Privacy Policy
Effective Date: 9 October 2025
1. WHO WE ARE
This Privacy Policy explains how X W W Real Estate L.L.C (“Global X”, “we”, “us”, “our”) collects, uses, discloses and protects personal data in connection with our activities in the Emirate of Dubai and through our website at www.globalxww.com (the “Website”).
Global X is a real estate brokerage and consultancy based in Dubai, United Arab Emirates, specialising in investment, acquisition and management of real estate assets in Dubai and internationally.
Data controller:
X W W Real Estate L.L.C (Global X Real Estate)
Bay Square Building 12, Office 807
Business Bay, Dubai, UAE
Phone: +971 4 575 3426
Email (general): info@globalxww.com
Email for privacy matters (recommended): privacy@globalxww.com
For the purposes of applicable data protection laws in the United Arab Emirates, X W W Real Estate L.L.C acts as the “data controller” for the processing activities described in this Privacy Policy.
If you deal with other companies within our group (for example, for consultancy, trading, events or branding services), additional privacy notices may apply and will be provided to you where relevant.
2. SCOPE OF THIS PRIVACY POLICY
This Privacy Policy applies to personal data we process when:
• you visit or use the Website (including any microsites hosted under globalxww.com),
• you contact us via online forms, email, phone, WhatsApp or other messaging tools,
• you follow, contact or interact with us on social media platforms,
• you attend our events, property tours, roadshows or meetings,
• you register interest in a specific property, project or investment opportunity,
• you apply for a role via our Careers page, or
• you otherwise interact with us as a client, prospective client, supplier or business partner.
This Privacy Policy does not replace any specific privacy notice or consent form we may provide to you for a particular service, deal or transaction. In case of conflict, the more specific notice will prevail for that specific processing.
3. PERSONAL DATA WE COLLECT
“Personal data” means any information relating to an identified or identifiable natural person.
3.1. Information you provide directly
We collect personal data that you provide to us, for example when you:
(a) Website contact and investment enquiries
• Identification and contact data: name, email address, mobile/phone number, country of residence, preferred language.
• Investment profile: budget range, currency, property type and location of interest, investment objectives (e.g. capital appreciation, rental yield, second home), timeline, preferred developers, risk profile and any other information you choose to share in free-text fields.
(b) Client onboarding and real estate transactions
When you proceed beyond an initial enquiry (for example to reserve, purchase, lease or sell a property, or to receive detailed advisory), we may also collect:
• Official identification data: passport, Emirates ID, residency visa, signatures and copies of these documents.
• Compliance and KYC/AML information: date of birth, nationality, source of funds/wealth, occupation, tax residency, information relating to politically exposed person (PEP) status, sanctions screening results and other risk-related information as required by applicable anti-money laundering laws and Dubai Land Department / RERA requirements.
• Transaction data: property details and reference numbers, contract forms (including DLD standard forms), reservation agreements, payment schedules, payment method information (excluding full payment card details, which are typically handled by banks or payment providers), records of meetings, instructions and correspondence.
(c) Events, property tours and roadshows
• Registration information: name, contact details, city/country, company, role, event preferences and any special requirements.
• Attendance data: which event(s) you joined, check-in time, invitee lists, seating lists, feedback forms and follow-up preferences.
(d) Marketing subscriptions and content downloads
• Name, email, mobile number, location, preferred communication channels and topics of interest (e.g. off-plan Dubai, branded residences, luxury rentals, golden visa, corporate solutions).
(e) Communications with us
• Records of communications: email, WhatsApp and other instant messages, call logs and, where permitted by law, audio recordings of calls (for quality, training and dispute resolution).
• Requests and instructions: content of your enquiries, complaints, feedback or other messages.
(f) Careers and recruitment
• Application details: CV/resume, cover letter, employment history, education, professional qualifications, languages, references and any other information you choose to provide.
3.2. Information we collect automatically
When you visit the Website or interact with our digital channels, we may automatically collect:
• Technical data: IP address, device identifiers, browser type and version, operating system, language settings and time zone.
• Usage data: pages visited, properties viewed, time spent on pages, clicks on links and CTAs, search filters, referring URLs, interactions with embedded maps or videos, error logs and performance data.
• Cookie and tracker data: identifiers stored in cookies, pixels, tags and similar technologies for analytics, security and marketing optimisation (see Section 6 below).
Where permitted by law, we may approximate your location (e.g. city/country level) based on IP address or similar technical information.
3.3. Information we receive from third parties
We may receive personal data about you from:
• Real estate developers and property owners, where you have requested that your details be shared with us or where we are co-marketing or co-brokering a project;
• Referral partners, introducers, property portals or external agents that you have interacted with and authorised to share your data with Global X;
• Social media platforms (for example, when you send us a direct message, comment on our posts, or use social login where available);
• Publicly available sources (for example, professional profiles, company records or property-related public registries), in order to verify information or perform due diligence as required by law.
3.4. Special categories of personal data and children
We do not intentionally collect “sensitive” categories of personal data (such as health information, biometric data, religious beliefs) through the Website, unless required by law (for example, for KYC/AML checks) or you voluntarily provide such information and consent to its processing.
The Website and our services are not directed at children under 18 years old. We do not knowingly collect personal data from children. If you believe a child has provided us with personal data, please contact us so we can take appropriate steps.
4. HOW WE USE PERSONAL DATA AND LEGAL BASES
We process your personal data only when we have a lawful basis to do so under applicable UAE data protection law. Depending on the context, we may rely on your consent, the need to perform a contract or take steps at your request, our legal obligations, or our legitimate interests where permitted by law.
4.1. Providing our services and responding to you
• To respond to your enquiries and requests, provide information about properties and investment opportunities, and schedule calls or meetings.
• To create and manage your client record in our CRM and maintain up-to-date contact information.
• To prepare tailored proposals, investment analyses and property shortlists based on your profile and instructions.
Legal bases: taking pre-contractual steps at your request, performing a contract with you, and our legitimate interest in operating an effective real estate advisory business (where permitted).
4.2. Real estate brokerage, advisory and related services
• To conduct due diligence and know-your-client checks as required for real estate transactions and investment services.
• To draft, negotiate and execute contracts (including DLD/RERA forms and documentation), facilitate payments and manage transaction workflows.
• To coordinate with developers, property owners, co-brokers, legal advisors and other parties involved in a transaction or advisory mandate.
Legal bases: performance of a contract, taking steps at your request prior to entering into a contract, and compliance with legal and regulatory obligations (including anti-money laundering and real estate regulations).
4.3. Compliance, risk management and security
• To comply with legal obligations under applicable UAE laws, including anti-money laundering, combating the financing of terrorism, sanctions screening and record-keeping requirements.
• To comply with obligations and best practices issued by Dubai Land Department and the Real Estate Regulatory Agency (RERA) relating to fair marketing, data confidentiality and investor protection.
• To prevent, detect and investigate potential fraud, cyber incidents, unauthorised access and misuse of our systems or our clients’ information.
• To manage legal disputes and enforce our contractual and legal rights.
Legal bases: compliance with legal obligations and our legitimate interest in protecting our business, our clients and the integrity of the Dubai real estate market.
4.4. Events, property tours and roadshows
• To register you for events, confirm attendance, send logistical information and manage access control and on-site security.
• To follow up after events or property tours with additional information, investment proposals or marketing communications in line with your preferences.
• To document our events through photos and video and, where lawful and agreed, use such media for marketing and brand-building purposes (see Section 13).
Legal bases: your consent, performance of a contract (event participation), and our legitimate interests in organising and improving our events and experiences.
4.5. Marketing, analytics and personalisation
• To send you updates about new launches, property releases, seminars, “Dubai Xperience” events, newsletters and other content that may be relevant to your profile.
• To build audiences and deliver advertising through digital platforms (such as Meta, Google, LinkedIn, TikTok and similar), including look-alike and remarketing campaigns, in accordance with their terms and applicable law.
• To analyse how users interact with the Website and our campaigns (including funnels, conversion rates and content performance) so we can optimise our content, user experience and marketing spend.
• To segment our database and refine our commercial strategy by geography, investment profile and engagement.
Legal bases: your consent (for example, when you subscribe or accept marketing cookies) and, where permitted, our legitimate interests in promoting and growing our business. You can opt out of direct marketing at any time (see Section 12).
4.6. Recruitment
• To review and process job applications, assess candidates, schedule interviews and make hiring decisions.
• To maintain a talent pool for future opportunities, where permitted or where you agree.
Legal bases: taking steps at your request prior to entering into an employment or services contract, and our legitimate interests in recruiting qualified professionals.
4.7. Other purposes
We may process your personal data for other specific purposes that are clearly explained to you at the time of collection and, where required, based on your explicit consent.
5. WHEN WE REQUIRE YOUR CONSENT
In many cases, we rely on your explicit consent to process your personal data – for example, for certain marketing activities, for the use of non-essential cookies, or for using identifiable photographs or testimonials in promotional materials.
Where we rely on consent, you are free to withdraw it at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal. To withdraw consent, follow the unsubscribe instructions in our messages or contact us at privacy@globalxww.com.
6. COOKIES AND SIMILAR TECHNOLOGIES
6.1. What are cookies?
Cookies are small text files stored on your device (computer, smartphone or tablet) when you visit a website. They are widely used to make websites function, to remember user preferences and to provide information to website owners.
We also use similar technologies such as pixels, tags, scripts and local storage (collectively “cookies” for simplicity).
6.2. Types of cookies we use
Subject to your choices, we may use:
• Strictly necessary cookies – required for the Website to function (for example, to load pages, manage sessions, balance traffic or apply security settings). These cannot normally be switched off in our systems.
• Functionality cookies – to remember choices you make (e.g. language, currency selection, region) and provide enhanced, personalised features.
• Analytics and performance cookies – to collect aggregated information about how visitors use the Website (pages visited, time on site, error messages) so we can improve usability and performance.
• Advertising and social media cookies – to deliver more relevant ads to you on third-party platforms, measure campaign performance, build audiences, and enable social sharing features.
6.3. Third-party cookies
We may use third-party service providers (such as analytics, marketing and social media partners) that set cookies on our behalf. These providers may also combine data collected on our Website with information from other websites or apps where you have consented to tracking, in line with their own privacy policies.
6.4. Managing cookie preferences
When you first visit the Website (and periodically afterwards), you may see a cookie banner or pop-up allowing you to accept or manage non-essential cookies. You can adjust your preferences at any time through your browser settings and, where available, via our cookie management tool.
If you block or disable some cookies, certain Website features may not function properly.
7. HOW WE SHARE PERSONAL DATA
We do not sell your personal data. We only share it where necessary and lawful, as described below.
7.1. Within the Global X ecosystem
We may share personal data with other companies within our wider group (for example, entities focused on consultancy, events, branding or investment services) to the extent they support us in providing real estate and related services, marketing and event experiences, or internal reporting and governance. These entities may act as data controllers or processors depending on the context.
7.2. Developers, owners and co-brokers
Where necessary to respond to your request or to progress a transaction, we may share your personal data with:
• Dubai and international real estate developers, project owners and master developers;
• Property owners and landlords;
• Other licensed real estate brokerage firms acting as co-brokers or sub-agents.
We will only share the information reasonably required to facilitate the specific enquiry, viewing or transaction, and subject to appropriate confidentiality and regulatory requirements.
7.3. Service providers and professional advisers
We may engage third parties to provide services such as:
• Web hosting, cloud infrastructure and data storage;
• Customer relationship management (CRM) and marketing automation platforms;
• Email, SMS and WhatsApp messaging services;
• Events and hospitality management;
• IT security, maintenance and support;
• Analytics, digital marketing and advertising;
• Legal, tax, compliance, consulting and auditing services.
These service providers act as our “processors” and are contractually bound to process personal data only on our documented instructions, implement appropriate security measures and not use the data for their own purposes.
7.4. Regulators, authorities and law enforcement
We may disclose personal data to:
• Dubai Land Department (DLD), the Real Estate Regulatory Agency (RERA) and other relevant authorities in relation to registrations, permits, compliance audits, inspections or investigations;
• Emirates or federal authorities supervising anti-money laundering and counter-terrorist financing;
• Courts, arbitrators, law enforcement bodies or other public authorities, where we are required to do so by law or where disclosure is necessary to establish, exercise or defend legal claims.
7.5. Corporate transactions
In the context of a merger, acquisition, restructuring, joint venture, assignment or sale of all or part of our business, we may transfer personal data to third parties involved in the transaction, subject to confidentiality obligations and in accordance with applicable law.
7.6. With your consent
In addition to the above, we may share your personal data with third parties where you have expressly requested or consented to such sharing (for example, when you ask us to introduce you to a banking partner, tax advisor, immigration specialist or other professional).
8. INTERNATIONAL TRANSFERS OF PERSONAL DATA
Our operations, clients and partners are international. As a result, your personal data may be processed and stored outside the country where it was collected, including outside the United Arab Emirates.
Where we transfer personal data outside the UAE, we will:
• transfer to countries that are recognised as providing an adequate level of data protection; or
• implement appropriate safeguards, such as contractual clauses imposing obligations on the recipient to protect the data in line with UAE standards; or
• rely on other grounds permitted by applicable law, such as your explicit consent, the necessity to perform a contract with you, or the need to establish or defend legal claims.
You may contact us for more information about the mechanisms we use for cross-border transfers in relation to your personal data.
9. HOW WE PROTECT PERSONAL DATA
We implement technical and organisational measures designed to ensure an appropriate level of security, confidentiality and integrity of personal data, including:
• access controls and role-based permissions;
• data encryption and secure communication protocols where appropriate;
• network and application security measures, including monitoring and logging;
• segregation of environments and regular backups;
• internal policies and procedures on data protection, information security and acceptable use;
• staff training and awareness on confidentiality and data protection obligations.
No system or transmission is completely secure. While we work hard to protect your personal data, we cannot guarantee absolute security. If we become aware of a personal data breach that is likely to result in a serious risk to your privacy, we will take steps required by applicable law, which may include notifying you and/or the relevant authorities.
10. DATA RETENTION
We keep personal data only for as long as necessary to fulfil the purposes for which it was collected, or to meet legal, regulatory, accounting or reporting requirements.
Retention periods depend on the type of data and context, but typically:
• General enquiries and marketing leads: kept for the duration of our interactions and for a reasonable period afterwards (for example, 2–3 years of inactivity), unless you request deletion earlier or consent is withdrawn.
• Client and transaction files: kept for at least the minimum periods required under applicable real estate and anti-money laundering laws (which may be 5 years or more after the end of the relationship or transaction) and for longer where necessary in connection with potential disputes or regulatory investigations.
• Event and roadshow participation records: kept for the duration of our relationship with you and a reasonable period afterwards for follow-up and record-keeping.
• Recruitment data: candidate information is generally kept during the recruitment process and, if you are not hired, for a limited period afterwards (for example, up to 2 years) unless you request earlier deletion or consent to a longer retention for future opportunities.
We may anonymise personal data so that it can no longer be associated with an identified person. In that case, we may use such anonymised information without further notice to you.
11. YOUR RIGHTS
Subject to the conditions and exceptions set out in applicable data protection law, you may have the following rights in relation to your personal data:
• Right to information: to receive clear information about how we process your personal data, including this Privacy Policy and any additional notices.
• Right of access: to obtain confirmation whether we process your personal data and to request a copy of the personal data we hold about you.
• Right to rectification: to request correction of inaccurate or incomplete personal data.
• Right to erasure: to request deletion of your personal data in certain circumstances (for example, if it is no longer needed for the purposes for which it was collected or if you have withdrawn consent), subject to legal retention obligations.
• Right to restriction: to request that we limit the processing of your personal data in certain situations (for example, while we verify its accuracy or assess an objection).
• Right to data portability: to receive certain personal data in a structured, commonly used and machine-readable format, and to request that we transmit that data to another controller where technically feasible.
• Right to stop processing: to object to certain processing activities, including direct marketing (in which case we will stop).
• Right not to be subject to automated decision-making: to object to decisions based solely on automated processing, including profiling, which produce legal or similarly significant effects on you.
• Right to withdraw consent: where processing is based on your consent, to withdraw that consent at any time.
To exercise your rights, please contact us at privacy@globalxww.com or at our postal address. We may ask you to verify your identity before responding to your request. We aim to respond within the timeframes required by applicable law.
If you believe we have not handled your personal data in accordance with the law, you also have the right to lodge a complaint with the competent supervisory authority in the UAE. We would, however, appreciate the opportunity to address your concerns directly first.
12. MARKETING COMMUNICATIONS
We may use your contact details to send you marketing communications about properties, developers, investment products, events, reports and other services we believe may be of interest to you.
We will only do this:
• where you have specifically requested such communications (for example, by subscribing); or
• where you are an existing client and we are permitted to send reasonable and relevant updates in line with your relationship with us and applicable law.
You can opt out of marketing communications at any time by:
• clicking the unsubscribe link or following the instructions in our emails or messages; or
• contacting us at privacy@globalxww.com and specifying the channels and topics you wish to stop.
Even if you opt out of marketing, we may still send you non-marketing communications relating to your transactions, legal notices, updates to this Privacy Policy or other important information.
13. USE OF IMAGES, VIDEO AND WEBSITE CONTENT
13.1. Images and video of properties and events
Our Website and marketing materials may display photographs, videos, renderings, floor plans and virtual tours of:
• residential and commercial properties and developments;
• events, roadshows, private dinners, seminars and other experiences organised or co-organised by Global X;
• our offices, team and brand-related content.
Some of this content may incidentally include images of individuals (for example, guests at events, staff or other participants). Where such images constitute personal data and the individual is identifiable, we will:
• obtain consent where required by law before using the material for marketing purposes; and/or
• take reasonable steps to minimise identifiability (for example, focusing on atmosphere rather than close-ups, or using angles and editing).
If you appear in an image or video published by us and wish to request its removal or anonymisation, you may contact privacy@globalxww.com. We will assess your request in light of our legitimate interests, contractual obligations and legal requirements and will respond in accordance with applicable law.
13.2. Client testimonials and case studies
From time to time, we may publish testimonials, quotes, case studies or success stories featuring clients or partners. Where these include personal data (such as your name, image or specific property details that identify you), we will only do so with your prior consent, which you may withdraw at any time for future uses.
13.3. Intellectual property and use of Website content
Unless otherwise indicated, all content on the Website – including text, images, videos, graphics, logos, icons, layouts, maps, brochures and digital assets – is owned or licensed by Global X or our partners and is protected by copyright and other intellectual property laws.
You may:
• view and print Website pages for your personal, non-commercial use in evaluating our services and properties.
You may not, without our prior written permission:
• copy, download (other than for transient caching), reproduce, distribute, publish, scrape, index, mirror or otherwise exploit any Website content for commercial purposes;
• alter or remove any copyright or proprietary notices;
• use our images, videos, project descriptions or brand elements in your own marketing materials, advertisements or websites;
• use automated tools (such as bots or scrapers) to systematically extract data or images from the Website.
Any unauthorised use of Website content may constitute a breach of intellectual property or other laws and may give rise to civil or criminal liability. Nothing in this Privacy Policy grants you any licence or right to use any of our trademarks or other proprietary material.
14. CHILDREN’S PRIVACY
Our services and Website are intended for adults and business users. We do not knowingly target or collect personal data from children under 18 years of age. If you believe that a child’s personal data has been provided to us without appropriate consent, please contact us so we can take appropriate steps.
15. THIRD-PARTY WEBSITES AND SERVICES
The Website may contain links to third-party websites, apps or services (including developers, partners, portals, payment providers or social media platforms). We do not control these third parties and are not responsible for their privacy practices.
We encourage you to read the privacy policies of any third-party sites or services you visit or use.
16. CHANGES TO THIS PRIVACY POLICY
We may update this Privacy Policy from time to time, for example to reflect changes in law, our processing activities, technologies or business structure.
When we make material changes, we will:
• update the “Last Updated” date at the top of this page; and
• take any additional steps required by law, which may include notifying you directly or seeking your renewed consent where appropriate.
We recommend that you review this Privacy Policy periodically to stay informed about how we process your personal data.
17. HOW TO CONTACT US
For any questions, requests or concerns regarding this Privacy Policy or our processing of your personal data, please contact:
X W W Real Estate L.L.C
Bay Square Building 12, Office 807
Business Bay, Dubai, UAE
Email (preferred for privacy matters): privacy@globalxww.com
General email: info@globalxww.com
Phone: +971 4 575 3426
We will do our best to respond promptly and to resolve any concerns you may have.
