Built DifferentTM
PRIVACY POLICY
Effective Date: [26-07-2026]
Last Updated: [26-07-2026]
1. INTRODUCTION
ANAX Developments L.L.C. (”ANAX”, “we”,“our” or “us”) is committed to protecting and respecting yourprivacy.
This Privacy Policy explains how ANAXcollects, uses, stores, discloses, transfers and otherwise processes PersonalData relating to individuals who interact with us through our website, mobileapplications, sales centres, show apartments, project sites, customer servicechannels, social media platforms, events, marketing campaigns and any otherproducts or services provided by ANAX (collectively, the “Services”).
Protecting your Personal Data is an integralpart of our corporate governance framework. We recognise that privacy isfundamental to maintaining the trust of our customers, investors, brokers,suppliers, contractors, consultants, employees and other stakeholders.
This Privacy Policy has been prepared inaccordance with applicable data protection legislation, including, whereapplicable:
· UAEFederal Decree-Law No. 45 of 2021 regarding the Protection of Personal Data(PDPL);
· itsExecutive Regulations;
· otherapplicable UAE federal and emirate-level legislation;
· applicableanti-money laundering legislation;
· regulationsissued by the Dubai Land Department (DLD), the Real Estate Regulatory Agency(RERA), and other competent governmental authorities; and
· anyother applicable privacy or data protection laws.
By accessing or using our Services, youacknowledge that your Personal Data may be processed as described in thisPrivacy Policy.
2. WHO WE ARE
For the purposes of applicable data protectionlegislation, ANAX Developments L.L.C. is the primary DataController responsible for determining the purposes and means by whichPersonal Data is processed.
Where certain services are delivered jointlywith carefully selected third-party service providers, those providers willprocess Personal Data only in accordance with applicable law and appropriatecontractual safeguards.
3. OUR PRIVACY COMMITMENT
ANAX is committed to processing Personal Datain accordance with the following principles:
Privacy considerations are incorporated intoour business operations, technology systems and governance framework throughprivacy-by-design and privacy-by-default principles wherever appropriate.
4. DEFINITIONS
For the purposes of this Privacy Policy:
“Applicable Laws” meansall applicable laws, regulations, governmental requirements and regulatoryguidance relating to privacy, data protection, cybersecurity, anti-moneylaundering, sanctions, real estate transactions and electronic communications.
“Controller” meansthe entity that determines the purposes and means of processing Personal Data.
“Processor” meansany person or organisation processing Personal Data on behalf of ANAX.
“Personal Data” meansany information relating to an identified or identifiable natural person,whether directly or indirectly.
“Sensitive Personal Data” includes any Personal Data requiringenhanced protection under applicable law, including biometric information,health information, financial information, government identificationinformation and other categories recognised by law.
“Processing” meansany operation performed on Personal Data including collection, recording,organisation, storage, adaptation, alteration, retrieval, consultation, use,disclosure, transmission, transfer, restriction, deletion or destruction.
“Services” meansall products, services, projects, websites, applications, sales centres, eventsand customer engagement channels operated by ANAX.
“Website” meansany website owned or operated by ANAX.
5. SCOPE OF THIS PRIVACY POLICY
This Privacy Policy applies to all PersonalData collected by ANAX through:
This Privacy Policy applies regardless of thetechnology used to access our Services.
6. PERSONAL DATA WE COLLECT
Depending on the nature of your relationshipwith ANAX, we may collect the following categories of Personal Data:
Identity Information
Contact Information
Property Transaction Information
Financial Information
Compliance Information
To comply with applicable legal and regulatoryobligations, ANAX may collect and process information required for:
7. HOW WE COLLECT PERSONAL DATA
ANAX may collect Personal Data directly fromyou, automatically through your use of our Services, and from authorised thirdparties.
Information You Provide
We collect Personal Data when you:
Information Collected Automatically
When you access our Website or digitalplatforms, we may automatically collect:
Information from Third Parties
We may obtain Personal Data from:
We only collect such information where legallypermitted and necessary for legitimate business or legal purposes.
8. PURPOSES FOR WHICH WE PROCESS PERSONAL DATA
ANAX processes Personal Data only wherenecessary for legitimate business purposes or to comply with legal obligations.
These purposes include:
Customer Relationship Management
Property Sales
Property Management
Where applicable:
Compliance
ANAX processes Personal Data to comply with:
Identity Verification
Including:
Marketing
Subject to applicable law, ANAX may usePersonal Data to:
Recipients may opt out at any time using theunsubscribe facility or by contacting ANAX.
Website Administration
Including:
Recruitment
Where applicable:
Supplier and Contractor Management
Including:
9. LEGAL BASIS FOR PROCESSING
Where required by applicable law, ANAXprocesses Personal Data on one or more of the following legal bases:
Where processing is based on consent, you maywithdraw that consent at any time, without affecting the lawfulness ofprocessing undertaken before withdrawal.
10. ARTIFICIAL INTELLIGENCE AND AUTOMATEDTECHNOLOGIES
ANAX may use artificial intelligence, machinelearning and other automated technologies to improve the efficiency, qualityand security of its operations.
Such technologies may assist with:
Where AI tools are used, appropriate humanoversight and governance measures are implemented.
ANAX does not make decisions producing legalor similarly significant effects solely through automated processing unlessauthorised by applicable law.
11. COOKIES AND SIMILAR TECHNOLOGIES
ANAX uses cookies and similar technologies toimprove user experience, maintain website security and understand how visitorsinteract with our Website.
Cookies may be used for:
You may manage cookie preferences through yourbrowser settings or the cookie consent tools made available on our Website.
Further information regarding cookies isavailable in our separate Cookie Policy.
12. MARKETING COMMUNICATIONS
Where permitted by law, ANAX may contact youregarding:
You may withdraw your marketing preferences atany time by:
Withdrawal from marketing communications doesnot affect service-related communications necessary to administer yourrelationship with ANAX.
13. CCTV AND VISITOR MONITORING
For the safety and security of our customers,visitors, employees and assets, ANAX operates CCTV systems at selectedlocations, including:
CCTV recordings may be used for:
Recordings are retained only for as long asreasonably necessary or as required by law.
14. DISCLOSURE OF PERSONAL DATA
ANAX treats Personal Data as confidential andwill not sell, rent or otherwise disclose Personal Data except where necessaryfor legitimate business purposes, to perform contractual obligations, to complywith applicable law, or with your consent where required.
Depending on the circumstances, ANAX maydisclose Personal Data to:
All third parties processing Personal Data onbehalf of ANAX are required to implement appropriate confidentiality, securityand data protection measures.
15. INTERNATIONAL TRANSFERS OF PERSONAL DATA
Given the international nature of ANAX’sbusiness operations, Personal Data may be transferred to, stored in or accessedfrom jurisdictions outside the United Arab Emirates.
Where such transfers occur, ANAX implementsappropriate safeguards to ensure that Personal Data continues to receive anadequate level of protection consistent with applicable law.
Such safeguards may include:
ANAX will take reasonable steps to ensure thatrecipients process Personal Data only for authorised purposes and maintainappropriate standards of security and confidentiality.
16. INFORMATION SECURITY
ANAX maintains a comprehensive informationsecurity programme designed to protect Personal Data against accidental orunlawful destruction, loss, alteration, unauthorised disclosure or unauthorisedaccess.
Our security measures may include:
While ANAX implements reasonable andappropriate technical and organisational measures, no method of transmissionover the internet or electronic storage can be guaranteed to be completelysecure. Accordingly, ANAX cannot guarantee absolute security but will continueto review and enhance its security controls in line with industry bestpractices.
17. DATA RETENTION
ANAX retains Personal Data only for as long asnecessary to fulfil the purposes described in this Privacy Policy, to complywith legal and regulatory obligations, to resolve disputes, to enforcecontractual rights and to protect ANAX’s legitimate business interests.
Retention periods are determined by referenceto factors including:
Where Personal Data is no longer required,ANAX will securely delete, anonymise or otherwise dispose of it in accordancewith its internal records management procedures.
18. YOUR PRIVACY RIGHTS
Subject to applicable law, you may have theright to:
To protect your privacy, ANAX may requireverification of your identity before responding to any request.
ANAX may decline or limit requests wherepermitted by law, including where compliance would adversely affect the rightsof others, prejudice legal proceedings, compromise legal privilege, conflictwith regulatory obligations, or where requests are manifestly unfounded orexcessive.
19. CHILDREN’S PRIVACY
ANAX does not knowingly collect Personal Datafrom children except where reasonably necessary in connection with propertyownership, family records, guardianship arrangements or other lawful purposes.
Where ANAX becomes aware that Personal Datarelating to a child has been collected contrary to applicable law, appropriatesteps will be taken to delete or otherwise appropriately manage suchinformation.
Parents or legal guardians who believe that achild has provided Personal Data may contact ANAX using the contact detailsprovided below.
20. FRAUD PREVENTION AND WEBSITE SECURITY
ANAX continuously monitors its digitalplatforms and systems to protect against:
Where necessary, security logs and technicalinformation may be analysed to investigate incidents, maintain system integrityand comply with applicable legal obligations.
21. LEGAL PROCEEDINGS AND LEGAL PRIVILEGE
ANAX may retain, review, disclose or otherwiseprocess Personal Data where reasonably necessary to:
Nothing in this Privacy Policy limits ANAX’srights to process Personal Data where required or authorised by applicable law.
22. BUSINESS TRANSFERS AND CORPORATE TRANSACTIONS
ANAX may disclose or transfer Personal Datawhere reasonably necessary in connection with:
Where such a transaction occurs, ANAX willtake reasonable steps to ensure that any recipient continues to processPersonal Data in accordance with applicable law and appropriate confidentialityobligations.
23. THIRD-PARTY WEBSITES
The Website may contain links to third-partywebsites, platforms or applications for your convenience.
ANAX does not control, endorse or assumeresponsibility for the privacy practices, security measures or content ofthird-party websites.
Accessing third-party websites is at your ownrisk, and you are encouraged to review their respective privacy policies beforeproviding any Personal Data.
24. SOCIAL MEDIA
If you interact with ANAX through social mediaplatforms, including by following our accounts, submitting enquiries,participating in campaigns or communicating through social media messagingservices, ANAX may process the Personal Data you choose to provide.
Such processing remains subject to thisPrivacy Policy in addition to the privacy policies of the relevant social mediaplatform.
25. INTERNAL DATA GOVERNANCE
ANAX maintains an internal privacy andinformation governance framework designed to ensure the responsible handling ofPersonal Data.
This framework may include:
ANAX regularly reviews and updates itsinternal controls to reflect evolving legal requirements, technologicaldevelopments and industry best practices.
26. CHANGES TO THIS PRIVACY POLICY
ANAX may amend this Privacy Policy from timeto time to reflect:
The updated version will be published on theWebsite together with the revised “Last Updated” date.
Where required by applicable law, ANAX willprovide appropriate notice of material changes.
Your continued use of the Services followingpublication of an updated Privacy Policy constitutes acknowledgement of therevised Privacy Policy, to the extent permitted by law.
27. CONTACT US
If you have any questions regarding thisPrivacy Policy or wish to exercise your privacy rights, please contact:
Legal & Compliance Department
ANAX Developments L.L.C.
Email: privacy@anaxdevelopments.com (or such other dedicated privacyemail address as ANAX may designate)
Telephone: +971 4 358 3688
Address: Dubai, United Arab Emirates
ANAX may request reasonable information toverify your identity before responding to any privacy request.
28. GOVERNING LAW
This Privacy Policy shall be governed by andconstrued in accordance with the laws of the United Arab Emirates and, whereapplicable, the laws and regulations of the Emirate of Dubai.
Nothing in this Privacy Policy limits anyrights or obligations arising under applicable mandatory laws.
29. DISCLAIMER
This Privacy Policy is intended to explain howANAX processes Personal Data and should not be interpreted as creatingcontractual rights beyond those provided under applicable law or under anyseparate written agreement entered into with ANAX.
Nothing in this Privacy Policy limits ANAX’sright to process Personal Data where such processing is required or authorisedby applicable law, regulatory requirements, court orders or lawful governmentalrequests.
If any provision of this Privacy Policy isdetermined to be invalid, unlawful or unenforceable, the remaining provisionsshall continue in full force and effect.
30. CONTACTING THE COMPETENT AUTHORITY
Where you believe that ANAX has not handledyour Personal Data in accordance with applicable law, you may have the right,subject to applicable legislation, to submit a complaint to the competentsupervisory authority responsible for personal data protection in the UnitedArab Emirates.
ANAX encourages individuals to contact theLegal & Compliance Department in the first instance so that we mayinvestigate and, where appropriate, resolve any concerns promptly and amicably.
FINAL STATEMENT
ANAX recognises that protecting Personal Datais fundamental to maintaining the confidence of its customers, investors,brokers, suppliers, contractors, consultants, employees and business partners.
Accordingly, ANAX is committed to maintainingrobust technical, organisational and administrative safeguards designed toensure that Personal Data is processed responsibly, securely, transparently andin accordance with the highest standards of legal and ethical compliance.
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