1.1 Santy Technology FZ-LLC (“Santy”), a Free Zone limited liability company incorporated in the Emirate of Dubai with commercial license number 94749 having its registered address at Shared Desk No. 58, Ground Floor, Building 07, Dubai, United Arab Emirates, maintains/owns/operates the www.hi-sandy.com Website and owns the application known as [hi sandy] (“the Application”) and owns all of the rights thereto. U C F Real Estate (“Broker“) is a sole establishment incorporated in the Emirate of Dubai with commercial license number 796680 having its registered address at Shop 01,D02,CBD,Internation city, Dubai, UAE. Santy and the Broker have agreed that (a) the Broker shall be provided with the right to operate the Application; and (b) Santy shall maintain the Application and assist the Broker with any technical matters required for its operation.
1.3 Throughout this Policy, the terms “we”, “our”, “us” means [Santy], the Broker and its subsidiaries, employees, officers, agents, affiliates or assigned parties. “You”, “you” or “yours” means you.
1.5 If any term of this Policy is or may become for any reason invalid or unenforceable at law, the validity and enforceability of the remainder will not be affected.
- DEFINITIONS AND INTERPRETATION
2.1 For the purposes of this Policy the following capitalized words will have the following meanings, unless the context clearly indicates otherwise:
2.1.1 “Control” means the ability to control or direct, directly or indirectly, the board, executive body, decision making process or management of an entity by virtue of ownership, right of appointment, right to control election or appointment, voting rights, the ability to control the exercise of voting rights, management agreement or any other agreement;
2.1.2 “General Information” has the meaning set forth in clause 3.1.2 of this Policy;
2.1.3 “Payment Data” has the meaning set forth in clause 3.1.3 of this Policy;
2.1.4 “Personal Data” mans any information that might be used to identify you, including information such as your IP address;
2.1.5 “Process” means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
2.1.6 “State” means the United Arab Emirates;
2.1.7 “Third Party Analytics” has the meaning given in clause 10.1;
2.1.8 “Group Company” means any other person or entity that directly or indirectly Controls, is Controlled by, or is under common Control of Santy and/or the Broker.
2.2 For the purposes of interpreting this Policy, the following conventions shall apply, unless the context clearly indicates otherwise:
2.2.1 a reference to a Section or Clause is a reference to a section or clause of this Policy;
2.2.2 a reference to the laws of the United Arab Emirates include the laws and regulations of an emirate or free zone (as may be applicable) within the State;
2.2.3 references to a sex and respective pronouns includes references to all other sexes and respective pronouns;
2.2.4 use of a singular form of a word includes a meaning corresponding to the plural form of the word;
2.2.5 use of the plural form of a word includes a meaning corresponding to the singular form of the word;
2.2.6 the words “include” or “including” or any similar phrase shall be construed as illustrative and shall not limit the generality of the related words;
2.2.7 references to a business day means any day from and including Sunday to and including Thursday which is not an official public holiday in the State; and
2.2.8 references to a calendar day means all days including business days, weekends and official public holidays.
- YOUR INFORMATION
3.1 We will collect the following information and data from you when you use the Application:
3.1.1 Personal Data: When you register on the Application as a user or otherwise, update your information, purchase any services, take part in promotions or campaigns or contests, sign into our Application using Personal Data or a social media account, send emails to us, send support requests, contact real estate agents via forms or phone numbers made available on our Application, provide feedback, or when you report a problem with our Application, you provide us with information that we store and Process. Such information may include your name, address, phone number, email address, purchase and transaction history, billing information, interests, and other such ‘Personal Data’. Personal Data may also include aspects of General Information and Payment Data referred to below, to the extent it could be used to identify you.
3.1.2 General Information: We also receive more general information from you as a result of your visits to, and use of, the Application. This general information will generally not identify you personally, including the date and time you access the Application, length of time you spend on the Application, your browsing history (recorded by the text and graphics files that compose that page), the Internet address of the website or application from which you linked directly to our Application, and other such ‘General Information’.
3.1.4 Information we receive from other Sources: We may receive information about you if you use the Application that we operate or from any other services that we provide. We are also working closely with third parties, including but not limited to, business partners, service providers, advertising networks, analytics providers, and search information providers. We may receive information about you from such third parties. This information may be combined with other information you provide to us, as described above.
- COLLECTING AND USING INFORMATION
4.1 Certain services and third-party technology may involve collection and usage of information from you, including but not limited to, Google Analytics (a description of their specific data collection and processing practices can be found via the following link: https://www.google.com/policies/privacy/partners/).
4.2 We use Personal Data to provide you with the following purposes:
4.2.1 to provide the services contemplated by the Application and any other services that you request from us;
4.2.2 to provide a better service, and in particular to: keep internal records, as well as, improve our products, services and the Application;
4.2.3 to communicate with you if you have ordered, purchased or participated in anything on the Application;
4.2.4 to contact you for market research purposes;
4.3.5 to provide you with information about new opportunities, promotions, special offers and other information that we may feel is relevant to you. If you contact us via the Application, or via email to the contacts set out on the Application, we may keep a record of that correspondence.
4.3.6 to provide you, or selected third parties to provide you, with information about real estate properties that may interest you;
4.3.7 to customize or enhance your experience on the Application and services, including via the display of adverts and direct communications you receive from us, which may be based on your activity on the Application;
4.3.8 to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you, which may be based on your activity on the Application;
4.3.9 to make suggestions and recommendations to you and other users of the Application about real estate properties that may interest you or them, which may be based on your activity on the Application.
4.3 We use General Information to help us make the Application more useful to customers (including to help us assess content of interest to visitors), and for other purposes such as determining the Application’s technical design specifications and identifying system performance or problem areas, for tracking activity on the Application, preparing reports, assessing trends, and otherwise monitoring the way in which the Application is being used, none of which would be in a way that personally identifies any users.
- DISCLOSURE OF PERSONAL DATA
5.1 By registering as a user of the Application you consent to us sharing your Personal Data with the following persons, in the following circumstances:
5.1.1 with any Group Company in connection with the purposes above and described elsewhere in this Policy;
5.1.3 business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
5.1.4 our third-party service providers. We partner with and are supported by service providers around the world. Personal Information will be made available to these parties only when necessary to fulfill the services they provide to us, such as software, system, and platform support; direct marketing services; cloud hosting services; advertising; data analytics; and order fulfillment and delivery. Our third-party service providers are not permitted to share or use Personal Data we make available to them for any other purpose than to provide services to us. Please also see section 10 of this Policy in relation to how we share information with Third Party Analytics.
5.3 By registering as a user of the Application you also consent that we may share your Personal Data with third parties:
5.3.1 in the event that we sell or buy any business or assets, in which case we may disclose your Personal Data to the prospective seller or buyer of such business or assets, along with its professional advisers. If substantially all of Santy’s or the Broker’s assets are acquired by a third party, Personal Data held by it about its customers will be one of the transferred assets;
5.3.2 if required in order to obtain professional advice;
5.3.4 to protect the rights, property, or safety of Santy, the Broker, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection.
6.1 Keeping your Personal Data secure and preventing unauthorized access is of utmost priority to us, and we take steps that are reasonably necessary to protect your Personal Data against any unauthorised access, use, alteration, disclosure or destruction. Whilst we have put in place physical, electronic and managerial procedures to secure and safeguard your Personal Data, we will not be held responsible for any unauthorised access by third parties and we cannot guarantee that the Personal Data provided by you or that is transmitted via the Application or by e-mail is totally secure and safe. We will take appropriate steps to ensure data privacy and security including through various hardware and software methodologies. However, we cannot guarantee the security of any information that is disclosed online and/or through this Application.
- STORAGE OF YOUR PERSONAL DATA
7.1 The information that we collect from you through this Application may be transferred to, and stored in, a country outside the country in which you, Santy or the Broker is located. It may also be Processed by Group Company staff operating outside such country, who work for us or for one of our suppliers. By registering as a user of the Application you consent to this transfer, storage, and/or Processing, which will be done in accordance with Sections 4 and 5 of this Policy. We will take steps reasonably necessary to ensure that your data is treated in accordance with this Policy in accordance with Section 6 of this Policy.
7.2 Where we have given you, or where you have created a username and password to allow you to access the Application, you are responsible for keeping this username and password confidential. We ask you not to share your username and password with anyone.
7.3 Unfortunately, the transmission of information via the internet is not completely secure. We will do our best to protect your Personal Data in accordance with Section 6 of this Policy, we cannot guarantee the security of your information transmitted to the Application. Any transmission of information made, is done so at your own risk.
- YOUR RIGHT TO ACCESS AND CORRECT YOUR PERSONAL DATA
8.1 We respect your right to access and control your Personal Data, and we will respond to requests for Personal Data and, where applicable, will correct, amend, or delete your Personal Data. Any such request can be made to firstname.lastname@example.org.
8.2 Access to Personal Data: If you request access to your Personal Data, we will comply, subject to any relevant legal requirements and exemptions. Before providing data to you, we will ask for proof of identity and sufficient information about your interaction with us so that we can locate any relevant data. We may also charge you a fee for providing you with a copy of your Personal Data (except where this is not permissible under local law).
8.3 Correction and deletion: You have the right to correct or amend your Personal Data if it is inaccurate or requires updating. You may also have the right to request deletion of your Personal Data; however, this is not always possible due to legal requirements and other obligations and factors.
8.4 Marketing preferences: To opt out of email marketing, you can use the unsubscribe link found in the email communication you receive from us or by sending an email to email@example.com. For other marketing preferences, you can contact us via any relevant link in the marketing communication, or by sending an email to firstname.lastname@example.org. Information related to controlling cookies, and information related to interest-based and mobile advertising can be found in sections 9 and 10 of this Policy.
9.2 Most browsers and mobile device operating systems accept cookies automatically. You can usually check this on your browser or mobile device operating system settings. If you choose you can disable the cookies from your browser or mobile device, you may find that certain functions and features will not work as intended on the Application.
9.3 We understand that you may want to know more about cookies. Here are some useful resources that provide detailed information about types of cookies, how they are used, and how you can manage your cookie preferences: http://www.aboutcookies.org/ or http://www.allaboutcookies.org/.
- USE OF THIRD PARTY ANALYTICS AND TRACKING PIXELS
10.2 As noted in clause 9.2, you may disable the cookies from your browser by adjusting your browser settings. However, in this scenario, you may not be able to make full use of all the functions available on the Application.
10.3 By registering as a user of the Application you consent to Third Party Analytics processing of the type of information discussed in the manner contemplated in this Policy. To the maximum extent permissible by applicable law, we, and our respective suppliers, and any of our owners, officers, directors, managers, members, agents, and employees, are not liable for any direct, indirect, punitive, incidental, special, or consequential damages or loss (including, without limitation, incidental and consequential damages, lost profits, or damages resulting from lost data or business interruption) arising out of, or in way connected with, the use of the type of information discussed in this section.
- WEB SERVER & APPLICATION LOGS
11.1 Our servers automatically collect certain information to help us administer and protect the Application, analyze usage, and improve users’ experience. The information collected includes, amongst others:
11.1.1 IP address and browser type;
11.1.2 device information including Unique Device Identifier (UDID), MAC address, Identifier For Advertisers (IFA), and similar identifiers we or others may assign;
11.1.3 device operating system and other technical facts;
11.1.4 pages visited and content viewed, stored, and purchased;
11.1.5 information or text entered;
11.1.6 links and buttons clicked;
11.1.7 URLs visited before and after you use the Application.
- THIRD PARTY ADVERTISERS
11.1 We allow third party advertising networks to serve advertisements on our behalf.
11.2 Third party advertisers may place cookies on the browsers of visitors to the Application or our associated websites, and may send their own cookies to the visitors’ cookie file. The cookies will allow these third-party advertisers to apply their personalized retargeting technology and to serve personalized banners; third party advertisers may collect and use this data in accordance with all applicable laws and regulations (including but not limited to laws governing privacy, and data protection).
11.3 Third party advertisers will have their own privacy policies and these will be available on their websites. For further information on what third party advertisers we use for the Application please contact: email@example.com.
- INTEREST-BASED ADVERTISING (IBA)
12.1 Interest-based advertising (IBA) allows us to deliver targeted advertising to users of our Application. IBA works by showing you advertisements that are based on the type of content you access or read. For example, as you browse the Application, one of the cookies placed on your device will be an advertising cookie so we can better understand what sort of pages or content you are interested in. The information collected about your device enables us to group you with other devices that have shown similar interests. We can then display advertising to categories of users that is based on common interests.
12.2 If you want to opt out of receiving interest-based advertising, it does not mean that you will no longer receive advertising when you are using our Application. It just means that we will not use information collected about you for IBA and that any advertising you see will not be customized or relevant to you. Remember, if you delete cookies, use a different device, or change web browsers, you may need to opt out again.
- LINKS AND CONNECTIONS TO AND USE OF OTHER THIRD-PARTY SERVICES
13.1 Our Application may contain links to and may be used by you in conjunction with third-party apps, services, tools, and websites that are not affiliated with, controlled, or managed by us. Examples include but are not limited to Facebook, LinkedIn, Twitter® and, third-party apps like voice software and readers. The privacy practices of these third parties will be governed by the parties’ own privacy policies. We are not responsible for the security or privacy of any information collected by these third parties. You should review the privacy policies applicable to these third-party services. We are not responsible for the privacy policies which link to this Application. If you provide any information to such third parties, different rules regarding the collection and use of your personal information may apply. You should contact these entities directly if you have any questions about their use of the information that they collect.
13.2 Information that you provide to third-party companies is not covered by this Policy.
- PRIVACY OF MINORS
14.1 The Application is not aimed at individuals under the age of eighteen years old (“Minors”). If, however, we collect and use information about any Minor, we will comply with the applicable laws.
14.2 We hereby prohibit all Minors from the use of the Application or service governed by the Terms and Policy, which includes those websites and services operated or provided by Santy and/or otherwise operated by the Broker.
- BUSINESS TRANSFER
15.1 Information obtained pursuant to this Policy, including Personal Data, may be transferred as part of any merge, acquisition, sale of company assets, or transition of service to another provider, as well as in the unlikely event of any insolvency, bankruptcy, or receivership in which the information pursuant to this Policy would be transferred to another entity as a result of such a proceeding. By registering as a user of the Application you acknowledge and accept that the information gathered pursuant to this Policy may form part of the transferred assets and consent to this transfer. You further acknowledge and accept that the acquirer or successor to Santy and/or the Broker may continue to use the information pursuant to this Policy, in the manner set forth in this Policy.
- LAW AND JURISDICTION
This Policy forms part of the Terms of the Application, and any dispute arising out of it will be governed by the Laws of Emirate of Dubai and the laws of the United Arab Emirates. Any dispute or claim arising out of and/or in connection with this agreement or its formation (including non contractual disputes or claims) shall be subject to the exclusive jurisdiction of the courts of Dubai.
- CONTACT US
To contact us, please call 04-5656182 OR email us at firstname.lastname@example.org OR visit us at Shared Desk No. 58, Ground Floor, Building 07, Dubai, United Arab Emirates.