What Agent Frank collects, why, who sees it, how long we keep it, and what you can ask us to do about it.
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This policy explains how Agent Frank Real Estate Brokerage L.L.C. handles personal data: what we collect, why we are allowed to, who else sees it, how long we hold it and what you can ask us to do about it. It covers this website and the brokerage behind it.
This version is the one in force
The policy takes effect on the date printed at the top of this page, and the version published here is always the current one. We review it and update it to stay compliant when the law, our systems or our suppliers change, and that date changes with it. No older version is still in force anywhere else.
The principles we work to
- We collect only the personal information we need to provide our services and run our business
- We protect what we collect
- We use it for the purpose it was collected for, and not quietly for another one
- We clear out what we no longer need, where the law allows us to
- We tell people how and when we are collecting their information
- If something goes wrong, we tell the people affected and the relevant authority
Who is responsible for your data
The personal data controller is Agent Frank Real Estate Brokerage L.L.C., ORN 33486, of Suite 904, Business Tower, Business Bay, Dubai. That company decides what is collected and what it is used for, and it is the company answerable for it.
Write to dubai@agentfrank.ae about anything on this page, including a request under Your rights below. A person reads it and replies, and we will confirm what we hold before we act on it.
How long we keep personal data
Retention is set by purpose rather than by one blanket rule, because the rules that bind us differ by record.
- Records of a sale or a lease we brokered, covering sellers, buyers and anyone who made an offer: kept for the period the applicable UAE brokerage and anti-money-laundering record-keeping regulations require, and no longer
- Accounting records: kept for the statutory accounting retention period that applies to us, and no longer
- Newsletter subscriptions: kept until you unsubscribe, and cleared when you do
- Buyer List registrations: kept until you ask us to remove you, and reviewed every two years so a brief nobody has answered does not sit there forever
- An enquiry that goes nowhere: cleared twelve months after the last contact
- Job applications and CVs: kept for twelve months after the decision, unless you ask us to delete them sooner
Your rights
Whatever we hold about you, and whatever we hold it for, you may:
- Ask for a copy of the personal data we hold about you
- Ask us to correct anything that is wrong or out of date
- Ask us to erase it, which we will do except where we are required to keep it, and we will tell you plainly which records those are
- Withdraw a consent you have given, with effect from the moment you withdraw it
- Object to marketing at any time, which stops it
Write to dubai@agentfrank.ae. Every newsletter also carries a working unsubscribe link, which is the fastest route for that one.
What personal data we process, and why
Three things make it lawful for us to hold personal data, and most of what we hold rests on more than one of them at once.
Contract. Processing we cannot avoid if we are to perform an agency or valuation agreement we have with you: marketing a property, arranging viewings, carrying offers between the parties and getting a transaction to completion.
Legal obligation. Processing we are required to carry out to meet our obligations under law and regulation, including brokerage registration and reporting, anti-money-laundering and identity checks, and accounting.
Legitimate interest. Making relevant offers to people who have asked to hear about them, marketing our own services, and arranging a sale or a letting. We weigh that interest against your privacy each time, and it never extends to selling your data to anybody.
The categories we actually process:
- Name
- Contact details: address, email address and telephone number
- Identity document details, where a transaction requires them
- Information about the property: address, size, tenure, condition, photographs and documents
- Bank or payment details, where a transaction requires them
- Enquiry and viewing history: what you asked about, and which properties you have been shown
- Visit statistics and click history, which here means the page an enquiry was sent from and the campaign that brought you to the site; this website sets no analytics or advertising cookies
- Offer and bid details, and the record of the negotiation around them
- Details of a completed instruction: what was sold or let, on what terms, and when
- Fees paid and other financial transactions between us
Whose data we process
- Sellers and landlords who instruct us
- Buyers and tenants
- Anyone who makes an offer or a bid on a property we are marketing
- Owners who ask for a valuation without having decided to sell
- Buyers who join Frank’s Buyer List
- Anyone who sends an enquiry through this website
- Newsletter subscribers
- Guests on the Frank Fridays list
- Job applicants
Where we collect it from
Most of it comes from you, on a form on this website or in a conversation with one of us.
The rest comes from public registers, for example the Dubai Land Department, and from developers and owners’ associations where a transaction requires it. Title, service charge and handover information is checked at source rather than taken on trust.
Who we share it with
- Sellers, where we are acting in a brokerage and an offer or an enquiry has to reach them
- Partners providing valuation, mortgage, legal, immigration or company-formation services, and only after we have told you
- Banks, in connection with a transaction
- Service providers who run our IT, email, marketing, photography and styling. They act only on our instructions and may not pass your data on
- Property portals and listing platforms, where a property is advertised
We do not sell personal data and we do not share it with third-party marketers.
Cookies
This website sets as few cookies as it can, and at present not one of them is an analytics or an advertising cookie. Each cookie is named on the cookie policy at /cookie-policy, with what it does and how long it lasts, along with how to refuse them.
Changes to this policy
If this policy changes, the updated version is published here and the date at the top of this page changes with it.