BrokersLynk — Privacy Notice

Version 1.0 · Effective 23 August 2026

⚠️ DRAFT — NOT YET REVIEWED BY A LAWYER. Written to be specific and honest about what
BrokersLynk actually does with personal information, so a UAE-qualified lawyer can review and
finalise it quickly. It is drafted against UAE Federal Decree-Law No. 45 of 2021 (PDPL).
Do not publish it as a final privacy notice until that review has happened.

1. Why this notice exists

BrokersLynk handles personal information about three different groups of people, and they are

owed different things. This notice says plainly what we hold, why, and what you can ask us to do

about it.

2. Whose information we handle

(a) Brokers who use BrokersLynk. Your name, work email, mobile number, firm, broker licence

details where you give them, and a record of your activity in the service — what you searched,

which contacts you unlocked, and when you signed in.

(b) Property owners and landlords. Where a brokerage's own CRM is connected, we hold the

owner's name and contact number against the property they instructed on. **This information is

never shown to other brokers on the platform.** It is used to contact the owner about their own

property, and to prevent the same owner being contacted repeatedly by different people.

(c) Buyers and tenants (leads). Name, contact number, and what they are looking for —

budget, area, size, bedrooms. Used to match them to suitable property and to give the broker

handling their enquiry what they need to help.

3. Where it comes from

industry groups where brokers publish property to other brokers.

data.

4. Why we handle it, and on what basis

What we doWhyBasis under PDPL
Run your account and sign you inTo provide the service you asked forPerformance of a contract
Match property to requirementsThe core purpose of the servicePerformance of a contract / legitimate interest
Show a broker their counterpart's contactSo a transaction can proceedLegitimate interest of both parties
Detect scraping and automated abuseTo protect the database and the people in itLegitimate interest
Keep records of contact and consentAccountability, and to avoid contacting people repeatedlyLegal obligation / legitimate interest
Send service messagesTo operate your accountPerformance of a contract

Where we rely on legitimate interest, we have considered the effect on the individual. We do

not sell personal information, and we do not use it for advertising.

5. What we deliberately do NOT do

Being explicit, because it matters. These are commitments about the product, stated precisely —

we would rather be accurate than sound better than we are:

for the brokerage that holds the instruction. They remain visible to that brokerage's own

staff, and to our administrators where operating or supporting the service requires it.

identifies a specific person's home, so it is removed from what any other broker receives —

removed entirely, not hidden behind a paywall. It remains visible to the brokerage that

holds the property, and to our administrators as above.

Administrative access is limited to named administrator accounts, and support access to personal

information is logged.

5a. Automated matching, and what it does and does not decide

BrokersLynk scores how well a property fits a requirement and ranks results accordingly. That

scoring is automated, and it affects what a broker is shown first.

It does not make any decision about a person, it does not assess anyone's creditworthiness,

suitability or character, and it produces no legal or similarly significant effect on anyone. A

broker sees the ranking and decides for themselves what to do. If you would like to understand

why a particular property was or was not matched, ask us and we will explain it in plain terms.

6. Who sees it

logged, deliberate action.

Some providers process data outside the UAE. Where that happens we transfer personal

information only to a country the UAE recognises as providing adequate protection, or under a

contract containing the safeguards PDPL requires (Article 23). We will name the current

providers and the mechanism relied on for each on request.

⚠️ For the lawyer: this paragraph must be completed with the actual hosting and processing
providers in use and the specific mechanism relied on for each. It currently states the correct
principle without the specifics, and PDPL expects the specifics.

7. How long we keep it

This is enforced automatically on every data load — expired records are purged from the working

set, not merely hidden. Account

records are kept while the account is open and for a reasonable period afterwards for accounting

and dispute purposes. Contact and consent logs are kept longer, because their purpose is to

prove what happened.

8. How we protect it

Passwords are stored using salted PBKDF2 hashing and are never readable, including by us.

Contact details are hidden by default and released only through a logged, metered action. Access

to administrative functions requires a named administrator account. We monitor for bulk

extraction and automated access and suspend accounts that show it. Data is transmitted over

encrypted connections.

No system is perfectly secure, and we will not claim otherwise.

9. Your rights

Under PDPL you may ask us to:

To exercise any of these, email privacy@brokerslynk.com. We will respond within the period

PDPL requires. There is no charge. If you are not satisfied, you may complain to the UAE Data

Office.

If you are a property owner or a buyer and would rather not be in the system at all, say so

and we will remove you. You do not need an account, and you do not need to explain why.

10. Children

The service is for licensed professionals. We do not knowingly hold information about anyone

under 18.

11. Changes

If we change this notice materially we will tell affected users and, where the law requires it,

ask for fresh consent.

12. Contact

privacy@brokerslynk.com — privacy questions, and any of the requests in section 9.

The person accountable for data protection at BrokersLynk is the company's founder, reachable at

that address. If we are required to appoint a formal Data Protection Officer under PDPL, or to

register with the UAE Data Office, we will do so and update this notice with the details.

⚠️ For the lawyer: please confirm whether BrokersLynk's processing triggers the mandatory
DPO appointment under PDPL Article 10, and whether registration with the UAE Data Office is
required at our scale. Both are left deliberately open here rather than guessed at.

13. If something goes wrong

If personal information we hold is lost or exposed, we will assess it immediately and, where

PDPL requires, notify the UAE Data Office and the people affected without undue delay. We will

tell you what happened, what it means for you, and what we are doing about it — in plain

language, not a legal notice.