Privacy Policy

Developer: RAK Ventures LLC

1. Who We Are and Scope

This Privacy Policy explains how RAK Ventures LLC (“we”, “our” or “us”), as the developer of Ritz‑Carlton Residences Al Wadi, collects, uses, discloses and protects personal data when you visit or interact with this website (the “Website”) and when you enquire about, reserve or purchase a residence in the development (each a “Residence”).

This Policy applies to visitors and users of the Website, including individuals who submit property enquiries, request brochures, contact the sales team or submit broker registrations and client introductions, and to prospective purchasers, purchasers and their authorised representatives, whether we deal with them through the Website, at our sales gallery or sales events, or otherwise in the course of the sale of a Residence.

The Ritz‑Carlton Residences, Ras Al Khaimah, Al Wadi Desert are not owned, developed or sold by The Ritz‑Carlton Hotel Company, L.L.C. or its affiliates ("Ritz‑Carlton"). Ras Al Khaimah Al Wadi LLC uses The Ritz‑Carlton marks under a license from Ritz‑Carlton, which has not confirmed the accuracy of any of the statements or representations made herein.

If you reserve or purchase a Residence, the reservation, sale and purchase and related documentation may contain further provisions on the use of your personal data, which will apply in addition to this Policy.

We process personal data in accordance with applicable laws and regulations in the United Arab Emirates, including Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data, as applicable.

2. What Data We Collect

We may collect the following categories of personal data:

Information you provide: Name, email address, telephone number, company or brokerage details, and information submitted through enquiry forms, brochure requests, broker registrations or other correspondence.
Property and sales enquiry information: Your stated interests in the residences, preferences and other information you choose to provide when communicating with our sales representatives.
Identity and verification information: Copies of passports, Emirates ID, residence visas or other identity documents, date of birth, nationality and residential address and, for purchasers that are companies or other entities, constitutional documents and details of directors, shareholders, beneficial owners and authorised signatories.
Purchase and payment information: Details of the Residence reserved or purchased, reservation and sale and purchase documentation, payment plans and payment records, bank account details for payments and refunds, information on source of funds and source of wealth, mortgage or other financing arrangements, and information required to register the sale.
Compliance and screening information: The results of sanctions, politically exposed person and adverse media screening, and other information we are required to obtain under applicable anti-money laundering and counter-terrorist financing laws.
Handover and ownership information: Information relating to the handover of your Residence and any defects or snagging matters and, following completion, to residential services, owners’ association and community management matters.
Technical and usage data: IP address, device and browser type, pages visited, access dates and times, referring URLs, general location derived from your IP address and similar technical identifiers.
Cookie and tracking data: Information collected through cookies and similar technologies, as described in Section 6.

Please avoid submitting sensitive personal information unless specifically requested and there is a lawful basis to collect it. Certain information collected for identity verification and compliance screening may include, or reveal, sensitive personal data, in which case we will process it only to the extent required or permitted by applicable law.

3. How We Obtain Your Data

We may obtain personal data through:

Direct interactions: When you submit a property enquiry, request a brochure, contact our sales team, visit our sales gallery or attend a sales event, reserve or purchase a Residence, register as a broker or otherwise communicate with us.
Automated means: Through cookies, server logs, analytics and similar technologies used to operate, maintain and secure the Website.
Third-party and public sources: Identity verification and screening providers, sanctions lists and other publicly available sources, banks and mortgage lenders, and competent government authorities in connection with the registration of your purchase.
Authorised representatives and service providers: Where relevant, information may be provided by sales representatives, brokers and authorised agencies, any joint purchaser or person holding a power of attorney on your behalf, or service providers assisting with your enquiry or purchase, subject to applicable law.

4. Our Lawful Bases for Processing

We process personal data only where a lawful basis applies. Depending on the activity, this may include:

Consent: For marketing communications and non-essential cookies where consent is required.
Legitimate interests: To respond to enquiries, manage sales-related communications, maintain the Website, improve user experience and protect our systems, where permitted by applicable law.
Contractual necessity: Where processing is necessary for steps requested by you before entering into a reservation, sale and purchase or other agreement relating to a Residence, or for performing such an agreement, including managing payments, registration and handover.
Legal obligations: To comply with applicable laws, regulatory requirements (including identity verification, anti-money laundering and counter-terrorist financing requirements and the registration of real estate transactions) and lawful requests from competent authorities.

Where consent is required, you may withdraw it at any time, subject to applicable law.

5. Purposes of Use

We may use personal data to:

Respond to property enquiries and requests for brochures or further information.
Facilitate communications with authorised sales representatives.
Manage broker registrations and client introductions.
Process reservations and sales of Residences, including preparing and administering reservation and sale and purchase agreements, managing payment plans and processing refunds where applicable.
Carry out identity verification, due diligence and screening, and meet our anti-money laundering, counter-terrorist financing and regulatory reporting obligations.
Register sales and related interests with the competent authorities in Ras Al Khaimah and administer escrow arrangements, where applicable.
Provide construction progress updates and manage handover, snagging and defects matters.
Following completion, facilitate the provision of residential services and any associated owner programmes under the Ritz‑Carlton brand, and the administration of owners’ association and community management arrangements.
Provide information about Ritz‑Carlton Residences Al Wadi and related project updates.
Operate, maintain, secure and improve the Website.
Measure Website performance and understand visitor interactions, subject to applicable cookie and privacy requirements.
Comply with legal obligations and establish, exercise or defend legal claims.

Where marketing communications are sent, we will comply with applicable consent and opt-out requirements.

6. Cookies and Similar Technologies

We may use cookies and similar technologies to maintain Website functionality, remember preferences, measure performance and improve the visitor experience.

Strictly necessary cookies may operate without consent where permitted by law. Analytics, advertising and other non-essential cookies will be activated only after consent where required. For visitors in the EU/EEA and other jurisdictions requiring prior consent, applicable consent requirements will be followed.

You can accept, reject or customise cookie categories through the Website's cookie banner and preferences centre, where available. You may also block or delete cookies through your browser settings. Disabling certain cookies may affect Website functionality.

Further details about the cookies used, their purposes and retention periods should be provided in the Website's cookie settings or a separate Cookie Policy, where applicable.

7. Disclosure of Your Data

We may share personal data, where necessary and lawful, with:

Authorised sales representatives, brokers and agencies involved in responding to your enquiry or your purchase.
Our affiliated or group entities, where relevant to the operation of the project.
Website hosting, security, analytics, customer relationship management, identity verification and screening and other service providers acting on our behalf.
Professional advisers, auditors and legal representatives.
Banks, escrow agents and mortgage lenders involved in the payment for, or financing of, your purchase.
Following completion, the operator of the residential services, the owners’ association and its appointed managers, and facilities management providers.
Government authorities, courts or regulators where required by law, including the competent property registration authorities in Ras Al Khaimah and the authorities responsible for anti-money laundering reporting.

As the Residences are branded under licence from The Ritz‑Carlton, we may share limited personal data of purchasers (such as contact details and details of the Residence purchased) with The Ritz‑Carlton Hotel Company, L.L.C., Marriott International, Inc. and their respective affiliates where required for brand compliance purposes, the provision of residential services and any associated owner programmes, and the onboarding of owners. Where those entities process personal data for their own purposes, they do so as independent controllers and in accordance with their own privacy statements.

Service providers receiving personal data will be subject to appropriate contractual and confidentiality obligations, where applicable.

8. International Transfers and Storage Location

Personal data may be stored in the United Arab Emirates or in other jurisdictions where our authorised service providers or systems operate, or where the brand-related entities referred to in Section 7 are located.

Where personal data is transferred outside the UAE, we will implement the transfer mechanisms and safeguards required under applicable law.

Further details regarding the locations of relevant service providers and any international transfers may be provided upon request, subject to applicable law.

9. Security

We implement appropriate technical and organisational measures designed to protect personal data against unauthorised access, use, disclosure, alteration, loss or destruction.

Although we take reasonable steps to safeguard information, no method of electronic transmission or storage can be guaranteed to be completely secure.

10. Data Retention

We retain personal data only for as long as necessary to fulfil the purposes described in this Policy, comply with applicable legal or regulatory requirements, manage relevant business records and resolve disputes.

Retention periods may vary depending on the type of information, the nature of the enquiry and applicable legal obligations. Where appropriate, information may be anonymised or pseudonymised for analytical or statistical purposes.

Records relating to the reservation or purchase of a Residence, including identity verification and due diligence records, will be retained for the periods required under applicable anti-money laundering and real estate laws, which will generally be not less than five years following completion of the transaction or the end of our business relationship with you.

11. Your Rights

Subject to applicable law, you may have the right to:

Request access to your personal data.
Request correction or updating of inaccurate information.
Request erasure of personal data in applicable circumstances.
Request restriction of, or object to, certain processing activities.
Request transfer of your personal data where a right to data portability applies.
Withdraw consent where processing is based on consent.
Exercise any applicable rights concerning automated processing.

To exercise your rights, please contact us using the details in Section 12. We may need to verify your identity before responding.

Certain rights may be limited where we are required to retain or process personal data to comply with our legal obligations, including anti-money laundering requirements, or to perform an agreement relating to a Residence.

You may also lodge a complaint with the competent UAE authority where permitted by applicable law.

12. Contact Us

For privacy-related enquiries or to exercise your data protection rights, please contact:

Data controller / relevant entity: RAK Ventures LLCEmail: legal@marjan.aePlease use “Privacy” as the subject line of your email.

13. Changes to This Policy

We may update this Privacy Policy from time to time to reflect legal, technical or business developments. The updated version will be published on the Website with a revised “Last updated” date where appropriate.

Where required by applicable law, we will notify users or obtain consent for material changes.