SAPE SPACE — PRIVACY NOTICE

Prepared in accordance with UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data

Last updated: 29 July 2026

1. Who we are
SAPE SPACE (Smart Advisor Property Expert) (“SAPE SPACE”, “we”, “us”, or “our”) refers collectively to the following affiliated commercial real estate brokerage entities operating under the SAPE SPACE brand in the United Arab Emirates, both beneficially owned and managed by Ms. Olga Sapegina:
•SAPE SPACE REAL ESTATE BROKERAGE L.L.C, registered in the Emirate of Dubai under trade licence No. 1423374, issued by the Dubai Department of Economy and Tourism (DET); and
•SAPE SPACE REAL ESTATE BROKERAGE – L.L.C – S.P.C, registered in the Emirate of Abu Dhabi under licence No. CN-6179459, issued by the Abu Dhabi Department of Economic Development through the Abu Dhabi Registration Authority (ADRA).
This Privacy Notice explains how we collect, use, disclose, and protect the personal data of visitors to our website www.sapespace.com, our clients, prospective clients, and other individuals we interact with in the course of our business, in accordance with UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (the “PDPL”) and its Executive Regulations.
This Notice is prepared to reflect the requirements of the PDPL, which applies on a federal basis across the UAE mainland — including the Emirates of Dubai, Abu Dhabi, Ras Al Khaimah, and every other Emirate — in the same manner. For visitors and clients in Ras Al Khaimah, we do not currently operate a separate registered office; enquiries and client relationships are handled through our Dubai office (see Section 14 below). If any part of SAPE SPACE's operations is instead registered within the DIFC (Dubai) or ADGM (Abu Dhabi) free zones, a separate or additional privacy notice may be required under DIFC Law No. 5 of 2020 on Data Protection or the ADGM Data Protection Regulations 2021, as applicable.

2. Scope of this Notice
This Notice applies to personal data we process in connection with our website, property enquiries, client onboarding, marketing communications (including by email, WhatsApp, and Instagram), and any other interactions you have with SAPE SPACE. It does not apply to third-party websites that may be linked from our website, which have their own privacy notices.

3. Personal data we collect
•Identity data: full name, nationality, Emirates ID or passport details, date of birth (where required for client due diligence)
•Contact data: email address, phone number, WhatsApp number, residential or mailing address
•Property and transaction data: property preferences, budget, viewing history, transaction and lease/purchase documentation
•Financial data: proof of funds, source of funds, bank details, where required for a transaction or due diligence
•Communication data: messages exchanged by email, WhatsApp, Instagram direct message, or our website contact form
•Technical data: IP address, browser type and version, device information, cookies and similar tracking technologies used on our website
•Marketing preferences: your choices regarding receiving marketing communications from us

4. How we collect personal dataWe collect personal data: directly from you, such as when you submit an enquiry, contact us by WhatsApp, email, or Instagram, or meet with us in person; automatically, through cookies and similar technologies when you visit our website; from publicly available sources or referral partners; and from government or regulatory bodies, where necessary for compliance purposes (for example, the Dubai Land Department or the Real Estate Regulatory Agency).

5. Purposes and legal bases for processing
•To respond to property enquiries and provide our services to you (performance of a contract, or steps taken at your request prior to entering into a contract)
•To conduct client due diligence and comply with UAE anti-money laundering and counter-terrorist financing regulations applicable to real estate agents (compliance with a legal obligation)
•To market our services to you, including by email, WhatsApp, and social media (based on your consent, which you may withdraw at any time)
•To operate, secure, and improve our website, including through cookies and analytics (based on your consent, or our legitimate interest in operating our business)
•To respond to lawful requests from UAE regulators, courts, or law enforcement authorities (compliance with a legal obligation)
•To protect our legitimate business interests, including preventing fraud and establishing, exercising, or defending legal claims (legitimate interest)

6. Cookies and similar technologies
Our website uses cookies and similar technologies to operate the site, remember your preferences, and, where you consent, to analyse traffic and personalise marketing (including through tools such as Google Ads and the Meta/Instagram Pixel). On your first visit, you will be shown a cookie banner where you can accept or reject non-essential cookies. You may withdraw or change your cookie preferences at any time through our cookie settings tool or your browser settings.

7. Sharing and disclosure of personal data
We may share personal data with: our employees and authorised personnel, on a need-to-know basis; property developers, landlords, buyers, or sellers involved in a transaction to which you are a party; our professional advisers, including lawyers and auditors; UAE regulatory and government authorities, where legally required (for example, the Dubai Land Department, the Real Estate Regulatory Agency, or Dubai Police); and IT and service providers who process personal data on our behalf under written agreements (for example, website hosting, CRM, and email or WhatsApp Business providers). We do not sell personal data to third parties.

8. Cross-border data transfers
Where personal data is transferred outside the UAE, for example to service providers or business partners located abroad, we will ensure appropriate safeguards are in place in accordance with the PDPL, such as verifying that the recipient country provides an adequate level of data protection, or entering into appropriate contractual data transfer safeguards.

9. Data retention
We retain personal data only for as long as necessary for the purposes described in this Notice, including to satisfy applicable legal, accounting, or regulatory requirements (for example, UAE anti-money laundering record-keeping obligations), after which it is securely deleted or anonymised.

10. Data security
We implement appropriate technical and organisational measures designed to protect personal data against unauthorised access, loss, misuse, or alteration, in line with the requirements of the PDPL.

11. Your rights under the PDPL
Subject to applicable exceptions, you have the right to:
•be informed of the processing of your personal data;
•access your personal data held by us;
•obtain a copy of your personal data, or request that it be transferred;
•request correction or completion of inaccurate or incomplete data;
•request erasure of your personal data (right to be forgotten), subject to legal retention requirements;
•restrict our processing of your data in certain circumstances;
•object to our processing of your data, including for direct marketing purposes;
•withdraw your consent at any time, without affecting the lawfulness of processing carried out before withdrawal; and
•lodge a complaint with the UAE Data Office.
To exercise any of these rights, please contact us using the details in Section 14 below.

12. Marketing communications
Where we rely on your consent to send you marketing communications by email, WhatsApp, or Instagram, you may opt out or withdraw your consent at any time by using the unsubscribe link in our communications, replying “STOP”, or contacting us directly, without affecting any other services we provide to you.

13. Children's data
Our services are directed at adults, and we do not knowingly collect personal data from individuals under the age of 18. If you believe we have inadvertently collected personal data from a minor, please contact us so that we can delete it.

14. Contact us
For any questions about this Privacy Notice, or to exercise your rights under the PDPL, please contact us at:
•Dubai office: Control Tower, Office Building, Al Hebiah First, Dubai Motor City, Dubai, UAE — Phone: +971 58 507 66 26 — Email: broker@sapespace.com
•Ras Al Khaimah: served by our Dubai office above (no separate registered office at this time)
•Abu Dhabi office: Al Kawakib Street, Musaffah, 403, Abu Dhabi 20319, UAE — Phone: +971 58 507 66 26 — Email: abudhabi@sapespace.com

15. Changes to this Notice
We may update this Privacy Notice from time to time to reflect changes in our practices or in applicable law. The “Last updated” date at the top of this Notice indicates when it was last revised. We encourage you to review this Notice periodically.