Privacy Policy | Welcome to Nichorya

1. LEGAL STATUS OF THE CONTROLLER

NICHORYA Real Estate LLP (“NICHORYA”, “Company”, “we”, “us”, “our”) is a real estate brokerage licensed by the Dubai Department of Economy and Tourism (DET), regulated by the Dubai Land Department (DLD) and the Real Estate Regulatory Agency (RERA), with its registered o􀆯ice in Business Bay, Dubai, United Arab Emirates. For the purposes of UAE Federal Decree Law No. 45 of 2021 regarding the Protection of Personal Data (“PDPL”), NICHORYA acts as a Data Controller in relation to personal data processed through its brokerage, digital platform, and event operations.
Contact for Data Protection Matters: Email: mike.nicholas@nichorya.com
Telephone: +971 54 408 6083

2. SCOPE OF THIS POLICY

This Privacy Policy governs the collection, processing, storage, transfer, and protection of personal data relating to:

Property buyers and investors.
Property sellers and landlords.
Developers and strategic partners.
Event attendees.
Website users.
Service providers.
Prospective clients.

This Policy applies to personal data processed within the UAE and, where applicable, internationally.

3. DEFINITIONS

For the purposes of this Policy:

“Personal Data” means any information relating to an identified or identifiable
natural person.
“Sensitive Personal Data” includes financial information, identification documentation, and compliance related documentation.
“Processing” means any operation performed on personal data including
collection, storage, use, disclosure, or deletion.

4. CATEGORIES OF PERSONAL DATA PROCESSED

4.1 Identification Data

Full legal name.
Nationality.
Passport copy.
Emirates ID.
Visa status (where applicable).
Signature.

4.2 Contact Information

Residential address.
Email address.
Telephone number.
Communication preferences.

4.3 Financial & Transaction Data

Investment preferences.
Budget range.
Source of funds documentation.
Bank reference letters.
Mortgage information.
Reservation and payment records.
Escrow documentation.

4.4 Compliance Data (AML / KYC)

Proof of identity.
Proof of address.
Politically Exposed Person (PEP) status.
Sanctions screening results.
Risk profiling data.

4.5 Digital Platform & Technical Data

IP address.
Device type.
Browser information.
CRM interaction records.
Engagement analytics.
Lead qualification metrics.

4.6 Event & Hospitality Data

RSVP details.
Attendance records.
Consultation notes.
Tiered guest classification.

4.7 Blockchain / Smart Contract Data (Where Applicable)

Escrow confirmation data.
Milestone payment verification.
Transaction hash references.

The Company does not store private cryptographic keys.

5. LEGAL BASIS FOR PROCESSING

Personal data is processed on one or more of the following lawful bases under PDPL:

1. Performance of a Contract
Processing necessary to facilitate property transactions, reservations, brokerage services, and developer agreements.

2. Legal Obligation

Processing required under:

UAE AML/CFT regulations.
DLD and RERA compliance obligations.
Tax and accounting regulations.

3. Legitimate Interest

Improving brokerage services.
Fraud prevention.
Security and risk management.
Platform optimization.

4. Explicit Consent

Marketing communications.
Event invitations.
Newsletter subscriptions.
Optional investment updates.

Where consent is required, it may be withdrawn at any time.

6. PURPOSES OF PROCESSING

Personal data is processed strictly for:

Facilitating real estate brokerage transactions.
Conducting AML/KYC compliance checks.
Managing escrow and milestone payment processes.
Coordinating developer partnerships.
Delivering virtual property presentations.
Managing invitation only events.
Communicating investment opportunities.
Maintaining secure CRM records.
Regulatory reporting.

No automated decision produces legal e􀆯ects without human review.

7. DATA SHARING AND DISCLOSURE

Personal data may be disclosed strictly on a need-to-know basis to:

7.1 Regulatory Authorities

Dubai Land Department (DLD).
Real Estate Regulatory Agency (RERA).
UAE Financial Intelligence Unit (FIU).
Courts or governmental authorities.

7.2 Developers
Where required to execute reservation agreements and sales transactions.

7.3 Financial Institutions
Banks, escrow agents, mortgage providers.

7.4 Technology Providers
Cloud hosting providers, CRM systems, secure communication platforms, analytics
systems, and escrow technology providers, under binding Data Processing Agreements.

7.5 Professional Advisors
Legal counsel, auditors, and compliance consultants.
The Company does not sell personal data.

8. INTERNATIONAL DATA TRANSFERS

Where personal data is transferred outside the UAE, the Company ensures:

Adequate level of protection under applicable law; or
Contractual safeguards; or
Explicit consent of the data subject; or
Legal necessity for performance of contract.

9. DATA RETENTION

Personal data is retained in accordance with UAE regulatory requirements:

Transaction records: Minimum 5 years (or longer where required by law)
AML/KYC documentation: As required by UAE AML regulations
Accounting records: As per UAE Commercial Companies Law
Marketing data: Until consent withdrawal
Event records: Up to 3 years

After expiry, data is securely deleted or anonymized.

10. DATA SECURITY

The Company implements appropriate technical and organizational measures
including:

End-to-end encryption.
Secure multi-region cloud infrastructure.
Role based access controls.
Multi-factor authentication.
Penetration testing.
Secure backup systems.
Encrypted communications.
Access logging and monitoring.

In the event of a data breach, the Company shall comply with PDPL notification obligations.

11. DATA SUBJECT RIGHTS

Under PDPL and applicable laws, individuals have the right to:

Request access to personal data.
Request correction or updating.
Request deletion where legally permissible.
Object to processing.
Request restriction of processing.
Withdraw consent.

Requests must be submitted in writing to: mike.nicholas@nichorya.com
The Company may refuse requests where legally permitted (e.g., AML retention obligations).

12. AUTOMATED PROCESSING

The Company may use analytics tools and lead prioritization systems. However:

No legally binding decision is made solely by automated means.
Human oversight applies to all transaction approvals.

13. MINORS

The Company does not knowingly process personal data of individuals under 18 years
of age.

14. COOKIES

The Company uses cookies and analytics technologies to improve website performance and user experience. Users may manage cookie settings through browser preferences.

15. CONFIDENTIALITY

All employees, agents, and contractors are bound by strict confidentiality obligations.

16. POLICY AMENDMENTS

The Company reserves the right to amend this Policy to reflect changes in law or operational practices. The updated version shall be published on the o􀆯icial website.

17. GOVERNING LAW

This Privacy Policy shall be governed by and construed in accordance with the laws of the United Arab Emirates and the Emirate of Dubai.

18. DECLARATION

This Privacy Policy has been reviewed and approved by the management of NICHORYA Real Estate LLP and is issued as the o􀆯icial data protection policy of the Company.

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