internet protocol (IP) address, browser type and version, device identifiers, operating system, referring URL, pages visited, session duration, and other clickstream data collected automatically via cookies and similar tracking technologies.
• Marketing and Communications Data: your preferences in receiving marketing communications from us and your communication and contact preferences.
• Transaction Data: details about transactions you carry out through us or in respect of which we have acted as a facilitating or introducing broker.

The Company does not intentionally collect Special Categories of Personal Data (as defined under applicable data protection law) and requests that you refrain from submitting such information through our platforms.

4. Lawful Bases and Purposes of Processing

The Company processes personal data only where a valid lawful basis exists. The applicable lawful bases and corresponding purposes are as follows:

• Performance of a Contract: to respond to enquiries, facilitate property viewings, prepare tenancy or sale agreements, and deliver the Services you have requested.
• Legitimate Interests: to operate, improve, and promote our business; to conduct analytics and market research; to detect, investigate, and prevent fraudulent or unlawful activity; and to enforce our contractual and legal rights.
• Compliance with Legal Obligations: to fulfil our obligations under UAE anti-money laundering legislation, real estate regulatory requirements, and tax reporting obligations.
• Consent: to send you direct marketing communications, newsletters, or promotional material where we are required by law to obtain your prior consent. You may withdraw consent at any time without detriment.

5. Disclosure and Onward Transfer of Personal Data

The Company does not sell, rent, or otherwise commercially exploit your personal data to third parties. We may disclose your personal data to the following categories of recipients, solely to the extent necessary and subject to appropriate data protection safeguards:

• Property Developers and Vendors: where you have expressly enquired about a specific development or property, relevant details may be shared with the relevant developer or vendor to progress your enquiry.
• Professional Advisers: including solicitors, accountants, auditors, and insurers who provide consultancy, legal, insurance, and accounting services to the Company on a need-to-know basis.
• Technology and Service Providers: third-party suppliers providing CRM systems, cloud hosting, email delivery, analytics, and website infrastructure services, each acting as data processors subject to binding data processing agreements.
• Regulatory and Government Authorities: including the Dubai Land Department (DLD), Real Estate Regulatory Agency (RERA), UAE Financial Intelligence Unit, and other competent authorities where disclosure is required by law or court order.

Any international transfer of personal data outside the UAE shall be conducted in accordance with the UAE PDPL and shall be subject to appropriate transfer mechanisms, including standard contractual clauses or equivalent safeguards as required by applicable law.

6. Data Retention

The Company retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements. In determining the appropriate retention period, we consider the amount, nature, and sensitivity of the personal data; the potential risk of harm from unauthorised use or disclosure; the purposes for which we process the data; and whether we can achieve those purposes through other means.

As a general guide, client data relating to concluded transactions is retained for a period of not less than ten (10) years from the date of transaction completion, in accordance with UAE regulatory requirements. Marketing preference data is retained until you withdraw consent or for a period of three (3) years from your last interaction with us, whichever is earlier. Upon expiry of the applicable retention period, personal data shall be securely deleted or anonymised in accordance with our Data Destruction Policy.

7. Technical and Organisational Security Measures

The Company has implemented a comprehensive suite of technical and organisational security measures to protect personal data against unauthorised or unlawful processing, accidental loss, destruction, or damage. These measures include, without limitation: end-to-end encryption for data in transit; access controls based on the principle of least privilege; regular penetration testing and vulnerability assessments; staff training on data protection and information security; and incident response and breach notification procedures.

Notwithstanding the foregoing, no method of electronic transmission or storage is entirely secure, and the Company cannot guarantee the absolute security of personal data transmitted to or from our digital platforms. Any transmission of personal data to us is at your own risk.

8. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to enhance your browsing experience on our website, analyse usage patterns, and deliver targeted content. For detailed information regarding the types of cookies we deploy, the purposes for which they are used, and how you may manage your cookie preferences, please refer to our Cookies Policy at infinityrealty.ae/CookiesPolicy, which forms an integral part of this Privacy Policy.

9. Your Data Subject Rights

Subject to applicable law and certain legal exceptions, you may have the following rights in respect of your personal data held by the Company:

• Right of Access: to obtain confirmation as to whether personal data concerning you is being processed and, where so, to receive a copy of such data.
• Right to Rectification: to require correction of inaccurate or incomplete personal data without undue delay.
• Right to Erasure: to request deletion of your personal data where processing is no longer necessary, where consent is withdrawn, or where processing is unlawful, subject to applicable overriding legal obligations.
• Right to Restriction of Processing: to request that we restrict the processing of your personal data in certain circumstances.
• Right to Data Portability: to receive your personal data in a structured, commonly used, and machine-readable format and to transmit it to another controller, where technically feasible.
• Right to Object: to object to processing of your personal data carried out on the basis of legitimate interests, including for direct marketing purposes.
• Right to Withdraw Consent: where processing is based on consent, to withdraw such consent at any time without prejudice to the lawfulness of processing carried out prior to withdrawal.

To exercise any of the above rights, please submit a written request to admin@infinityrealty.ae. We will respond to your request within thirty (30) days of receipt, subject to verification of your identity. Please note that certain rights are not absolute and may be subject to exemptions or limitations under applicable law; in such cases, we will notify you of the relevant limitation and the reasons therefor in writing.

Without prejudice to any other administrative or judicial remedy available to you, and notwithstanding your right to contact the Company directly in the first instance, you retain at all times the statutory right to refer any unresolved complaint, dispute, or concern regarding the Company’s processing of your personal data to the competent supervisory authority having jurisdiction over such matters. In the United Arab Emirates, the designated supervisory authority for the purposes of Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data is the UAE Data Office, established pursuant to that legislation and vested with powers of investigation, enforcement, and administrative sanction in respect of data protection infringements. Where you are habitually resident in or otherwise subject to the data protection laws of another jurisdiction, you may additionally or alternatively have the right to lodge a complaint with the supervisory authority competent in that jurisdiction. The Company shall cooperate fully with any lawful investigation or inquiry conducted by any competent supervisory authority.

10. Automated Decision-Making and Profiling

The Company does not engage in solely automated decision-making processes that produce legal or similarly significant effects on individuals. To the extent that we employ analytical or profiling tools to personalise content or marketing communications, such processes are subject to human oversight and you retain the right to object to such processing at any time.

11. Children’s Privacy

The Company’s Services are not directed to, and we do not knowingly collect personal data from, individuals under the age of eighteen (18) years. If you are a parent or guardian and believe that your child has provided us with personal data without your consent, please contact us immediately and we will take prompt steps to delete such information.

12. Links to Third-Party Websites

Our website may contain hyperlinks to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We have no control over, and accept no responsibility for, the privacy practices or content of third-party websites. We encourage you to review the privacy policy of every website you visit.

13. Amendments to This Policy

The Company reserves the right to amend this Policy at any time to reflect changes in applicable law, regulatory guidance, or our data processing practices. Any material changes will be notified to you by posting the updated Policy on this page with a revised effective date, and where required by law, we will provide additional notice. Your continued use of our Services following the posting of any amended Policy constitutes your acknowledgement and acceptance of such changes.

14. Contact and Complaints

If you have any questions, concerns, or complaints regarding this Policy or our data processing activities, please contact our Data Protection Contact: Infinity Realty Real Estate LLC, 310, Al Asmawi, Dubai Investment Park, Dubai, UAE. Email: admin@infinityrealty.ae. Phone: +971 54 778 9838.