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Privacy Policy

Privacy Policy

Effective Date: 01/01/2025
Last Updated: 19/01/2025

1. Introduction

Welcome to Sunray Estate LLC. We are committed to safeguarding your privacy and protecting your personal data. This Privacy Policy outlines how we collect, use, store, and disclose personal information in compliance with United Arab Emirates (UAE) Federal Decree-Law No. 45 of 2021 on Personal Data Protection (PDPL) and Dubai International Financial Centre (DIFC) Data Protection Law No. 5 of 2020, in alignment with global best practices, including GDPR.

2. Scope of Policy

This Privacy Policy applies to all personal data collected, processed, and stored by Sunray Estate LLC in Dubai, UAE, or when offering goods/services to individuals in Dubai. It applies to our website, mobile applications, and any related digital platforms or services.

3. Data We Collect

3.1 Personal Information

  • Full Name

  • Date of Birth

  • Nationality

  • Gender

  • Emirates ID or Passport Number

  • Contact Information (Phone Number, Email Address, Physical Address)

  • Financial Information (Bank Account Details, Payment Card Details)

3.2 Sensitive Personal Data (if applicable)

  • Biometric Data (fingerprints, facial recognition, etc.)

  • Health Records (for specific services requiring medical data)

  • Criminal Record Data (if required for background checks under UAE laws)

3.3 Digital Information

  • IP Address

  • Cookies and Tracking Technologies

  • Device Identifiers

  • Browser Type

  • Website Usage Data

  • Location Data

4. How We Collect Your Data

We collect personal data through the following means:

  • Direct Collection: When you provide information through forms, registrations, or inquiries.

  • Automated Collection: Through cookies, analytics, and digital tracking tools.

  • Third-Party Sources: Business partners, government entities, and publicly available sources.

5. Legal Basis for Processing Data

Under Dubai’s PDPL and DIFC Data Protection Law, we process personal data based on:

  • Consent: When explicit permission is given for marketing or sensitive data processing.

  • Contractual Obligation: When data is necessary to fulfill contractual commitments.

  • Legal Requirements: When processing is required by UAE laws and regulations.

  • Legitimate Interest: When processing is necessary for business operations without overriding user rights.

6. How We Use Your Data

We use personal data for:

  • Providing and managing our services/products.

  • Processing transactions and payments.

  • Customer support and service improvements.

  • Marketing and promotional communications (with opt-out options).

  • Security, fraud detection, and compliance with legal obligations.

  • Website performance tracking and analytics.

7. Data Sharing and Transfers

We do not sell personal data but may share it under the following circumstances:

  • With Business Partners and Service Providers: For payment processing, cloud storage, analytics, etc.

  • With Law Enforcement and Government Authorities: When legally required by Dubai/UAE regulations.

  • With Affiliates and Subsidiaries: If necessary for business operations.

  • For Mergers or Acquisitions: In the case of business restructuring.

7.1 International Data Transfers

If personal data is transferred outside the UAE, we ensure adequate data protection mechanisms such as:

  • Adequacy Decisions: Only transferring to countries with sufficient legal protections.

  • Standard Contractual Clauses (SCCs): Binding agreements ensuring data security.

  • Explicit Consent: When users agree to international data transfers.

8. Data Retention and Security

8.1 Retention Period

We retain personal data only for the necessary duration to fulfill its intended purpose, legal obligations, or regulatory requirements.

8.2 Security Measures

We implement strict security protocols, including:

  • Encryption (TLS, SSL) for data in transit.

  • Secure server storage with restricted access.

  • Multi-factor authentication for access control.

  • Regular cybersecurity audits and penetration testing.

9. User Rights

Under Dubai’s data protection laws, you have the following rights:

  • Access to Personal Data – Request a copy of your data.

  • Rectification – Correct inaccurate or incomplete data.

  • Erasure (Right to be Forgotten) – Request deletion of data under legal conditions.

  • Restriction of Processing – Limit data processing in certain circumstances.

  • Data Portability – Obtain your data in a portable format.

  • Right to Object – Withdraw consent or object to certain processing.

To exercise these rights, contact us at privacy@sunrayestate.com.

10. Cookies and Tracking Technologies

We use cookies to enhance user experience, analyze traffic, and personalise content. Users can manage cookie preferences through browser settings. For more details, refer to our [Cookie Policy].

11. Data Protection Officer (DPO) and Complaints

We have appointed a Data Protection Officer (DPO) to oversee compliance.

  • DPO Contact: [Insert Name, Email, and Contact Number]

  • Regulatory Authority Complaints: Users may lodge complaints with the UAE Data Office or DIFC Data Protection Commissioner.

12. Updates to This Privacy Policy

We may update this policy periodically. Users will be notified of significant changes through our website or direct communication.

13. Contact Information

For inquiries regarding this Privacy Policy, contact us at:

  • Company Name: Sunray Estate LLC

  • Address: Dubai World Trade Centre, Sheikh Zayed Rd – Trade Centre – Trade Centre 2 – Dubai – UAE

  • Email: privacy@sunrayestate.com

  • Phone: +971 22 55 669

By using our services, you agree to the terms of this Privacy Policy.

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