Legal & Data Governance
Privacy Policy.
How Genius OWL Technologies LLC manages, protects, and governs your personal and telemetry data under UAE Federal Decree-Law No. 45 of 2021 (PDPL) and Dubai digital standards.
Genius OWL Technologies LLC operates with a strict principle of data minimization and local-first architecture. We design smart homes that run privately on your local network, ensuring your household routines and telemetry remain under your sovereign control.
Introduction & Scope
This Privacy Policy sets out the basis on which Genius OWL Technologies LLC ("Genius OWL", "we", "us") processes personal, architectural, and telemetry data collected through our engineering consultancy, smart system installations, annual maintenance services, and website (geniusowl.ae).
Our operations are governed by UAE Federal Decree-Law No. 45 of 2021 regarding Personal Data Protection (PDPL), Dubai Law No. 26 of 2015 (Dubai Data Law), and cybersecurity directives from the Dubai Electronic Security Center (DESC).
Data Controller Identity
The designated data controller responsible for the governance and custody of personal data processed under this policy is:
Genius OWL Technologies LLC
Licensed by the Department of Economy and Tourism (DET), Dubai, UAE
Office 7, Ground Floor, Kazim Building, Al Garhoud, Dubai, United Arab Emirates
Direct Inquiries: info@geniusowl.ae | Phone: +971 50 455 5040 / +971 52 878 5858
Data Protection Office: dpo@geniusowl.ae
Categories of Data We Process
We collect only the information necessary to design, install, commission, and maintain physical automation infrastructure:
Client & Contact Records
Name, contact numbers, email address, property physical address (villa/unit number and development community name), and designated project stakeholders (interior designers, MEP consultants, main contractors).
Architectural & Engineering Schematics
AutoCAD/Revit containment layouts, electrical distribution schedules, lighting fixture schedules, Wi-Fi coverage heatmaps, IP network topologies, and scene customization profiles.
Security & Access Metadata
SIRA-compliant CCTV camera layout plans, intercom call logs, and timestamped smart lock access records. Biometric templates remain stored strictly on client-owned local hardware and are never centralized.
Commercial Invoicing Data
Quotations, Bills of Quantities (BOQ), signed engineering agreements, VAT registration details, bank transaction receipts, and maintenance logs.
Legal Grounds for Processing
Pursuant to Article 4 of UAE Federal Decree-Law No. 45 of 2021, all processing activities rely upon:
- Contract Performance: Delivering design, procurement, cable pulling, hardware termination, system programming, and warranty obligations.
- Statutory Compliance: Meeting SIRA surveillance regulations, DEWA electrical requirements, and Federal Tax Authority (FTA) accounting mandates.
- Legitimate Interest: Maintaining network security, preventing unauthorized remote access, and performing diagnostic troubleshooting under active service contracts.
Local-First Architecture & Privacy
We prioritize decentralized, on-premise hardware architectures (KNX bus systems, local processors, on-site Network Video Recorders). Your ambient preferences, lighting schedules, and temperature telemetry execute directly on local processors.
Disclosure & Hardware Partners
We do not monetize, rent, or sell client data. Necessary information is shared only with:
- Certified Hardware Manufacturers: Registering serial-number equipment warranties with certified brand partners (Crestron, Lutron, Control4, Hikvision, Dahua).
- Appointed Site Contractors: Coordinating containment routes with client-approved MEP engineers and interior designers.
- UAE Authorities: SIRA inspectors, Dubai Police, or judicial entities when mandated by UAE Federal or Dubai law.
Cross-Border Data Transfers
Where cloud automation features are enabled (e.g., Apple HomeKit, Google Home), data is routed across encrypted channels adhering to Articles 22 and 23 of UAE Federal Decree-Law No. 45 of 2021, ensuring adequate levels of legal protection.
Data Retention Schedules
As-built wiring schematics and device network maps are retained for the functional lifecycle of the residence (typically 5 to 10 years) to support maintenance and future expansions. Commercial invoices and tax documents are retained for 5 years in compliance with UAE FTA requirements.
Security & Network Hardening
Our systems incorporate technical controls consistent with Dubai Electronic Security Center (DESC) guidelines:
IoT VLAN Isolation
Subnet separation preventing compromised smart devices from accessing personal computers.
Encrypted Transport
TLS 1.3 and AES-256 for all remote maintenance sessions and encrypted configuration backups.
Zero Default Credentials
All factory passwords and management ports are rotated before client handover.
Your Rights Under UAE PDPL
You hold full legal rights under UAE Federal Decree-Law No. 45 of 2021 to:
- Access & Portability: Request copies of your system network documentation in a structured digital format.
- Rectification: Correct outdated contact or architectural records.
- Erasure: Request deletion of non-essential records, subject to statutory UAE warranty and tax obligations.
- Consent Revocation: Opt out of non-critical communications or telemetry updates at any time.
Data Protection Inquiries
For statutory requests or data inquiries, contact our Data Protection Officer:
Data Protection Officer
Genius OWL Technologies LLC
Office 7, Ground Floor, Kazim Building, Al Garhoud, Dubai, UAE
Email: dpo@geniusowl.ae
Have questions regarding your project data?
Our certified engineers and project directors are available to discuss system security, data privacy, and on-premise infrastructure.
Or call +971 50 455 5040 / +971 52 878 5858, Sat–Thu, 9:30–18:30 GST