Privacy Policy

The entity responsible for processing your personal information (the “Data Controller”) under UAE law is:

Our data governance policy is established in strict adherence to:

• UAE Federal Decree-Law No. 45 of 2021 on Personal Data Protection (PDPL): Governing the processing, retention, and transfer of personal data within the UAE.
• Dubai Land Department (DLD) & RERA Regulations: Including Bylaw No. 85 of 2006 regulating real estate brokers in the Emirate of Dubai, the Dubai Real Estate Institute directives, and Trakheesi regulatory guidelines.
• UAE Federal Decree-Law No. 20 of 2018 on Anti-Money Laundering (AML) & Counter-Financing of Terrorism (CFT): Mandating rigorous Know-Your-Customer (KYC) compliance for real estate transactions.

Depending on whether you browse our property portfolio, make an inquiry, or engage our brokerage for a sale, purchase, or lease, we collect:

We process personal data solely on lawful grounds under Article 4 and Article 5 of the UAE PDPL:

• Contractual Performance: Arranging private property inspections, preparing developer NOCs, and executing unified RERA contracts.
• Legal & Regulatory Obligations: Lodging official tenancy agreements via Ejari, recording transactions on the Dubai REST application, and submitting regulatory returns to the UAE Financial Intelligence Unit (FIU) goAML platform.
• Legitimate Interests: Ensuring website security, refining our tailored property matches, and preventing fraudulent representations.
• Explicit Consent: Where you request to receive curated property market updates or exclusive off-market opportunities.

Keys & Smiles does not sell, rent, or monetize your personal data. Disclosures are made strictly to authorized statutory and professional partners necessary to complete your transaction:

• Governmental Authorities: The Dubai Land Department (DLD), the Real Estate Regulatory Agency (RERA), and the UAE Ministry of Economy.
• Authorized Developers & Master Communities: For obtaining developer No Objection Certificates (NOC), community access, and handover documentation.
• Licensed Trustee & Conveyancing Offices: Authorized DLD Real Estate Registration Trustee offices facilitating final title deed transfers.
• Financial Institutions: Your designated mortgage lenders or escrow banks, exclusively upon your written authorization.

As a licensed real estate brokerage in the United Arab Emirates, Keys & Smiles Real Estate L.L.C is designated as a Designated Non-Financial Business and Profession (DNFBP) under UAE Federal Law No. 20 of 2018.

We are legally mandated to conduct comprehensive Customer Due Diligence (CDD), verify Ultimate Beneficial Ownership (UBO), screen parties against national and international sanctions lists, and retain transaction records. Failure to supply requested KYC documentation may preclude us from assisting with property viewings, contracts, or transfers.

Personal data is retained only for as long as necessary to fulfill the intended business purpose or statutory requirements:

• Transaction & Contract Records: Retained for a minimum of 5 years following completion of the transaction, pursuant to UAE Federal AML/CFT statutory regulations and DLD recordkeeping requirements.
• General Inquiry Data: Retained for 12 months following your last communication, unless ongoing advisory services are requested.
• Marketing Consents: Retained until you actively opt out or withdraw consent.

We implement multi-layered physical and technical safeguards to protect your personal data against unauthorized access, loss, alteration, or disclosure:

• Transport Layer Security (TLS/HTTPS 256-bit encryption) on all web communications.
• Role-based access controls ensuring only licensed brokers assigned to your transaction have access to identity files.
• Regular system audits and secure internal document destruction protocols for expired KYC data.

Under the UAE Personal Data Protection Law (Federal Decree-Law No. 45 of 2021), you have the right to:

• Right to Access: Request confirmation and a copy of the personal information we hold about you.
• Right to Rectification: Request correction of inaccurate, incomplete, or outdated details.
• Right to Erasure (“Right to be Forgotten”): Request deletion of your personal data where retention is no longer required by law. (Please note that records required by DLD or UAE AML laws for 5 years cannot be erased prematurely.)
• Right to Restrict Processing: Request limitation of processing under specific circumstances.
• Right to Withdraw Consent: Unsubscribe from marketing or advisory circulars at any time without affecting prior lawful processing.

Our website uses strictly necessary and performance cookies to maintain user session integrity, remember your preferences, and track aggregate traffic patterns. We do not employ intrusive third-party cross-site profiling cookies. You may manage cookie settings through your browser preferences.

To exercise your data protection rights or submit an inquiry regarding our compliance practices, please contact our designated compliance team: