1. Introduction
Inner Circle Real Estate Brokerage L.L.C. (“we”, “us”, “our”) is committed to protecting the privacy of individuals whose personal data we process. This Privacy Policy explains how we collect, use, disclose and protect your personal data when you visit www.InnerCircleRealtors.com, contact us or engage with our services.
This Policy is designed to comply with Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (PDPL) and other applicable UAE laws.
By using the Website or providing your personal data to us, you acknowledge that you have read and understood this Privacy Policy.
2. Data Controller
For the purposes of the PDPL, the data controller is:
Inner Circle Real Estate Brokerage L.L.C
Abu Dhabi, United Arab Emirates
Email: Contact@InnerCircleRealtors.com
3. Categories of Personal Data We Collect
Depending on your interactions with us, we may collect and process the following categories of personal data:
Contact details: name, email address, phone number, country of residence, preferred language.
Property & investment preferences: budget, property type, locations of interest, timeline, purpose of purchase (own use/investment).
Identification & KYC information (where relevant): copy of passport or ID, visa/residency details, proof of address and other documents required by UAE real estate and anti-money-laundering regulations.
Communication data: records of enquiries, emails, and call notes and other communication with our team.
Website usage data: IP address, device type, browser type, pages visited, time and date of visits, referring URL, and interaction with our forms and content. This may be collected using cookies and similar technologies.
Marketing & consent data: your preferences regarding marketing communications and cookie choices.
Zoho service interaction data (Forms / Bigin / Mail): where you submit information via our website forms or communicate with us, your details and interaction history may be processed and stored in our business systems, including:
Zoho Forms (form submissions and related metadata),
Bigin by Zoho (CRM records, deal/enquiry history, follow-up status),
Zoho Mail (email communications and related correspondence records).
We do not intentionally collect special category data (e.g. health data, political opinions) unless strictly required by law and with appropriate safeguards in place.
4. How We Obtain Personal Data
We may obtain your personal data from:
information you provide directly via forms, calls, emails, messaging apps or in person;
your use of the Website and our digital channels;
developers, business partners and marketing partners, where lawful;
publicly available sources, where appropriate.
5. Purposes and Legal Bases for Processing
We process your personal data only when we have a lawful basis under PDPL, which may include your consent, performance of a contract, compliance with legal obligations or our legitimate interests.
We use your data in particular to:
Respond to enquiries and provide services
to contact you after you submit a form or message;
to understand your requirements and send you tailored property options;
to create and manage enquiry records and follow-ups in Bigin (Zoho);
legal basis: performance of a contract or pre-contractual steps; legitimate interests.
Arrange viewings, reservations and transactions
to liaise between you and developers, sellers, banks or other partners;
to carry out KYC/AML checks as required by UAE regulations;
legal basis: compliance with legal obligations; performance of a contract.
Marketing and communications
to send you market updates, project launches, newsletters or invitations to events, where permitted;
to manage correspondence using Zoho Mail and maintain enquiry history in Bigin;
you can opt out at any time by using the unsubscribe link or by contacting us;
legal basis: your consent or our legitimate interests, depending on the channel and jurisdiction.
Website operation, security and improvement
to operate and secure the Website;
to process enquiries submitted through Zoho Forms and improve form performance and user experience;
to understand how visitors use our Website and improve content and user experience (analytics);
legal basis: legitimate interests (running and securing our business); consent where required for non-essential cookies.
Legal and regulatory obligations
to comply with UAE laws and regulations (e.g. real estate, anti-money-laundering, tax, data protection);
to respond to lawful requests from authorities or courts;
legal basis: compliance with legal obligations.
6. Cookies and Similar Technologies
We use cookies and similar technologies on the Website. Some cookies are essential for the operation and security of the Website. Other cookies (e.g. for analytics or marketing) are used only with your consent, which we obtain via our cookie banner in line with PDPL requirements.
If embedded tools or integrations (including Zoho Forms) use cookies or similar technologies, these are managed through our cookie banner and settings where required.
Details can be found in our separate Cookie Policy.
7. Who We Share Your Data With
We may share your personal data with:
UAE and international developers and sellers in connection with property enquiries or transactions;
our affiliates and group companies (if any) involved in marketing or transaction support;
service providers who support our operations (e.g. IT hosting, CRM, email platforms, marketing tools, professional advisers), including Zoho as a provider of:
Zoho Forms (collection and management of online form submissions),
Bigin by Zoho (customer relationship management),
Zoho Mail (email communications);banks, mortgage advisers, legal advisers and similar third parties, with your knowledge and where necessary for a transaction;
government authorities and regulators where required by law or for compliance (e.g. real estate regulators, tax authorities, law enforcement).
We require our service providers to handle personal data securely and only in accordance with our instructions and applicable law.
We do not sell your personal data.
8. International Transfers
Your personal data may be transferred to and stored in countries outside the UAE (for example, where our service providers host their servers, including Zoho). Where we transfer personal data internationally, we will take reasonable steps to ensure that appropriate safeguards are in place in line with PDPL, such as contractual protections and security measures.
9. Data Retention
We retain personal data only for as long as necessary for the purposes set out in this Policy, and to meet legal, regulatory, tax and accounting requirements.
General enquiry data: typically retained for up to 1 year after last contact, unless longer retention is required.
Transaction and KYC/AML records: retained for at least five (5) years after the end of the relationship or completion of the transaction, in line with UAE obligations for real estate brokers.
CRM and correspondence records (Bigin / Zoho Mail): retained in line with the periods above and any legal/regulatory retention requirements applicable to brokerage and AML compliance.
When data is no longer needed, we will delete or anonymise it in a secure manner.
10. Your Rights Under PDPL
Under the UAE PDPL, you may have the following rights, subject to certain conditions:
Right to access – to obtain confirmation whether we process your data and to receive a copy.
Right to rectification – to request correction of inaccurate or incomplete data.
Right to erasure – to request deletion of data where it is no longer needed, or where you withdraw consent and no other legal basis applies.
Right to restriction – to request that we restrict certain processing.
Right to object – to object to processing based on legitimate interests, including direct marketing.
Right to data portability – where applicable, to receive your personal data in a structured, commonly used, machine-readable format.
Right to withdraw consent – where processing is based on your consent, you can withdraw this at any time, without affecting prior lawful processing.
To exercise your rights, please contact us at Contact@InnerCircleRealtors.com. We may need to verify your identity before processing your request.
You may also have the right to lodge a complaint with the competent UAE data protection authority if you believe your rights have been infringed.
11. Security
We implement appropriate technical and organisational measures to protect personal data against unauthorised access, alteration, disclosure or destruction, taking into account the nature of the data and the risks involved. However, no system can be guaranteed to be 100% secure.
12. Minors
Our Website and services are not directed at children under 18. We do not knowingly collect personal data from minors. If you believe a minor has provided us with personal data, please contact us so we can delete it where appropriate.
13. Updates to This Privacy Policy
We may update this Privacy Policy from time to time. The “Last updated” date at the top of this page indicates the latest version. We encourage you to review this page periodically.
14. Contact
If you have any questions about this Privacy Policy or our data practices, please contact:
Inner Circle Real Estate Brokerage L.L.C
Abu Dhabi, United Arab Emirates
Email: Contact@InnerCircleRealtors.com