Effective date: 30 MAY 2026 Last updated: 30 JUNE 2026

This Privacy Policy explains how this website, rafayameen.com ("the Site"), collects, uses, discloses and protects your personal data when you visit the Site, contact Rafay Ameen, or subscribe to updates and content.

The Site is operated by [Rafay Ameen / full registered legal entity, e.g. Mineola Real Estate LLC] ("we", "us" or "our"), with a registered address at [registered address]. Real estate advisory services are provided through mineola; where your enquiry leads to an advisory engagement, the additional handling described in Section 9 also applies.

Because we operate across the United Arab Emirates, Canada and the European Union, this policy is designed to meet the requirements of:

• the EU General Data Protection Regulation (Regulation (EU) 2016/679) ("GDPR") and applicable national laws, including in France;
• Canada's Personal Information Protection and Electronic Documents Act ("PIPEDA") and applicable provincial laws, including Québec's Law 25; and
• the UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data ("PDPL") and its Executive Regulations.

Where the laws of more than one jurisdiction apply to you, we apply the protections most favourable to you.

Rafay Ameen is the founder of mineola, a boutique real estate advisory operating across Abu Dhabi and Dubai, with satellite offices in Toronto, Miami and Lyon. This Site is the personal platform through which he publishes market analysis and educational content and through which you can get in touch.

For any privacy question, request or complaint, contact us at:

• Email: AMEEN@APTC-UAE.COM
• Postal address: 1907 REGAL TOWER-BUSINESS BAY-DUBAI UAE
• Data protection contact / Data Protection Officer (where appointed): RAFAY AMEEN

If we are required to appoint a representative or Data Protection Officer under any applicable law, their details are set out above.

Depending on how you interact with the Site, we may collect:

Information you give us directly

• Identity and contact details: name, email address, phone number, and country of residence.
• Enquiry information: the content of messages you send through contact forms, email, WhatsApp or social media, including any property interests, budget, timelines or intended use you choose to share.
• Subscription information: the email address and preferences you provide when you sign up for newsletters, content or updates.

Information we collect automatically

• Technical and usage data: IP address, device and browser type, pages viewed, referring URLs, and interactions with the Site, collected via cookies and similar technologies (see Section 5).

Information from third parties

• Information from analytics, advertising and social-media platforms (such as Instagram), and from referral partners, where lawful.

If your enquiry progresses into an advisory engagement with mineola, we may then collect identity-verification and compliance information required by anti-money-laundering law (see Section 9). We collect sensitive / special-category personal data only where necessary and permitted by law.

We use personal data to:

• respond to your enquiries and messages;
• send you newsletters, market analysis and educational content you have asked for or are entitled to receive (see Section 6);
• operate, secure and improve the Site and understand how it is used;
• where relevant, begin steps toward an advisory engagement provided through mineola;
• comply with our legal, regulatory and tax obligations; and
• establish, exercise or defend legal claims.

For individuals in the EU/EEA (GDPR) and in the UAE (PDPL), we rely on one or more of the following:

PurposeLegal basisResponding to enquiries and taking steps at your requestPerformance of a contract, or pre-contractual steps at your requestNewsletters, content and marketingYour consent, and/or our legitimate interests (where permitted), which you can object to at any timeOperating, securing and improving the Site; analyticsYour consent (for non-essential cookies) and/or our legitimate interestsIdentity verification and AML record-keeping (where an engagement proceeds)Compliance with a legal obligationMeeting tax, accounting and regulatory dutiesCompliance with a legal obligation 

Where we rely on consent, you may withdraw it at any time without affecting the lawfulness of processing carried out before withdrawal.

For individuals in Canada (PIPEDA / Law 25), we collect, use and disclose personal information with your consent (express or implied, depending on the sensitivity of the information and the circumstances), or as otherwise permitted or required by law.

We use cookies and similar technologies to operate the Site, remember your preferences, measure traffic and, where you allow it, support marketing.

Where required by law (including in the EU/EEA and Québec), we ask for your consent before placing non-essential cookies, and you can manage your choices through our cookie banner or your browser settings. Strictly necessary cookies do not require consent. For details of the specific cookies we use, see our [Cookie Policy / cookie settings].

With your consent or where otherwise permitted by law, we may send you newsletters, market insights and educational content by email, WhatsApp or other channels.

You can opt out at any time by using the unsubscribe link in our emails, replying "STOP" to messages, or contacting us. We do not sell your personal data.

We may share personal data with:

• service providers and processors acting on our instructions — for example website hosting, email and newsletter platforms, cloud storage, analytics and marketing providers;
• mineola and our professional advisers (such as lawyers and accountants) where an enquiry progresses or where needed to run the business;
• regulators, government and law-enforcement authorities where required by law; and
• a buyer or successor in the event of a business sale or reorganisation.

We require our processors to protect personal data and to use it only for the purposes we specify.

Because we operate across the UAE, Canada, the EU and the US, your personal data may be transferred to, stored in, or accessed from countries other than your own, including countries that may not provide the same level of data protection as your home jurisdiction.

When we transfer personal data across borders, we put in place the safeguards required by the applicable law, which may include:

• From the EU/EEA: transfers to countries covered by a European Commission adequacy decision, or protected by Standard Contractual Clauses together with any additional measures required.
• From the UAE (PDPL): transfers to jurisdictions recognised as providing adequate protection, or otherwise made under the contractual safeguards, consent, or other legal grounds permitted by the PDPL and its Executive Regulations.
• From Canada: measures ensuring a comparable level of protection where personal information is processed outside Canada, with transparency about such processing.

You may request more information about these safeguards using the contact details in Section 1.

If your contact with the Site develops into an advisory engagement with mineola, additional processing applies. As a real estate advisory business, mineola is subject to anti-money-laundering and counter-terrorist-financing laws, which require verifying client identity, conducting customer due diligence, keeping certain records, and in some cases reporting transactions to the relevant authorities. Records collected for these purposes are retained for the minimum period required by applicable UAE law (currently at least five years) and any longer period required elsewhere. In some circumstances we are prohibited by law from telling you when such a report has been made.

We keep personal data only for as long as necessary for the purposes set out in this policy and to meet our legal, regulatory, accounting and reporting obligations. Newsletter and contact data is kept until you unsubscribe or ask us to delete it, and then removed within a reasonable period, subject to any records we must retain by law. When personal data is no longer needed, we securely delete or anonymise it.

We maintain appropriate technical and organisational measures to protect personal data against unauthorised access, loss, misuse or alteration, including access controls, encryption in transit and at rest where appropriate, and restricting access to those who need it. Where a personal-data breach is likely to result in a risk to your rights, we will notify the relevant authority and, where required, affected individuals, in line with applicable law.

Your rights depend on where you are located. We will not discriminate against you for exercising them, and in most cases you can exercise them free of charge by contacting us using the details in Section 1. We may need to verify your identity before acting on a request.

If you are in the EU/EEA (GDPR): you have the right to access, rectification, erasure, restriction of processing, data portability, and to object to processing (including direct marketing); the right to withdraw consent; and the right to lodge a complaint with a supervisory authority.

If you are in the UAE (PDPL): you have the right to be informed; to access and obtain a copy of your data; to rectification; to erasure; to restrict or stop processing; to data portability; to object to certain processing including automated decision-making; and to withdraw consent. You may also complain to the UAE Data Office.

If you are in Canada (PIPEDA / Law 25): you have the right to access and correct your personal information, to withdraw consent (subject to legal or contractual restrictions), and to be informed about how your personal information is handled. In Québec, additional rights apply, including data portability and rights relating to automated decision-making.

We will respond within the timeframe required by the applicable law.

We do not make decisions producing legal or similarly significant effects about you based solely on automated processing. If this changes, we will update this policy and, where required, obtain your consent or provide the safeguards the law requires.

The Site and our services are intended for adults. We do not knowingly collect personal data from children. If you believe a child has provided us with personal data, please contact us and we will delete it.

We may update this Privacy Policy from time to time. We will post the updated version on this page and update the "Last updated" date above. Where changes are material, we will take additional steps to notify you where required by law.

If you have a concern about how we handle your personal data, please contact us first using the details in Section 1 so we can try to resolve it. You also have the right to complain to the relevant supervisory authority:

• EU/France: the Commission Nationale de l'Informatique et des Libertés (CNIL), or the data protection authority in your country of residence.
• UAE: the UAE Data Office.
• Canada: the Office of the Privacy Commissioner of Canada (OPC), or, in Québec, the Commission d'accès à l'information (CAI).