Privacy Policy
Last updated: 29/09/2026
We keep this short because we collect very little.
1. Who is responsible for your data
Elsermans Adams and Partners L.L.C-FZ Meydan Grandstand, 6th Floor, Meydan Road, Nad Al Sheba, Dubai, United Arab Emirates Trade Licence No. 2651322.01
For anything in this policy: info@elsermansadams.com
We are the controller of the personal data described below, whether it reaches us through this website or through our social media channels. Elsermans Adams Real Estate L.L.C (licence no. 1643087) is a related company.
2. Which law applies
This policy is written to meet both:
- Regulation (EU) 2016/679 (GDPR), which applies to us because we offer our services to people in the European Union, including Belgium and the Netherlands; and
- UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data.
Where the two differ, we apply the standard that gives you more protection.
3. What we collect
This site has no forms. There is no contact form, no newsletter signup and no account. We collect only the following.
When you contact us. If you email us, call us, or send us a message on LinkedIn or Instagram, we hold what you send: your name, your contact details and the content of your message, together with our replies.
Analytics. If you consent, Google Analytics records how the site is used: pages visited, approximate location, device and browser type, and how you arrived. Until you consent, no analytics cookies are placed. Google may still receive limited signals without cookies, such as that a page was viewed and whether consent was given, which are not linked to you through a cookie.
Your cookie choice. Our cookie tool records the choice you make in the cookie banner, so that we can respect it and show that we did.
Server logs. Our host records technical data, including IP address, time of request and pages served, for security and to keep the site running.
Fonts. The typefaces on this site are delivered by Adobe Fonts. To deliver them, Adobe receives your IP address and browser details. Adobe Fonts sets no cookies.
Our social media pages. We have a company page on LinkedIn and an account on Instagram, and our partners publish on their own LinkedIn profiles. LinkedIn and Meta give us statistics about how our pages and posts are used, such as views and the regions, sectors and functions of visitors. We see these only as totals, not as information about you, unless you interact with us visibly (a like, comment or share) or send us a message.
Our campaigns. When we promote posts on LinkedIn, we choose the audience by general criteria such as country, profile language, seniority and industry. LinkedIn decides who sees the post on the basis of the data it holds. We do not upload lists of people, we use no tracking pixels on this site, and we do not show you ads because you visited it. We receive only totals: how many people saw and engaged with a post, and in which regions, sectors and functions.
We do not collect special category data, and we do not ask for it.
4. Why we use it, and on what basis
What | Why | Legal basis (GDPR) |
|---|---|---|
Your correspondence, including messages on LinkedIn or Instagram | To answer you and, if it goes further, to discuss working together | Legitimate interest in responding to someone who contacted us; steps prior to entering a contract at your request |
Analytics | To understand how the site is used and improve it | Your consent; for the limited signals without cookies before consent, our legitimate interest in basic measurement |
Your cookie choice | To respect it and to be able to show that we did | Legal obligation to demonstrate consent |
Server logs | Security, diagnostics, keeping the site available | Legitimate interest in operating the site securely |
Fonts | To display the site as designed | Legitimate interest in a consistent presentation |
Social media statistics | To understand how our pages and posts are received | Legitimate interest, shared with LinkedIn or Meta (see section 5) |
Promoted posts on LinkedIn | To make our work known to relevant professionals in Belgium and the Netherlands | Legitimate interest in presenting our services |
We never sell your data. We build no profiles of you, we do not follow you across other websites, and no decision affecting you is made automatically. LinkedIn and Meta may use data for their own purposes under their own policies.
5. Who else handles it
- Combell NV, Belgium, which hosts the site and its server logs.
- Microsoft Ireland Operations Limited, which provides our email (Microsoft 365) and therefore holds correspondence sent to us.
- Google Ireland Limited / Google LLC, which provides Google Analytics, where you have consented.
- Objectis Ltd (CookieScript), Lithuania, which runs our cookie banner and records your choice.
- Adobe Systems Software Ireland Limited, which delivers the fonts.
Each acts under contract and may use the data only to provide the service to us. We never share your data with anyone else for their own purposes.
LinkedIn and Instagram. LinkedIn Ireland Unlimited Company and Meta Platforms Ireland Limited run their platforms under their own responsibility and privacy policies. For the page statistics described above, we and the platform are jointly responsible. Under the arrangements between us, the platform handles the data it processes and requests about your rights in relation to it. You may also write to us and we will pass your request on. See linkedin.com/legal/privacy-policy and privacycenter.instagram.com.
6. International transfers
We are based in the United Arab Emirates, which the European Commission has not recognised as offering an adequate level of protection. When you contact us, your message comes to us directly in the UAE. The GDPR continues to apply to how we handle it, and we apply the protections set out in this policy.
Some providers named above (Google, Microsoft, Adobe, LinkedIn and Meta) may process data in the United States. They rely on the EU–US Data Privacy Framework or on the European Commission's standard contractual clauses.
You may ask us for details of the safeguards that apply.
7. How long we keep it
- Enquiries that do not become a client relationship, including social media messages: 24 months from our last exchange, then deleted.
- Client correspondence: for the duration of the relationship and afterwards for as long as required by UAE law.
- Analytics: 14 months. The analytics cookies themselves expire after 13 months.
- Your cookie choice: stored on your device for one month.
- Server logs: 90 days.
- Social media statistics and campaign results: as kept by LinkedIn or Meta.
8. Your rights
Under the GDPR you may ask us to:
- give you a copy of the data we hold about you
- correct it if it is wrong
- delete it
- restrict how we use it
- provide it in a portable format
- stop using it where we rely on legitimate interest
Where we rely on consent, which is only analytics, you may withdraw it at any time via the cookie icon on the page. Doing so does not affect anything done before you withdrew.
Write to us at info@elsermansadams.com and we will respond within one month.
If you are not satisfied, you may complain to your national data protection authority. In Belgium that is the Gegevensbeschermingsautoriteit / Autorité de protection des données; in the Netherlands, the Autoriteit Persoonsgegevens. You may also complain to the UAE Data Office.
Comparable rights apply under UAE Federal Decree-Law No. 45 of 2021, and we apply them to everyone regardless of where you live.
9. Security
We keep personal data on services with access controls and encryption in transit. Access within EAP is limited to the people who need it. No system is perfectly secure, and we do not claim otherwise.
10. Children
This site is not directed at children and we do not knowingly collect their data.
11. Changes
We may update this policy. The version in force is the one published here, with the date shown above. If we change it materially, we will say so on this page.