Privacy Policy
Effective date: 15 September 2025
This Privacy Policy explains how REEF Luxury Developments (“REEF”, “we”, “us”, “our”), a company registered in Dubai, United Arab Emirates, acting as Data Controller, collects, uses, shares, and protects information when you interact with:
- Our website: https://www.reefdevelopments.ae/ (the “Website”).
- Email, SMS/WhatsApp, and other electronic messages between you and REEF.
- Mobile or desktop apps we make available via the Website.
- Our advertising and applications on third-party websites/services that link to this Policy.
- Our contact centers (including recorded or monitored calls for quality and compliance).
By using our Website or otherwise providing personal data to us, you acknowledge that you have read and understood this Policy. Your use of our services constitutes explicit consent to the processing of your personal data as described herein, where consent is required under applicable UAE law.
This Privacy Policy is designed to comply with the UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (“PDPL”), as may be amended.
Personal Data We Collect
“Personal Data” means any information that identifies you or can be linked to you. We may collect:
- Identity & contact data: name, email, phone, postal address.
- Government/ID data (where legally required): Emirates ID, passport no., property/unit ID.
- Contract & transaction data: unit selections, reservation/contract details, payments.
- Financial data: payment card details, bank transfer information, financing details.
- Profile & preferences: interests, language, communication preferences.
- Technical & usage data: IP address, device/browser, cookies, pages viewed, interaction timestamps.
- Communications data: emails, messages, call recordings (for training, service quality, and dispute resolution).
- CCTV footage collected at REEF sales centers, project sites, or offices for security and safety purposes.
You can choose not to share certain data, but this may limit access to some features or services.
Non-Personal Data: We also collect aggregated or de-identified information (e.g., device type, general usage patterns) that does not identify you individually.
How We Collect Data
- Directly from you: when you browse the Website, complete forms, use live chat, subscribe to newsletters, request brochures, or participate in events/briefings.
- Automatically: via cookies, pixels, and similar technologies as you navigate the Website.
- From third parties: channel/agency partners, marketing vendors, analytics providers, social platforms, public sources, and where permitted, data verification/AML/KYC service providers.
- Through physical security systems, including CCTV monitoring at sales centers or project sites.
How We Use Personal Data
We process your data to:
- Provide and improve services: respond to enquiries; enable registrations/applications; support viewings/briefings; service existing relationships.
- Operate the Website and apps: troubleshooting, analytics, security, fraud prevention.
- Customer communications: send project updates, availability, pricing, policy/terms changes.
- Marketing (where permitted): send brochures, event invites, product news, and offers by REEF or appointed marketing vendors.
- Surveys & promotions: conduct satisfaction surveys, contests, or campaigns.
- Legal & compliance: KYC/AML (as applicable), prevent fraud, exercise/defend legal claims.
- Comply with obligations under Dubai Land Department (DLD) and Real Estate Regulatory Agency (RERA) requirements.
- For external processing: we sometimes employ third parties outside of REEF to process information on our behalf in compliance with this Privacy Policy and using other appropriate security and confidentiality measures.
- For legal purposes: we share your information when we believe that the disclosure is reasonably necessary to (a) comply with applicable laws, regulations, legal process, or requests from law enforcement or regulatory authorities, (b) prevent, detect, or otherwise handle fraud, security, or technical issues, and (c) protect the safety, rights, or property of any person, the public, or REEF.
- For business purposes: we may share your information in connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company. We may also share your information between and among REEF, and its current and future parents, affiliates, subsidiaries, and other companies under common control and ownership.
- We share your information with trusted marketing service providers who assist us in managing and delivering targeted campaigns. You may withdraw your consent and opt out of receiving marketing communications and related data sharing at any time through your account settings (see Section 9).
- Any purpose disclosed at collection or with your consent.
Legal Bases (where applicable)
Depending on the jurisdiction and context, we rely on one or more of the following lawful bases:
- Contract: to perform a contract or take steps at your request (e.g., processing a booking).
- Legitimate interests: to run and protect our business, improve services, and communicate appropriately, balanced against your rights.
- Legal obligation: to comply with laws (e.g., AML, tax, accounting).
- Consent: for certain marketing or where required by law. You can withdraw consent at any time.
- For UAE residents, direct marketing communications are only sent based on consent.
International Transfers
Your data may be processed or stored outside your country. This may include transfers to jurisdictions where our group entities, service providers, cloud hosting providers, banks, or professional advisers are located.
Where required, we implement safeguards (e.g., contractual protections) so that your Personal Data receives an equivalent level of protection. In particular, for transfers to countries outside the United Arab Emirates, we rely on one or more of the following safeguards to ensure compliance with the UAE Personal Data Protection Law (PDPL):
- Adequacy decisions issued by the UAE Data Office confirming that the recipient jurisdiction provides an adequate level of protection.
- Standard contractual clauses or data transfer agreements with the data recipient, incorporating supplementary technical and organizational measures (e.g., encryption, access restrictions) where required.
- Other lawful grounds for transfer under the PDPL, including transfers necessary to perform a contract with you, to establish, exercise, or defend legal claims, or to comply with regulatory obligations (including those of the Dubai Land Department, RERA, or other competent UAE authorities).
If the law of the country from which you access our Website or services imposes stricter requirements for international transfers, we will comply with those local requirements in addition to PDPL safeguards.
Security
We use administrative, technical, and physical safeguards to help protect Personal Data against accidental loss and unauthorized access, use, alteration, or disclosure.
While we work to protect your information, no method of transmission over the Internet is completely secure. Any transmission is at your own risk.
Access to Personal Data is restricted to authorized employees, contractors, directors, and service providers who are subject to confidentiality obligations.
Your Choices & Rights
- Access & correction: You may request access to, or correction of, your Personal Data.
- Rectification: If you notice that your personal data is incorrect, you can always request that we correct it.
- Deletion & restriction: You may request deletion or restriction, subject to legal exceptions.
- Objection: You may object to certain processing based on legitimate interests.
- Marketing preferences: You can opt out of marketing at any time (e.g., using unsubscribe links or contacting us).
- Consent withdrawal: Where we rely on consent, you can withdraw it at any time.
- We will respond to verified data subject requests within 30 days, in line with the PDPL.
To exercise rights, contact us (Section 15). We may need to verify your identity before acting on requests.
You also have the right to lodge a complaint with the UAE Data Office if you are not satisfied with our response.
Data Retention
We keep Personal Data only as long as necessary for the purposes described in this Policy.
The duration for which we retain your personal data is determined by factors such as the scope, nature and purposes of the personal data processing, and whether we have legitimate interests or legal obligations that require us to retain your personal data.
Third-Party Links
The Website may link to third-party sites/apps. We are not responsible for their privacy practices. Please review their policies before providing data.
REEF is not responsible for any data collected independently by third-party real estate portals, agencies, or listing websites.
Sensitive Personal Data
We do not intentionally collect or process sensitive categories of personal data (such as health information, biometric data, or political/religious beliefs) unless required by law (e.g., KYC/AML checks). Where collected, we apply additional safeguards.
Data Minimization Principle
We only collect personal data that is necessary and proportionate for the purposes described in this Policy and retain it only for as long as required by law or legitimate business purposes.
Changes to This Policy
We may update this Policy from time to time.
Updates take effect when posted on the Website, so we encourage you to review it regularly.
Your continued use after changes means you accept the updated Policy.
Contact Us
If you have questions, requests, or complaints regarding this Policy or our data practices, please contact:
- REEF Luxury Developments LLC
- Email: clientexperience@reefdevelopments.ae
- Registered Office: REEF Luxury Development LLC, REEF Villa 522, Jumeirah Third, Dubai, UAE.