Effective date: 23 October 2025

1) Who we are (Data Controller)

This Privacy Policy explains how Injaz Real Estate Trustee LLC (“Injaz”, “we”, “us”, or “our”) collects, uses, discloses, and protects personal data when you use Aqari at aqari.injazrt.ae or our Aqari channels (including WhatsApp intake for Ejari/other services), contact us, or receive services we facilitate with the Dubai Land Department (DLD). Aqari is operated by Injaz as a digital extension of our Registration Trustee services. (aqari.injazrt.ae)

Contact (privacy & support):

• Email: cs@injazrt.ae (general support) | aqari@injazrt.ae (Aqari)

• Phone: +971 600 546529 (Injaz) | +971 600 527274 (Aqari)

• Address: Ground Floor, Office No. 1, Emaar Business Park 3, The Greens, Dubai, UAE. (injazrt.ae)

2) Scope

This Policy covers:

• aqari.injazrt.ae and embedded forms;

• Aqari WhatsApp intake/communication flows (e.g., remote Ejari);

• Email/phone support; and

• Any digital document intake we operate for DLD-facing trustee services.
  It doesn’t cover third-party platforms we don’t control (e.g., WhatsApp, payment gateways, analytics vendors). Their policies apply. (providentestate.com)

3) Legal framework

We process personal data under the UAE Personal Data Protection Law (PDPL) (Federal Decree-Law No. 45 of 2021) and applicable guidance, which outlines lawful bases, principles, and individual rights. (General PDPL references.) (Dubai Land Department)

4) What data we collect

a) Identity & contact

Name, nationality, date of birth, Emirates ID/passport details, email, phone, address. (Typical for DLD transactions/Ejari.) (Dubai Land Department)

b) Property & transaction data

Property identifiers/title deed data, tenancy/ownership contracts, NOCs, PoAs, developer/building details, fee amounts and receipts. (Dubai Land Department)

c) Uploaded/forwarded documents

Files/images you upload via Aqari forms or send via WhatsApp (IDs, contracts, PoAs, corporate docs). (aqari.injazrt.ae)

d) Website & device data

IP address, device/browser type, pages viewed, and cookies/SDK events for essential operation, performance, and (if enabled) analytics on aqari.injazrt.ae. (aqari.injazrt.ae)

e) Communications & preferences

Your messages with us (site forms, email, phone, WhatsApp), service choices, and notification preferences.

We collect data from you, from your authorized representative (e.g., broker/landlord/company signatory), and from third parties (DLD systems/records) as required to deliver services. (Dubai Land Department)

5) Why we process your data (purposes & lawful bases)

Under PDPL, we rely on one or more of: consent, contract, legal obligation, legitimate interests, or public interest for government-linked registries.

• Deliver Aqari services (e.g., remote Ejari, title/tenancy updates, digital intake, appointment/support). Bases: Contract, Legal obligation, Public interest tied to DLD registries. (providentestate.com)

• Submit to DLD systems (document verification, data entry, audit, fee payment, receipt generation). Bases: Legal obligation, Public interest, Contract. (Dubai Land Department)

• Payments & reconciliation via approved gateways (e.g., Noqodi/Dubai Pay) and cards; we keep only necessary references. Bases: Contract, Legal obligation. (Dubai Land Department)

• Customer support & operations (responding to queries, troubleshooting, service improvements). Bases: Contract, Legitimate interests.

• Security, fraud/AML compliance & audits (including KYC/verification). Bases: Legal obligation, Legitimate interests.

• Analytics & optimization on aqari.injazrt.ae (where used). Bases: Legitimate interests and/or Consent (for non-essential cookies/SDKs).

6) Who we share data with

We share the minimum necessary, with safeguards, to deliver Aqari services:

• Dubai Land Department & connected gov’t platforms to process registrations/Ejari, issue receipts, and update records. (Dubai Land Department)

• Payment service providers (e.g., Noqodi/Dubai Pay, card processors) to collect fees and reconcile payments. (Dubai Land Department)

• Messaging/communications platforms you choose (e.g., WhatsApp) for remote intake; your use of these also follows their terms/policies. (providentestate.com)

• Service providers (secure hosting, IT/CRM, email delivery, analytics) under data-processing/ confidentiality commitments.

• Counterparties/authorized agents (e.g., landlord/tenant, broker, developer) where needed to complete your request.

• Regulators/law enforcement if required by law or to establish/exercise legal rights.

We do not sell your personal data.

7) International transfers

Some providers may store/process data outside the UAE. Where this happens, we use PDPL-permitted safeguards (e.g., adequacy, contractual clauses, or other lawful bases). (General PDPL reference.) (Dubai Land Department)

8) Data retention

We retain personal data only as long as needed for the purposes above, including:

• statutory/DLD record-keeping periods;

• contractual limitation periods; and

• audit/compliance requirements.
  After that, we securely delete or anonymize data. (Dubai Land Department)

9) Your rights

Subject to UAE law, you may have rights to access, rectify, erase (where applicable), restrict or object to processing, port data, and withdraw consent for optional processing. You may also have protections around automated decisions. To exercise rights, contact cs@injazrt.ae or aqari@injazrt.ae; we’ll verify your identity and respond within PDPL timelines. (General PDPL reference.) (Dubai Land Department)

10) Aqari cookies, SDKs & tracking

• Essential cookies/SDK events operate the site and protect against abuse.

• Performance/analytics (if enabled) help us understand use and improve Aqari.
  Where required, we’ll present a cookie banner/settings so you can manage consent for non-essential cookies on aqari.injazrt.ae. (aqari.injazrt.ae)

11) WhatsApp & remote submissions

If you submit documents or complete Ejari via WhatsApp on Aqari, your messages/files are processed by WhatsApp under its own terms/policies in addition to ours. For your safety, avoid sending full payment card data in chat; we will direct you to approved payment channels where needed. (providentestate.com)

12) Payments

Government and service fees may be paid through Noqodi/Dubai Pay or card channels authorized by DLD. Payment credentials are handled by the payment provider; we keep only required references/receipts for reconciliation. (Dubai Land Department)

13) Security

We implement administrative, technical, and physical controls appropriate for trustee operations (access controls, encryption in transit, role-based permissions, secure document handling, staff training). No method is 100% secure; notify us immediately if you suspect unauthorized access or misuse.

14) Children’s data

Aqari services target adult property stakeholders. We do not knowingly collect children’s data. If you believe a child has provided data, contact us to request deletion unless retention is legally required.

15) Acting for others

If you act for another person or a company (e.g., landlord, tenant, corporate officer or attorney-in-fact), you confirm that you have lawful authority and that information provided is accurate and lawful.

16) Third-party links

Aqari may link to third-party sites/apps (e.g., WhatsApp, Noqodi, DLD portals, social accounts). We are not responsible for their privacy practices; review their policies before sharing data. (aqari.injazrt.ae)

17) Changes to this Policy

We may update this Policy to reflect changes in law, DLD requirements, or our services. Updates will appear here with a new Effective date; if changes are significant, we’ll take additional steps to inform you (e.g., on-site notice).

18) How to contact us / complaints

Questions or requests about privacy: cs@injazrt.ae or aqari@injazrt.ae; phone +971 600 546529 / +971 600 527274; or visit us at Emaar Business Park 3, Ground Floor, Office No. 1, The Greens, Dubai, UAE. You may also have the right to complain to the UAE Data Office under the PDPL. (injazrt.ae)