Data Privacy Policy

Cavendish Maxwell (which includes Cavendish Maxwell Real Estate Valuation Services LLC and all affiliates in the United Arab Emirates, Kuwait and Oman) ("we") are committed to protecting and respecting your privacy.

This policy (together with any other documents referred to herein) (“Policy”) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.

Cavendish Maxwell Real Estate Valuation Services LLC (“CM”) is a "data controller" for the purposes of the UAE Federal Data Protection Law No. 45 of 2021 and any other applicable data protection laws in respect of certain types of personal data that we collect about you. This means that CM is responsible for, and controls the processing of, the types of personal data that we collect about you.

We take your privacy very seriously and we ask that you read this Policy carefully as it contains important information on:

(a)   the personal data we collect about you;

(b)   how we process your personal data; and

(c)   with whom your personal data might be shared.

PERSONAL DATA WHICH WE COLLECT

Personal data provided by you

We collect personal data about you when you:

The personal data collected in the above manner may include your:

Personal data provided by 3rd parties

We may receive information about you from other sources (such as banks or surveyors acting on your behalf and the service providers we use to undertake background checks against you), which we will add to the information we already hold about you in order to help us provide our products and services in accordance with your requirements and to improve and personalise our service to you.

Personal data about other individuals

If you give us information on behalf of someone else, you confirm that the other person has appointed you to act on his/her behalf and has agreed that you can:

(a)   give consent on his/her behalf to the processing of his/her personal data;

(b)   receive on his/her behalf any data protection notices; and

(c)   give consent to the transfer of his/her personal data abroad.

Monitoring and recording communications

We may monitor and record communications with you (such as telephone conversations and emails) for the purpose of quality assurance, training, fraud prevention and compliance activities.

HOW WE USE YOUR PERSONAL DATA

Overview

We collect information about you so that we can:

(a)   identify you and provide and manage any services you request from us;

(b)   respond to your enquiries;

(c)   process your purchases;

(d)   detect and prevent fraud;

(e)   comply with our legal and regulatory obligations (for example, AML obligations);

(f)   investigate complaints made;

(g)   undertake marketing;

(h)   customise our website and its content to your particular preferences;

(i)   make or defend against complaints or formal legal claims and proceedings;

(j)   make or safeguard our position in respect of any actual or potential insurance claims;

(k)   notify you of any changes to our website or to our services that may affect you; and

(l)   improve our services and ensure quality control.

Marketing

We would like to send you information by post, email, telephone, or text message (SMS) about our products and services and special offers which may be of interest to you.

If you provide us with consent, we may share your details with the Cavendish Maxwell companies who may also send you similar marketing messages. The Cavendish Maxwell companies include, but are not limited to:

• Cavendish Maxwell Consultants L.L.C;
• Cavendish Maxwell Real Estate L.L.C;
• Cavendish Maxwell Valuation Services L.L.C;
• Cavendish Maxwell Real Estate Valuation Services L.L.C;
• Cavendish Maxwell Real Estate Consulting L.L.C.;
• Cavendish Maxwell Real Estate Broker L.L.C;
• Property Monitor Software & Services L.L.C;
• Cavendish Maxwell For Inspection and Pricing Services L.L.C;
• Lewis Grant Associates L.L.C;
• Cavendish Maxwell Real Estate Valuation Services L.L.C - License No. 2021/19899 Kuwait; and
• Cavendish Maxwell Company for Assessing Heavy & Light Equipment, Vehicles and Industrial L.L.C -License No. 18756/2022 Kuwait

We will only send you marketing messages (or share your details with the third parties listed above) when you tick the relevant consent box when you provide us with your personal data. If you have consented to such receive marketing from us, or the third parties listed above, you can opt out at any time.

Credit checking

We may do a credit check on you:

(a)   so that we can make credit decisions about you and members of your household;

(b)   to prevent and detect fraud and money laundering; and

Our search will be recorded on the files of the credit reference agency.

We may also disclose information about how you conduct your account to credit reference agencies and your information may be linked to records relating to other people living at the same address with whom you are financially linked.

Other credit businesses may use your information to:

(a)   make credit decisions about you and the people with whom you are financially associated;

(b)   trace debtors; and

(c)   prevent and detect fraud and money laundering.

If you provide false or inaccurate information to us and we suspect fraud, we will record this.

If you want to see your credit file, please contact us.

WHEN WE MIGHT SHARE YOUR PERSONAL DATA WITH 3RD PARTIES

For the purposes of delivering our services, we may disclose your personal data to:

(a)   other Cavendish Maxwell companies;

(b)   our agents and service providers (including professional service providers such as law firms and accountants);

(c)   banks in connection with any payments to be made to or from you;

(d)   law enforcement agencies in connection with any investigation to help prevent unlawful activity;

(e)   insurers in respect of any claims or complaints made against us, and

(f)   our business partners.

CONSENT

In those cases where we need your consent to hold and process your personal data, we will ask you to check a box on any form requiring consent. By checking these boxes you are stating that you have been informed as to why we are collecting the information, how it will be used, for how long it will be kept, who else will have access to it and what your rights are as a data subject (all of which is set out in this Policy).

HOW WE KEEP YOUR PERSONAL DATA SECURE

To protect your information we have policies and procedures in place to make sure that only authorised personnel can access the information, that information is handled and stored in a secure and sensible manner, and that all systems that can access the information have the necessary security measures in place. To accomplish this, all employees, contractors and sub-contractors have roles and responsibilities defined in those policies and procedures.

To make sure all employees, contractors and sub-contractors understand these responsibilities they are provided the necessary training and resources they need.

In additional to these operational measures, we also use a range of technologies and security systems to reinforce the policies, including ensuring that:

(a)   we store your personal data on secure servers; and

(b)   payment details are encrypted using SSL technology (typically you will see a lock icon or green address bar (or both) in your browser when we use this technology) To make sure that these measures are suitable vulnerability tests are run regularly. Audits to identify areas of weakness and non-compliance are routinely scheduled. Additionally, all areas of the organisation are constantly monitored and measured to identify problems and issues before they arise.

HOW LONG DO WE KEEP YOUR PERSONAL DATA

We shall retain your information for the duration of the mandate that you have instructed us to assist with. Thereafter, we will delete your personal data unless we are required by law to retain your personal data for a longer period or unless we require it to continue providing you with the services you acquire from us. For example, in order to comply anti-money laundering laws, we are required to retain certain personal data for five (5) years in  UAE and for ten (10) years in Oman.

TRANSFERS OF YOUR PERSONAL DATA OUT OF THE JURISDICTION IN WHICH YOUR DATA IS COLLECTED

We may need to transfer and store your personal data outside of your jurisdiction (for example, if you are a customer based in the UAE but whom we serve across several GCC territories in which we operate, it may be appropriate for us to transfer your data to one of our other offices in another jurisdiction in order to best serve you). We will obtain your consent to make such international transfers, unless the laws in your jurisdiction otherwise permit us to make such transfers (for example, where we are transferring to a country which your jurisdiction has determined provides you with adequate safeguards and protections for your data and gives you remedies in the unlikely event of a security breach, etc.).

YOUR RIGHTS

In order to process any of the requests listed below, we may need to verify your identity for your security. In such cases your response will be necessary for you to exercise this right.

The right to access information we hold on you

At any point you can contact us to request the information we hold on you as well as why we have that information, who has access to the information and where we got the information. Once we have received your request we will respond to you within the number of days set out below:

The right to correct and update the information we hold on you

If the data we hold on you is out of date, incomplete or incorrect, you can inform us and we will ensure that it is updated.

The right to have your information erased

If you feel that we should no longer be using your data or that we are illegally using your data, you can request that we erase the data we hold. When we receive your request, we will confirm whether the data has been deleted or tell you the reason why it cannot be deleted.

The right to object to processing of your data

You have the right to request that we stop processing your data. Upon receiving the request, we will contact you to tell you if we are able to comply or if we have grounds to continue. If data is no longer processed, we may continue to hold your data to comply with your other rights.

The right to ask us to stop contacting you with direct marketing

You have the right to request that we stop contacting you with direct marketing. In order to process your request we may need to verify you identity for your security.

The right to data portability

You have the right to request that we transfer your data to another controller. Once we have received your request, we will comply where it is feasible to do so.

The right to complain

You can make a complaint to us by contacting us via dataprotection@cavendishmaxwell.com or to the UAE's data protection supervisory authority, the Data Office.

COOKIES AND TRACKING

Use of cookies

A cookie is a small text file which is placed onto your computer (or other electronic device) when you access our website. We use cookies on this website to:

(a)   recognise you whenever you visit this website (this speeds up your access to the website as you do not have to log in each time);

(b)   obtain information about your preferences, online movements and use of the internet;

(c)   carry out research and statistical analysis to help improve our content, products and services and to help us better understand our customer requirements and interests;

(d)   target our marketing and advertising campaigns more effectively by providing interest-based advertisements that are personalised to your interests; and

(e)   make your online experience more efficient and enjoyable.

In most cases we will need your consent in order to use cookies on this website. The exception is where the cookie is essential in order for us to provide you with a product or service you have requested.

Consent to cookies

If you visit our website when your browser is set to accept cookies, we will interpret this as an indication that you consent to our use of cookies and other similar technologies as described in this Policy. If you change your mind in the future about letting us use cookies, you can modify the settings of your browser to reject cookies or disable cookies completely.

Description of cookies

The table below provides some information on the cookies which we use on our website:

Turning off cookies

If you do not want to accept cookies, you can change your browser settings so that cookies are not accepted. If you do this, please be aware that you may lose some of the functionality of this website.

CONTACTING US

If you have any queries about this Policy, need further information or wish to lodge a complaint you can use the details below to contact us.

By Email

dataprotection@cavendishmaxwell.com

By Post

Data Protection Officer, Cavendish Maxwell, 2205 Marina Plaza, Dubai Marina, P.O. Box 118624, Dubai, United Arab Emirates

CHANGES TO THIS POLICY

We may change this Policy from time to time. You should check this Policy on our website occasionally to ensure that you are aware of the most recent version or you may request a copy of this Policy by sending an email with your request to dataprotection@cavendishmaxwell.com.