PRIVACY POLICY
Last updated on: 6th December 2024
We are committed to keeping your data secure, your private information private and being transparent about our practices. We adhere to the best practices to secure information collected from You.
Rezio Tech Limited , having its registered office at Unit IH-00-VZ-01-FL-138 Level 1, Innovation Hub, Dubai International Financial Centre (“Company” or “we” or “us” or "our"), owns and operates the website domain at https://www.rezio.ai/ and mobile application titled Rezio available for download on the Google Play Store and Apple Play Store (collectively referred as “Platform”). This Privacy Policy governs the collection, use, sharing, transfer, and safeguarding of personal information of the Users of the Platform (hereinafter referred to as “you”, “your” or “User”) who access or uses the Platform, including any services available on it, and constitutes part of the Terms of Service for using the Platform, as available on the Platform.
This Privacy Policy has been formulated in compliance with Federal Decree - Law No. 45 of 2021, on the Protection of Personal Data in (“PPD”), applicable in the United Arab Emirates (“UAE”/ “State”) to govern the processing of Personal Data of Users of the Platform.
This Privacy Policy is applicable to any individual who visits, browses, uses, registers, or accesses the Platform, or utilizes any Services (as defined under the Terms of Services) provided on the Platform.
1. INTRODUCTION AND APPLICABILITY:
1.1. The purpose of this Privacy Policy is to provide a clear framework governing the collection, usage, and protection of any Personal Data through the Platform. This Privacy Policy outlines our procedures regarding collection, usage, storage, processing, disclosure, sharing and protection of any Personal Data. By using the Platform, you consent to the collection and processing of your Personal Data in accordance with the Privacy Policy to provide and improve our Platform and Services.
1.2. We may modify or revise the Privacy Policy from time to time and shall accordingly notify you of any changes to the Privacy Policy by posting the revised Privacy Policy on the Platform with an updated date of revision. We shall endeavour to review, revise, update, modify, amend, or correct the Privacy Policy on a regular and routine basis, especially whenever a significant update is made to the technology employed by us. You must periodically review the Privacy Policy for the latest information on our privacy practices. In the event you continue to use the Platform and our services after any update in the Privacy Policy, your use of the Platform shall be automatically subject to such updated Privacy Policy. Your continued usage of Services or access of the Platform post any amendment would deem to mean that you accept and agree to the revised Privacy Policy. Further, we retain the right at any time to deny or suspend access to all, or any part of, the Service to anyone who we reasonably believe has violated any provision of this Privacy Policy.
1.3. The Platform may include links to certain external websites, plug-ins, services, and applications (“Third-Party Services”). By clicking on such third party links you may allow third parties to gather or share information about you. We do not have control over, no do we endorse, these Third Party Services. we are not liable for their privacy policies in any manner whatsoever.
2. DISCLAIMER
2.1. Please be advised that any Personal Data (as defined herein below) procured by us, will be: (a) processed fairly, lawfully and in a transparent manner only for rendering the Services; (b) obtained only for specified and lawful purposes, and will not be used in any manner which is against the law or policy in force in United Arab Emirates (“Applicable Law”); (c) sufficient and limited to what is necessary in accordance with the purpose for which it is collected; (d) made available to the User for its review, and correction as and when required by the User; (e) kept securely, protected from any violation, penetration, or illegal or unauthorized processing and (e) not kept longer than for the time which it is required or the purpose for which it is required or as required by the Applicable Law, except where the Data may be retained in an anonymized form, ensuring that the identity of the user is concealed in accordance with the provisions of the UAE PPD (“Anonymisation Mechanism”).
2.2. THE PERSONAL DATA WILL BE UTILIZED AND PROCESSED ON AN "AS IS" BASIS. WE SHALL NOT BE LIABLE FOR THE ACCURACY OR COMPLETENESS OF THE PERSONAL DATA PROVIDED BY THE USER. IF THE USER BECOMES AWARE THAT THE PERSONAL DATA THEY HAVE PROVIDED IS INCORRECT, OR IF THERE IS AN UPDATE TO THAT PERSONAL DATA, THEY MUST PROMPTLY INFORM THE COMPANY. THE USER SHALL REQUEST EITHER THE DELETION OF THE INCORRECT PERSONAL DATA OR THE UPDATE OF THE INFORMATION TO REFLECT THE CORRECT DETAILS.
2.3. WE SHALL NOT BE LIABLE FOR ANY LOSS OR DAMAGE SUSTAINED BY REASON OF ANY DISCLOSURE (INADVERTENT OR OTHERWISE) OF ANY OF YOUR INFORMATION AND PERSONAL DATA, IF THE SAME IS EITHER (A) REQUIRED FOR SHARING YOUR INFORMATION FOR LEGITIMATE PURPOSES; OR (B) WAS AFFECTED THROUGH NO FAULT, ACT, OR OMISSION OF THE COMPANY OR (C) WAS AFFECTED IN OFFERING OF OUR LAWFUL SERVICES OR (D) IS ATTRIBUTABLE TO THE NEGLIGENCE OF THE USER.
2.4. BY USING THE PLATFORM OR SERVICES, YOU EXPLICITLY ACCEPT AND CONSENT TO, WITHOUT LIMITATION OR QUALIFICATION, THE COLLECTION, USE AND TRANSFER OF THE PERSONAL DATA IN THE MANNER DESCRIBED HEREIN.
3. YOUR CONSENT
3.1. Please note that by accessing our Platform and/or registering on our Platform and/or availing the Services and providing consent to process your Personal Data, you provide your consent and authorize us to collect, use or disclose such Personal Data for the business and research purposes and as stated in this Privacy Policy and the Terms of Use, and as permitted or required by Applicable Law.
3.2. You understand and hereby consent that your Personal Data may be disclosed/ shared to any third party for the purpose of processing and/or Automated Processing (as defined hereafter) of the Personal Data, assessing or evaluating whether the Services can be provided to you, providing Services through the Platform or to any third-party providers for rendering Services (as defined in the Terms of Service), any jointly developed or marketed services, payment processing, order fulfilment, customer services, fraud management services, data analysis, information technology services and such other services which enable us to provide Services through the Platform.
3.3. You hereby acknowledge and understand that the processing of your Personal Data shall comply with Applicable Law. Specifically, your Personal Data will be processed in such a manner that it cannot be directly associated or attributed to you without the use of additional information. This additional information will be maintained separately and securely, ensuring that your Personal Data remains unlinkable to your identity and that unauthorized third parties cannot identify you through your Personal Data (“Pseudonymisation Mechanism”)
3.4. This Privacy Policy shall be enforceable against you in the same manner as any other written agreement. By visiting, browsing, using, registering, or accessing the Platform and voluntarily providing us with Data, you are consenting to our use of the Personal Data, in accordance with this Privacy Policy. If you do not agree with this Privacy Policy, you may choose to not provide us with any Personal Data. Under such circumstance, we may be unable to render Services.
4. TYPES OF DATA COLLECTED
4.1 We collect several different types of information and/or data for various purposes to provide Services and improve our Platform to you.
(a) “Sensitive Personal Data” means and includes any data which directly or indirectly reveals a natural person's family, ethnic origin, political or philosophical opinions, religious beliefs, criminal record, biometric data, or any data relating to such person’s health and physical, psychological, mental, genetic or sexual condition, including information related to the provision of healthcare services to him/her which reveals his/her health status.
(b) “Personal Data” means and includes any data related to a specific natural person or related to a natural person that can be identified directly or indirectly by linking the data, through the use of identification elements such as his/her name, voice, image, identification number, his/her electronic identifier, his/her geographical location, or by one or more physical, physiological, economic, cultural or social characteristics. It includes Sensitive Personal Data and Biometric Data.
(c) “Biometric Data” means and includes Personal Data resulting from processing using a specific technology related to the physical, physiological, or behavioural characteristics of the User, which allows the identification or confirmation of the unique identification of the User, such as facial images or fingerprints.
(d) “Technical Information” means and includes any Information gathered through various technologies that may employ cookies, web beacons, or similar technologies to automatically record certain information from your device through which you use the Platform. This technical information may include your Internet Protocol (IP) address, time stamp, device or browser type, Internet service provider (ISP), referring or exit pages, clickstream data, operating system, hardware model, operating system version, unique device identifiers, and mobile network. This data includes usage information and user statistics.
(e) “Locational Information” shall mean and include the information obtained through GPS or other means, such as the geographical location of the User.
(f) “Non-Personal Information” means and includes any information that does not reveal your specific identity, such as, browser information, information collected through Cookies (as defined below), pixel tags and other technologies, demographic information, and responses to preference inquiries related to the Services provided, etc. As is true with most websites, our Company gathers some information automatically when you visit the Platform. When you use the Platform, we may collect certain information about your computer or mobile to facilitate, evaluate and verify your use of the Platform. For example, we may store environmental variables, such as browser type, operating system, speed of the central processing unit (CPU), referring or exit web pages, click patterns and the internet protocol (IP) address of your computer. This information is generally collected in aggregate form, without identifying any user individually.
(g) “Property Information” means and includes information about the properties you own, list for rent or lease, or are interested in, including their location, specifications, and pricing.
(h) “Financial Information” means and includes financial information and payment information, such as your credit or debit card number and other card information, other account and authentication information, and billing, delivery and contact details where you use our Services or Platform for buying or renting an immovable property or other financial transactions related to such activities, we collect information about the transaction.
(i) “Communication Information” means and includes records of communications, such as emails, phone calls, or messages, exchanged between you, our representatives, or our Artificial Intelligence Assistant (“AI”) for quality assurance and training purposes.
4.2 For the purposes of this Privacy Policy, all types of data and information referenced in clause 4.1 shall be collectively referred to as "Personal Data" or “Data”.
4.3 All references to “processing” under this Privacy Policy shall mean any operation or set of operations performed on Personal Data using any electronic means, including processing and other means. This processing includes collecting, storing, recording, organizing, adapting, modifying, circulating, altering, retrieving, exchanging, sharing, using, characterizing, disclosing Personal Data by broadcasting, transmitting, distributing, making available, coordinating, merging, restricting, blocking, erasing, or destroying it or creating forms thereof.
4.4 All references to “Automated Processing” shall mean processing which is carried out using an electronic program or system which operates in an automated and automatic manner either completely independently without any human intervention or partially with limited human supervision and intervention.
4.5 All references to “Profiling” shall mean a form of Automated Processing which involves the use of Personal Data to assess certain personality aspects associated with the User, including analysing, or predicting aspects related to his/her financial performance or condition, health, personal preferences, interests, behaviour, location, movements, or reliability.
5. HOW DO WE COLLECT DATA
When you sign up to avail a service from our Platform as an “Owner” renting or selling your immovable property/ies, or as a “Real Estate Agent” (real estate professional assisting Investors, Owners, and/or other Real Estate Agents in buying, selling, leasing, or renting immovable property/ies), or as an “Investor” looking to purchase or rent an immovable property (Owner, Real Estate Agent , Investor are hereinafter collectively referred to as “Participants”) we may ask certain Personal Data from you. By entering your details of the Personal Data in the fields requested, you enable the Company, its third-party service providers to provide you with the Services you select. This may include sharing your Personal Data with other Participants to enhance their ability to connect and transact effectively within the Platform. Please note that sometimes on the Platform we will require you to provide additional information, and at times this may be Personal Data or Sensitive Personal Data. When we ask such information, we will specify further on the Platform why we are collecting your information and how we will use it. The Company also uses cookies and collects IP addresses (an IP address is a number that can uniquely identify a specific computer or other network devices on the internet). We use analysis software to look at IP addresses and cookies for the purpose of diagnosing problems with our server, compiling statistics on site usage and enhancing your User experience.
6. PURPOSE OF COLLECTION AND USAGE OF DATA
6.1 The Personal Data collected by us shall be used for providing Services on our Platform and will be utilised for other functions including but not limited to:
(a) providing you with updates regarding Participants.
(b) to analyse how you use our Services, Platform, such as the types of content that you view or engage with, the features you use, the actions you take, the people or accounts you interact with and the time, frequency, and duration of your activities
(c) we also receive and analyse content, communications, and information that other people provide when they view, buy, lease, or rent your property on the Platform. This can include information about you, your property, location such as when others share or comment on a post or listing you have made.
(d) to resolve any complaints, you may have and ensure that you receive the highest quality of Services;
(e) communicate with you regarding your inquiries, requests, and updates related to our Services.
(f) notifying you about changes to our Platform;
(g) providing analysis or valuable information so that we can improve the Platform;
(h) monitoring and maintaining the usage of the Platform;
(i) sending out system updates of the Platform;
(j) detecting, preventing, and addressing technical issues;
(k) detecting or preventing fraud, or any other form of risks;
(l) sending out payment/ collection reminders;
(m) analysing usage patterns;
(n) improving user experience;
(o) notifying you about new services and features added to or introduced via the Platform;
(p) evaluation/ assessment for the purposes of providing Services.
(q) To comply with applicable laws, regulations, and legal processes, and respond to lawful requests or court orders.
6.2 Business or Research Purposes: The Anonymised Data of the User may be used for business or research purposes, including improving and customizing the Platform for ease of use and the services offered by us. We may archive this information to use it for future communications for providing updates and/or surveys.
6.3 Aggregated Information: We may aggregate and anonymise the Personal Data of the User and analyse it in a manner to further accentuate the level of Services that we offer to our customers. This Anonymised Data may include average number of users of the Platform, the average clicks of the Services/, the features used, the response rate, listings by the User, comments added by the User, etc. and other such statistics regarding groups or individuals.
7. DISCLOSURE AND SHARING OF INFORMATION:
7.1 We do not rent, sell, or disclose or share any Personal Data that we collect from you, with third parties, save and except in order to provide you with the Services. Any such disclosure, if made, shall be in accordance to this Privacy Policy and as per the procedure prescribed by Applicable Law and in compliance with our legal obligations. We may share your Personal Data in circumstances and for the purposes as specified hereunder:
7.2 We may share the Personal Data to the third-party service providers/ vendors, to provide you with the Services or to improve the Services or to evaluate any possible business arrangement with third parties which may enhance the quality of Services being provided or to evaluate whether Services may be provided to you. This may include but not be limited to Participants, storage providers, data analytics providers, consultants, lawyers, and auditors.
7.3 We may share your Personal Data with the Participants. In the case of Real Estate Agents and Owners, we may use, display, and/or share information about Investors seeking to purchase or lease properties, including their preferences. Additionally, we may use, display, and/or share details about other Real Estate Agents with whom you might consider collaborating. For Investors, we may present information regarding available properties, as well as data about Owners and Real Estate Agents. Where profile for an immovable property is created by a Real Estate Agents, it is shared with the Owner for verification. Please note that a Real Estate Agents may be assigned to a limited number of properties, at the sole discretion of the Company, and such assignments shall be made for specific periods of time as determined by the Company.
7.4 We may share your Personal Data with AI that handles communication with you, and/or on behalf of you particularly, in case you are an Owner, Investor or a Real Estate Agent , in order to assist in the process of buying, selling, or renting immovable properties and other Services provided by the Company.
7.5 When compelled by Applicable Law, we may disclose any Personal Data provided by you on the Platform as may be deemed to be necessary or appropriate.
7.6 We may share Personal Data upon merger or acquisition of Company with another company, which shall automatically acquire the rights and obligations mentioned in the Privacy Policy.
7.7 We may share Personal Data with other service providers on a need-to-know basis, subject to obligations of confidentiality for provision of Services. We hereby clarify that Company works with institutions, vendors, partners, advertisers, processors and other service providers, including (but not limited) to those who provide services such as contact Information verification, website hosting, data analysis, providing infrastructure, information technology services, auditing services and other similar services, in different industries and categories of business by virtue of lawful contracts instituted between such third parties and Company to improve our services. Accordingly, we may share your Information with such service provider as reasonably necessary to provide you with Services.
7.8 We follow a strict confidentiality policy with regard to disclosure of confidential information to our employees or other personnel. There may be situations, where we may disclose the Data only to those of our employees and other personnel on a need-to-know basis. Any breach of confidential information by the employees, personnel within the Company is dealt with stringently by us.
7.9 We may share your Data with our present or future business partners to either provide you Services or to enhance the quality of our Services.
7.10 We may remove parts of Personal Data that can identify you and share Anonymized Data with other parties. We may also combine your information with other information in a way that it is no longer associated with you and share that Aggregated Information.
8. RETENTION OF INFORMATION
All Information provided by you, save and except upon withdrawal or termination, shall be retained in locations outside the direct control of Company (for instance, on servers or databases co-locates with hosting providers). We will delete Information based on a request received from you within a reasonable period and latest within 45 business days of receiving a deletion or withdrawal request in accordance with the terms of this Privacy Policy. However, we may retain such portion of Information and for such periods as may be required under Applicable Law or in accordance with the terms of this Privacy Policy.
9. RIGHT TO CORRECTION OR ERASURE OF PERSONAL DATA
9.1 The User shall have the right to request the correction of any inaccurate Personal Data, or request to complete the Personal Data held by the Company without undue delay at hey@rezio.ai
9.2 Without prejudice to the Applicable Law in force in the State and what is required for the public interest, the User shall have the right to request erasure of their Personal Data held by the Company in any of the following cases:
(a) User’s Personal Data is no longer necessary for the purposes for which it is collected or processed.
(b) Withdrawal of the consent of Personal Data on which the processing is based, in accordance with the terms of this Privacy Policy.
(c) The User’s objection to the processing, or the absence of legitimate reasons for the Company to continue the processing.
(d) The Personal Data is processed in violation of the provisions of the UAE PPD and the Applicable Laws, and the erasure process is necessary to comply with the legislations and approved standards in force in this regard.
9.3 As an exception to what is stated under clause 9.2 of this Privacy Policy, the User is not entitled to request erasure of their Personal Data held by the Company in the following cases:
(a) If the request is related to the erasure of their Personal Data related to public health in private facilities.
(b) If the request affects the investigation procedures and claiming and defending rights.
(c) If the request contradicts other legislations to which the Company is subject.
(d) Any other cases determined by the Executive Regulations
10. WITHDRAWAL OF PERSONAL DATA
10.1 You may, at any time, withdraw your consent to process your Personal Data. Such an intimation to withdraw your consent can be sent to hey@rezio.ai . You understand that withdrawal of consent shall lead to suspension of any of your account registered with us as we shall not be able to provide the Services to you. Such withdrawal of consent shall not affect the legality of the processing based on the given consent before withdrawing it.
10.2 Your withdrawal of consent or any explicit objection to the provision of consent shall not affect the Company's processing or Automated Processing of your Data in the following circumstances:
(a) If the processing is necessary to protect public interest.
(b) If the processing is related to Personal Data which has become available and known to all by an act of the User.
(c) If the processing is necessary to initiate any procedures of legal claim or defense of rights or is related to judicial or security procedures.
(d) If the processing is necessary for purposes of occupational or preventive medicine in order to assess the employees' ability of to work, performing medical diagnosis, providing health or social care, treatment, or health insurance services, managing health or social care systems and services in accordance with the legislation in force in the State.
(e) If the processing is necessary to protect public health, including protection from existing diseases and epidemics, or for the purposes of ensuring the safety and quality of healthcare, medicines, drugs, and medical devices, in accordance with the legislation in force in the State.
(f) If the processing is necessary for archival purposes or for scientific, historical, and statistical studies in accordance with the legislation in force in the State.
(g) If the processing is necessary to protect the interests of the User.
(h) If the processing is necessary for the purposes of the Company or the User carrying out their obligations and exercising their legally established rights in the field of employment, social security or laws concerned with social protection, to the extent permitted by such Laws.
(i) If the processing is necessary to perform a contract to which the User is a party, or to take measures at the request of the User with the aim of concluding, amending, or terminating a contract.
(j) If the processing is necessary to fulfil specific obligations stipulated in other laws in force in the State for the Company.
(k) Any other cases set out in the Executive Regulations of this UAE PPD (“Executive Regulations”).
11. RIGHT TO RECEIVE INFORMATION
11.1 The User has the right, by submitting a request to the Company at hey@rezio.ai , without any additional charges, to obtain the following information:
(a) The types of its Personal Data that are being processed.
(b) Purposes of processing.
(c) Decisions made based on Automated Processing, including Profiling.
(d) The targeted sectors or establishments with whom its Personal Data will be shared from inside and outside the State.
(e) Controls and standards for the period of storage and preservation of the User’s Personal Data.
(f) Procedures for correcting, erasing, or limiting processing and objection to the User’s Personal Data.
(g) Protection measures for cross-border processing carried out in accordance with the UAE PPD.
(h) Actions to be taken in the event of a breach or misuse of the User’s Personal Data, especially if the breach or misuse has a direct and serious threat to the privacy and confidentiality of the Personal Data.
(i) How to submit complaints to the Bureau.
11.2 The Company may reject the User’s request as outlined in the clause 11.1 in the following cases:
(a) The request is not related to the information referred under clause 11.1 of this Privacy Policy, or it is excessively repetitive.
(b) The request conflicts with judicial procedures or investigations conducted by competent authorities.
(c) The request may negatively affect the efforts of the Company to protect information security.
(d) The request affects the privacy and confidentiality of Personal Data of third parties
12. RIGHT TO RESTRICT PROCESSING
12.1 The User shall have the right to oblige the Company to restrict and stop processing its Personal Data in any of the following cases:
(a) The User’s objection to the accuracy of the Personal Data, in which case the processing shall be restricted for a specific period to allow the Company to verify the data accuracy.
(b) The User's objection to the processing of his/ her Personal Data in violation of the agreed-upon purposes.
(c) The processing is carried out in violation of the provisions of the UAE PPD and the applicable legislations.
12.2 The User shall have the right to request the Company to continue to keep his/ her Personal Data after the completion of the processing purposes when such data is necessary to complete procedures related to claiming or defending rights and lawsuits.
12.3 Notwithstanding what is stated under clause 12.1 of this Privacy Policy, the Company may proceed with the processing of the Personal Data of the User without his/ her consent in any of the following cases:
(a) If the processing is limited to storing Personal Data.
(b) If the processing is necessary to pursue any of the procedures related to claiming or defending rights and lawsuits or related to judicial proceedings.
(c) If the processing is necessary to protect the rights of third parties.
(d) If the processing is necessary to protect the public interest.
(e) If the processing is related to Personal Data which has become available and known to all by an act of the User.
(f) If the processing is necessary for archival purposes or for scientific, historical and statistical studies in accordance with the legislation in force in the State.
(g) If the processing is necessary to protect the interest of User.
(h) If process is necessary to perform a contract to which the User is a party or to take measures at the request of User with the aim of concluding, amending or terminating a contract.
(i) Any other cases set out in the Executive Regulations of PPD by Applicable Law.
12.4 In all cases, the Company, if it lifts the restriction stipulated under this clause 12, shall notify the User of the same.
13. RIGHT TO STOP PROCESSING
13.1 The User shall have the right to oblige the Company to restrict and stop processing of his/her Personal Data in any of the following cases:
(a) The User’s obligation to the accuracy of the Personal Data in which case the processing shall be restricted for a specific period to allow the Company to verify the data accuracy.
(b) The User’s objection to processing of its Personal Data in violation of the agreed upon purposes.
(c) The processing is carried out in violation of the provisions of PPD and the applicable legislations.
13.2 The User shall have the right to object to the processing of his/her Personal Data and stop it in any of the following cases:
(d) If the processing is intended for the purposes of direct marketing, including Profiling related to direct marketing.
(e) If the processing is intended for the purposes of conducting statistical surveys, unless the processing is necessary to serve the public interest.
(f) If the processing is carried out in violation of the UAE PPD.
14. RIGHT TO PROCESSING AND AUTOMATED PROCESSING
14.1 The User shall have the right to object to any decisions resulting from Automated Processing, including Profiling, particularly those decisions which have legal impact on or adversely affect the User.
14.2 Notwithstanding anything contained in clause 14.1, the User may not object to the decisions resulting from automated processing in the following cases:
(a) If the Automated Processing is agreed upon under the contract made between the User and the Company.
(b) If the Automated Processing is required under other legislations which are applicable in the State.
(c) If the User gives prior consent to the Automated Processing in accordance with the UAE PPD.
14.3 The Company shall adopt appropriate measures to protect the privacy and confidentiality of the User's Personal Data in the cases referred to in clause 14.2 of this Privacy Policy and shall not cause any prejudice to the User's rights.
14.4 The Company shall include the human element in reviewing Automated Processing decisions at the request of the User.
15. COMPANY OBLIGATIONS
15.1 The Company has and has ensured that its third-party processors have developed and undertaken appropriate technical and regulatory measures to ensure the highest standard of information security that is suitable for the risks related to Data processing in accordance with the best international practices and standards including the following:
(a) Encryption of Personal Data and the application of Pseudonymisation Mechanism.
(b) Applying measures which ensure the continuous confidentiality, safety, accuracy and flexibility of Data processing systems and services.
(c) Applying measures which ensure timely retrieval of and access to Personal Data in case of any actual or technical failure.
(d) Applying measures which ensure a seamless testing and evaluation of the effectiveness of the technical and regulatory measures to ensure the security of processing.
15.2 When evaluating the information security level as set out in of clause 15.1 of this Privacy Policy, the Company has observed the following:
(a) Data processing risks, including damage, loss, accidental or illegal change and disclosure of or access to the Personal Data, whether being transferred, stored or processing.
(b) The costs of Data processing, and its nature, scope, and purposes, in addition to potential risks impacting the confidentiality and privacy of the User's Personal Data.
15.3 Taking into account the nature, scope and purposes of Data processing, the Company has, before carrying out the processing, evaluated the impact of the proposed processing operations on the protection of Personal Data, when using modern technologies that has a potential to pose high risk to the privacy and confidentiality of the User's Personal Data.
15.4 Please note that the assessment of the impact provided for in clause 15.3 of this Privacy Policy shall be required only in the following cases:
(a) If the processing includes a systematic and comprehensive assessment of the personal aspects of the User, using Automated Processing, including Profiling, having legal consequences or serious impact on the User.
(b) If processing would be carried out on a large volume of Sensitive Personal Data.
15.5 Please note that the assessment stipulated in clause 15.3 of this Privacy Policy shall include, at a minimum, the following:
(a) Clear and systematic explanation of the suggested processing operations for the protection of Personal Data and the purpose of processing.
(b) Evaluation of how necessary the processing operations are and how they are suitable for the purpose of processing.
(c) Evaluation of potential risks related to the privacy and confidentiality of the User's Personal Data.
(d) The suggested procedures and measures aimed at reducing the potential risks related to the protection of Personal Data
15.6 The Company may carry out one evaluation of a set of processing operations which have similar nature and risks and the Company shall coordinate with the Data Protection Officer upon evaluating the impact of the protection of Personal Data.
15.7 The Company reviews the evaluation results on a regular basis to make sure that the processing is being carried out in accordance with the evaluation in case the processing risks level changes.
16. CROSS-BORDER TRANSFER AND SHARING OF PERSONAL DATA FOR PROCESSING PURPOSES IF A PROPER PROTECTION LEVEL IS AVAILABLE
16.1 Your Personal Data may be transferred to, and maintained on, computers/ servers located within the State, and will be governed by the Applicable Law.
16.2 Your Personal Data may be transferred to outside of the State in the following cases approved by the Bureau:
(a) The State or Province to which the Personal Data is transferred has a judicial or regulatory authority imposing appropriate measures against the Company or its third party processor, if any, legislations addressing Personal Data Protection including most significant provisions, measures, controls, stipulations and rules related to the protection of the privacy and confidentiality of the User’s Personal Data, and User’s ability to exercise their legal rights.
(b) Where the State joins a bilateral or multilateral agreement related to the protection of Personal Data concluded with countries to which the Personal Data is transferred.
17. CROSS-BORDER TRANSFER AND SHARING OF PERSONAL DATA FOR PROCESSING PURPOSES IF A PROPER PROTECTION LEVEL IS NOT AVAILABLE
17.1 Notwithstanding anything contained in clause 16 of this Privacy Policy, Personal Data may be transferred to outside the State in the following cases:
(a) To companies, operating in countries where there are no laws for Data Protection, under a contract or agreement obligating the companies in such countries to adopt measures, controls and requirements set out in the UAE PPD, in addition to provisions forcing the companies or the processors to adopt appropriate measures which are imposed by a judicial or regulatory authority in such countries as set out in the contract.
(b) If you grant an explicit consent to transfer your Personal Data outside the State, provided that such transfer shall not contradict the public or security interest of the State.
(c) If the transfer is necessary to fulfil obligations and establish rights before judicial entities, exercise or defend the same.
(d) If the transfer is necessary to sign or implement a contract made between the Company and the User, or between the Company and third parties to serve the interest of the User.
(e) If the transfer is necessary to implement an action related to an international judicial cooperation If the transfer is necessary to protect the public interest.
17.2 The Company shall ensure that it adheres to controls and stipulations referred to under clause 17.1 of this Privacy Policy, stipulated under the Executive Regulations of UAE PPD, if any, during the transfer of Data outside the State.
18. APPLICATIONS USED
18.1 You may utilize our Services to view, purchase, sell, rent, or lease properties, content, and documents listed by Owners or Real Estate Agents, which are not sold, leased, or rented directly by us. We strongly recommend that you thoroughly review the policies, terms and conditions, and property documents associated with any third-party links, listings, or content provided by Participants.
18.2 We exercise no control over and assume no responsibility for the content, policies, or practices of any third-party applications, Participant content, or services.
19. CHILDREN’S PRIVACY
Our Platform and Services are not meant for use by children and we knowingly do not collect or solicit Data from anyone under the age of 18. If you are under 18, please do not attempt to register for the Services or send any personal information about yourself to us. If we learn that we have collected Information from/of a person under the age of 18, we shall take steps to remove such Information from our servers as quickly as possible. If you believe that a person under age 18 may have provided us with Personal Information, please write to us at the email address – hey@rezio.ai .
20. REPORTING PERSONAL DATA BREACH
19.1 The User shall promptly notify the Company upon becoming aware of any breach or violation related to Personal Data.
19.2 The Company shall, at the time it becomes aware of the existence of any breach or violation of Personal Data of the User, by itself or through receipt of notification of breach from the respective User or a third party processor, that would prejudice the privacy, confidentiality and security of data, notify the UAE Data Bureau established under the Federal Decree by Law No. (44) of 2021 (“Bureau”) of such breach or violation and the investigation rights within the period and in accordance with the measures and requirements set by the Executive Regulations under this UAE PPD, accompanied by the following data and documents:
(a) description of the nature of the breach or violation, its form, causes, approximate number, and records.
(b) Details of the appointed Data Protection Officer.
(c) Potential and expected effects of the breach or violation.
(d) Corrective measures and actions taken or suggested by it to confront such violation and reduce its negative impacts.
(e) Documents of the violation and corrective actions taken by it.
(f) Any other requirements required by the Bureau
19.3 The Company shall also notify the User in the event that the violation or breach would prejudice the privacy and confidentiality of the security of his/her Personal Data within the period and in accordance with the measures and requirements set by the Executive Regulations and shall also inform the User of the actions taken in response.
21. COMPLAINTS TO THE BUREAU
20.1 The User shall have the right to submit complaints to the Bureau if he/she believes that there is a violation of the UAE PPD or that the Company or the third-party processor of the Company is processing his/ her Personal Data in violation of the rules and procedures set by the Bureau in this regard.
20.2 The Bureau shall receive complaints from the User in accordance with clause 20.1 and shall examine such complaints in coordination with the Company and such third-party processors, if any.
22. COOKIES AND OTHER TRACKING TECHNOLOGIES
Our Platform may utilize “cookies” and other Technical Information. “Cookies” are a small text file consisting of alphanumeric numbers used to collect the information (standard Internet log information and visitor behaviour information) about Platform activity.The Technical Information helps us analyse web traffic and helps you by customizing the Platform to your preferences. Cookies in no way gives us access to your computer or mobile device beyond the data you voluntarily share with us. We will notify you when Cookies are being utilized, specify the types of Cookies that will be stored, and obtain your consent prior to their use. You can deny access to the installation of the Cookies by modifying the settings on your web browser, however, this may prevent you from taking full advantage of the Platform. Our use of Cookies and Technical Information allows us to improve Platform and your experience of Platform and Services. We may also analyse Technical Information that does not contain Personal Information for trends and statistics.
23. DATA SECURITY
You agree and accept that your Data may be stored in third-party cloud service infrastructure providers. While all reasonable measures as per the UAE PPD and other Applicable Law have been taken from our end to ensure the safe and secure storage of your Data, we shall not be liable for any data breach on the part of the third-party cloud service infrastructure provider that was the Company’s control or obligations set out under this Privacy Policy. In addition to the security measures put in place by the third-party cloud service infrastructure provider for safe and secure storage of your information, we use certain physical, managerial, technical, or operational safeguards as per industry standards and established best practices to protect the Data we collect. We use reasonable security practices and procedures and use secure servers as mandated under Applicable Laws for the protection of your Data. We review our Data collection, storage, and processing practices, including physical security measures to guard against unauthorized access to systems. However, as effective as these measures are, no security system is impenetrable. We cannot guarantee the security of our database, nor can we guarantee that the Data you supply will not be intercepted while being transmitted to us over the internet. You accept the inherent security implications of data transmission over the internet and the internet cannot always be guaranteed as completely secure. Therefore, your use of the Platform will be at your own risk. If you have any concerns, please feel free to contact us by emailing us at – hey@rezio.ai DISCREPANCIES AND GRIEVANCES WITH COMPANY
In case of any discrepancy or grievance with respect to all or any Data shared with Company, please feel free to contact our Data Protection Officer:
Email ID: dpo@rezio.ai
We will promptly acknowledge each grievance that is received and put our best efforts to redress the grievances of the User. The Data Protection Officer shall maintain the confidentiality of information and data it receives from the Users. The User agrees and acknowledges that the Company shall address and attempt to resolve the complaint received in accordance with the standard policies and procedures adopted by the Company, the User’s disapproval/discontent with the outcome/mode of redressal shall not be deemed to mean non-redressal of the grievance by the Company. Any suggestions by Company regarding use of the Service shall not be construed as a warranty.
24. MISCELLANEOUS
THE INVALIDITY OR UNENFORCEABILITY OF ANY PART OF THIS PRIVACY POLICY SHALL NOT PREJUDICE OR AFFECT THE VALIDITY OR ENFORCEABILITY OF THE REMAINDER OF THIS PRIVACY POLICY. THIS PRIVACY POLICY DOES NOT APPLY TO ANY INFORMATION OTHER THAN THE INFORMATION COLLECTED BY US THROUGH THE PLATFORM. THIS PRIVACY POLICY SHALL BE INAPPLICABLE TO ANY UNSOLICITED INFORMATION YOU PROVIDE US THROUGH THE PLATFORM OR THROUGH ANY OTHER MEANS. ALL UNSOLICITED INFORMATION SHALL BE DEEMED TO BE NON-CONFIDENTIAL AND WE SHALL BE FREE TO USE AND/ OR DISCLOSE SUCH UNSOLICITED INFORMATION WITHOUT ANY LIMITATIONS. THE RIGHTS AND REMEDIES AVAILABLE UNDER THIS POLICY MAY BE EXERCISED AS OFTEN AS NECESSARY AND ARE CUMULATIVE AND NOT EXCLUSIVE OF RIGHTS OR REMEDIES PROVIDED BY LAW. RIGHTS UNDER THIS POLICY MAY BE WAIVED ONLY IN WRITING. DELAY IN EXERCISING OR NON-EXERCISE OF ANY SUCH RIGHT OR REMEDY DOES NOT CONSTITUTE A WAIVER OF THAT RIGHT OR REMEDY, OR ANY OTHER RIGHT OR REMEDY.
25. GOVERNING LAWS AND JURISDICTION
This Privacy Policy, the Platform, the Services, and the use of it is governed by the Applicable Laws of UAE and the court of competent jurisdiction in Dubai shall have exclusive jurisdiction over any disputes connected to our Privacy Policy, Platform or the Services and your use of it.
26. YOUR ACCEPTANCE OF THESE TERMS
BY USING OR VISITING THIS PLATFORM, YOU SIGNIFY YOUR AGREEMENT OF THIS POLICY. IF YOU DO NOT AGREE TO ANY OF THESE TERMS, PLEASE DO NOT USE OUR PLATFORM OR SERVICES.
27. CONTACT US
Email ID: hey@rezio.ai