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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.

Cookies & Similar Technologies

We and our partners use cookies and similar tools to operate the Website, enhance performance, remember your preferences, and measure marketing effectiveness.

  • Managing cookies: Most browsers let you block or delete cookies. If you disable cookies, parts of the Website may not function properly.
  • For guidance on managing cookies, visit resources like aboutcookies.org or your browser's help section.

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.

Sharing Personal Data

We do not sell your Personal Data. We may share it with:

  • REEF group entities and trusted service providers (e.g., hosting, analytics, marketing vendors, customer support, electronic signature platforms, document storage) under contracts that require data protection.
  • Channel partners/agents involved in servicing your enquiry/transaction, where relevant.
  • Banks/financiers, trustees, and authorities as needed to process registrations/mortgages or comply with law.
  • Advertising/measurement partners to deliver/measure campaigns (in line with your settings).
  • Professional advisers (legal, audit, accounting) and fraud prevention/law enforcement where required.
  • Corporate transactions: if we sell, merge, or transfer part of our business, your data may transfer to the new owner under the same protections.
  • Government authorities such as the Dubai Land Department, RERA, or other competent UAE authorities, where required by law.
  • Third-party marketing vendors and service providers are not permitted to use your Personal Data for their own independent purposes.

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.

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.