1. Definitions
Personal Data — any information relating to an identified or identifiable individual.
Processing — any operation performed on Personal Data, including collection, storage, use, disclosure, or deletion.
Cookies — small text files stored on your device when visiting the Website.
User — any individual accessing or interacting with the Website.

2. Legal Basis for Processing
We process Personal Data in accordance with applicable legislation, including:

• UAE Federal Decree-Law No. 45 of 2021 on Personal Data Protection
• General Data Protection Regulation (GDPR) (where applicable)
• Other relevant international data protection standards

Processing is based on:

• Consent — where you voluntarily provide your data
• Legitimate interests — including business operations, analytics, and communication

3. Acceptance of This Policy
You provide consent to the processing of your Personal Data when you:

• Submit any form on the Website
• Request a callback or consultation
• Contact us via messaging platforms (WhatsApp, Telegram, etc.).
• Continue browsing and using the Website

We may record and retain proof of consent where required for compliance purposes.

4. Categories of Data Collected
4.1 Contact DataName

• Phone number
• Any additional information you voluntarily provide

4.2 Messenger Data
When contacting us via messaging platforms, we may receive:

• Account identifiers
• Public profile information
• 4.3 Technical and Usage Data
• IP address
• Browser type and device information
• Operating system
• Pages visited, session duration, and interaction data

5. Purposes of Processing
We process Personal Data for the following purposes:

• Responding to enquiries and providing requested information
• Presenting real estate opportunities and project materials
• Communicating via phone, email, or messaging platforms
• Sending marketing communications (until you opt out)
• Improving Website functionality and user experience
• Managing internal records, databases, and CRM systems
• Ensuring security, fraud prevention, and compliance with legal obligations

6. Data Retention
Personal Data is retained:

• For the duration necessary to fulfil the purpose of collection
• And for up to 3 years thereafter, unless a longer retention period is required by law

Data may be retained longer where necessary to protect legal interests or comply with regulatory obligations.

7. Data Sharing
We may share Personal Data with:

• Companies within the Whitewill group
• Service providers (including CRM systems, hosting providers, analytics platforms)
• Communication platforms (e.g., WhatsApp, Telegram)
• Governmental or regulatory authorities where required by law

All recipients are required to process Personal Data in accordance with confidentiality and security obligations.

8. International Data Transfers
Your Personal Data may be transferred to jurisdictions outside your country of residence.
Where such transfers occur, we implement appropriate safeguards, including:

• Contractual data protection clauses
• Secure processing standards aligned with international requirements

9. Your Rights
Subject to applicable law, you may have the right to:

• Access your Personal Data
• Request correction of inaccurate data
• Request the deletion of your data
• Restrict or object to processing
• Withdraw consent at any time
• Request data portability

To exercise your rights, please get in touch with us using the details below.

10. Cookies
We use cookies to:

• Ensure proper Website functionality
• Analyse traffic and user behaviour
• Improve performance and usability
• Types of Cookies Used
• Functional cookies — essential for Website operation
• Analytical cookies — used to understand and improve user experience

You may disable cookies via your browser settings.
Please note that disabling cookies may affect certain Website functionalities.

11. Data Security
We implement appropriate technical and organisational measures, including:

• Secure servers and firewall protection
• Role-based access controls
• Internal data protection policies and procedures

These measures are designed to prevent unauthorised access, loss, or misuse of Personal Data.

12. Third-Party Data
If you provide Personal Data relating to third parties, you confirm that:

• You have obtained the necessary consent from such individuals
• You are authorised to disclose such data

You bear full responsibility for compliance with applicable data protection laws in such cases.

13. Policy Updates
We reserve the right to update this Policy at any time.
The most current version will always be available on the Website.
Continued use of the Website constitutes acceptance of any updates.

14. Contact Information
For any questions, requests, or data protection enquiries:
General: info@whitewill.ae
Privacy: privacy@whitewill.ae
Address: Dubai, UAE, The Onyx Tower