Privacy Policy

1. Introduction

We take your privacyseriously and are committed to safeguarding your personal information at GAFProperty LLC (which term includes all subsidiaries of GAF Property LLC)referred as (“Company”, “we” or “us” or “GAF”). We value you as our customer,respect your privacy and are committed to protecting it through our compliancewith this policy.

This policy describesthe sources of your personal information that we may collect from you or thatyou may provide to us, our purposes for collecting and processing yourinformation, and our practices for collecting, using, maintaining, retaining,protecting and disclosing that information.

If you have anyquestions or concerns about this privacy policy or your personal information,please contact us using the details provided in the Section – ‘How do youcontact us?’.

2. What are thesources of your personal data?

The sources of yourpersonal data collected (collectively referred to as “Platforms” in thispolicy) may include without limitation the following:

• GAF websites: These are websites we created for you that     are operated by us, they include websites operated by GAF under our own     domains and web addresses (URLs) and our own micro-sites that are part of     a third-party social media networks such as Facebook, Twitter, or     Instagram.
• Emails, text messaging services, and other     electronic messages: These     are the electronic text-based interaction between you and GAF.
• GAF mobile applications: These are smartphone applications created     for you and operated by GAF or one of our partners.
• GAF customer service: Any communication between you and our     customer service centre (e.g. phone, chatbot, email, WhatsApp etc.).
• Online / Offline registration forms: These include printed/digital     registrations, surveys, or questionnaires GAF collects via registration     forms, contests, events, and various promotions when you participate in     one of our events or visit our promotional stands in malls to enquire     about our properties
• Contact Us Form: These include feedback/ complaints you     submit in the “Contact Us” section of the website
• Advertising: You might interact with one of our or our     partners’ advertisements on our websites and apps and we might receive and     collect this information.
• Career Portal: This includes recruitment portal across GAF.
• Data we create: GAF may also create data about you, when     you avail our services.
• Data from other sources: These include social media networks,     market research agencies, GAF third party sales agents, registered     brokers, GAF promotional partners (such as Banks, UAE Government     entities), public sources, and data received when we acquire other     companies.
• GAF Public Wi-Fi: Any usage of the GAF public Wi-Fi network     at our registered offices.

This policy does notapply to information collected:

• through any other means, including any     other website operated by any third party; or
• by any third party, including through any     application or content (including advertising) that may link to the     Website.

3. What informationwe collect about you and how we use your personal information?

The type of personalinformation we collect on or through our platforms, why we collect and how weuse the personal information are explained in the following:

3.1 To respond toany queries or expression of interest made by you:

We would use yourpersonal data to help us respond to your queries or expression of interest andto ensure we help you find the right property that suits your needs. We mayreceive your personal data through one of the following channels:

When you send us anenquiry, via our website/social media page/call/WhatsApp, regarding one of ourproperties; When you participate in one of our events or visit our stands toenquire about our properties; When you may have expressed interest about our propertiesthrough our third-party agents; When you visit our sales office or contact oursales advisors regarding any property you wish to purchase.

We collect thefollowing personal information: name, email address, phone number, nationalityand details of your enquiry pursuant to our legitimate business interests. Incertain cases, your enquiry may relate to a specific service request, forexample: raising an enquiry regarding a specific property. For such requests,we need to use your personal information to help us respond to your request andto fulfil our contractual obligations under the requested service.Additionally, when you call our customer service centre, we would maintain arecord of the communications, including call recordings, in pursuit of ourlegitimate business interest to monitor and improve the quality of our customersupport.

3.2 To enter into orto conclude a sales purchase agreement:

Once you have decidedto move forward to purchase of a property with GAF, we collect personal datasuch as name, passport, visa details, address, national ID, contact to concludethe contractual arrangements to finalise the property sale and to facilitateproperty registrations, handover and payment arrangements. Additionally, toconclude property sales, we are required to carry out a security clearance ofour customer in compliance to local laws and pursuant to our legitimatebusiness interest to combat any fraudulent transactions.

3.3 To request yourfeedback, and to respond to complaints:

Your satisfaction isour utmost priority and we proactively take necessary steps to ensure you arewell satisfied with our services. To help us respond to your feedback orcomplaints, we collect the following personal information: name, email ID,transaction details (such as service you availed) and your feedback/ complaintsin the “We Care submission form”, through a survey conducted after you completea transaction or after the completion of your call with our customer serviceteam. We collect and use your personal information in pursuit of our legitimatebusiness interests to address your concerns and to take necessary steps towardscontinual improvement. In the event you prefer not to receive such information,you may opt out by following the instruction provided in Section – “How to optout?”.

3.4 To personalize andprovide you with information about GAF’s services and latest offers:

We may combine theinformation we receive and collect about you to better understand yourinterests and preferences so that we can provide you with an experience that istailored to those interests and preferences. For example, we may do this bynotifying you of any events conducted by GAF, or sending you personalizedoffers, discounts or promotions by our mobile application, or email (where youhave agreed to receive our emails), or advertising content that is relevant toyour interests. It is in our legitimate business interests to send youinformation about GAF services and latest offers. We use your personalinformation such as email ID and/ or contact number to share informationrelating to GAF services and latest offers that may be of interest to you. Inthe event you prefer not to receive such information, you may opt-out byfollowing the instruction provided Section – “How to opt-out?”.

3.5 To facilitateemail campaigns carried out by our sales and marketing departments:

As part of our emailcampaigns, we track whenever you receive, open, click a link, or download anyattachments from an e-mail you receive from GAF. We will carry out automatedprofiling of such information to evaluate your interest in our serviceofferings or promotions. This processing will enable us to identify and targetpotential customers or business partners, tailor our marketing and provide youwith relevant and timely content based on your interests, in pursuit of ourlegitimate business interests. In the event you prefer not to receive suchinformation, you may opt out by following the instruction provided in Section –“How to opt out?”.

3.6 To facilitateAdvertisements:

GAF uses the personalinformation you provide us for a commercial purpose to help us tailor and showadvertisements to you. We may partner with third parties to help us displayrelevant advertising and to manage our advertising across multiple channelsincluding social media platforms. Our third-party partners may use cookies andnon-cookie-based technologies to help us show you advertising based upon yourbrowsing activities and interests. In the event you wish to opt-out, you may doso by following the instruction provided Section – “How to opt out?”

3.7 To fulfil anymaintenance/ service requests you raise using our online services orapplication:

We provide variousservices to our property owners and residents such as Move-In and NOC requests,manage any service fees and instalment payments, facilitate any amenitiesbooking, facilitate home service bookings etc. As part of these services we mayprocess your personal information such as name, contact details, details ofyour requests in accordance to our contractual obligations to provide you therequested the fulfilment of your service and to assign the right professionalsto assist your needs.

3.8 To service thecommunities, we manage:

Under GAF  Community Management, our primary objective isto manage and enhance the wellbeing of the property and lifestyle of theresidents in our care. We serve a portfolio of six Master Communities, eachcomprising smaller sub-communities. These six covers a range of properties,which present their own unique set of characteristics and challenges. Aspart of the GAF Community Management, we provide various services such asassociation management, customer service, site management, financial managementetc. We collect and process personal data of the residents of the communitiesto facilitate ‘Move in permits’, ‘Access Permits’ and any maintenance/ servicerequests to fulfil our contractual obligations and pursuant to our legitimatebusiness interests towards ensuring safety and comfort  to the residentsof our communities.

3.9 To establish aworking relationship with our Tenants, Third Party Agents and BusinessPartners:

We collect/ receivepersonal information about you through one of the following channels:

When you send us anenquiry for Tenancy or if you were previously engaged under a Tenancyarrangement with us; When you participate in any of our sales, marketing andthought leadership events (including webinars) organized or hosted by GAF; Whenour sales executive or business leaders visit events organized by externalorganizations (including the company you represent); We collect from our salesexecutives or business leaders who share a professional/ personal relationshipwith you; or We collect from publicly available information that you haveshared on professional networking platforms such as LinkedIn.

We collect thefollowing personal information: name, email ID, contact number, designation,and the company you represent. We use this information for the purposes, listedbelow, in pursuit of our legitimate business interests to share informationrelating to GAF services, and possible tenancy opportunities; to invite you tofuture events, that may be of interest to you and/ or the company yourepresent; and to establish a working relationship with the company yourepresent.

3.10 To enter into,renew or fulfil service contracts with our Tenants, Third Party Agents andBusiness Partners:

We collect and usepersonal information such as name, email ID, contact number and in certaincases passport/ government ID proof to facilitate the performance of thetenancy contract between GAF and the Organization you represent. We may alsocollect personal information (such as Name, contact details, passport/government ID etc.,) of the employees of your Organization that would bestationed within our malls/ facilities for sales events to facilitate securitypass clearance pursuant to our legitimate business interest and to fulfil ourcontractual obligations.

3.11 To enter,Commercial or Investment relationship:

We collect and useInformation when you enter a commercial or investment relationship (as ashareholder or buyer of one or more assets from the Group’s portfolio) with a GAFGroup company. It is in accordance with Contractual obligations to collect thefollowing Data either directly from you, or from the company that you work orrepresent: Name, contact details, phone number, postal address, email address,date and place of birth, percentage of capital and voting rights held, otherdata but strictly linked to the investment, etc.

3.12 To comply withlegal requirements and exercise or defend legal claims:

We may need to processand retain your personal information to comply with legal requirements to whichwe are subject (for example in relation to licensing, health and safety). It isin our legitimate interests to process personal information for the purposes ofexercising and defending legal claims. Processing personal information may alsobe necessary to ensure compliance with the relevant legal and regulatoryobligations.

3.13 To process yourpayments and protect against fraudulent transactions:

We may need to processyour personal information to keep your payments safe and secure and protectagainst fraudulent transactions. It is in our legitimate interests to processpersonal information to keep your payments secure and to prevent fraud. We mayalso require your personal information to send payment reminders and legalintimations in case of overdue payments. Processing personal information inthis way may also be necessary to ensure compliance with the relevant legal andregulatory obligations.

3.14 To comply withany opt-out or do not disturb requests we receive from you:

We understand that youmay not prefer for us to contact you with any offers, promotions or details ofour products and services. In the event you opt-out, we may be required tomaintain information such as name, email ID/contact number and the subscription(s)that you have opted out of to ensure compliance with your requests. Also, inthe future, if you wish to hear from us, you may at any time, contact us toopt-in and we would be happy to keep you posted about our latest offers,promotions and/ or details of our products and services.

3.15 To comply withhealth and safety obligations:

We may be required toprocess your medical information or any other health related information in theevent of an accident or injury at our residential units or the communities wemanage. It is our legitimate interest for the management of accidents and injuriesoccurring in our managed facilities. This information would also be requiredfor the improvement of the accident prevention system (including fireprotection and prevention against foreseeable natural and technological risks).It could also possibly be required for legal purposes or to prepare for anddefend against legal claims.

3.16 Other informationwe collect

There is otherinformation we may collect that does not directly reveal your specific identityor does not directly relate to you as an individual. We may automaticallycollect the following information pursuant to our legitimate business interestswhen you visit our website or utilize our services:

• Your equipment, browsing actions and     patterns collected automatically as you navigate through our websites.
• Usage details, time of requests, browser     types, operating system, IP addresses and information collected through     cookies, web beacons and other tracking technologies.
• Details of your visits to our website,     including traffic data, location data, logs and other communication data     and the resources that you access and use on the website.

The information wecollect automatically is statistical data. It helps us to improve our Websiteand to deliver a better and more personalized service by enabling us to:

• Estimate our audience size and usage     patterns.
• Store information about your preferences,     allowing us to customize our Website according to your individual     interests.
• Speed up your searches and recognize you     when you return to our Website.

The technologies weuse for this automatic data collection may include:

• Cookies: A cookie is a small piece of data, which includes an     identifier made of letters and numbers that is sent by a web browser and     stored on your computer. Cookies are used as a reliable mechanism to     remember information about you, so your interaction with our website is     seamlessly simple. Cookies typically do not contain any information that     personally identify you, but personal information that we store about you     may be linked to the information stored in and obtained from cookies.     Please click here for details on Cookie Policy.
• Flash Cookies: Certain features of our Website may     use local stored objects (or Flash cookies) to collect and store     information about your preferences and navigation to, from and on our     Website. Flash cookies are not managed by the same browser settings as are     used for browser cookies.
• Web Beacons: Pages of the Website and our e-mails     may contain small electronic files known as web beacons (also referred to     as clear gifs. pixel tags and single-pixel gifs) that permit the Company,     for example, to count users who have visited those pages or opened an     e-mail and for other related website statistics (for example, recording     the popularity of certain website content and verifying system and server     integrity).

We use these cookiesfor the following purposes:

• To identify you when you visit our     platforms and to help you navigate through our platforms;
• To help determine if you are logged into     our platforms:
• To store information about your     preferences and to personalize our platforms for you;
• To secure and protect your user account     and our platforms; and

3.17 Information wereceive from others

We work closely withthird parties and receive information about you from them as well. We alsocollect personal information from individuals who may refer you as a friend toour loyalty schemes or third-party agents (to whom you may have expressed interestabout our properties) or products or services. We ask these individuals toconfirm that you are happy to hear from us.

4. How to opt out?

1. Email: You can click on the unsubscribe link     provided in the email you receive from us.
2. SMS: You can follow the instruction provided in the messages you     receive from us
3. Applications: You may use the “opt out” option     provided within the GAF applications
4. Contact us: You may contact us using the details     provided in Section – ‘How do you contact us?’.

5. Who might weshare this information with?

We may disclosepersonal information that we collect, or you provide as described in thisprivacy policy:

• We may share your personal information     with any member of the GAF, including subsidiaries, affiliates and holding     companies, in order to enable you to request our services, to process your     payments, understand your preferences, conclude a sale, facilitate any     maintenance/ service requests, send you information about products and     services that may be of interest to you and conduct the other activities     described in this privacy policy. Such group companies are located outside     the European Economic Area (“EEA“). Please visit our website to see a list of locations within our corporate group.
• We may use carefully selected third     parties to perform services on our behalf or to assist us with the     provision of services to you. For example, we may engage third party     agents, distribution partners cloud service providers, IT service     providers and other third parties to support and facilitate property sales     and bookings, property handover, security services, brand promotions,     marketing, advertising, communications, to personalize and optimize our     service, to analyse and enhance data (including data about users’     interactions with our services), and to provide legal, accounting,     insurance, audit and other professional services.  While providing     such services, these third parties may have access to your personal     information.
• We may share your personal information     with select business partners in sectors including banking, travel,     entertainment, lifestyle, and other industries to enable our customer to     avail special offers. For example, our partnership with banks enables our customers     to avail home financing options.
• Where required or permitted by law,     personal information may be provided to others, such as regulators and law     enforcement agencies.
• We may share to a buyer or other successor     in the event of a merger, divestiture, restructuring, reorganization,     dissolution or other sale or transfer of some or all the Company’s assets,     whether as a going concern or as part of bankruptcy, liquidation or     similar proceeding, in which personal information held by the Company     about our Website users is among the assets transferred.
• We may share with government or regulatory     authorities upon request to comply with any court order, law or legal     process
• We may share with other companies and     organizations for the purposes of fraud protection and credit risk     reduction if we believe disclosure is necessary or appropriate to protect     the rights, property, or safety of the Company, our customers or others.

The personalinformation that we collect from you may be transferred to, and stored at, adestination outside the EEA (for example, in Dubai). It may also be processedby staff operating outside the EEA who works for us or for one of ourthird-party vendors. We will take all steps that are reasonably necessary toensure that your personal information is treated securely and in accordancewith this privacy policy and applicable data protection laws, including, whererelevant, entering EU standard contractual clauses (or equivalent measures)with the party outside the EEA receiving the personal information. We carry outsuch transfers to facilitate the performance of our contract and in pursuit ofour legitimate business interests of helping us serve you better. We haveimplemented adequate safeguards to protect and secure the information involvedin such transfers. Where we transfer personal information outside of EU, weeither transfer personal information to countries that provide an adequatelevel of protection (as determined by the European Commission) or we haveappropriate safeguards in place. Appropriate safeguards to cover thesetransfers are in the form of standard contractual/data protection clausesadopted by the European Commission.

If you would like moreinformation on protection measures and transfer mechanisms, please contact ususing the details provided in Section – ‘How do you contact us?’.

6. How long do wekeep information about you?

We will only keep yourpersonal information for as long as is reasonably necessary taking intoconsideration our need to answer queries or resolve problems, any other purposeoutlined above or to comply with legal requirements under applicable law(s). Thismeans that we may retain your personal information for a reasonable period, forexample, till the end of the leasing contract with the organization yourepresent, or after your query has been addressed. In certain cases, we mayretain your personal information for a longer period where extended retentionperiods are required by law or regulation and to establish, exercise or defendour legal rights. We will ensure that it is disposed in a secure manner whenit’s no longer needed.

For more informationon where and how long your personal information is stored, and for moreinformation on your rights of erasure and portability, please contact us usingthe details provided in Section – ‘How do you contact us?’.

7. How secure isyour information?

Your personal datasecurity is an important concern to us. We provide the utmost care in securetransmission of your personal information from your computer, smartphone, andother electronic devices to our servers. We use industry security standards tosafeguard the confidentiality of your information (e.g. firewalls, TransportSecurity Layer (“TLS”) etc.) and to make sure that your personalinformation is secure with us.

We have implementedand maintained appropriate technical and organizational security measures,policies and procedures to protect your personal information from theaccidental loss, unauthorized access, use, alteration and disclosure. Allinformation you provide to us is stored on our secure servers behind firewalls.All payment transactions are encrypted using TLS technology. Ex: Measures wetake includes:

• Placing confidentiality requirements on     our staff and service providers;
• Restriction of access to your personal     information to employees and third parties strictly on a need to know     basis, such as to respond to your enquiry or request;
• Destroying or anonymizing personal     information if it is no longer needed for the purposes for which it was     collected; and
• Using secure communication channels for     transmitting personal data.

The safety andsecurity of your information also depend on you. Where we have given you (orwhere you have chosen) a password for access to certain parts of our Website,you are responsible for keeping this password confidential. We ask you not toshare your password with anyone.

Unfortunately, thetransmission of information via the internet is not completely secure. Althoughwe do our best to protect your personal information, we cannot guarantee thesecurity of your personal information transmitted to our Website. Any transmissionof personal information is at your own risk. We are not responsible forcircumvention of any privacy settings or security measures contained on theWebsite.

8. What are yourrights?

If you are subject tolaws that provide you with such rights, you may have certain rights in relationto your personal information given below.

If you wish to accessany of these rights, we may ask you for additional information to confirm youridentity and for security purposes, before disclosing personal information toyou. We reserve the right to charge a fee where permitted by law, for example,if your request is manifestly unfounded or excessive.

If you would like toaccess the below rights, you may contact us by mailing us atinfo@gafproperty.com or sending us a communication to Data Privacy Office, POBox 9440, Dubai, United Arab Emirates. We shall aim to comply with all requestswithin reasonable time in-line with applicable laws. We may not always be ableto fully address your request, for example,

• if it would impact the confidentiality we     owe to others.
• if we are legally entitled to deal with     the request differently.
• if your request involves deletion of     information that are required to comply with the legal requirements.

We will make everyreasonable effort to honour your request in-line with applicable laws. In theevent we require additional time due to the complexity of the request, we shallpromptly inform you of the same.

The right to access

You have the right toobtain confirmation whether we process personal data about you, receive a copyof your personal data held by us, and obtain certain other information abouthow and why we process your personal data (like the information provided in thisprivacy statement).

The right torectification

You have the right torequest for your personal data to be amended or rectified where it isinaccurate (for example, if you change your name or address) and to haveincomplete personal data completed.

The right torestrict processing of personal data

You have the right torestrict our processing of your personal data in the following cases:

• Temporarily for a period when you have     contested for the accuracy of the personal data;
• Temporarily for a period when you have     objected for the legitimate interest identified by us,
• Your personal data have been unlawfully     processed and you request the restriction of processing instead of     deletion;
• The personal data are no longer necessary     in relation to the purposes for which they were collected and processed,     but the personal data are required by you to establish, exercise or defend     legal claims;

We can continue to useyour personal information following a request for restriction, where:

• we have your consent; or
• to establish, exercise or defend legal     claims; or
• to protect the rights of another natural     or legal person.

The right toerasure (also known as ‘the right to be forgotten’)

You have the right toobtain deletion of your personal data in the following cases:

• The personal data are no longer necessary     in relation to the purposes for which they were collected and processed;
• Our lawful basis for processing is     consent, you withdraw consent and we have no other lawful basis for the     processing;
• Our lawful basis for processing is that     the processing is necessary for a legitimate interest pursued by us, you     object to our processing and we do not have overriding legitimate grounds;
• You object to our processing for direct     marketing purposes;
• Your personal data have been unlawfully     processed; and
• Your personal data must be erased to     comply with a legal obligation under EEA to which we are subject.

We are not required tocomply with your request to erase personal information if the processing ofyour personal information is necessary:

• For compliance with a legal obligation; or
• For the establishment, exercise or defence     of legal claims.

The right to objectto the processing of personal data

You have the right toobject to our processing of your personal data in the following cases:

• our lawful basis for processing is that     the processing is necessary for a legitimate interest pursued by us; and     our processing for direct marketing purposes.

The right to dataportability

You have the right toreceive your personal data provided to us and have the right to send the datato another organization (or ask us to do so if technically feasible) where ourlawful basis for processing the personal data is consent or necessity for theperformance of our contract with you and the processing is carried out byautomated means.

The right towithdraw consent at any time (where processing is based on consent)

Where we processpersonal data based on consent, individuals have a right to withdraw consent atany time.

The right to lodgea complaint with a supervisory authority

If you are not contentwith how we manage your personal information, you can lodge a complaint with asupervisory authority in your country of residence, place of work or thecountry in which an alleged infringement of data protection law has occurred withinthe EEA. We sincerely hope that you will never need to, but if you do want tocomplain about our use of personal data, you can contact us in one of the waysmentioned in Section – ‘How do you contact us?’. We will look into and respondto any complaints we receive.

9. Updates on Policy

This policy may changefrom time to time. Your continued use of our platforms after we make changes isdeemed to be acceptance of those changes, so please check the policyperiodically for updates.

10. How do you contactus?

In case of any queriesrelated to this policy, you can contact our Data Privacy Office in one of thefollowing ways.

1. Email us at xxx
2. Call us at xxx
3. Send us mail at xxx

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