1. Introduction

TIER ONE PROPERTIES LLC (“the Company,” “we,” “us,” or “our”) is committed to protecting the privacy and personal data of visitors to our website [www.tier-one.ae] (the “Website”), as well as our clients, prospects, and business contacts.

This Privacy Policy explains how we collect, use, store, share, and protect your personal data when you interact with us, whether through our Website, by email, phone, WhatsApp, in person, or through third-party real estate portals such as Property Finder, Bayut, and Dubizzle.

This Policy is issued in accordance with Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (the “PDPL”) of the United Arab Emirates and other applicable UAE data protection laws and regulations.

By using our Website or providing us with your personal data, you acknowledge that you have read and understood this Privacy Policy.

2. Data Controller

For the purposes of UAE data protection laws, the data controller responsible for your personal data is TIER ONE PROPERTIES LLC.

Trade License Number: 1197059
RERA ORN (Office Registration Number): 36361
Registered Address: Office #204-056 Aspin Commercial Tower 104, Sheikh Zayed road Trade Center 1, Jumeirah, Dubai – Dubai
Email: info@tier-one.ae
Telephone: +971 50 1711983

3. Personal Data We Collect

Through our Website, we collect only the personal data that you voluntarily provide to us. We may collect and process the following categories of personal data:

a) Contact Data

Your full name, email address, mobile and landline numbers, and (where you choose to provide it) your country of residence or correspondence address. This is collected through our contact forms, property inquiry forms, viewing requests, and newsletter signup.

b) Property Preference Data

Information you share about your property interests, including the type of property you are looking for, budget range, preferred locations, intended use (residential or investment), and your inquiry history with us.

c) Technical Data

Information automatically collected when you visit our Website, including IP address, browser type, device information, operating system, referring URLs, and pages visited. This is collected through cookies and similar technologies, as detailed in our Cookies Policy.

d) Marketing Data

Your newsletter subscription status, marketing preferences, and engagement with our marketing communications (such as whether you have opened our emails or clicked on links).

e) Communication Records

Records of your communications with us, including emails, WhatsApp messages, SMS, and notes from telephone calls or in-person meetings, where these arise from your use of the Website.

Important note on identification documents: We do not collect copies of passports, Emirates IDs, or other identification documents through our Website. If you proceed with a property transaction, any identification documents required for legal or regulatory purposes (such as Dubai Land Department registration or anti-money laundering compliance) will be requested separately, on a transaction-by-transaction basis, with your explicit knowledge and consent.

4. How We Collect Your Personal Data

We collect personal data through the following channels:

• Directly from you, when you complete contact forms, submit property inquiries, request a viewing, subscribe to our newsletter, or communicate with us by email, phone, or WhatsApp.
• From third-party property portals on which we list properties, including Property Finder, Bayut, and Dubizzle, when you submit an inquiry through those platforms.
• Automatically through your use of our Website, via cookies and similar technologies (see our Cookies Policy for details).
• From publicly available sources, such as business directories or social media platforms, where relevant.

5. Why We Process Your Personal Data and Legal Basis

We process your personal data for the following purposes, relying on the following legal bases under the PDPL:

a) To provide our services

Including responding to inquiries, arranging property viewings, facilitating sales/leases, drafting contracts, and providing property management services. Legal basis: performance of a contract or steps prior to entering into a contract.

b) To comply with legal and regulatory obligations

Including obligations under RERA regulations and other applicable UAE laws, where website data is relevant. Most regulatory obligations (such as anti-money laundering and Dubai Land Department requirements) apply to actual property transactions and are addressed separately at the time of each transaction. Legal basis: compliance with a legal obligation.

c) For our legitimate business interests

Including improving our services, ensuring Website security, fraud prevention, internal record-keeping, and protecting our legal rights. Legal basis: legitimate interests, balanced against your rights and freedoms.

d) For marketing communications

Including sending you newsletters, property updates, market reports, and promotional offers. Legal basis: your consent, which you may withdraw at any time.

e) For analytics and Website improvement

Including understanding how visitors use our Website to improve user experience. Legal basis: your consent (via the cookie consent banner).

6. How We Share Your Personal Data

The personal data we collect through our Website is only shared with a limited number of recipients, strictly where necessary, and with appropriate safeguards in place. These include:

• IT and hosting service providers, including website hosting, email, CRM, and cloud storage providers, who process data on our behalf under data processing agreements.
• Analytics and marketing providers, including Google Analytics and Meta (Facebook/Instagram), in accordance with our Cookies Policy and only with your prior consent through our cookie consent banner.
• Property portals on which we list properties, including Property Finder, Bayut, and Dubizzle, in connection with inquiries you make about a specific listing.
• Law enforcement, courts, or regulatory authorities, where we are legally required to do so or to protect our legal rights.

If you choose to proceed with a property transaction, additional sharing of your personal data with relevant parties (such as property owners, developers, banks, government authorities, or legal advisors) may be necessary. Any such sharing will take place separately, on a transaction-by-transaction basis, and only with your explicit consent for the specific purpose involved.

We do not sell your personal data to third parties.

7. International Transfers of Personal Data

Some of our service providers (such as cloud hosting, email, and analytics platforms) may be located outside the United Arab Emirates. Where personal data is transferred outside the UAE, we ensure that:

• The destination country provides an adequate level of data protection as recognized by the UAE Data Office; or
• Appropriate safeguards are in place, such as standard contractual clauses or binding corporate rules; or
• The transfer is necessary for the performance of a contract with you or for the establishment, exercise, or defense of legal claims; or
• You have provided your explicit consent to the transfer.

8. How Long We Keep Your Personal Data

We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, including to satisfy any legal, regulatory, accounting, or reporting requirements. Typical retention periods for data collected via the Website are:

• Inquiry and contact data (where no transaction follows): up to 2 years from last contact.
• Newsletter subscriber data: until you unsubscribe, plus a short period for record-keeping.
• Website analytics and cookie data: as set out in our Cookies Policy.

If you proceed with a property transaction, transactional and contractual records (collected separately, not through the Website) are retained for the periods required under UAE commercial, tax, and anti-money laundering laws, typically a minimum of 5 years from the end of the transaction or business relationship.

After the applicable retention period, we will securely delete or anonymize your personal data.

9. How We Protect Your Personal Data

We implement appropriate technical and organizational measures to safeguard your personal data against unauthorized access, loss, alteration, disclosure, or destruction. These measures include:

• Secure servers and encrypted data transmission (HTTPS/SSL).
• Access controls, authentication, and role-based permissions.
• Regular security reviews and software updates.
• Confidentiality obligations imposed on staff and service providers.
• Staff training on data protection and information security.

While we take reasonable steps to protect your data, no method of electronic transmission or storage is 100% secure. We cannot guarantee absolute security but will notify you and the relevant authorities of any data breach in accordance with applicable law.

10. Your Rights Under UAE Data Protection Law

Subject to applicable laws and certain exceptions, you have the following rights in relation to your personal data:

a) Right to be Informed

You have the right to know how and why we process your personal data. This Privacy Policy fulfills that obligation.

b) Right of Access

You have the right to request a copy of the personal data we hold about you.

c) Right to Rectification

You have the right to request correction of any inaccurate or incomplete personal data.

d) Right to Erasure

You have the right to request deletion of your personal data, subject to our legal and regulatory obligations.

e) Right to Restrict Processing

You have the right to request that we limit how we use your personal data.

f) Right to Data Portability

You have the right to receive your data in a structured, commonly used format and to transfer it to another controller.

g) Right to Object

You have the right to object to processing based on legitimate interests or for direct marketing purposes.

h) Right to Withdraw Consent

Where processing is based on your consent, you have the right to withdraw that consent at any time, without affecting the lawfulness of processing carried out before withdrawal.

i) Right to Lodge a Complaint

You have the right to lodge a complaint with the UAE Data Office if you believe your rights have been violated.

To exercise any of these rights, please contact us using the details in Section 14. We will respond to your request within the timeframes prescribed by law. We may need to verify your identity before processing your request. There is generally no fee, but we may charge a reasonable fee or refuse to act on requests that are manifestly unfounded or excessive.

11. Marketing Communications

If you have subscribed to our newsletter or otherwise consented to receive marketing communications, we may send you property listings, market updates, investment opportunities, and promotional offers.

You can opt out of marketing communications at any time by:

• Clicking the “unsubscribe” link in any marketing email.
• Replying “STOP” to any marketing SMS or WhatsApp message.
• Contacting us directly at [info@tieroneproperties.com].

Opting out of marketing communications will not affect transactional or service-related communications (e.g., responses to your inquiries, contract documents, or legally required notices).

12. Children’s Privacy

Our services are not directed at children under the age of 18. We do not knowingly collect personal data from minors. If you believe we have inadvertently collected personal data from a minor, please contact us so that we may delete it promptly.

13. Cookies and Tracking Technologies

Our Website uses cookies and similar tracking technologies. For detailed information about the cookies we use and how to manage them, please refer to our Cookies Policy, which is available on our Website.

14. Contact Us and Data Protection Inquiries

If you have any questions, concerns, or requests regarding this Privacy Policy or how we handle your personal data, please contact us at:

TIER ONE PROPERTIES LLC
Registered Address: Office #204-056 Aspin Commercial Tower 104, Sheikh Zayed road Trade Center 1, Jumeirah, Dubai – Dubai
Email: info@tier-one.ae
Telephone: +971 50 1711983

If you are not satisfied with our response, you have the right to lodge a complaint with the UAE Data Office, which is the competent authority for data protection in the United Arab Emirates.

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors. Any changes will be posted on this page with an updated “Last updated” date. Where the changes are significant, we will provide a more prominent notice or, where required by law, seek your renewed consent.

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your personal data.

By using our Website and providing us with your personal data, you acknowledge that you have read and understood this Privacy Policy.