Version of 1 October 2026
This policy explains what data lyukos.com collects about you, why, who it is shared with and how you can control it. We comply with UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (PDPL).
1. Who processes your data
The data controller is the real estate agency 2088 Real Estate, Dubai, UAE.
Address: The Opus by Omniyat, Tower A, office 1006, Al A’amal St, Business Bay, Dubai, UAE.
Legal entity: TWENTY EIGHTY EIGHT REAL ESTATE L.L.C S.O.C, trade licence No. 1528974, RERA registration number (ORN) 52923.
For any question about personal data, write to info@lyukos.com.
2. What data we collect
Data you give us in the consultation request forms and in DXB Radar:
- your name;
- your phone or WhatsApp number;
- your answers in the form: purpose of purchase, budget, area of interest, comment.
Technical data sent automatically:
- IP address, browser and device type;
- the page the request was sent from and where you came to the site from;
- time spent on the page before sending the form (to protect against spam bots).
Analytics and cookie data — only if you agreed in the banner on the site (see section 7).
We do not collect passport or bank card details and never ask for them on the site.
3. Why we use the data
- To contact you about your request and give you a real estate consultation.
- To find options that match your request and answer your questions.
- To protect the site and forms from spam and fraud.
- To understand how people use the site and make it better (only with your consent to analytics).
We do not sell your data or share it with third parties for their own marketing.
4. Legal basis
We process data on the basis of your consent, which you give by sending a form, and your separate consent to cookies and analytics in the banner. The data from a request is also needed to do what you asked for — contact you and advise you. You can withdraw consent at any time (section 8).
5. Who the data is shared with
Only agency staff who handle requests have access to your data. To run the site we use established services:
- Bitrix24 — the customer relationship system (CRM) where requests arrive;
- an automation service that passes the request from the site to the CRM;
- messengers — for internal notifications to staff about a new request and to contact you if you chose WhatsApp or Telegram;
- the hosting provider whose servers run the site;
- Google Analytics, Yandex Metrica and Meta Pixel — only with your consent to analytics.
We may also disclose data if required by UAE law or a request from a government authority.
6. Transfers outside the UAE
Some of these services store data on servers outside the UAE, for example in Europe, the USA or Russia (Yandex Metrica). We transfer data abroad only with your consent and choose services that protect data.
7. Cookies and analytics
Cookies are small files the site stores in your browser.
- Necessary — remember your choice in the cookie banner, the site language and form contents. The site does not work properly without them; no consent is needed.
- Analytics and advertising — Google Analytics, Yandex Metrica (without session recording) and Meta Pixel. They show which pages are read and where visitors come from. These services are switched on only after you click “Accept” in the banner.
You can change your choice at any time: cookie settings. You can also delete cookies in your browser settings.
8. Your rights
You can:
- find out what data we hold about you and get a copy;
- correct inaccurate data;
- ask us to delete your data;
- restrict or object to processing;
- withdraw consent, including to analytics and cookies.
To do this, write to info@lyukos.com. We will reply within 30 days. If you believe your rights have been violated, you can contact the Emirates Data Office, the UAE data protection authority.
9. How long we keep data
We keep request data while we work with you and no longer than 3 years after the last contact, unless UAE law requires a longer period. The site’s technical request log keeps only the last 500 entries. Analytics data is kept according to the rules of each service.
10. Data security
The site runs over secure HTTPS. Logging in to the site’s admin area is protected by a password and two-factor verification, and only responsible staff have access to requests in the CRM.
11. Children
The site is intended for adults. We do not knowingly collect data from anyone under 18.
12. Changes to this policy
We may update this policy. The current version is always on this page, with the update date at the top.
