Privacy Policy

Avenya Real Estate Brokerage L.L.C S.O.C (“Avenya Properties”, “Avenya”, “we”, “us” or “our”) is committed to respecting your privacy and handling your personal information responsibly.

This Privacy Policy explains how we collect, use, store and share personal information when you visit our website, submit an enquiry, communicate with us, interact with our advertising, or use our real estate brokerage and advisory services.

Avenya Properties is based in the United Arab Emirates and provides services to clients and prospective clients in the UAE, United Kingdom and other international markets.

Where applicable, we process personal information in accordance with relevant privacy and data protection laws, including the UAE Federal Decree-Law No. 45 of 2021 Regarding the Protection of Personal Data and applicable UK data protection legislation, including the UK GDPR and Data Protection Act 2018. The UAE law establishes requirements around processing, security, individual rights and cross-border transfers of personal data.

1. Who we are

The data controller responsible for your personal information is:

2. Personal information we may collect

The information we collect depends on how you interact with us.

We may collect information including:

• your name
• email address
• telephone number
• WhatsApp contact details
• country of residence or location
• property preferences
• investment objectives
• budget and purchasing requirements
• preferred locations, property types and completion timelines
• information you provide when registering interest in a property or development
• information contained in communications with us
• records of calls, emails, messages or other correspondence
• enquiry source and marketing attribution information
• IP address
• browser and device information
• operating system
• referring website or advertising source
• pages viewed and interactions with our website
• cookie and analytics identifiers

Where a transaction progresses beyond an initial enquiry, we may also collect additional information required for legal, regulatory, compliance, identity-verification or transaction purposes.

3. How we collect your information

We may collect personal information directly from you when you:

• complete an enquiry or contact form on our website
• register your interest in a property or development
• contact us by email, telephone or WhatsApp
• communicate with one of our advisors
• submit a lead form through Google, Meta or another advertising platform
• respond to an advertisement
• subscribe to updates or marketing communications
• attend an event, presentation or property consultation
• enter into discussions regarding a property transaction

We may also receive personal information from third parties, including:

• advertising platforms
• property developers
• property portals
• referral partners
• technology and CRM providers
• other lead-generation channels

Where we receive information from another source, we will process it in accordance with applicable law and this Privacy Policy.

4. How we use your personal information

We may use your personal information to:

• respond to enquiries and requests
• understand your property requirements
• recommend properties or investment opportunities that may be relevant to you
• provide information about developments, pricing, payment plans, availability and launches
• arrange telephone calls, meetings or property consultations
• manage our relationship with you
• maintain records within our customer relationship management systems
• contact you regarding an active enquiry
• facilitate communications with developers and other relevant transaction parties
• provide ongoing client support
• measure the performance of our website and advertising campaigns
• understand how visitors use our website
• improve our website, services and marketing
• prevent fraud, abuse or misuse of our services
• maintain the security of our systems
• comply with legal and regulatory obligations
• establish, exercise or defend legal rights

We may also use your information to send relevant property updates, market information, launches and promotional communications where permitted by applicable law.

5. Our lawful bases for processing

Where UK data protection law applies, we must have an appropriate lawful basis for using your personal information. The appropriate basis may vary depending on the purpose for which the information is used.

We may rely on:

Where we rely on consent, you may withdraw that consent at any time.

6. Property enquiries and CRM records

When you submit an enquiry, we may record your information within our customer relationship management systems.

We currently use HubSpot to manage enquiries, communications and prospective client relationships.

Information stored in our CRM may include your contact details, enquiry history, property requirements, communication records and the source through which your enquiry was received.

We use this information to respond to you efficiently, understand your requirements and maintain an appropriate record of our relationship with you.

7. Advertising, analytics and tracking technologies

We use digital analytics and advertising technologies to understand how our website is used and to measure the effectiveness of our marketing.

These services may include:

• Google Analytics 4
• Google Ads
• Google Tag Manager
• advertising and lead-generation services provided by Google
• advertising services provided by Meta and other platforms where applicable

These technologies may collect information such as:

• IP address
• browser and device information
• pages viewed
• interactions with our website
• referring URLs
• advertising identifiers
• campaign and conversion information

We may use this information to understand website performance, measure advertising effectiveness, attribute enquiries to marketing campaigns and improve our advertising.

8. Cookies and similar technologies

Our website uses cookies and similar technologies.

Some cookies are necessary for the website to function. Others may be used for analytics, advertising, performance measurement or personalisation.

Where required by applicable law, non-essential cookies and similar technologies will only be used after you have provided appropriate consent.

We intend to provide website controls that allow you to manage your cookie preferences.

UK guidance requires organisations to provide clear information about cookies and, subject to applicable exemptions, obtain consent before using non-essential cookies or similar technologies.

A separate Cookie Policy may provide further detail about the cookies and technologies used on our website.

9. Marketing communications

Where permitted by applicable law, we may contact you regarding:

• property opportunities
• new project launches
• availability updates
• market information
• investment insights
• events
• services that may be relevant to your enquiry or interests

Communications may be sent by:

• email
• telephone
• SMS
• WhatsApp

Where consent is required, we will obtain it before sending such communications.

You may opt out of marketing communications at any time by using an unsubscribe mechanism where available or by contacting us at info@avenyaproperties.com.

Opting out of marketing communications will not prevent us from contacting you where necessary to respond to an active enquiry or provide a service you have requested.

10. Who we may share your information with

We may share personal information where necessary with trusted third parties involved in providing our services or operating our business.

These may include:

• property developers
• relevant transaction counterparties
• CRM providers such as HubSpot
• website hosting and infrastructure providers
• analytics and advertising providers such as Google
• communication and messaging providers
• email service providers
• professional advisers
• compliance and verification providers
• regulators, governmental bodies or law-enforcement authorities where required by law

We only share information where there is a legitimate reason to do so and seek to limit disclosures to information reasonably necessary for the relevant purpose.

We do not sell your personal information to third parties.

11. International transfers

Avenya Properties operates from the United Arab Emirates and works with clients, technology providers and business partners in multiple jurisdictions.

Your personal information may therefore be transferred to or processed in countries outside the country in which you reside.

This may include transfers between the United Arab Emirates, United Kingdom and other jurisdictions in which our service providers operate.

Where applicable, we take steps designed to ensure that international transfers are made in accordance with relevant data protection requirements and that appropriate safeguards are used where required.

Both UK privacy rules and the UAE Personal Data Protection Law contain requirements relating to international transfers of personal information.

12. How long we retain your information

We retain personal information only for as long as reasonably necessary for the purpose for which it was collected.

The appropriate retention period may depend on:

• the nature of your enquiry
• whether you become a client
• the nature and duration of our relationship with you
• legal or regulatory requirements
• accounting or compliance obligations
• the need to resolve disputes or maintain appropriate business records

Where information is no longer required, we will take reasonable steps to delete, anonymise or otherwise securely dispose of it.

13. How we protect your information

We use appropriate technical and organisational measures designed to protect personal information against:

• unauthorised access
• accidental loss
• misuse
• alteration
• disclosure
• destruction

Access to personal information is limited to personnel and service providers who require it for legitimate business purposes.

We also use appropriate technical safeguards in connection with our website and systems.

However, no method of transmitting or storing information electronically can be guaranteed to be completely secure.

14. Your privacy rights

Depending on the laws applicable to you, you may have rights in relation to your personal information.

These may include the right to:

• request access to personal information we hold about you
• request correction of inaccurate or incomplete information
• request deletion of your personal information in certain circumstances
• request restriction of processing
• object to certain processing activities
• withdraw consent where processing is based on consent
• request portability of certain personal information
• ask us to explain certain processing activities
• lodge a complaint with an appropriate data protection authority

The UAE Personal Data Protection Law also recognises rights relating to access, correction and restriction or cessation of certain processing activities.

To exercise a privacy right, contact us at info@avenyaproperties.com.

We may need to verify your identity before responding to a request.

15. Complaints

If you have concerns about how we handle your personal information, please contact us first at:

info@avenyaproperties.com

We will aim to review and respond to your concerns appropriately.

Depending on your location and the applicable law, you may also have the right to make a complaint to the relevant data protection authority.

16. Third-party websites and services

Our website may contain links to websites, applications or services operated by third parties.

We are not responsible for the privacy practices, security or content of third-party websites or services.

We recommend reviewing the relevant privacy information provided by those third parties before providing personal information to them.

17. Children’s privacy

Our services are not directed toward children, and we do not knowingly seek to collect personal information from children for property investment or brokerage purposes.

If we become aware that personal information relating to a child has been collected inappropriately, we will take reasonable steps to address the matter.

18. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in:

• our business
• our services
• the technologies we use
• legal or regulatory requirements

The latest version will be published on this page and the “Last updated” date will be amended accordingly.

We encourage you to review this Privacy Policy periodically.

19. Contact us

If you have questions about this Privacy Policy, wish to exercise your privacy rights, or have concerns about how your personal information is handled, please contact: