Legal
Privacy Policy
Draft prepared for Keys & Numbers Properties' review — informed by UAE PDPL (Federal Decree-Law No. 45 of 2021) and common Dubai real-estate industry practice. Please have this reviewed by UAE legal counsel before publishing live, to confirm it matches your actual data practices and licence details.
This Privacy Policy explains how Keys & Numbers Properties ("Keys & Numbers", "we", "us" or "our") collects, uses, shares and protects your personal data when you visit keysandnumbers.com, contact us, or message us on Facebook Messenger, Instagram or WhatsApp.
Introduction & Scope
This policy applies to visitors to keysandnumbers.com, people who submit an enquiry, valuation request, affiliate/partner or careers application, and anyone who contacts us by phone, WhatsApp, Facebook Messenger or Instagram.
Keys & Numbers Properties is a RERA-licensed real estate brokerage in Dubai (ORN 63508).
This policy is governed by UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data ("UAE PDPL") and its implementing regulations, alongside the rules of the Real Estate Regulatory Agency (RERA) and the Dubai Land Department (DLD) that apply to us as a licensed brokerage. If you are located outside the UAE, other laws may also apply to how your data is handled (for example, the GDPR for residents of the EEA or UK); where they do, we aim to honour equivalent protections regardless of where you are.
Information We Collect
Information you give us directly — your name, email, phone/WhatsApp number, nationality, budget, property preferences, the content of your messages, and any documents you choose to share with us (for example, a passport copy or proof of funds) as a transaction progresses. This includes information submitted through our contact, valuation, affiliate/partner, careers and newsletter forms.
Information collected automatically — your IP address, browser and device type, pages viewed, referring page, approximate location, and cookies or similar tracking data. See our Cookie Policy for detail.
Information from third parties — property portals, referral partners, developers, mortgage advisors, and publicly available sources such as DLD/RERA records, where relevant to a transaction.
Information via social and messaging channels — when you message our Facebook Page or Instagram account, we receive your name, public profile information and the content of your messages. See "Facebook & Instagram Messaging Platform" below.
Our services are directed at adults, and we do not knowingly collect personal data from children.
How We Use Your Information
We use your information to:
respond to your enquiry and provide the property information, valuation or advice you asked for
match you with the specialist who knows your community or transaction type
arrange viewings and support transactions, leasing and property management
send market updates and relevant opportunities, only where you have consented (for example, by ticking "I would like to receive market updates")
process affiliate/partner and careers applications
improve our website and services through analytics
meet our legal, regulatory and RERA/DLD obligations, including anti-money-laundering checks where applicable
keep records for dispute resolution and other legitimate business purposes
We do not sell your personal data to third parties.
Legal Basis & Your Rights
We process your data on the following legal grounds: your consent; performance of a contract or steps you ask us to take before entering one (such as arranging a viewing); our legitimate business interests (such as fraud prevention and service improvement), balanced against your rights; and compliance with our legal and regulatory obligations.
Subject to certain exceptions under UAE PDPL, you have the right to:
access the personal data we hold about you
correct inaccurate data
request erasure or deletion of your data (see "Data Deletion Instructions" below)
object to, or restrict, certain processing, including direct marketing — you can unsubscribe at any time
withdraw consent at any time, where processing relies on it
request data portability, where applicable
To exercise any of these rights, contact us using the details under "Contact Us" below; we will respond within a reasonable time in line with UAE PDPL. You may also have the right to lodge a complaint with the UAE Data Office if you believe your data has been mishandled.
How We Share Your Information
We share your data with:
Our own staff and advisors who need it to assist you
Service providers, including IT/hosting, CRM, email/SMS/WhatsApp messaging platforms, analytics providers, payment processors, and marketing platforms such as Meta, for advertising purposes subject to Meta's own terms
Developers and property partners, when you register interest in an off-plan project or listing, so they can follow up with you
Professional advisors, such as mortgage brokers or conveyancers, only where you ask us to introduce you
Regulators and authorities, including RERA and the DLD, where legally required
A buyer or successor, if we are involved in a merger, acquisition or sale of assets, subject to confidentiality commitments
International transfers. Keys & Numbers has offices in Dubai, the United Kingdom and India, so your data may be accessed or processed from any of these locations. Where we transfer personal data outside the UAE, we take reasonable steps to ensure it receives a comparable level of protection, including through contractual safeguards with our service providers.
Data Retention & Security
We keep personal data only as long as necessary for the purposes described in this policy, to meet legal and regulatory obligations (including RERA/DLD record-keeping requirements), resolve disputes, and enforce our agreements. Enquiry and transaction records are typically kept for the duration of our relationship with you, plus a further period required by law or good practice; contact us if you would like more detail on a specific retention period.
We use reasonable administrative, technical and physical safeguards — including access controls and restricted staff access — to protect your data. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.
Cookies
Our website uses cookies and similar technologies to operate the site, remember your preferences and, once enabled, measure performance and personalise marketing. Full detail on the cookies we use, why, and how to manage them is set out in our separate Cookie Policy.
Facebook & Instagram Messaging Platform
We use Meta's Messenger and Instagram Direct Messaging to communicate with people who reach us through our Facebook Page or Instagram account.
When you message us on these channels, we may receive and store your name and public profile information, your Facebook/Instagram user ID, and the content of the messages you send us — including any contact details, property preferences or documents you choose to share.
We use this information solely to respond to your enquiry, provide property information and advisory services, and follow up on your interest, consistent with Meta's Platform Terms and Messenger Platform Policy. We do not use Messenger or Instagram data for any purpose incompatible with Meta's policies, we do not use it for advertising to you without your consent, and we do not sell it.
Automated replies. We may use basic automated or templated responses — for example, business hours or initial enquiry routing — to acknowledge your message quickly. A member of our team follows up personally for anything substantive.
You can stop receiving messages from us at any time by blocking our Page or account, or by telling us to stop within the conversation. This data is handled under the same rights, retention and security commitments set out elsewhere in this policy.
Data Deletion Instructions
You can request deletion of the personal data we hold about you — including data collected through Facebook or Instagram Messaging — at any time, in any of the following ways:
Email us using the address on our Contact page, with the subject line "Data Deletion Request", including your full name and the email, phone number or Facebook/Instagram profile you used to contact us.
Remove our access directly through Facebook: go to Settings & Privacy > Settings > Apps and Websites, find Keys & Numbers, and select Remove.
WhatsApp us using the number on our Contact page, with "Data Deletion Request".
We will verify your request, then delete or anonymise the personal data associated with you within 30 days — except data we are legally required to retain, such as records needed for RERA/DLD compliance or an active transaction — and confirm with you once it is complete. If you have questions about this process, contact us using the details under "Contact Us" below.
Children's Privacy & Third-Party Links
Our services are intended for adults capable of entering into property transactions, and we do not knowingly collect personal data from children.
Our website may link to third-party sites — developers, portals, mortgage providers, social media — whose privacy practices we do not control. We encourage you to review their own privacy policies.
Changes to This Policy & Contact Us
We may update this Privacy Policy from time to time to reflect changes in our practices, technology or legal requirements. The date at the top of this page shows when it was last revised, and we will highlight material changes here.
Contact us
See our Contact page for our current phone number, email and office address.