PRIVACY POLICY

Last Updated: September 14, 2026

This Privacy Policy ("Policy") governs the collection, processing, use, disclosure, and protection of personal data by Wide Wings Consultancy DMCC ("Company", "we", "us", or "our"), a company duly incorporated and operating under the laws of the United Arab Emirates (Dubai Multi Commodities Centre), holding commercial license number DMCC-870296, with its registered office at:

Unit No: BA1151, DMCC Business Centre, Level No 1, Jewellery & Gemplex 3, Dubai, United Arab Emirates.

The Company operates the Premier International Real Estate Investors Association (PIREIA) website and platform ("Platform"). All commercial information services, institutional networking, promotional events, and investor outreach campaigns provided via the Platform are strictly rendered in accordance with the Company’s registered business activity: Commercial Information Services.

By accessing, browsing, or using our Platform, registering for events, or subscribing to our information services, you ("User", "you", or "your") acknowledge that you have read, understood, and agreed to the practices described in this Policy.

1. LEGAL BASIS AND COMPLIANCE STATEMENT

1.1. Regulatory Framework: This Policy is drafted in strict compliance with the UAE Federal Decree-Law No. 45 of 2021 on Personal Data Protection ("UAE Data Protection Law"), the rules and regulations of the Dubai Multi Commodities Centre (DMCC), and, where applicable to international users, the General Data Protection Regulation (EU) 2016/679 ("GDPR").

1.2. Commercial License Boundaries: Wide Wings Consultancy DMCC operates as a provider of Commercial Information Services. The Company does not operate as a financial institution, broker-dealer, investment advisor, or asset manager. Personal data collected is strictly utilized to deliver information services, conduct market research, facilitate business introductions, and manage association activities.

2. CATEGORIES OF DATA WE COLLECT

We collect information that identifies, relates to, describes, or is reasonably capable of being associated with you ("Personal Data").

2.1. Information You Provide Voluntarily:

• Identity Data: Full name, title, professional designation, corporate affiliation, passport/ID details (where required for VIP event accreditation or compliance verification).
• Contact Data: Email address, telephone number, mailing address, country of residence, corporate address.
• Professional & Investor Profile Data: Investor accreditation status, area of interest (e.g., residential, commercial real estate, debt/equity deals), typical investment ticket size, and geographic preferences (e.g., Central Asia, MENA, South Asia).
• Communication Data: Inquiries submitted via forms, correspondence records, event registration details, feedback, and survey responses.

2.2. Information Collected Automatically:

• Technical Data: IP address, browser type and version, time zone setting, operating system, device identifiers.
• Usage Data: Uniform Resource Locators (URL) clickstream to, through, and from our Platform; pages viewed; page response times; interaction data (scrolling, clicks, and mouse-overs).

3. PURPOSES OF DATA PROCESSING

We process your Personal Data for the following lawful business purposes:

• Service Delivery: Providing access to association resources, market analytics, information digests, pitch sessions, webinars, and commercial updates.
• Event Management: Organizing and executing offline events, VIP dinners, investor breakfasts, and regional roadshows.
• Lead Qualification & Business Matching: Facilitating connections between accredited investors, wealth managers, and real estate issuers/developers within the scope of Commercial Information Services.
• Communications: Responding to inquiries, delivering contractual documentation, sending corporate newsletters, and providing legal or policy updates.
• Legal & Regulatory Compliance: Fulfilling obligations under UAE laws, combating financial crimes, and verifying compliance for access to high-ticket deal information.
• Platform Optimization: Enhancing website functionality, security, performance, and user experience.

4. LEGAL GROUNDS FOR PROCESSING

We rely on the following legal bases for processing your Personal Data:

• Consent: You have given explicit consent for us to process your Personal Data for specific purposes (e.g., subscribing to newsletters or registering for roadshows).
• Contractual Necessity: Processing is necessary for the performance of an agreement to which you are a party or to take steps at your request prior to entering into an agreement.
• Legitimate Interests: Processing is necessary for our legitimate business interests, such as advancing cross-border investor networking and refining our commercial information offerings, provided your fundamental rights do not override those interests.
• Legal Obligation: Processing is required to comply with applicable statutory laws, regulatory frameworks, or lawful court orders in the UAE.

5. DISCLOSURE AND SHARING OF PERSONAL DATA

We treat your Personal Data with strict confidentiality. We do not sell, rent, or trade your Personal Data to third-party marketing companies. We may share your data only under the following circumstances:

5.1. Authorized Partners & Issuers: Where explicitly requested or consented to by you (e.g., opting in to receive project information), we may share your contact and professional profile data with real estate developers, institutional issuers, or wealth managers participating in the PIREIA ecosystem.

5.2. Service Providers: Trusted third-party vendors operating under strict confidentiality agreements who perform technical infrastructure, CRM, email delivery, event hosting, or database management services on our behalf (e.g., Unisender, cloud hosts).

5.3. Corporate Restructuring: In the event of a merger, acquisition, reorganization, or sale of company assets, your Personal Data may be transferred to the acquiring entity.

5.4. Legal & Regulatory Mandates: When required by law enforcement, judicial authorities, or government bodies (including DMCC authorities or UAE federal ministries) to comply with statutory requirements.

6. CROSS-BORDER DATA TRANSFERS

As Wide Wings Consultancy DMCC operates across international capital corridors (including Central Asia, MENA, and South Asia), your Personal Data may be transferred to and processed in countries outside your country of residence.

We ensure that all cross-border data transfers comply with applicable data protection laws. Transfers outside the UAE or EEA are protected through appropriate safeguards, such as Standard Contractual Clauses (SCCs), data protection agreements, or transferring data to jurisdictions recognized as providing an adequate level of data protection.

7. DATA SECURITY

7.1. Security Measures: We implement robust technical, administrative, and physical security safeguards to protect your Personal Data against unauthorized access, loss, alteration, disclosure, or destruction. These measures include data encryption, firewalls, secure socket layer (SSL) protocols, access restrictions, and periodic security audits.

7.2. Incident Response: In the unlikely event of a personal data breach, we maintain an incident response protocol to mitigate risks, notify affected individuals, and inform relevant regulatory authorities where required by law.

8. DATA RETENTION

We retain your Personal Data only for as long as necessary to fulfill the purposes for which it was collected, including satisfying any legal, accounting, reporting, or audit requirements. To determine the appropriate retention period, we consider the volume, nature, and sensitivity of the data, the potential risk of harm from unauthorized use, and applicable legal retention periods under UAE law.

9. YOUR LEGAL RIGHTS

Depending on your jurisdiction, you may hold the following rights regarding your Personal Data:

• Right to Access: Request confirmation of whether we process your data and obtain a copy of your Personal Data.
• Right to Rectification: Request correction of inaccurate or incomplete Personal Data.
• Right to Erasure ("Right to be Forgotten"): Request deletion of your Personal Data where legal conditions are met.
• Right to Restrict Processing: Request restriction of processing under specific circumstances.
• Right to Data Portability: Request transfer of your data to another controller in a structured, machine-readable format.
• Right to Object: Object to processing based on legitimate interests or direct marketing purposes.
• Right to Withdraw Consent: Withdraw previously granted consent at any time without affecting the lawfulness of processing based on consent prior to withdrawal.

To exercise any of these rights, please contact our Data Protection Officer at privacy@pireia.com.

10. COOKIES AND TRACKING TECHNOLOGIES

The Platform uses cookies, web beacons, and analytical tools to distinguish you from other users, monitor traffic patterns, and optimize site performance. You can manage or disable cookies through your browser settings. However, disabling certain cookies may limit your ability to access specific features of the Platform.

11. THIRD-PARTY LINKS

The Platform may contain links to third-party websites, plug-ins, or applications. Clicking on those links may allow third parties to collect or share data about you. Wide Wings Consultancy DMCC does not control these third-party websites and is not responsible for their privacy statements or data handling practices.

12. AMENDMENTS TO THIS POLICY

We reserve the right to modify or update this Privacy Policy at any time to reflect changes in regulatory mandates, technology, or operational practices. Any updates will be posted on this page with a revised "Last Updated" date. We encourage you to review this Policy periodically.

13. CONTACT INFORMATION & DATA PROTECTION INQUIRIES

If you have questions, concerns, complaints, or wish to exercise your data protection rights, please direct your communication to:

Wide Wings Consultancy DMCC

Attn: Legal & Data Protection Department

Unit No: BA1151, DMCC Business Centre, Level No 1

Jewellery & Gemplex 3, Dubai, United Arab Emirates

Commercial License No: DMCC-870296

Licensed Activity: Commercial Information Services

Email: info@pireia.com

Website: www.pireia.com