Privacy Notice
Summary of how we use your data

What do we do with your information and what is the legal basis for this use? The Forum Group, comprising Forum Group DMCC as well as its affiliates, subsidiaries and related entities like XXII Carat Club Villas ("XXII Carat"), uses your personal information to process and facilitate inquiring, provide you with highly-individualized information about our development or to inform you of our products and services and other purposes as set out in this notice.

Disclosure: Data is shared with companies in the Forum Group, third party service providers and professional advisers that may be located outside the UAE.

Consent: Where we rely on your consent, such as for marketing our products and services to you, use of cookies, and collection and use of your sensitive personal data, you may withdraw this consent at any time.

Cookies: Our site uses cookies to track visitors using our site, analyse trends and usage patterns for research and marketing purposes. You are not obliged to accept cookies. More information is set out in the "Cookies and Web Beacons" section.

Your rights: You have certain rights to your personal information under applicable laws, including a right to object to some of the processing which XXII Carat carries out.

what does this notice cover?

This is the Privacy Notice of XXII Carat. It describes how we will make use of all Personal Information which you provide to us or any of our Forum Group companies.

Please read this page carefully before you start to use this site. If you do not wish to be bound by this Privacy Notice then you should not access this site. Where permitted by law, access of this site by you shall be deemed to be your acceptance of this Privacy Notice and your agreement that we may process and use your personal information in accordance with this Privacy Notice.

If you have any queries regarding this Privacy Notice or complaints about our use of your information please contact us at “” and we will do our best to deal with your complaint or query as soon as possible.

information which we may obtain about you

The types of personal information we may collect and process from you include:

your contact information (e.g. name, telephone number, email address, postal address);

information related to your client profile (address, country of residence, favourite currency…);

subject to your prior and explicit consent as may be required under applicable law

if you contact us or our agents, we may keep a record of that communication and any communications and correspondence with you; and information about your computer, including where available, your IP address, operating system and browser type, for system administration and security reasons and to collect aggregate information. This is statistical data about our users' browsing actions and patterns, and does not identify any individual.

what information about you do we receive from third parties?

Sometimes, we receive information about you from third parties. In particular, we may receive information about you from real estate agents whom you have direct contact.

The information we collect from such third parties include your contact information and information related to your personal profile.

what we do with your information and what is the legal basis for this use?

We may use the personal information you supply to us via our site for the following purposes:

to fulfil your personal contract information;

as required by XXII Carat to conduct our business and pursue our legitimate interests, in particular:

responding to requests which you have submitted via our site and to deal with on-going matters relating to such requests;

presenting content from our site in the way that we consider most effective;

providing you with highly-individualized service at our resorts and presenting you with information relating to XXII Carat;

placing cookies and using similar technologies in accordance with the "Cookies and Similar Technologies" section and the information provided to you when those technologies are used;

on other occasions where we ask you for consent, we will use the data for the purpose which we explain at the time;

for purposes which are required by law, such as:

in response to requests by government or law enforcement authorities conducting an investigation.

Relying on our legitimate interests

We have carried out balancing tests for all the data processing we carry out on the basis of our legitimate interests, which we have described above. You can obtain information on any of our balancing tests by contacting us using the details set out later in this notice.

Withdrawing consent or otherwise objecting to direct marketing/profiling

Wherever we rely on your consent, you will always be able to withdraw that consent, although we may have other legal grounds for processing your data for other purposes, such as those set out above. In some cases, we are able to send you direct marketing without your consent, where we rely on our legitimate interests. You have an absolute right to opt-out of direct marketing, or profiling we carry out for direct marketing, at any time.


transmission of personal information outside UAE

The information you provide to us may be given to our third party service suppliers outside the United Arab Emirates for the purpose of delivering the personalized services and communications stated above. XXII Carat will always take steps to ensure that your information is used by third parties in accordance with this Privacy Notice and that your information is kept secure at all times.

cookies and similar technologies

Our site uses cookies or similar technologies (e.g. web beacons). A "cookie" is a small file of letters and numbers that is sent to your computer by a website and automatically saved on your computer by your web browser (e.g. "Internet Explorer"). Each time you request a page from the website, your web browser sends this cookie back to the website server.

XXII Carat uses the following cookies:

Performance Cookies

These cookies collect information about how visitors use our website, so that we can continually improve our website.

We use cookies provided by Google and Facebook.

Functionality Cookies

These cookies allow our website to remember choices users make (such as user name, or the region users are in) and provide enhanced, more personal features. These cookies can also be used to remember changes users have made to text size, fonts, currency, country of delivery and other parts of web pages that users can customise.

We also use cookies for other functionalities including:

to identify the country for the selection of relevant language and to block the firing of some pixels

to remember the user name, currency, country of delivery, product selection and quantity for the bag

to enable Wordpress, Woocommerce and other plugins functionalities

for use of fonts

for the operation of videos

Social Media Cookies

These cookies are used when users share information using social media accounts. We use Facebook's, Vimeo's and Brightcove's pixels.

Advertising Cookies

These cookies collect information about your browsing habits to deliver advertising to you that is relevant to you and your interests. The cookies we use include Google Ad Services, Google Tag Manager, Facebook.

We may also use the information collected from our use of cookies to estimate our audience size, analyse trends and general usage patterns of our site, optimize our site, and for other research and marketing purposes. This is statistical information and does not identify any individual.

You are not obliged to accept cookies. If you wish, you can set your browser to notify you before you receive a cookie so you have the chance to accept it and you can also set your browser to refuse to receive or send all cookies. The website (run by the Interactive Marketing Bureau) contains step-by-step guidance on how cookies can be switched off by users.

By using our site without disabling cookies via your browser settings you are consenting to our use of cookies and similar technologies as described in this notice.

Please note that our advertisers and third party partners may also use cookies. These parties may use so-called “third party” cookies so that they can track your response to their adverts and/or identify you on any other website that you visit which also contains their adverts. Please refer to their Privacy Notice for further details.

what rights do i have?

In accordance with applicable laws, you may have rights in relation to your personal information. Such rights include:

You have the right to ask us for a copy of your personal information; to correct, delete or restrict (stop any active) processing of your personal information; and to obtain the personal information you provide to us for a contract or with your consent in a structured, machine readable format, and to ask us to share (port) this data to another controller.

In addition, you can object to the processing of your personal information in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement, or where we are using the data for direct marketing (see below "Opting Out").

These rights may be limited, for example if fulfilling your request would reveal personal information about another person, where they would infringe the rights of a third party (including our rights) or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. Relevant exemptions are included in applicable data protection laws. We will inform you of relevant exemptions we rely upon when responding to any request you make.

To exercise any of these rights, or to obtain other information, such as a copy of a legitimate interests balancing test, you can get in touch with us using the details set out below. If you have unresolved concerns, you have the right to complain to an applicable data protection authority where you live, work or where you believe a breach may have occurred.

opting out

If you do not wish to remain on our database and to receive our personalized mailings (electronic or otherwise) or other communications, please note that you may opt out of our database by using the “Unsubscribe” option at the foot of our email communications, or by sending an email to our Data Protection Manager at the following email address:

how long will you retain my data?

Where we process personal information for marketing purposes or with your consent, we process the data until you ask us to stop and for a short period after this (to allow us to implement your requests). We also keep a record of the fact that you have asked us not to send you direct marketing or to process your data so that we can respect your request in future.

Where we process your financial information, we will only keep the information for as long as necessary for the purpose/s for which it is collected and up to two months thereafter.

In relation to all your other personal data including registration data, we will not retain your data for longer than required for the purposes indicated above, and will delete personal data if they are no longer necessary for the purposes for which they are collected or otherwise processed, unless we are required to keep the data to comply with applicable legal obligations.

queries or complaints

If you have any queries or complaints regarding this Privacy Notice or use of your personal information please contact our data protection manager using the contact details set out in the “Opting Out” section above.

UAE representative

If you are in the UAE, XXII Carat representative is Forum Group DMCC, and can be contacted at:

Address: HDS Tower, Office 2509, Jumeirah Lake Towers, POBox 283365, Dubai, UAE

Contact No: +971 4 374 6698

which XXII Carat entity is my data controller, and which affiliates might my data be shared with?

The data controller for your information is Forum Group DMCC.


We may update this Privacy Notice from time to time and we will notify you of any material changes using the email address you have provided upon registration or by an announcement on the site. The changes will apply to the use of the site after such notice. Where permitted by law, if you use the site after the date on which the changes come into effect, you will be deemed to have accepted the new Privacy Notice.

12 November 2019
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