Privacy Policy
What Data is Collected?
Totality Real Estate LLC ("Company") collects various types of personal data necessary for providing our services and maintaining business relationships. The data collected includes:
Personal Information: Names, correspondence addresses, telephone numbers, and email addresses.
Identifiers: Date and place of birth, gender, nationality, and other similar information.
Corporate Details: Information about owners, directors, shareholders, beneficiaries, and counterparties.
Financial Information: Bank account details, including debit/credit card information required for transactions.
Tax Information: Details related to taxation.
Employment Data: Information on income, salary, occupation, and employment status.
Identification Documents: Specimen signatures, copies of Passports, Emirates IDs, or other identification documents.
Proof of Address: Copies of documents such as utility bills.
Compliance Information: Data required to comply with Anti-Money Laundering (AML) regulations and for conducting Customer Due Diligence (CDD).
Other Information: Any additional details or documents necessary for establishing a business relationship or providing agreed-upon services.
Personal information is collected directly from the individual through communication and interactions on our website.
How is the Data Used?
The Company uses personal data to facilitate our services and conduct routine business operations. The data may be used for the following purposes:
Client Relations: To manage and enhance relationships with clients, including representatives and beneficial owners.
Legal Compliance: To process data as required by regulatory obligations, such as AML laws.
Supplier Management: To handle relationships with suppliers and service providers.
Event Participation: For those who attend our events or subscribe to newsletters.
Employment: To manage current, past, or prospective employees, including shareholders and senior management.
Professional Networking: To maintain business connections, such as those established through exchanging business cards.
Legal Basis for Using the Data
The Company processes data based on legitimate business interests, legal obligations, and, where necessary, the consent of the data subject. The primary purposes for processing include:
Business Management: Overseeing and improving business relationships, conducting business development, and analyzing activities.
Legal Protection: Establishing, exercising, or defending legal claims and safeguarding the Company’s rights and assets.
Communication: Direct communication or through partners for customer service, updates, marketing, and promotional activities.
Service Quality: Investigating and resolving issues, maintaining service quality, and training personnel.
Compliance: Adhering to legal requirements, including AML measures, and reporting to regulatory bodies.
Internal Operations: Managing tasks such as bookkeeping, auditing, and regulatory reporting.
Personal data is used only for the purposes it was collected unless required for another purpose under applicable laws. If needed for an unrelated purpose, the Company will inform the concerned parties and provide the legal basis for such use.
Consent is sought for processing personal data in specific instances, and individuals have the right to withdraw consent at any time. However, any processing conducted before the withdrawal remains valid. In some cases, processing may be necessary to perform tasks in the public interest, such as crime prevention, which does not require consent.
Involvement of Third Parties
The Company may share personal data with third parties or within the organization when necessary to fulfill service engagements or for legal reasons. The Company does not sell personal data under any circumstances.
When third parties are involved, they must comply with the Company’s Data Privacy and Protection Policies. Consent will be obtained where required by law before sharing data with third parties.
Data Security
The Company implements appropriate technical, organizational, and security measures to protect personal data from accidental loss, unauthorized access, use, alteration, or disclosure. This is outlined in the Company’s Data Protection Policy.
Access to personal data is restricted to authorized employees, agents, or third parties involved in service delivery or business management, all of whom are bound by confidentiality obligations.
Personal data is retained only for as long as necessary to fulfill the purpose for which it was collected, including legal and reporting requirements. Once the data is no longer needed, it will be securely deleted, archived, or anonymized to prevent unauthorized use.
The Company also has procedures in place to address potential breaches of data privacy and protection standards.
How to Raise Data Privacy Concerns
If you have any concerns, complaints, or general inquiries regarding your personal data, please contact our Data Protection Officer by emailing legal@totalityestates.com. All requests will be handled in accordance with the Company’s Data Protection Policy.