DATA PROTECTION POLICY
  www.exclusivedubairesidences.com
Effective date: 30/07/2025 
INTRODUCTION  
The purpose of this policy (hereinafter referred to as "Policy") is to define the privacy and data policy of Exclusive Marketing Agency FZCO(trade number: 104376262200003; e-mail: info@najahworks.com; registered office: 41802-001, IFZA Business Park, DDP, Silicon Oasis, Dubai, U.A.E) (hereinafter referred to as "Company") as the owner and operator of the www.exclusivedubairesidences.com website (hereinafter referred to as "Website"), which the Company, as the data controller, acknowledges as binding.  
This Policy sets out the principles for the processing of personal data provided by users on the Website and provides information to data subjects about the processing of their personal data.  
This Policy regulates the processing of data on the following Website: www.exclusivedubairesidences.com  
The Data Protection Policy is available at: www.exclusivedubairesidences.com   Amendments to this Policy will enter into force upon publication at the above-mentioned Website.  
1. INTERPRETATIVE PROVISIONS
1.1. Data controller: the natural or legal person or organization without legal personality who, alone or jointly with others, determines the purposes of data processing, makes and implements decisions relating to data processing (including the means used), or has them implemented by the data processor.  
1.2. Data processing: any operation or set of operations performed on data, regardless of the procedure used, including in particular collection, recording, recording, organization, storage, alteration, use, retrieval, transmission, disclosure, alignment or combination, blocking, erasure and destruction, as well as preventing further use of the data, taking photographs, audio or video recordings, and recording physical characteristics suitable for identifying a person (e.g. fingerprints or palm prints, DNA samples, iris scans).  
1.3. Personal data: data that can be linked to a data subject – in particular the name, identification number and one or more specific physical, physiological, mental, economic, cultural or social characteristics of the data subject – and the conclusion that can be drawn from the data concerning the data subject.  
1.4. Consent: a voluntary and definite indication of the data subject's wishes, based on adequate information, by which he or she gives his or her unambiguous consent to the processing of personal data relating to him or her, in whole or in part.  
1.5. Data processing: the performance of technical tasks related to data management operations, regardless of the method and means used to perform the operations and the place of application, provided that the technical task is performed on the data.  
1.6. Data processor: a natural or legal person, or an organization without legal personality, who processes data on the basis of a contract - including a contract concluded on the basis of a legal provision.  
1.7. Data subject: any natural person identified or identifiable, directly or indirectly, on the basis of specific personal data.  

2. DETAILS OF THE DATA CONTROLLER  
The Company is the controller of your personal data, which means that the Company is responsible for the lawful processing of your personal data.   You can contact them using the contact details below:  
Company name: Exclusive Marketing Agency FZCO
Trade number: 104376262200003;
E-mail: info@najahworks.com
Registered office: IFZA Business Park, DDP, Silicon Oasis, Dubai, U.A.E  

3. A DESCRIPTION OF DATA MANAGEMENT AT THE LEVEL OF EACH DATA MANAGEMENT PROCESS  
Establishing contact
To enable the Company to establish contact with you, it is necessary to complete a dedicated form. By submitting the form, you consent to the collection of your personal data.  
Cookies
The Company places a small data packet (hereinafter referred to as "Cookie") on the user's computer to provide a personalized service. The purpose of the cookie is to ensure the highest possible quality of the operation of the site, to provide personalized services and to enhance the user experience. The Cookie can be deleted from the user's computer, or the user can set his/her browser to refuse the use of cookies. By disabling the use of Cookies, the user acknowledges that the functionality of the site is incomplete without Cookies.   Cookies may be used according to their function as follows:  
Essential (functional) cookies help you to use our website by enabling basic functions such as site navigation, displaying the site in a language that suits you, and protecting our website from external attacks. Our website cannot function properly without these cookies;

Cookies that are used for statistical purposes help us understand how our users use our Website. These Cookies allow us to measure e.g., the number of visitors to the Website, the time spent on it, and to select the most popular content. The data collected by statistical cookies is usually anonymous and does not identify you;

  We also use Cookies for marketing purposes to track the activities of visitors to our Website. The purpose is to provide relevant advertisements and promotions to individual users on Meta Platform Inc. sites and Google services and to encourage them to act, which makes our Website even more valuable for content publishers and third-party advertisers.

  4. WHAT PERSONAL DATA DO WE COLLECT?  
Establishing contact
The Company collects the following data when you complete the dedicated contact form: name (for your identification);
e-mail address (for the purpose of responding to your inquiry submitted through the contact form);
phone number (for the purpose of responding to your inquiry submitted through the contact form).
Cookies
The Website runs software that analyses visitor data and receives automatically generated information about visitors; these are: the Internet Protocol (IP) address of the visitor;
the date and duration of the visit;
the name of the browser program you are using;
frequency of website visits.

  5. FOR WHAT PURPOSES DO WE COLLECT PERSONAL DATA? 
Establishing contact
The purpose of the collection is to enable us to respond to your message, provide you with the requested information, clarify any issues you may have raised by completing the form, and maintain further communication where necessary in relation to your inquiry.   Cookies
The purpose of using cookies: to facilitate the customization of the services and advertisements used by the users of the Website, and to make use of the convenience features;
to prepare of statistics and analyzes on Website visits and visitor preferences.
  Google Analytics will use this information for the purpose of evaluating and analysing your use of the Website, and that of other data subjects, compiling reports on Website activity and providing other services relating to that and also internet usage. 

6. LEGAL BASIS FOR PROCESSING  
The legal basis for processing the personal data specified above is your consent as the data subject. In all cases, the processing is voluntary. You may withdraw your consent at any time.  
Consent to the processing of personal data is given by completing and submitting the contact form (consent as described in the Policy), as well as by visiting the Website and using the content there in the case of cookies. You can withdraw your consent to this implicit behavior at any time by deleting the cookies from your computer or by setting your browser to disable the use of cookies.  

7. DURATION OF THE PROCESSING 
Establishing contact
Until consent is withdrawn, but no longer than is necessary to fulfill the purpose. 
Cookies
Session cookies are automatically deleted when you close your browser. In all other cases, the Company will process your personal data until the purpose of the cookie is achieved.  

8. DATA PROCESSOR 
The personal data we collect is transferred to La Boutique Collection Real Estate LLC (e-mail: info@laboutiquerealestate.com; Office Number: 47340), which acts as a data processor and processes the data solely on behalf of and under the instructions of Exclusive Marketing Agency.  
For analytics and advertising in relation to cookiies we use:
 Google LLC (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA) for Google Analytics.
Meta Platforms Ireland Ltd. (4 Grand Canal Square, Dublin 2, Ireland) for Facebook Pixel.
Google LLC processes data on our behalf and transfers data to the USA under the Standard Contractual Clauses (SCC), providing adequate safeguards for your data. We do not transfer personal data to other third countries.  

9. DATA SECURITY 
We implement appropriate technical and organizational measures to protect your personal information against unauthorized access, disclosure, alteration, or destruction. We maintain industry-standard security protocols and regularly review and update our security practices to mitigate risks and safeguard your data.  

10. YOUR RIGHTS AND REMEDIES 
What rights are you entitled to as a data subject in relation to your data?
·       Request information about the data stored about you
·       Access your personal data
·       Correct or delete your data
·       Restrict data processing
·       Object to data processing
·       Exercise the right to data portability 

What are your rights if you consider that the processing is unlawful?
If you have concerns about the lawfulness of the processing, you have the right to object to the processing. The objection must include a request that we stop processing your data and delete your data.
If you object to the processing of your personal data, the Company will within one month examine the grounds for the objection, take a decision on the merits and notify you in writing of its decision.
If we find that your objection is justified, we will terminate all processing operations, block the data concerned and notify the objection and subsequent actions to all those to whom we have previously disclosed the personal data concerned by the objection. These recipients are also required to take action to give effect to your objection.
If you do not agree with our decision or if the Company does not comply with the one-month time limit above, you may take legal action within 30 days of the date of the decision or the last day of the time limit.
If you wish to request deletion, modification, access or exercise any of your data subject rights, you can do so by emailing us at info@najahworks.com. This applies to all rights described in this Policy, including correction, erasure, restriction, objection, and data portability. 
Judicial enforcement
If you believe that we have violated your right to privacy or that our decision to object or not to respond to your objection was wrong, you can take us to court. You can also choose to bring your case in the courts in the place where you live or where you are resident. In addition, under the conditions set out in the law, if we cause you damage because of unlawful processing or a breach of data security requirements, you may bring a claim for damages against the Company in court. If your privacy rights have been violated, you may be entitled to damages, which you may also claim in court. We are responsible for our data processors in this area.

  11. AUTOMATED DECISION-MAKING AND PROFILING
All processing of your personal data under this Policy is performed manually; we do not engage in any automated decision-making or profiling that could affect you. This ensures compliance with GDPR requirements and guarantees that no decisions are made about you solely by automated means.