# Privacy Policy | Davies+Harrison > How Davies+Harrison collects, uses, and protects your personal data. Our commitment to privacy and data security for international property investors. Canonical: https://daviesandharrison.com/legal/privacy-policy D+H Legal # Privacy Policy Last Updated 26 February 2026 ## 1\. Introduction **DAH Real Estate Brokerage L.L.C.**, trading as **Davies & Harrison** (“we”, “us”, “our”), is a RERA-licensed real estate brokerage registered in Dubai, United Arab Emirates. Our registered office is at The Binary by Omniyat, Business Bay, Dubai, UAE. We are committed to protecting the privacy and security of your personal data. This Privacy Policy explains how we collect, use, store, share, and protect your personal information when you visit our website at daviesandharrison.com (the “Site”), use the Davies & Harrison investment platform (the “Platform”, accessible via web and mobile application), or interact with us through other channels. This Privacy Policy applies to all visitors to our Site and users of our Platform, including prospective property buyers, investors, sellers, newsletter subscribers, and anyone who contacts us through our website forms, the Platform, email, WhatsApp, or other communication channels. We comply with applicable data protection legislation, including the UAE Personal Data Protection Law (Federal Decree-Law No. 45 of 2021, the “UAE PDPL”) and, where we process the personal data of individuals located in the European Economic Area (“EEA”) or United Kingdom (“UK”), the EU General Data Protection Regulation (Regulation (EU) 2016/679, the “GDPR”) and the UK GDPR. Where these frameworks impose different standards, we apply the stricter requirement. ## 2\. Data Controller For the purposes of the UAE PDPL and GDPR, the data controller responsible for your personal data is: **DAH Real Estate Brokerage L.L.C.** Trading as: Davies & Harrison The Binary by Omniyat, Business Bay, Dubai, UAE RERA Broker Registration Number: 53447 DED Trade Licence Number: 1532907 Email: privacy@daviesandharrison.com Telephone: +971 58 180 0505 ### 2.1 EU/EEA Representative We are in the process of appointing a representative in the European Union in accordance with Article 27 of the GDPR. This section will be updated once the appointment is confirmed. In the meantime, you may contact us directly at privacy@daviesandharrison.com for any data protection inquiries. ## 3\. What Personal Data We Collect We collect and process the following categories of personal data: ### 3.1 Data You Provide Directly **Collection Point** **Data Collected** **Purpose** “Get Expert Guidance” form Name, email address, phone number To respond to your property investment inquiry and connect you with an advisor “Get My Free Guide” form Name, email address, phone number To deliver the requested Dubai Investment Guide to you “Register Your Interest” form (project pages) Name, email address, phone number To register your interest in a specific property development and follow up with relevant information Newsletter signup (footer) Email address To send you curated market updates, pre-launch alerts, and investment opportunities (subject to double opt-in confirmation) WhatsApp contact Phone number, message content To communicate with you in response to your inquiry via WhatsApp (operated by Meta Platforms, Inc.) Email correspondence Name, email address, message content To respond to your inquiry or communication ### 3.2 Data Collected Through the Investment Platform If you are a client with access to the Davies & Harrison investment platform (the “Platform”), we collect and process additional categories of personal data: **Collection Point** **Data Collected** **Purpose** Account creation (internal) Name, email address, password (set by D&H) To create and maintain your Platform account. Accounts are created internally by Davies & Harrison and credentials are provided to you. Project and unit preferences Liked and dismissed projects and units To understand your investment preferences and tailor the properties and opportunities presented to you In-platform chat Message content, timestamps, any files or attachments shared To facilitate communication between you and your Davies & Harrison advisor within a secure environment Platform usage data Pages viewed, features used, time spent, interaction patterns To operate, maintain, and improve the Platform **Mobile application:** The Platform may also be accessed via a mobile application. When you use the mobile app, we may additionally collect device identifiers, operating system and version, push notification tokens (if you enable notifications), and app usage analytics. We do not collect precise geolocation data unless you explicitly enable location services and grant permission. We will update this Privacy Policy before the mobile app is released to reflect any additional data collection. ### 3.3 Data We Collect Automatically When you visit our Site or use our Platform, we may automatically collect certain technical data, including: - IP address and approximate geographic location - Browser type and version, device type, and operating system - Pages visited, time spent on pages, and referring website - Data collected through cookies and similar technologies (see our Cookie Policy for details) We do not currently use any third-party analytics tools on our Site. For details on cookies used by embedded third-party services, see Section 8 (Cookies) and our separate Cookie Policy. ### 3.4 Data Collected for Legal and Regulatory Compliance As a RERA-licensed brokerage and a Designated Non-Financial Business or Profession (DNFBP) under UAE law, we may collect additional personal data during the course of a property transaction, including: - Copies of identification documents (passport, Emirates ID) - Proof of address - Source of funds documentation - Sanctions and politically exposed persons (PEP) screening results This data is collected and retained as required under UAE Federal Decree-Law No. 20 of 2018 (Anti-Money Laundering Law) and related regulations. The legal basis for this processing is compliance with a legal obligation. ## 4\. Legal Basis for Processing We process your personal data on the following legal bases under the GDPR and UAE PDPL: **Processing Activity** **Legal Basis (GDPR)** **Explanation** Responding to property inquiries submitted through our forms Legitimate interest (Art. 6(1)(f)) / Pre-contractual steps (Art. 6(1)(b)) You have initiated contact with us about our services. Processing is necessary to respond to your inquiry. No checkbox is required; a disclaimer near the submit button informs you of this processing. Delivering the Dubai Investment Guide Performance of a contract (Art. 6(1)(b)) You have requested a specific resource. We process your data to deliver what you asked for. Sending marketing communications (property updates, newsletters, promotional offers) Consent (Art. 6(1)(a)) We only send marketing communications if you have given explicit, separate opt-in consent via an unticked checkbox. You may withdraw consent at any time. Newsletter subscription Consent (Art. 6(1)(a)) Newsletter signups use a double opt-in process. You will receive a confirmation email and must click the link to activate your subscription. Analytics and Site improvement Consent (Art. 6(1)(a)) via cookie consent We do not currently use analytics cookies. If analytics tools are introduced in the future, they will only be activated after you have given consent via our cookie banner. Operating your Platform account and delivering Platform services Performance of a contract (Art. 6(1)(b)) Processing is necessary to provide and maintain the Platform services we have agreed to deliver to you as a client. Recording your project and unit preferences (likes/dismissals) Legitimate interest (Art. 6(1)(f)) We use your preferences to tailor the properties presented to you and improve our service. You can reset or change your preferences at any time within the Platform. In-platform chat communications Performance of a contract (Art. 6(1)(b)) / Legitimate interest (Art. 6(1)(f)) Chat enables communication between you and your advisor as part of our service. We retain chat records for service quality, continuity, and dispute resolution. AML/KYC identity verification Legal obligation (Art. 6(1)(c)) UAE law requires us to verify client identity and source of funds for property transactions. Establishing, exercising, or defending legal claims Legitimate interest (Art. 6(1)(f)) We may retain and process data as necessary to protect our legal rights. **Important:** Where we rely on legitimate interest as our legal basis, we have conducted a legitimate interest assessment to ensure that our interests do not override your fundamental rights and freedoms. You have the right to object to processing based on legitimate interest at any time (see Section 9). ## 5\. How We Use Your Data We use your personal data for the following purposes: - To respond to your property inquiries and connect you with an investment advisor - To deliver resources you have requested (such as the Dubai Investment Guide) - To register your interest in specific property developments and provide relevant follow-up information - To send marketing communications, including property alerts, market insights, and newsletters, where you have opted in - To operate, maintain, and improve our Site and Platform - To manage your Platform account, including providing access to property details, documents, and portfolio information - To record and use your project and unit preferences (likes and dismissals) to tailor the investment opportunities presented to you - To facilitate communication between you and your advisor through the in-platform chat - To analyse Site and Platform usage through analytics tools (subject to your cookie consent for the Site) - To comply with our legal and regulatory obligations, including anti-money laundering and customer due diligence requirements - To establish, exercise, or defend legal claims We do not use your personal data for automated decision-making or profiling that produces legal effects or similarly significant effects on you. ## 6\. Data Sharing and Third Parties We may share your personal data with the following categories of recipients: ### 6.1 Service Providers and Data Processors We use third-party service providers who process personal data on our behalf. These processors act only on our documented instructions and are contractually bound to protect your data. Our current processors include: **Provider** **Service** **Data Processed** **Location** HubSpot, Inc. Customer relationship management (CRM), email marketing, and newsletters Name, email, phone, inquiry details, subscription preferences, consent records United States (with EU data processing addendum) Calendly, LLC Appointment scheduling Name, email address, scheduling preferences, timezone United States Meta Platforms, Inc. (WhatsApp) Messaging and communication Phone number, message content United States / Ireland Amazon Web Services, Inc. (AWS) Website hosting All data submitted through the Site United States (US-East-1) Supabase, Inc. Database and backend services Form submissions, user data Middle East (Bahrain) ### 6.2 Other Disclosures We may also share your personal data in the following circumstances: - With property developers, where you have registered interest in a specific project and sharing is necessary to progress your inquiry - With regulatory authorities, including RERA, the Dubai Land Department, the UAE Financial Intelligence Unit, or other competent authorities, where required by law or regulation - With legal and professional advisors, where necessary for the establishment, exercise, or defence of legal claims - In connection with a merger, acquisition, or sale of assets, in which case we will notify you of any change in data controller We do not sell your personal data to third parties. ## 7\. International Data Transfers Davies & Harrison is based in Dubai, UAE. Some of the third-party service providers listed in Section 6 are located outside the UAE and outside the European Economic Area (EEA), including in the United States. Where we transfer personal data outside the EEA, we ensure that appropriate safeguards are in place in accordance with GDPR Chapter V, including: - Standard Contractual Clauses (SCCs) approved by the European Commission - Data Processing Agreements incorporating GDPR-compliant transfer mechanisms - Adequacy decisions, where the European Commission has determined that the recipient country provides an adequate level of data protection Where we transfer personal data outside the UAE, we comply with the requirements of the UAE PDPL and any applicable decisions of the UAE Data Office regarding adequate jurisdictions. You may request further details of the safeguards in place by contacting us at privacy@daviesandharrison.com. ## 8\. Cookies and Tracking Technologies Our Site uses cookies and similar technologies. A cookie is a small text file placed on your device when you visit a website. We categorise cookies as follows: - **Strictly Necessary Cookies:** Required for the Site to function. These do not require consent. - **Analytics Cookies:** We do not currently use analytics cookies. If introduced in the future, they will only be activated after you have given consent. - **Marketing Cookies:** Used to deliver relevant advertisements and track campaign effectiveness. These are only activated after you have given consent. When you first visit our Site, a cookie consent banner will give you the option to accept or reject non-essential cookies. You can change your preferences at any time by clicking the “Manage Cookies” link in our Site footer. For a full list of cookies used on our Site, including their purpose, provider, and expiry, please refer to our Cookie Policy. ## 9\. Your Rights Depending on your location and the applicable data protection law, you have the following rights in relation to your personal data: **Right** **Description** Right of access You may request a copy of the personal data we hold about you. Right to rectification You may request that we correct inaccurate or incomplete personal data. Right to erasure (“right to be forgotten”) You may request that we delete your personal data, subject to any legal retention obligations. Right to restriction of processing You may request that we restrict the processing of your personal data in certain circumstances. Right to data portability You may request that we provide your personal data in a structured, commonly used, machine-readable format. Right to object You may object to processing based on legitimate interest or for direct marketing purposes. Where you object to direct marketing, we will stop immediately. Right to withdraw consent Where processing is based on consent, you may withdraw consent at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal. Right to lodge a complaint You have the right to lodge a complaint with a supervisory authority. For the UAE, this is the UAE Data Office. For the EU, this is the data protection authority in your member state of residence. To exercise any of these rights, please contact us at privacy@daviesandharrison.com. We will respond to your request within 30 days (or such shorter period as required by applicable law). We may ask you to verify your identity before processing your request. We will not charge a fee for responding to a reasonable request. If a request is manifestly unfounded or excessive, we may charge a reasonable administrative fee or refuse to act on the request, in accordance with applicable law. ## 10\. Data Retention We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by law. Our standard retention periods are: **Data Category** **Retention Period** **Basis** Inquiry form submissions (non-converted leads) 24 months from date of last contact Legitimate interest; reviewed periodically Client transaction records 10 years from completion of transaction UAE Commercial Transactions Law; RERA record-keeping requirements AML/KYC records (ID, source of funds) 5 years after the end of the business relationship UAE Federal Decree-Law No. 20 of 2018 (AML Law) Marketing consent records Duration of consent plus 3 years after withdrawal GDPR accountability; evidence of valid consent Newsletter subscriber data Until unsubscription, then suppression list retained indefinitely Consent; suppression list maintained to honour opt-out requests Website analytics data Not currently collected. If analytics tools are introduced, retention period will be specified here. Consent (via cookie banner) Platform account data Duration of client relationship plus 24 months Contractual necessity; retained for continuity and to allow account reactivation Project/unit preferences (likes and dismissals) Duration of client relationship Legitimate interest; deleted when account is closed unless required for legal purposes In-platform chat records Duration of client relationship plus 24 months Legitimate interest; retained for service continuity and dispute resolution WhatsApp chat records 12 months from date of last message Legitimate interest; reviewed periodically When personal data is no longer required, we will securely delete or anonymise it. Where deletion is not immediately possible (for example, because data is held in backup systems), we will isolate the data from further processing until deletion is carried out. ## 11\. Data Security We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These measures include: - Encryption of data in transit (TLS/SSL) and at rest - Access controls limiting data access to authorised personnel on a need-to-know basis - Regular security reviews of our systems and third-party processors - Staff training on data protection and confidentiality obligations While we take all reasonable steps to protect your data, no method of transmission over the internet or electronic storage is completely secure. We cannot guarantee absolute security but are committed to maintaining industry-standard protections. **Important:** We do not collect sensitive personal documents (such as passports, financial statements, or identification) via WhatsApp or other unencrypted messaging platforms. If we require such documents as part of a transaction, we will direct you to a secure channel. ## 12\. Children’s Privacy Our services are not directed at individuals under the age of 18. We do not knowingly collect personal data from children. If we become aware that we have inadvertently collected data from a child, we will take steps to delete it promptly. If you believe a child has provided us with personal data, please contact us at privacy@daviesandharrison.com. ## 13\. Third-Party Links Our Site may contain links to third-party websites, including property developer websites, social media platforms, and our newsletter platform. We are not responsible for the privacy practices or content of these third-party sites. We encourage you to review the privacy policies of any website you visit via links from our Site. ## 14\. WhatsApp Communication Our Site includes a WhatsApp button that allows you to contact us directly via WhatsApp, which is operated by Meta Platforms, Inc. (“Meta”). When you use WhatsApp to contact us, your phone number and message content are processed by Meta in accordance with Meta’s own privacy policy. Meta may process this data on servers located outside the UAE and outside the EEA, including in the United States. We use the information you send us via WhatsApp solely to respond to your inquiry. We do not use WhatsApp conversations for marketing purposes unless you have separately opted in to marketing communications. _We strongly advise against sending sensitive personal documents (such as passport copies, bank statements, or proof of funds) via WhatsApp. If such documents are required, we will provide you with a secure alternative channel._ ## 15\. Changes to This Privacy Policy We may update this Privacy Policy from time to time to reflect changes in our practices, our service providers, or applicable law. When we make material changes, we will: - Update the “Last Updated” date at the top of this policy - Post a notice on our Site (for significant changes) - Where required by law, notify you directly (for example, by email) We encourage you to review this policy periodically. Your continued use of our Site after any changes constitutes acceptance of the updated policy. ## 16\. Contact Us If you have any questions about this Privacy Policy, wish to exercise your data protection rights, or have a concern about how we handle your personal data, please contact us: **Davies & Harrison — Data Protection** DAH Real Estate Brokerage L.L.C. The Binary by Omniyat, Business Bay, Dubai, UAE Email: privacy@daviesandharrison.com Telephone: +971 58 180 0505 **EU/EEA Representative:** Appointment pending. Please contact us directly at privacy@daviesandharrison.com. If you are not satisfied with our response, you have the right to lodge a complaint with the relevant supervisory authority. For the UAE, this is the UAE Data Office. For the EU/EEA, this is the data protection authority in the member state where you reside or work, or where the alleged infringement took place. ## Table of Contents [1\. Introduction](#1-introduction) [2\. Data Controller](#2-data-controller) [3\. What Personal Data We Collect](#3-what-personal-data-we-collect) [4\. Legal Basis for Processing](#4-legal-basis-for-processing) [5\. How We Use Your Data](#5-how-we-use-your-data) [6\. Data Sharing and Third Parties](#6-data-sharing-and-third-parties) [7\. International Data Transfers](#7-international-data-transfers) [8\. Cookies and Tracking Technologies](#8-cookies-and-tracking-technologies) [9\. Your Rights](#9-your-rights) [10\. Data Retention](#10-data-retention) [11\. Data Security](#11-data-security) [12\. Children’s Privacy](#12-children-s-privacy) [13\. Third-Party Links](#13-third-party-links) [14\. WhatsApp Communication](#14-whatsapp-communication) [15\. Changes to This Privacy Policy](#15-changes-to-this-privacy-policy) [16\. Contact Us](#16-contact-us) --- Davies+Harrison — RERA-licensed Dubai real estate investment advisory (ORN 53447). Contact: info@daviesandharrison.com | +971 58 180 0505 | https://daviesandharrison.com/contact Agent guidance: https://daviesandharrison.com/llms.txt