Whitehorse International
Facebook Instagram Tiktok Linkedin-in Youtube
0
Your Cart
No products in the cart.
Add Properties

Privacy Policy

  1. Home
  2. Privacy Policy

Effective date: 01 August 2025
Last updated: 01 August 2025

Whitehorse International (“Whitehorse”, “we”, “us”, “our”) is a Dubai-based luxury real-estate advisory and brokerage. We are committed to safeguarding your privacy and handling personal data in a lawful, fair, and transparent manner. This Privacy Policy explains what we collect, why we collect it, how we use and protect it, and the rights available to you.

This Policy applies to personal data we process via our websites, landing pages, social media, WhatsApp and other messaging channels, events/roadshows, client onboarding, property transactions (off-plan and secondary), and property management services.

1. Who we are & legal framework

  • Controller: Whitehorse International (Real Estate Brokerage) (Dubai, UAE).

  • Applicable law: UAE Federal Decree-Law No. 45 of 2021 on Personal Data Protection (PDPL) and its Executive Regulations; where applicable, DIFC Data Protection Law No. 5 of 2020 for processing carried out in/from DIFC; UAE real-estate and AML/CFT rules; and other local laws (e.g., record-keeping).

  • International: If you are in the UK/EU, where relevant to your circumstances, we will also observe the principles of UK/EU data protection when we target or serve you.

  • Contact (privacy): privacy@whitehorseuae.com

  • Data Protection Officer (DPO): dpo@whitehorseuae.com (for PDPL enquiries/rights requests).

2. What personal data we collect

We collect only what we need for clearly defined purposes:

  • Identity & contact: Name, nationality, passport/ID details, contact numbers, email, postal address, Power of Attorney details.

  • KYC/AML: Source-of-funds/wealth information, residency/visa status, sanctions/PEP screening results (as required by UAE AML/CFT regime for real estate).

  • Transactional: Property preferences, budgets, offers, SPAs/Oqood references, title deed details, service-charge statements, escrow references, payment schedules.

  • Event & marketing: RSVP records, consents, content preferences, campaign interactions (ads, emails, WhatsApp).

  • Technical: Device/browser data, IP address, cookies/analytics identifiers, website usage (see Cookies below).

Note: We do not intentionally collect special-category data unless strictly necessary and lawful (e.g., accessibility needs for event access, collected with explicit consent).

3. Why we process your data (purposes & legal bases)

Under the UAE PDPL, we rely on one or more lawful bases:

  • A. Contract: To provide advisory/brokerage services you request; arrange viewings; negotiate, conclude, and transfer property sales/leases; and manage after-sales.

  • B. Legal obligation: To meet DLD/RERA rules, record-keeping (min. five years for brokers/agents), and AML/CFT due-diligence, screening, and reporting duties.

  • C. Consent: For certain marketing (email/SMS/WhatsApp), event filming/photography, and cookies where required. You can withdraw consent anytime.

  • D. Legitimate interests: To protect our business, prevent fraud, manage client relations, improve services, and promote similar services to existing clients (respecting opt-out rights).

4. Where your data comes from

  • Directly from you (forms, calls, WhatsApp, meetings, events).

  • From your authorised representatives (e.g., PA/family office).

  • Public sources/portals (DLD, Oqood, court records as lawfully available).

  • Third-party providers (KYC screening partners, mortgage brokers, developers) — each subject to contractual and legal safeguards.

5. Sharing your data

We share personal data only when necessary and lawful, under confidentiality and data-processing terms:

  • Regulators & authorities: Dubai Land Department (DLD), RERA, trustees, notaries, UAE Data Office (if required), law-enforcement/AML units.

  • Developers & co-brokers: To arrange allocations, viewings, SPAs, NOCs, and transfers (off-plan/secondary).

  • Banks/mortgage brokers, valuers, insurers: To support financing/insurance.

  • Professional advisers: Lawyers, auditors, consultants.

  • Vendors: Cloud hosting, CRM, marketing platforms, analytics, communications.

We do not sell personal data.

6. International transfers

We may transfer personal data outside the UAE (e.g., secure cloud hosting, global client communications, family-office coordination). Where we do, we apply PDPL transfer rules (adequacy, safeguards, or your explicit consent), and DIFC transfer requirements where applicable.

7. Retention (how long we keep data)

We keep data only as long as necessary for the purposes above and to meet legal obligations, including a minimum of five (5) years for broker/agent records and transaction data, unless law requires longer (e.g., AML). Thereafter, we securely delete or irreversibly anonymise data.

8. Security measures

We maintain administrative, technical, and physical controls appropriate to the sensitivity of UHNWI data, including:

  • Encryption in transit and at rest.

  • Access controls (least-privilege, MFA).

  • Network segmentation and logging.

  • Vendor risk due diligence and DPAs.

  • Staff confidentiality and PDPL/AML training.

  • Secure device policies for mobile/WhatsApp communications.

  • Incident/breach response procedures, including PDPL notifications where required.

9. Your privacy rights

Under the UAE PDPL, you have the right (subject to legal exemptions) to:

  • Access your data and obtain copies.

  • Request correction/rectification.

  • Request erasure.

  • Restrict or object to processing.

  • Data portability (where technically feasible).

  • Not be subject to decisions based solely on automated processing that produce legal or similarly significant effects.

  • Withdraw consent (where processing is based on consent).

How to exercise your rights: Email dpo@whitehorseuae.com. We may need to verify your identity and the scope of your request. If we cannot resolve your concern, you may lodge a complaint with the UAE Data Office under the PDPL.

10. Marketing preferences

We will contact you for marketing only in line with PDPL and applicable anti-spam/communications rules. You can opt out at any time (unsubscribe link, email, or WhatsApp “STOP”). We maintain suppression lists to respect your choice.

11. Cookies & analytics

We use cookies and similar technologies to operate our websites, measure performance, and improve content. Where consent is required, we will display a cookie banner with choices. You can change preferences via our cookie settings or your browser. See our Cookie Notice for details (types, retention, third parties).

12. WhatsApp, social media & third-party links

If you message us via WhatsApp, Instagram, Facebook, TikTok, LinkedIn, or YouTube, your data is also processed by those platforms under their privacy terms. We recommend reviewing their notices. Links on our sites may take you to third-party sites we do not control.

13. Children’s data

Our services are intended for adults. We do not knowingly collect data from children. If you believe a child has provided data to us, contact privacy@whitehorseuae.com and we will act promptly.

14. AML/CFT and fraud prevention

To protect the integrity of the UAE real-estate sector, we carry out Customer Due Diligence (CDD/KYC), sanctions/PEP checks, source-of-funds/wealth verification, and report suspicious activity as required by UAE AML/CFT law and guidance for real-estate brokers. These obligations may limit certain PDPL rights where disclosure would prejudice investigations.

15. DIFC & other jurisdictions

Where processing occurs in/through the DIFC, we also comply with the DIFC Data Protection Law (and any 2025 amendments). For cross-border matters (e.g., UK/EU clients), we adopt equivalent safeguards consistent with international standards.

16. Changes to this Policy

We may update this Policy to reflect legal or operational changes. The “Last updated” date will change accordingly. Significant changes will be notified through our website or by direct notice where appropriate.

17. Contact us

Data Protection Officer: dpo@whitehorseuae.com
General privacy enquiries: privacy@whitehorseuae.com
Postal: Whitehorse International Real Estate Brokerage LLC, Dubai, United Arab Emirates

Important legal sources (selected):

  • UAE PDPL – Federal Decree-Law No. 45 of 2021 (personal data protection) and Executive Regulations; UAE Data Office guidance.

  • DIFC Data Protection Law No. 5 of 2020 (where applicable).

  • RERA/DLD Brokerage Practice Guide (broker duties, advertising, trustee offices).

  • Record retention for real-estate brokers/agents: keep transaction data ≥ 5 years.

  • AML/CFT expectations for UAE real estate (CDD/KYC, reporting).

Disclaimer: This Privacy Policy is designed for UAE compliance and international best practice and reflects requirements current as of August 2025. It does not constitute legal advice. For tailored legal guidance, please consult qualified counsel.

This will close in 0 seconds