Privacy Policy

This Privacy Policy describes how Palmera Elite Real Estate Brokerage L.L.C ("Palmera", "we", "us", or "our"), a licensed real-estate brokerage based in Dubai, United Arab Emirates, handles the personal data of visitors to palmera.realestate (the "Site") and people who contact us. We are committed to processing your data lawfully, fairly, and transparently, in line with the UAE Personal Data Protection Law (Federal Decree-Law No. 45 of 2021, the "PDPL") and its implementing regulations.

By using the Site or submitting your details to us, you confirm that you have read and understood this policy.

We collect only the data we need to respond to you and to operate the Site:

• Information you give us. When you complete a lead or contact form, request property details, or message us, we collect your name, email address, phone number, and the contents of your message or enquiry.
• Analytics and cookies. When you browse the Site, we automatically collect technical and usage data such as your IP address, browser type, device information, the pages you view, and how you navigate, through cookies and similar technologies.

We use the personal data we collect to:

• Respond to your enquiries and contact you about your request.
• Send you property information, listings, and investment opportunities in the United Arab Emirates that match your interests (all prices are quoted in AED).
• Operate, maintain, and improve the Site, our content, and your browsing experience.

Under the PDPL, we process your personal data on the basis of your consent (given when you submit a form, accept cookies, or otherwise ask us to contact you) and, where applicable, on the basis of our legitimate interest in operating and improving our brokerage services and responding to your requests.

You may withdraw your consent at any time (see "Your rights" below). Withdrawing consent does not affect the lawfulness of processing carried out before the withdrawal.

We do not sell your personal data. We may share it only as follows:

• Developers and partners. With your consent, we may share your enquiry details with the relevant property developer or partner so they can assist with your specific request.
• Service providers. We use trusted third parties, such as hosting, analytics, email and customer-relationship tools, who process data on our behalf and only under instructions consistent with this policy.
• Legal requirements. We may disclose data where required by applicable UAE law or by a competent authority.

The Site uses cookies and similar technologies to remember your preferences, keep the Site secure, and understand how it is used so we can improve it. You can control or delete cookies through your browser settings; disabling some cookies may affect how parts of the Site work.

We keep your personal data only for as long as necessary to fulfil the purposes set out in this policy (for example, to handle your enquiry and provide follow-up information) and to meet our legal, accounting, or regulatory obligations. When data is no longer needed, we securely delete or anonymise it.

Under the UAE Personal Data Protection Law, you have the right to:

• Access the personal data we hold about you.
• Correct data that is inaccurate or incomplete.
• Delete your personal data, subject to our legal retention obligations.
• Withdraw consent to processing at any time, and object to or restrict certain processing.

To exercise any of these rights, contact us using the details in the "Contact us" section below. We will respond within the period required by the PDPL.

We apply appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, misuse, or disclosure. While no method of transmission or storage is completely secure, we work continuously to safeguard the information you entrust to us.

This section applies to Palmera partners who connect a Google account to the Google Ads tool in the Palmera Partner Area (account.palmera.realestate, account.palmera.co.il and account.palmera.ru). It explains what the tool accesses through Google APIs and how that data is used, stored, shared and deleted.

• What we access. With your permission, given on Google's own consent screen, the tool accesses the email address of the Google account you connect; the Google Ads accounts that Google account can reach (their names, IDs, currency, time zone, and whether they are active and have an approved payment method); and, in the account you choose, your campaigns, budgets, ad groups, keywords, ads, assets, negative keyword lists and conversion actions, with their performance reports, including search terms and ad click identifiers.
• How we use it. Only to provide the tool's features to you: to list your accounts; to create the campaigns you approve and apply the changes you approve; to turn on auto-tagging and create two conversion actions in the account you choose; to keep negative keyword lists in your campaigns under the Partner Terms; to show your campaigns' results beside the leads they brought; and, at the end of a notice period set out in the Partner Terms, to pause keywords that use a project name Palmera has taken back. With the Data Manager permission, we upload a conversion to your account when a lead from one of your ads is verified or becomes a deal. The upload contains the ad click identifier and the time of the conversion, and no name, email address or phone number of the buyer.
• AI drafting. To draft ads and suggest improvements, we send the project's published facts, your campaign settings and your campaigns' performance figures (such as keywords, search terms, costs, clicks and conversions) to our AI service provider, which processes them only to return the draft or the suggestion and does not use them to train its models. We do not use data received from Google APIs to develop, improve or train any artificial intelligence or machine learning model.
• Storage and security. The refresh token Google issues for your account is stored encrypted (AES-256) on Palmera's servers and is never shown to anyone. We also keep the connection details (the Google email address, the account name and ID), the campaigns built through the tool, and the record of every action taken through it.
• Sharing. We do not sell data received from Google APIs, do not use it for advertising, and do not share it with anyone except our AI service provider as described above, the hosting providers that run our systems, and where the law requires it. Palmera staff see the connection details and the record of actions in order to operate and support the tool; they do not otherwise read the data from your Google Ads account unless you ask us to, for security reasons, or where the law requires it.
• Your control and deletion. You can disconnect in the Partner Area at any time: we revoke our access at Google and delete the stored token at once. You can also remove Palmera's access from your Google account at myaccount.google.com/permissions. Your campaigns stay in your Google Ads account. We keep the record of the tool's campaigns and actions while your partner account exists and for as long as a referral fee could be in dispute, and delete it on request (write to team@palmera.realestate) unless the law requires us to keep it.
• Google's policy. Palmera's use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

If you have questions about this policy or wish to exercise your data rights, contact our team at team@palmera.realestate, call +971 54 215 4066, or reach us via our contact page.

Palmera Elite Real Estate Brokerage L.L.C, Dubai, United Arab Emirates.