Diwine Liviing Realty L.L.C, trading as Divine LiWing (“Company”, “We”, “Us”), is committed to protecting and respecting the privacy of every individual who interacts with us. This Privacy Policy explains how we collect, use, store, disclose, and safeguard your personal information when you visit www.divineliwing.com, submit an enquiry, engage with our Meta advertising campaigns, contact us via WhatsApp, or use any of our real estate services. This Privacy Policy is prepared in full compliance with UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (PDPL) and the regulatory framework of the Dubai Land Department (DLD) and RERA. By using our Website or services, you consent to the practices described herein.
1. Who We Are — Legal Identity
The data controller for personal information collected through this Website and our services is: Legal Company Name: DIWINE LIVIING REALTY L.L.C Trading Name: Divine LiWing Trade License No.: 1606521 Commercial Register No.: 2819569 DCCI Membership No.: 676167 Licensed Activity: Real Estate Buying & Selling Brokerage Owner / Manager: Tushar Sunil Bajpai Registered Address: Office 3205, Citadel Tower, Marasi Drive, Business Bay, Dubai, UAE Data Contact Email: divineliving@gmail.com Phone: +971 50 411 5746 | +971 50 352 7485
2. Information We Collect
We collect personal information only when necessary to provide our services or respond to your enquiries. 2.1 Information You Provide Directly
- Full name, email address, and phone / WhatsApp number
- Country of residence and nationality
- Investment budget and property preferences
- Property requirements (type, location, purpose — investment or own use)
- Any other information voluntarily shared via forms, email, or WhatsApp
2.2 Information Collected via Meta Lead Generation Campaigns When you submit your details through our Meta (Facebook or Instagram) lead generation ads, we receive the name, email address, and phone number you provide. By submitting a Meta lead form, you expressly consent to Divine LiWing contacting you via phone, WhatsApp, email, or SMS in relation to your enquiry. 2.3 Information Collected Automatically
- IP address and approximate geographic location
- Browser type, version, and device type
- Pages visited, time on page, and referring URL
- Cookies and tracking technologies (see Section 7)
2.4 Information from Third-Party Platforms We may receive information from Meta (Facebook/Instagram), Google Ads, WhatsApp Business API, and developer portals where you have expressed interest in a property. All such data is processed in accordance with this Privacy Policy.
3. How We Use Your Information
3.1 Service Delivery
- To respond to property enquiries and provide relevant listings
- To schedule viewings, property tours, and consultations
- To process and facilitate property transactions
- To provide investment advisory, market analysis, and due diligence support
- To arrange and communicate the Divine Energy Certificate assessment
- To assist with UAE investor visa enquiries related to property investment
3.2 Communication and Marketing
- To send relevant property listings, market updates, and investment opportunities
- To notify you of new developments, off-plan launches, and promotions
- To respond to your questions, comments, or complaints
- To send periodic newsletters (you may unsubscribe at any time)
3.3 Legal and Regulatory Compliance
- To comply with UAE law, DLD, RERA, and DET regulations
- To verify identity for Anti-Money Laundering (AML) compliance under UAE Federal Law No. (1) of 2004
- To maintain records as required by law and RERA
- To enforce our Terms and Conditions and legal rights
3.4 Website and Campaign Improvement
- To analyse website usage and improve user experience
- To monitor the performance of digital marketing campaigns including Meta Ads
- To detect and prevent fraud, security breaches, or technical issues
4. Legal Basis for Processing
Under UAE Federal Decree-Law No. 45 of 2021 (PDPL), we process your personal data on the following legal bases:
- Consent — where you have given us explicit consent (e.g., submitting a lead form, opting into marketing)
- Contractual necessity — where processing is necessary to fulfil a service agreement or pre-contractual steps
- Legal obligation — where we are required to process data to comply with UAE law, AML, DLD, or RERA requirements
- Legitimate interests — where processing is necessary for our legitimate business interests, provided these are not overridden by your rights
You have the right to withdraw your consent at any time by emailing divineliving@gmail.com. Withdrawal does not affect the lawfulness of processing carried out prior to withdrawal.
5. Sharing Your Personal Information
Diwine Liviing Realty L.L.C does not sell, rent, or trade your personal data to third parties for commercial purposes. We may share your information only in the following limited circumstances: 5.1 Property Developers and Landlords Where you have expressed interest in a specific property or development, we may share your contact details with the relevant developer or landlord solely to progress your enquiry. Such sharing is done with your knowledge and for the direct fulfilment of your request. 5.2 Trusted Service Providers
- CRM and property management platforms
- Email and WhatsApp marketing platforms
- Meta Business Manager (for lead generation campaign management)
- Cloud storage and data hosting providers
- Website analytics providers (e.g., Google Analytics)
All service providers are contractually required to maintain confidentiality and use your data only for the purposes specified by us. 5.3 Legal and Regulatory Authorities We may disclose your information to the Dubai Land Department (DLD), RERA, Department of Economy and Tourism (DET), law enforcement agencies, or courts where required by UAE law, court order, or regulatory obligation including AML compliance. 5.4 Business Transfers In the event of a merger, acquisition, or sale of all or part of our business, your personal data may be transferred to the acquiring entity, subject to this Privacy Policy continuing to apply.
6. Data Retention
We retain your personal information only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable UAE law:
- Enquiry and lead data: up to 3 years from last contact (unless earlier deletion is requested)
- Transaction and contract records: up to 10 years as required by UAE commercial and property law
- Marketing consent records: until consent is withdrawn or 3 years from last interaction
- Website analytics data: up to 26 months
- AML / KYC verification records: minimum 5 years as required by UAE AML law
When your data is no longer required, we will securely delete or anonymise it in accordance with our data retention schedule.
7. Cookies and Tracking Technologies
Our Website uses cookies and similar tracking technologies to enhance your browsing experience and analyse how our site is used.
- Essential Cookies — Necessary for the Website to function. Cannot be disabled.
- Analytics Cookies — Help us understand visitor behaviour (e.g., Google Analytics). Data is aggregated and anonymous.
- Marketing Cookies — Used to deliver relevant advertisements including through the Meta Pixel. These track activity across websites.
- Preference Cookies — Remember your settings and preferences.
You may control cookies through your browser settings. Disabling certain cookies may affect Website functionality. To opt out of Facebook advertising, visit: www.facebook.com/help/568137493302217
8. Meta Pixel and Digital Advertising
We use the Meta Pixel on our Website to measure the effectiveness of our advertising and to understand actions taken on our Website after viewing a Meta (Facebook/Instagram) advertisement. The Meta Pixel may collect pages visited, actions taken (e.g., form submissions), device information, and IP address (anonymised where possible). This data is processed by Meta Platforms, Inc. in accordance with Meta’s Data Policy (www.facebook.com/privacy/policy). Divine LiWing and Meta are joint data controllers for data collected via the Meta Pixel. You may opt out via your Facebook Ad Preferences at www.facebook.com/settings?tab=ads or via www.aboutads.info.
9. Your Rights Under UAE PDPL
Under UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data, you have the following rights:
- Right of Access — Request a copy of the personal data we hold about you
- Right to Rectification — Request correction of inaccurate or incomplete data
- Right to Erasure — Request deletion of your personal data (subject to legal retention obligations)
- Right to Restriction — Request restriction of processing in certain circumstances
- Right to Data Portability — Receive your data in a structured, machine-readable format
- Right to Object — Object to processing for marketing purposes at any time
- Right to Withdraw Consent — Withdraw consent at any time without affecting prior lawful processing
To exercise any of these rights, please contact us at divineliving@gmail.com. We will respond within 30 calendar days. We may need to verify your identity before processing your request.
10. Data Security
Diwine Liviing Realty L.L.C implements appropriate technical and organisational measures to protect your personal information, including:
- Encrypted data transmission (SSL/TLS)
- Access controls limiting data access to authorised personnel only
- Regular review of data handling and security practices
- Secure deletion of data when retention periods expire
In the event of a personal data breach likely to result in a risk to your rights, we will notify the UAE Data Office and affected individuals as required by applicable UAE PDPL.
11. International Data Transfers
Your data is primarily processed and stored within the UAE. However, some service providers and platforms (including Meta, Google, and cloud storage providers) may process data outside the UAE. Where we transfer personal data outside the UAE, we ensure appropriate safeguards are in place in accordance with UAE PDPL requirements, including contractual protections and adequacy verification.
12. WhatsApp Communications
Divine LiWing uses WhatsApp Business as a primary communication channel. When you contact us via WhatsApp, your phone number and shared information will be used solely to respond to your enquiry. WhatsApp communications are subject to WhatsApp’s own Privacy Policy (www.whatsapp.com/legal/privacy-policy). You may opt out of WhatsApp communications from Divine LiWing at any time by informing us directly.
13. Children’s Privacy
Our Website and services are not directed at individuals under the age of 18. We do not knowingly collect personal information from children. If you believe your child has provided us with personal information, please contact us immediately at divineliving@gmail.com and we will take immediate steps to delete such data.
14. Changes to This Privacy Policy
Diwine Liviing Realty L.L.C reserves the right to update this Privacy Policy at any time to reflect changes in our practices, legal requirements, or regulatory guidance. The “Last Updated” date will be revised accordingly. Your continued use of our Website or services after any update constitutes your acceptance of the revised Privacy Policy.
15. Contact Us and Data Complaints
For all data privacy enquiries, subject access requests, or complaints: Company: DIWINE LIVIING REALTY L.L.C (Trading as Divine LiWing) Address: Office 3205, Citadel Tower, Marasi Drive, Business Bay, Dubai, UAE Trade License No.: 1606521 — Department of Economy & Tourism, Dubai Email: divineliving@gmail.com Phone: +971 50 411 5746 | +971 50 352 7485