PRIVACY POLICY
Last Updated: 7 September 2026

This Privacy Policy explains how KALINKA KULM EXCLUSIVE PROPERTIES BROKER - L.L.C - S.P.C (“Company”, “Kalinka”, “we”, “our”, or “us”) collects, uses, stores, shares and protects personal data in connection with uaeproperty-estate.com (“Website”), our real estate services, enquiries, advertising campaigns and communications.
We process personal data in accordance with applicable data protection laws of the United Arab Emirates, including Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data, where applicable.
This Privacy Policy should be read together with our Terms & Conditions and any cookie or consent notices displayed on the Website.

1. Personal Data We Collect
Depending on how you interact with us, we may collect the following categories of personal data.
1.1. Information You Provide
This may include:
  • full name;
  • telephone number;
  • email address;
  • WhatsApp or other contact details;
  • details of your enquiry;
  • property preferences and requirements;
  • indicative budget;
  • preferred location or property type;
  • information you provide during communications with our agents;
  • documents or other information you voluntarily provide where relevant to a requested service or transaction.
Please do not provide documents or sensitive personal information unless reasonably necessary for the service you are requesting.

1.2. Website and Technical Information
When you use the Website, certain information may be collected automatically, including:
  • IP address;
  • browser and device information;
  • operating system;
  • pages viewed and interactions with the Website;
  • date and time of visits;
  • referring website or source;
  • cookie and similar technology identifiers;
  • UTM parameters and other campaign attribution information;
  • advertising identifiers, including Google Click ID (GCLID), where applicable;
  • analytics and conversion event data.
1.3. Advertising and Analytics Information
When you interact with our advertisements or Website, we may receive or generate information through advertising and analytics platforms, such as:
  • advertisement and campaign attribution;
  • conversion events;
  • lead form information where you submit a form through an advertising platform;
  • aggregated campaign performance information;
  • device and Website interaction information.
1.4. Information from Third Parties
Where permitted by applicable law, we may receive relevant personal data from third parties involved in providing real estate or related services, including:
  • property developers;
  • property owners;
  • real estate brokers and agencies;
  • advertising and lead-generation platforms;
  • CRM and communication service providers;
  • other parties where you have requested or authorized the relevant interaction.
2. How We Use Personal Data
We may process personal data for purposes including:
  • responding to your enquiry;
  • identifying properties relevant to your requirements;
  • providing real estate brokerage and consultation services;
  • sending requested brochures, floor plans, payment plans and project information;
  • arranging meetings, calls and property viewings;
  • communicating with developers and other parties where necessary to assist with your enquiry or transaction;
  • managing leads and client relationships through our CRM;
  • maintaining records of communications;
  • operating and securing the Website;
  • measuring Website and advertising performance;
  • measuring conversions and campaign attribution;
  • improving our Website, services and advertising;
  • sending marketing communications where permitted by applicable law;
  • complying with applicable legal, regulatory and record-keeping requirements;
  • establishing, exercising or defending legal rights.
We do not sell personal data to third parties.

3. Legal Basis for Processing
Depending on the circumstances and applicable law, we process personal data on one or more appropriate legal bases, including:
  • Consent — where you have provided valid consent for a particular processing activity;
  • Steps requested before entering into a contract and contractual necessity — where processing is necessary to respond to your request or provide services;
  • Legal obligations — where processing is required under applicable UAE law or regulatory requirements;
  • Other lawful grounds available under applicable UAE data protection legislation.
Where processing is based on consent, you may withdraw that consent, subject to applicable law. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.

4. Sharing Personal Data
We may disclose personal data where reasonably necessary for the purposes described in this Privacy Policy.
Recipients may include:
4.1. Real Estate Transaction Parties
Where relevant to your enquiry or transaction:
  • property developers;
  • property owners;
  • authorized developer sales representatives;
  • licensed real estate brokers or brokerage companies;
  • other professional or transaction parties where necessary.
We will not disclose your information to unrelated third parties for their independent marketing merely because you submitted an enquiry to us.

4.2. Service Providers
We may use third-party providers for functions such as:
  • CRM and lead management;
  • Website hosting and infrastructure;
  • email and communications;
  • WhatsApp and messaging services;
  • analytics;
  • advertising and conversion measurement;
  • IT and cybersecurity;
  • cloud storage.
Such providers may process personal data on our behalf or, depending on the service, as independent controllers subject to their own privacy terms.

4.3. Authorities and Legal Requirements
We may disclose information to governmental, judicial, law-enforcement or regulatory authorities where required or permitted by applicable law.

5. Cookies, Analytics and Advertising Technologies
The Website may use cookies and similar technologies for purposes including:
  • essential Website functionality;
  • security;
  • analytics and performance measurement;
  • conversion measurement;
  • advertising attribution;
  • remarketing and advertising personalization, where enabled.
These technologies may include services provided by third parties such as Google Analytics and Google Ads.
  • You may control or disable certain cookies through your browser settings. Disabling cookies may affect some Website functionality.
6. Marketing Communications
Where permitted by applicable law, we may contact you regarding properties, projects and real estate opportunities that may be relevant to you.
Marketing communications may be made through channels such as:
  • email;
  • telephone;
  • WhatsApp;
  • SMS or other electronic messaging services, where applicable.
Where consent is required, we will rely on the consent provided through the relevant form or communication channel.
You may withdraw your consent or request that marketing communications stop at any time by using an available unsubscribe method or contacting us.
A request to stop marketing communications will not prevent us from sending communications that are necessary to respond to an active enquiry or provide a service you have requested.

7. Data Retention
We retain personal data only for as long as reasonably necessary for the purposes for which it was collected, including to:
  • manage enquiries and client relationships;
  • provide requested services;
  • maintain appropriate business and transaction records;
  • comply with legal and regulatory obligations;
  • resolve disputes and establish or defend legal claims.
Retention periods may vary depending on the type of information, nature of the relationship and applicable legal requirements.
When personal data is no longer required, we will delete, anonymize or otherwise handle it in accordance with applicable requirements.

8. Data Security
We implement reasonable technical and organizational measures designed to protect personal data against unauthorized access, disclosure, alteration, loss or destruction.
Such measures may include, where appropriate:
  • encrypted transmission using HTTPS;
  • access controls;
  • restricted access to CRM and business systems;
  • account authentication and security controls;
  • appropriate safeguards applied by our technology service providers.
However, no Internet-based transmission or electronic storage system can be guaranteed to be completely secure.

9. International Transfers
Some of our technology, analytics, advertising, CRM, communications or cloud service providers may process or store personal data outside the United Arab Emirates.
Where personal data is transferred internationally, we take appropriate steps to ensure that such transfers are made in accordance with applicable UAE data protection requirements.

10. Your Data Protection Rights
Subject to applicable UAE law and any relevant exceptions, you may have rights concerning your personal data, including rights to:
  • obtain information regarding the processing of your personal data;
  • access personal data relating to you;
  • request correction or updating of inaccurate personal data;
  • request deletion of personal data where applicable;
  • restrict or object to certain processing where applicable;
  • withdraw consent where processing is based on consent;
  • request transfer of personal data where the applicable requirements are met;
  • object to certain automated processing where applicable.
To exercise a right, please contact us using the details provided below.
We may need to verify your identity before processing certain requests.

11. Third-Party Websites and Platforms
The Website may link to third-party websites or interact with external services such as property developer websites, maps, social media platforms or messaging services.
The privacy practices of those third parties are governed by their respective privacy policies. We encourage users to review them when leaving our Website or using an external service.

12. Changes to This Privacy Policy
We may update this Privacy Policy to reflect changes in our Website, services, technology, business practices or applicable legal requirements.
The latest version will be published on this page with an updated “Last Updated” date.

13. Contact Us
For questions about this Privacy Policy or requests concerning your personal data, please contact:
KALINKA KULM EXCLUSIVE PROPERTIES BROKER - L.L.C - S.P.C
Website: uaeproperty-estate.com
Email: info@kulm-group.com
Registered Address: Hidd Saadiyat Sunrise Residences SR3, SolAzure Business Centre, office 13 - Abu Dhabi
Trade Licence No.: CN-5921660
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