Privacy Policy

1. Who is the data controller

The controller of the personal data collected through kovodubai.com (the "Website") is:

KOVO Real Estate L.L.C., a company incorporated in Dubai (United Arab Emirates) and engaged in real estate brokerage.
Commercial License: 1612813 · ORN: 61053
Address: Office 1310, Ontario Tower, Business Bay, Dubai, United Arab Emirates
Email: marian@kovodubai.com
Phone / WhatsApp: +971 50 554 6705

For any question about this policy or your data, please write to marian@kovodubai.com.

2. Applicable law

We process your data in accordance with UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (PDPL) and its implementing regulations where applicable.

The Website is also aimed at people resident in Spain and other European Union countries. Where the processing of your data falls within the territorial scope of Regulation (EU) 2016/679 (General Data Protection Regulation, "GDPR"), in particular because we offer our services to you while you are in the European Union, we will also apply the GDPR and honour the rights it provides.

3. What data we process

We only process the data you give us through the Website's forms or when you contact us directly, and the minimal technical data described below.

Analyse my investment

Contact details: name, email and, if you choose to provide them, country and phone/WhatsApp.
Investment profile: goal (capital growth, rental income, living or second home), budget range, purchase structure (cash, financing or a combination), investment timing, holding horizon, priorities and interest in UAE residency.
Only if your goal is to live in the property or use it as a second home: number of bedrooms, who you will live with, preferences such as nearby schools, beach, work location or pets, and any other needs you wish to tell us.
Any free-text message you choose to write.
The property or opportunity from which you started your enquiry, where applicable.

KOVO Map

Name and email to send you the KOVO Map and, if you tick the box, your agreement to receive KOVO Brief.

KOVO Brief

Email, to send you our informative communication on the Dubai real estate market.

Partners

Name, company, country, professional activity, email, phone/WhatsApp, the type of collaboration you are interested in and, if you add it, how you would like to collaborate.

Direct contact by email or WhatsApp

The data you send us yourself when you write to us by email or WhatsApp (for example, name, phone number and the content of the conversation).

Source and consent data

Together with each form we record: Website language, the page from which you submitted it, form version, date and time of submission, whether you accepted the privacy policy and the version of the policy accepted and, where applicable, your agreement to receive KOVO Brief communications.

Only if you have accepted analytics cookies do we also record the referring website (referrer) and campaign parameters (UTM) when your visit comes through a link that includes them. If you reject them, this information is not stored.

Only if you have accepted analytics cookies does Google Analytics also collect browsing data: a random identifier, pages visited, enquiries sent, WhatsApp clicks, device and browser type, and approximate location. It does not include your name, email or phone number (see the Cookie Policy).

Please do not include particularly sensitive data (for example, about health, religion or ethnic origin) or identity documents in free-text fields: they are not needed to handle your enquiry through the Website.

4. Why we use your data and on what legal basis

Handling your request and contacting you about it (forms, email or WhatsApp). Legal basis: steps taken at your request prior to entering into a contract and, where no such relationship exists, your consent. Under the GDPR: Art. 6(1)(b) and, where applicable, Art. 6(1)(a).
Analysing your investment profile and preparing a selection of opportunities suited to what you have told us. Legal basis: pre-contractual steps requested by you (GDPR Art. 6(1)(b)).
Sending you the KOVO Map you request. Legal basis: your request (GDPR Art. 6(1)(b)).
Sending you KOVO Brief and other informative KOVO communications, only if you have expressly requested or opted in. Legal basis: your consent (GDPR Art. 6(1)(a)), which you may withdraw at any time.
Handling professional partnership proposals. Legal basis: pre-contractual steps at the request of the data subject and KOVO's legitimate interest in assessing professional partnerships (GDPR Art. 6(1)(b) and 6(1)(f)).
Understanding where enquiries come from (referrer and UTM parameters) to know which channels work. Legal basis: your consent, given when you accept analytics cookies (GDPR Art. 6(1)(a)). You can withdraw it at any time from "Cookie settings".
Keeping evidence of your consents and protecting the Website against automated submissions. Legal basis: compliance with legal obligations and legitimate interest (GDPR Art. 6(1)(c) and 6(1)(f)).
Analytics measurement (Google Analytics), only with your prior consent through the cookie panel. Legal basis: your consent (GDPR Art. 6(1)(a)), which you can withdraw at any time. Details in the Cookie Policy.
Complying with the legal obligations applicable to KOVO as a licensed real estate brokerage in Dubai and responding to requests from competent authorities (GDPR Art. 6(1)(c)).

If the relationship moves towards a specific transaction, KOVO may need additional information or documents required by applicable law, by the developer or by the competent authorities. In that case we will inform you specifically about that processing; it is not requested through the Website.

5. Technology tools and automated decisions

KOVO may use technology tools, including automation and artificial intelligence solutions, to support the internal analysis of the information you provide and the selection of opportunities. When we add tools that process personal data, we will do so in accordance with this policy and update it if the processing described changes.

We do not make decisions based solely on automated processing that produce legal effects concerning you or similarly significantly affect you.

Any information, analysis, selection or result provided to you through the Website is for information purposes. It does not constitute personalised legal, tax, financial or investment advice, nor a guarantee of results, and investment decisions remain yours.

6. Who we share your data with

We do not sell your data. We only share it in the following cases:

Service providers processing data on KOVO's behalf and under its instructions, to the extent necessary to provide their service: website and database hosting, file storage, email and technical support. If we add other tools in the future (for example, contact management or email delivery tools), we will update this policy.
Google, only if you accept analytics cookies, to measure how the Website is used. Google processes this data as KOVO's service provider, under the Google Analytics data processing terms. We do not give it your name, email or phone number.
Developers, owners or other real estate professionals connected with a specific property, only where necessary to handle the interest you have shown in it and with your prior knowledge.
KOVO's professional advisers (legal, tax or accounting), bound by confidentiality, where necessary.
Authorities, regulators and courts where there is a legal obligation or a valid request.

If you choose to contact us via WhatsApp, that service is provided by a third party (WhatsApp / Meta), which processes data under its own terms and privacy policy.

7. International transfers

KOVO is established in the United Arab Emirates, so your data is processed in that country. If you write to us from the European Union or another country, your data will be processed in the UAE. Our service providers may be located in, or process data in, other countries. In particular, if you accept analytics cookies, Google may process measurement data in the United States and other countries; for data from the European Economic Area it relies on the EU-U.S. Data Privacy Framework and, where applicable, standard contractual clauses.

Where an international data transfer so requires, we will apply the safeguards provided for by applicable law: under the PDPL, the cross-border transfer conditions it establishes; and, where the GDPR applies, the mechanisms of its Chapter V, such as the standard contractual clauses approved by the European Commission. You can ask us for information about the safeguards applied by writing to marian@kovodubai.com.

8. How long we keep your data

We keep your data only for as long as necessary for the purpose for which it was collected:

Enquiries and investment profiles: while we remain in active contact with you. If the enquiry does not progress, we will keep it for a maximum of 24 months from our last contact, unless you ask us to delete it sooner.
Partners: while the collaboration is being assessed or maintained and, if it does not go ahead, for a maximum of 24 months from the last contact.
KOVO Brief: until you unsubscribe or withdraw your consent.
Analytics measurement (Google Analytics): data linked to cookies is kept for a maximum of 14 months. After that, only aggregated statistics that do not identify you remain.
Consent records: for as long as necessary to demonstrate that consent was validly obtained.
Where there is a contractual relationship or legal obligation: for the periods required by applicable law and those needed to establish, exercise or defend legal claims.

After these periods, we will delete or anonymise the data.

9. Your rights

Under the PDPL, you may request information about the processing of your data and access it, obtain it in a structured format, have it corrected or completed, request its erasure, request restriction of processing, object to or request that processing stop, and object to decisions based solely on automated processing, under the terms of that law.

If the GDPR applies to you, you also have the rights of access, rectification, erasure, restriction, portability and objection, and the right to withdraw your consent at any time without affecting the lawfulness of prior processing.

To exercise them, write to marian@kovodubai.com stating the right you wish to exercise. We may ask for additional information to verify your identity. We will respond within the time limits set by applicable law.

If you believe we have not handled your request properly, you may lodge a complaint with the competent UAE data protection authority and, if the GDPR applies to you, with the supervisory authority of your country of residence in the European Union (in Spain, the Agencia Española de Protección de Datos).

You can unsubscribe from KOVO Brief at any time through the link included in each mailing or by writing to us.

10. Security

We apply reasonable technical and organisational measures to protect your data against loss, misuse or unauthorised access: access to enquiries received is restricted to authorised KOVO staff, the Website uses encrypted connections (HTTPS) and forms validate the data they receive on the server.

11. Minors

The Website and our services are intended for adults. We do not knowingly collect data from minors. If we find that we have done so, we will delete it.

12. Cookies

Our use of cookies and similar technologies is explained in our Cookie Policy.

13. Changes to this policy

We may update this policy to reflect changes to the Website, our processing or the law. The current version will always be published on this page with its last updated date. If the changes are significant, we will let you know through an appropriate channel.