Privacy Policy

1. Data Controller

The Data Controller for the purposes of UAE Federal Decree-Law No. 45 of 2021 (PDPL) is Arcady Polansky — a RERA-licensed real-estate broker, BRN 50032, operating in Dubai, UAE.

2. Contact for data matters

For any questions about your data or to exercise your rights, use the contact form or message via WhatsApp / Telegram: +971 50 503 8761. The email address itself is not published on the site for spam-protection reasons — the form delivers your message to my personal inbox.

3. What data we collect

• Form data — name, phone (WhatsApp), budget, area of interest (buy / sell / consult), optional message. This is encoded into a WhatsApp link that opens in your client. Where a CRM webhook is configured, the data is also forwarded to the broker's CRM for follow-up.
• Technical data — IP, user-agent, country-by-IP, pages visited. Held in CDN/hosting logs for no longer than 30 days.
• Analytics data — anonymised page views, events and sessions, gathered via Google Analytics 4, Meta Pixel and Yandex Metrica, only with your consent.
• UTM parameters — utm_source, utm_medium, utm_campaign etc. captured from URL and stored in browser sessionStorage for attribution.
• Language preference — preferred-lang cookie + localStorage so the Site opens in your chosen language.

4. Purposes of processing

• Reach you back on your enquiry (the core brokerage service).
• Operate the Site reliably, securely and fast.
• Understand which content is useful (analytics, with consent).
• Attribute marketing channels (marketing cookies, with consent).
• Comply with regulatory requirements (RERA, DLD, AML/KYC at transaction).

5. Legal basis (PDPL Art. 4)

• Consent — for analytics and marketing cookies.
• Performance of contract at your request — for form data and correspondence.
• Compliance with law — KYC at transaction, anti-money-laundering.
• Legitimate interest — site security, anti-spam.

6. Your rights as a data subject

Under PDPL you have the right to:

• Request access to your data.
• Request correction of inaccurate data.
• Request erasure (right to be forgotten), absent overriding legal grounds.
• Request restriction of processing.
• Object to processing — including direct marketing.
• Receive a portable copy of your data.
• Withdraw any previously given consent at any time.

Exercise rights via the contact form or WhatsApp/Telegram above. Response time: up to 30 days (PDPL Art. 16).

7. Cross-border transfers

Some processing happens at vendors whose servers may sit outside the UAE:

• Google Analytics — Google infrastructure (mostly US/EU).
• Meta Pixel — Meta infrastructure (mostly US/EU).
• Yandex Metrica — Yandex infrastructure (Russian Federation).
• CDN / hosting — global edge.

Transfers are based on the vendors' standard contractual terms and/or your consent (for marketing cookies). The list and jurisdictions can change — see the cookies page for the current state.

8. Retention

• Form data — for the duration of working with you, and up to 7 years for AML/KYC compliance.
• Analytics — up to 24 months in Google/Yandex.
• Hosting logs — up to 30 days.
• Cookies — as listed on the cookies page.

9. Security measures

The Site is served over HTTPS (TLS) with auto-renewing Let's Encrypt certificates. Data access is restricted to the owner. The Site does not collect payment or passport data. KYC at transaction time is handled separately via regulated DLD / UAE banking channels.

10. Complaints

If you believe your rights have been violated, you can lodge a complaint with the UAE Data Office (https://u.ae/en/about-the-uae/digital-uae/data/data-office) or with the data-protection authority in your country of residence.

Last updated: 10 May 2026.