Privacy Policy

1. Introduction

At Dugasta Properties Development LLC, including all of its subsidiaries (collectively referred to as the “Company,” “Dugasta,” “we,” “us,” or “our”), we take your privacy seriously. We value you as our customer and are committed to protecting your personal information through our compliance with this Privacy Policy.

This Privacy Policy explains the types and sources of personal information we may collect from you, or that you may provide to us. It also describes the purposes for which we collect and process your personal information, as well as our practices for collecting, using, storing, retaining, protecting, and disclosing that information.

We encourage you to read this Privacy Policy carefully to understand how we handle your personal information. If you have any questions or concerns regarding this Privacy Policy or the way we process your personal information, please contact us.

2. Who We Are

We act as the data controller of your personal data. This means that we determine the purposes for which, and the manner in which, your personal data is collected, used, disclosed, stored, and otherwise processed, either independently or jointly with other parties where applicable.

Where you use facilities or services managed by one of our subsidiaries or affiliated entities, the relevant entity managing or providing those facilities or services may also act as a data controller in relation to your personal data.

3. When This Privacy Policy Applies

This Privacy Policy applies to the personal data we collect through the various channels by which you interact with Dugasta (collectively referred to in this Privacy Policy as the “Channels”).

These Platforms include, without limitation:

Digital Channels

Dugasta Website: When you visit our official website, currently available at www.dugasta.com, or any future websites, microsites, landing pages, or online services operated by Dugasta, we may collect personal information relating to your use of those services.
Email, SMS and Other Electronic Communications: When you communicate with us by email, SMS, WhatsApp, or any other electronic messaging service, we may collect and process the information contained in those communications.
Public Wi-Fi: When you use the public Wi-Fi services available at Dugasta offices, properties, or other locations, we may collect certain information relating to your use of those services.

Customer Interactions

Customer Service: If you contact our customer service team by telephone, email, live chat, chatbot, WhatsApp, or any other support channel, we may collect the personal information you provide in connection with your enquiry, request, or feedback.
Feedback and Complaints: We collect and process feedback, complaints, enquiries, and service requests submitted through the Dugasta Feedback portal or any similar customer support platform.
Registration Forms and Promotional Activities: We may collect personal information when you complete online or paper registration forms, participate in surveys, competitions, exhibitions, events, promotional campaigns, or make enquiries through our sales offices, promotional stands, shopping malls, or other marketing activities.

Marketing and Recruitment

Advertising and Marketing Activities: We may collect information when you interact with advertisements or marketing campaigns published by Dugasta or our authorised marketing partners on websites, mobile applications, social media platforms, or other digital channels.
Career Portal: If you apply for employment with Dugasta or submit information through our recruitment portal, we will collect and process the personal information relevant to your application.
Customer Rewards: If you participate in any current or future Dugasta customer rewards or loyalty programme, we may collect and process information relating to your registration, participation, and transactions.

Other Sources of Personal Data

We may also obtain or generate personal data through other means, including:

Information We Generate – Information created during the course of providing our products and services to you, including records relating to your transactions, enquiries, and interactions with us.
Information from Third Parties – Information obtained from social media platforms, market research agencies, authorised sales agents, registered brokers, promotional partners (such as banks and government entities), publicly available sources, or as part of a corporate acquisition or business transfer.

4. Personal Data Directly Obtained from You

The types of personal information we collect through or in connection with our Channels, the purposes for which we collect such information, and how we use your personal data are explained below. We process your personal data based on our legitimate interests, where such processing is necessary for the purposes described below and does not override your fundamental rights and freedoms.

Description of Processing	Purpose for Processing	Category of Personal Data
We collect and process personal data when you contact us, submit an enquiry, express interest in our properties, visit our sales offices, participate in our events, contact our sales representatives, or communicate with us through our website, social media platforms, telephone, WhatsApp, or authorised third-party agents.	To respond to your enquiries, understand your requirements, provide information about our properties, and assist you in identifying suitable properties and services.	Name, email address, telephone number, nationality, communication details, property preferences, and enquiry details; Web data; other personal information
We process your personal data for marketing purposes (e.g. personalising offers and for lead generation activities), as well as for analytics purposes. We may do this by notifying you of any events conducted by Dugasta, or sending you personalized offers, discounts or promotions by our mobile application, or email (where you have agreed to receive our emails), or advertising content that is relevant to your interests. It is in our legitimate business interests to send you information about Dugasta’s services and latest offers.	Marketing and analytics services	Name, email address, telephone number, nationality, communication details, property preferences, and enquiry details; web data; other personal information
We may use your personal data to facilitate email campaigns carried out by our sales and marketing departments. As part of our email campaigns, we track whenever you receive, open, click a link, or download any attachments from an e-mail you receive from Dugasta. We will carry out automated profiling of such information to evaluate your interest in our service offerings or promotions.	Marketing and analytics services
We process your personal data to manage operations related to real estate development.	Operations	Name, email address, telephone number, nationality, communication details, property preferences, and enquiry details; Web data, other personal information; and visa details
We process your personal data to manage sales purchase of a property with Dugasta and related operations.	Operations	Name, email address, telephone number, nationality, communication details, property preferences, and enquiry details; Web data; other personal information
We process your personal data for real estate sales activities including operations and managing the brokerage network.	Supporting Service	Name, email address, telephone number, nationality, communication details, property preferences, and enquiry details; web data; other personal information; and financial data
We process your personal data for procurement purposes, such as vendor management and contract management.	Supporting Service	Name, email address, telephone number, nationality, communication details, property preferences, and enquiry details; Web data, other personal information, financial data
We process your personal data for invoicing purposes.	Account Management	Name, email address, telephone number, nationality, communication details, property preferences, and enquiry details; web data; other personal information; and financial data
For management and audit of our business operations including accounting.	Financial Management	Name, email address, telephone number, nationality, communication details, property preferences, and enquiry details; Web data, other personal information; and financial data
We process your personal data in order to comply with legal requirements and exercise or defend legal claims. It is in our legitimate interests to process personal information for the purposes of exercising and defending legal claims. Processing personal information may also be necessary to ensure compliance with the relevant legal and regulatory obligations.	Litigation & Disputes	Identification Data, Contact Details, Financial Data, Other Personal Information
We process your personal data for security purposes and to ensure secure backup and archival of IT systems.	Security Purposes	Identification Data, Contact Details, Financial Data, Web Data, Other Personal Information
We process your personal data for application management and support purposes and to respond to customer requests.	Security Purposes	Identification Data, Contact Details, Financial Data, Web Data, Other Personal Information
We process personal data in relation to the usage of Wi-Fi services provided at our locations.	Security Purposes	Contact Details, Web Data
We process your personal data to facilitate application integration within our systems.	Security Purposes	Identification Data, Contact Details, Financial Data, Web Data, Other Personal Information
We process your personal data to conclude property sales. We are required to carry out a security clearance of our customer in compliance with local laws and pursuant to our legitimate business interest to combat any fraudulent transactions.	Operations	Name, email address, telephone number, nationality, communication details, property preferences, and enquiry details; Web data; other personal information; and visa details
We may use your personal information you provide us for a commercial purpose to help us tailor and show advertisements to you. We may partner with third parties to help us display relevant advertising and to manage our advertising across multiple channels, including social media platforms. Our third-party partners may use cookies and non-cookie-based technologies to help us show you advertising based upon your browsing activities and interests.	Advertising	Name, email address, telephone number, nationality, communication details, property preferences, and enquiry details; web data, other personal information
We may need to process your personal information to keep your payments safe and secure and protect against fraudulent transactions. It is in our legitimate interests to process personal information to keep your payments secure and to prevent fraud. We may also require your personal information to send payment reminders and legal intimations in case of overdue payments. Processing personal information in this way may also be necessary to ensure compliance with the relevant legal and regulatory obligations.	Financial Operations	Name, email address, telephone number, nationality, communication details, property preferences, and enquiry details, Web data, other Personal Information, Visa details, Financial Details

5. Other information we collect

In addition to the personal information described above, we may collect certain information that does not directly identify you or is not otherwise associated with you as an identifiable individual. We may collect such information automatically when you visit our website or use our services, where such collection is necessary for our legitimate business interests.
The information we may collect includes:
Information relating to your device, browsing activities, and usage patterns when you access or interact with our website.
Technical information, including usage details, the date and time of requests, browser type, operating system, IP address, and information collected through cookies, web beacons, and similar tracking technologies.
Details regarding your interaction with our website, including traffic data, approximate location data, access logs, communication data, and the resources you access and use.
The information collected automatically is generally aggregated and statistical in nature. It enables us to improve our website, enhance user experience, and provide more efficient and personalised services by allowing us to:
Understand our audience size, usage trends, and user preferences.
Remember your preferences and customise our website experience based on your interests.
Improve website performance, facilitate faster searches, and recognise you when you return to our website.

The technologies we use for collecting information automatically may include:

Cookies: Cookies are small data files containing an identifier made up of letters and numbers that are stored on your device through your web browser. We use cookies and similar tracking technologies to enhance your experience on our website, remember your preferences, analyze website usage, and improve our services. Cookies generally do not contain information that directly identifies you; however, information collected through cookies may be combined with other personal information we hold about you. You may manage or disable cookies through your browser settings; however, doing so may affect certain features and functionality of Dugasta Websites.
Local Storage Technologies: Certain features of our website may use local storage technologies, including Flash cookies or similar technologies, to store information about your preferences and interactions with our website. These technologies may not be managed through the same settings used to control standard browser cookies.
Web Beacons: Our website pages and emails may contain small electronic tracking technologies, such as web beacons, clear GIFs, pixel tags, or similar tools. These technologies help us understand how users interact with our website and communications, including measuring page visits, email engagement, website performance, and the effectiveness of our content.

We use cookies and similar technologies for the following purposes:

To recognize you when you access or revisit our platforms and provide a more seamless browsing experience;
To enable certain functionalities and determine whether you are logged into our platforms;
To remember your preferences and customize your experience;
To enhance the security and protection of our platforms and user accounts; and
To analyze usage trends and improve the performance, functionality, and overall user experience of our platforms.

6. Information We Receive from Third Parties

We may obtain personal information about you from third-party sources with whom we have business relationships or from other individuals who provide your details to us. This may include information provided by individuals who refer you to our loyalty programmes, as well as third-party agents, partners, or service providers through whom you have shown an interest in our properties, products, or services.

Where appropriate, we require such third parties to confirm that they are authorized to share your information with us and that you are willing to receive communications from us. We may use the information obtained from third parties for the purposes described in this Privacy Policy and in accordance with applicable data protection laws.

How You Can Opt Out

If you no longer wish to receive marketing communications from us, you may opt out at any time through the following channels:

Email Communications: Use the unsubscribe link provided in our marketing emails.
SMS Communications: Follow the opt-out instructions included in the SMS messages you receive from us.
Contact Us: Reach out to us using the contact details provided in Section Contact Us of this Privacy Policy.

7. Who Might We Share Your Information With?

We may disclose personal information that we collect, or you provide as described in this privacy policy:

We may share your information with our subsidiaries, affiliates, and related entities to provide our services, process transactions, manage customer relationships, support service requests, and communicate with you about relevant products and services.
We may share information with trusted third-party service providers, agents, contractors, and professional advisors who assist us with property services, payments, technology, marketing, communications, security, analytics, legal, accounting, insurance, and other operational activities.
We may share information with selected business partners to provide you with relevant offers, benefits, or services, including financing, lifestyle, travel, and other customer benefits.
We may disclose information where required by law, regulation, court order, or legal process, or where necessary to protect our rights, property, safety, or prevent fraud.
In the event of a merger, acquisition, restructuring, sale, or transfer of assets, your personal information may be transferred as part of the relevant transaction.

Your personal information may be transferred to and processed in countries outside your country of residence. We will implement appropriate safeguards to ensure that such transfers comply with applicable data protection laws and that your information remains adequately protected.

We retain your personal information only for as long as necessary to fulfill the purposes for which it was collected, comply with legal and regulatory obligations, resolve disputes, and protect our legal rights. Once your information is no longer required, we securely delete or anonymize it in accordance with applicable laws.

8. How Do We Keep Your Information Secure?

Protecting your personal information is important to us. We implement appropriate technical and organizational measures to safeguard your personal information against accidental loss, unauthorized access, use, alteration, or disclosure.

We use industry-standard security measures, including encryption technologies, firewalls, secure communication channels, and access controls, to help protect the confidentiality and integrity of your information when it is collected, stored, and processed.

Our security measures include:

Requiring confidentiality obligations from our employees, contractors, and service providers;
Limiting access to personal information to authorized personnel and third parties on a need-to-know basis;
Using secure systems and communication channels for the transmission and storage of personal information;
Regularly reviewing and improving our security practices; and
Securely deleting or anonymizing personal information when it is no longer required, in accordance with applicable laws.

You are also responsible for protecting the security of your account information. Where you have been provided with a password or access credentials, you should keep them confidential and avoid sharing them with others.

While we take reasonable measures to protect your personal information, no method of transmission or storage over the internet can be guaranteed to be completely secure. Accordingly, we cannot guarantee the absolute security of information transmitted through our website or services, and any transmission is undertaken at your own risk.

9. What Are Your Rights?

Depending on the applicable data protection laws, you may have certain rights in relation to your personal information. These rights may include:

Right to Access: You may request confirmation of whether we process your personal information and, where applicable, request access to a copy of the personal information we hold about you.
Right to Rectification: You may request that inaccurate or incomplete personal information is corrected or updated.
Right to Restrict Processing: You may request that we limit the processing of your personal information in certain circumstances, including where you believe the information is inaccurate, the processing is unlawful, or where you require the information for legal claims.
Right to Erasure: You may request deletion of your personal information where permitted by applicable laws, including where the information is no longer required for the purposes for which it was collected or where you withdraw consent (where applicable). We may retain certain information where required by law or for legitimate purposes, including establishing, exercising, or defending legal claims.
Right to Object: You may object to certain types of processing of your personal information, including processing based on legitimate interests or for direct marketing purposes.
Right to Data Portability: Where applicable, you may request to receive your personal information in a structured, commonly used format or request its transfer to another organization where technically feasible and permitted by law.
Right to Withdraw Consent: Where we rely on your consent to process personal information, you may withdraw your consent at any time. Withdrawal of consent will not affect the lawfulness of processing carried out before such withdrawal.
Right to Lodge a Complaint: You may have the right to submit a complaint to the relevant data protection authority or supervisory body in accordance with applicable laws.

10. Updates to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, services, legal requirements, or other operational considerations. Any changes will be effective when the updated Privacy Policy is published on our website or otherwise communicated to you, where appropriate.

We encourage you to review this Privacy Policy periodically to stay informed about how we collect, use, and protect your personal information.

11. How Do You Contact Us?

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal information, you may contact our Data Privacy Office through the following channels:

Email: sales@dugasta.com
Telephone:+971 800 DUGASTA [3842782]
Mail: Unit 31-30 Central Park Tower Offices,
31st Floor Omlaat Street – Trade Centre –
DIFC Dubai, U.A.E