PRIVACY POLICY

Last Updated: August 2026

1. INTRODUCTION AND GENERAL PROVISIONS
Welcome to kovodubai.com (the “Website”), operated by KOVO REAL ESTATE L.L.C (“Company”, “we”, “us”, or “our”).

Company Details:
– Trade Name: KOVO REAL ESTATE L.L.C
– Commercial License No.: 1612813 (Issued by the Department of Economy and Tourism, Dubai, UAE)
– Commercial Register No.: 2837632
– Registered Address: Office No. 247-R20, Mulk Danube Building Materials FZC, Wadi Al Safa 2, Dubai, United Arab Emirates
– Primary Contact Email: playamarinmo@gmail.com
– Primary Contact Phone: +971-50-5546705

We are committed to protecting and respecting your privacy. This Privacy Policy governs our data collection, processing, and usage practices in relation to visitors and users of our Website, particularly those residing in the European Union (EU) and European Economic Area (EEA), in compliance with Regulation (EU) 2016/679 (General Data Protection Regulation or “GDPR”), as well as Federal Decree-Law No. 45 of 2021 on Personal Data Protection (PDPL) of the United Arab Emirates.

By accessing or using our Website and submitting your personal information, you acknowledge that you have read, understood, and agreed to the practices described in this Privacy Policy.

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2. DATA CONTROLLER AND DATA PROTECTION OFFICER
KOVO REAL ESTATE L.L.C acts as the Data Controller responsible for your personal data. Because we target clients in the European Union for real estate brokerage services in Dubai, we strictly adhere to GDPR rules regarding lawful processing, data security, and data subject rights.

If you have any questions, concerns, or requests regarding this Privacy Policy or how we handle your personal data, please contact us at:
Data Protection Contact: playamarinmo@gmail.com

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3. CATEGORIES OF PERSONAL DATA WE COLLECT
We collect only the personal data that is necessary to fulfill your requests, provide real estate brokerage services, and improve your user experience on our Website.

A. Information You Voluntarily Provide to Us:
When you fill out contact forms, request a callback, inquire about a property listing, or contact us via email/phone, we collect:
– Full Name
– Telephone / Mobile Number (including WhatsApp contact details)
– Email Address
– Specific property preferences, budget requirements, or messages included in your inquiry.

B. Information Collected Automatically (Technical & Usage Data):
When you navigate through our Website, we automatically collect certain technical data via cookies and tracking technologies (see our Cookie Policy for details):
– IP Address and approximate geographical location
– Browser type, version, and language settings
– Operating system and device hardware details
– Referrals (how you arrived at our Website)
– Pages viewed, links clicked, time spent per page, and navigation paths.

C. Financial Data:
We DO NOT collect, store, or process any payment card details or banking information on this Website. We do not operate online payment gateways or e-commerce transactions.

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4. LEGAL BASIS FOR PROCESSING PERSONAL DATA (GDPR ARTICLE 6)
We process your personal data under the following legal bases:

1. Consent (Art. 6(1)(a) GDPR): When you expressly consent to submit a contact form, request marketing communications, or accept performance/targeting cookies on our site.
2. Performance of a Contract or Pre-Contractual Steps (Art. 6(1)(b) GDPR): When processing is necessary to respond to your inquiry, provide property consultation, or arrange real estate viewing services prior to entering into a formal agreement.
3. Legitimate Interests (Art. 6(1)(f) GDPR): To analyze Website usage, prevent fraud, maintain system security, improve our commercial services, and conduct direct business communications related to your real estate interests.
4. Compliance with Legal Obligations (Art. 6(1)(c) GDPR): To comply with applicable UAE laws, real estate regulatory authority (RERA/DLD) compliance, anti-money laundering (AML) checks, and legal audits.

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5. HOW WE USE YOUR PERSONAL DATA
We process your personal information strictly for the following purposes:
– To contact you regarding real estate properties, developments, or investment opportunities in Dubai that match your inquiries.
– To schedule consultations, phone calls, or video meetings with our licensed real estate agents.
– To analyze user traffic and website performance using analytical tools (Google Analytics).
– To deliver relevant online advertising and retargeting campaigns (via Meta Pixel and Google Tag Manager).
– To detect, prevent, and address technical issues or unauthorized security breaches.

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6. DATA RECIPIENTS AND INTERNATIONAL DATA TRANSFERS
A. Data Sharing:
We do not sell, rent, or trade your personal data to third parties for marketing purposes. We may share your personal data only with:
– Internal Employees & Brokers: Licensed agents of KOVO REAL ESTATE L.L.C who need access to assist with your property search.
– IT & Technical Service Providers: Hosting providers, website maintenance engineers, CRM system operators, and marketing execution platforms bound by strict confidentiality agreements.
– Legal & Regulatory Authorities: If required by law, court order, or governmental agencies (such as Dubai Land Department or Law Enforcement agencies).

B. International Data Transfers (EU to UAE):
KOVO REAL ESTATE L.L.C is headquartered in Dubai, United Arab Emirates (outside the EEA). When you interact with our Website from the EU, your data is transferred to, stored, and processed in the UAE.
We ensure that appropriate safeguards are implemented for international data transfers in accordance with GDPR requirements (such as Standard Contractual Clauses – SCCs), ensuring your personal data receives an equivalent level of protection as mandated within the EU.

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7. DATA RETENTION PERIODS
We will retain your personal data only for as long as is necessary to fulfill the purposes for which it was collected:
– Lead and Consultation Data: Kept for a period of two (2) years from your last active communication or until you request its deletion.
– Analytics & Log Data: Kept for up to fourteen (14) months via Google Analytics before automatic deletion/anonymization.
– Statutory Records: Certain transaction-related records may be kept longer (up to 5-7 years) to comply with UAE tax, legal, and anti-money laundering regulations.

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8. YOUR DATA PROTECTION RIGHTS (UNDER GDPR & UAE PDPL)
If you reside in the EU/EEA, or under applicable UAE regulations, you possess the following rights regarding your personal data:

– Right to Access: You can request copies of your personal data held by us.
– Right to Rectification: You can request that we correct any inaccurate or incomplete personal information.
– Right to Erasure (“Right to be Forgotten”): You can request that we delete your personal data, subject to certain legal exceptions.
– Right to Restrict Processing: You can request that we limit how we process your personal data under specific circumstances.
– Right to Data Portability: You can request a digital transfer of your personal data to another controller in a structured, machine-readable format.
– Right to Object: You can object to our processing of your personal data based on legitimate interests or for direct marketing purposes.
– Right to Withdraw Consent: Where processing is based on consent, you may withdraw your consent at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, please send a written request to: playamarinmo@gmail.com. We will respond within 30 days.

You also have the right to lodge a complaint with a supervisory data protection authority in your EU member state of residence if you believe our processing infringes upon data privacy laws.

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9. DATA SECURITY MEASURES
We implement appropriate technical and organizational measures (such as SSL encryption, firewalls, restricted database access, and secure administrative controls) to protect your personal data against accidental loss, unauthorized access, alteration, or disclosure. However, no internet transmission is 100% secure, and we cannot guarantee absolute security.

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10. CHANGES TO THIS PRIVACY POLICY
We reserve the right to update or modify this Privacy Policy at any time to reflect changes in legal requirements or our operational procedures. Any updates will be posted on this page with a revised “Last Updated” date. We encourage you to review this Policy periodically.