Scope of Policy & Regulatory Framework

This Privacy and Cookie Policy explains how Kemet collects, uses, stores, transfers, and safeguards your personal data when you interact with our website or utilize our real estate services. We process personal data in strict compliance with Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (“PDPL”) and its executive regulations. For the purposes of the PDPL, Kemet acts as the Data Controller.

Personal Data We Collect

• Identity Data: First name, last name, nationality, and details from your Emirates ID or Passport (for clients undergoing KYC checks).
• Contact Data: Email address, mobile telephone number, WhatsApp ID, and corporate billing addresses.
• Property & Transaction Data: Property details, title deeds, Oqood registrations, unit numbers, rental rates, and payment milestone structures associated with your listings or purchases.
• Financial Data: Credit card information (processed securely through PCI-DSS compliant third-party gateways; Kemet does not store full credit card data), bank account details (for commission refunds or security deposit routing), and transaction history.
• Technical & Usage Data: IP address, device type, operating system, geolocation coordinates (if enabled on your mobile device to find adjacent properties), clickstream history, and saved search preferences.
• Communication Data: Records of messaging exchanges conducted through our click-to-chat web components, customer service emails, and call tracking logs.

How Personal Data is Collected

• Direct Interactions: Voluntarily provided by you when completing contact forms, signing up for newsletters, requesting property valuations, or initiating messaging on the Site.
• Automated Technologies: Collected automatically via cookies, server tracking logs, and web beacons during your navigation of the Site.
• Third Parties and Public Registries: Verifying developer license status, project escrow validity, or broker credentials via DLD, RERA, and DET public database integrations.

Cookie Disclosure & Consent Framework

Cookies are small technical text files placed on your device to support browser performance, personalize navigation, and deliver targeted advertising. Kemet operates a strict explicit consent opt-in model under the UAE PDPL:

• Consent Script Blocking: No non-essential cookies (including Google Analytics tracking, Meta Pixel, and social media retargeting scripts) will fire or load on your device until you have actively clicked “Accept All” or configured preferences in our Cookie Consent Banner.

Cookie Categories:

• Strictly Necessary Cookies: Required for basic Site security, language preservation, and lead-form routing. These do not require consent and cannot be turned off.
• Analytics and Performance Cookies: Used to monitor anonymous user flow and help us improve website responsiveness. These are entirely optional.
• Marketing and Advertising Cookies: Allow us to showcase tailored Kemet property recommendations on third-party portals (such as Facebook, Google, and Instagram) based on listings you viewed on our Site. These are entirely optional.
• Preference Adjustment: You can reject non-essential cookies via the “Reject All” button or change your preferences at any time via the “Cookie Settings” link in the Site footer.

Lawful Basis and Purposes of Processing

• Data Subject Consent (Article 4(1)): When you complete an enquiry form, request a call, or agree to cookies.
• Contractual Necessity (Article 4(2)): When processing is required to draft brokerage agreements (Form A, B, or F), process bookings, or register tenancy agreements.
• Legal and Regulatory Obligation (Article 4(3)): When maintaining records required by RERA, performing goAML checkmarks, or filing reports to UAE tax authorities.

Cross-Border Data Transfers

Kemet may utilize international cloud hosting platforms, Customer Relationship Management (CRM) databases, and analytics services located outside the UAE. In accordance with Article 22 of the PDPL, Kemet only transfers personal data to destination jurisdictions that provide an adequate level of data protection, or where Kemet has implemented standard contractual clauses with the processor that mirror the privacy protections established under UAE law.

Secure Disclosures of Personal Data

We do not sell your personal data. We disclose your data to the following third parties strictly to facilitate transactions:

• RERA-Registered Developers and Landlords: Sharing your contact details only when you submit an explicit inquiry regarding a specific off-plan or secondary property listing, so they may process bookings or draft sales contracts.
• Authorized Service Providers: Secure cloud hosting engines, CRM systems, SMS gateway operators, and PCI-DSS compliant credit card processors.
• Governmental Authorities: DLD, RERA, DET, and UAE financial intelligence units when required under statutory obligations.

Data Security Protocols

Kemet employs technical and organizational security measures to protect your personal data from unauthorized access, loss, or alteration. These include TLS/HTTPS encryption for data transit, hashed storage formats for customer profiles, firewall protection systems, and audited access controls limiting data visibility to authorized personnel with a business “need-to-know.”

Regulatory Data Retention

We retain personal data only as long as necessary to fulfill the operational purposes detailed in this policy.

• Financial and Transaction Records: Maintained for a minimum of 10 years to comply with UAE Commercial Law and RERA auditing guidelines.
• General Enquiries: Maintained for 5 years from your last recorded interaction before being securely purged or anonymized.

Your Data Subject Rights

• Right to Access: Request a readable digital copy of the personal data Kemet holds about you.
• Right to Rectification: Request the correction of inaccurate or incomplete personal records.
• Right to Erasure (“Forgotten”): Request the deletion of your personal data when processing is no longer supported by a valid legal basis, subject to RERA’s statutory data retention limits.
• Right to Restrict Processing: Request Kemet to limit how your data is used under disputed scenarios.
• Right to Portability: Request transfer of your data to another controller in a structured format.
• Right to Withdraw Consent: Revoke your consent for future marketing communications or tracking cookies at any time.

Privacy Compliance Contact

To exercise any of your data subject rights, or if you have questions regarding our data practices, contact our designated privacy team:

Contact Entity	Legal Compliance & Data Protection Dept, Kemet Prime Properties LLC
Email	info@kemetprimeproperties.ae

  Kemet will verify your identity and respond to legitimate, verified requests within thirty (30) days as mandated under the PDPL. If your concern remains unresolved, you possess the statutory right to file a formal complaint with the UAE Data Office.