политика конфиденциальности
Privacy Policy
Sakani respects your privacy and is committed to protecting your Personal Data. This Privacy Policy will inform you as to how we collect, use, disclose, manage and protect your Personal Data when you visit our Platform (regardless of where you visit it from) and/or use our Platform Services.
Please use the definitions below to understand the meaning of some of the terms used in this Privacy Policy. Unless specifically defined, any capitalized terms used throughout this Privacy Policy (but not defined herein) shall have the same meaning attributed to it in Sakani’s General Terms and Conditions. Please read this Privacy Policy carefully before using the Platform or submitting any information to us.
This Privacy Policy will apply when you visit the Platform, sign up for, access, or use our Services, features, technologies or functions offered on or through our Platform. By accessing and using the Platform, or otherwise providing any Personal Data to us, you acknowledge that you have read, understood, and agreed to this Privacy Policy, as amended from time to time, including the manner in which we use your Personal Data. We may, from time to time, amend this Privacy Policy or parts of it in accordance with clause 2.2 below. If you do not agree to any part of this Privacy Policy, or to any changes we subsequently make to this Privacy Policy, you shall immediately cease from accessing our Platform or using any of our Platform Services or otherwise providing any Personal Data or information to us.
1. Definitions:
The following terms are used throughout this Privacy Policy and have specific meanings.
“Applicable Law” means all the laws, rules, regulations, notifications, guidelines, ministerial decisions or cabinet resolutions in force and effect, as of the date hereof and which may be promulgated or brought into force and effect hereinafter in the United Arab Emirates, including judgments, decrees, injunctions, or orders of any court of record, as may be in force and effect during the subsistence of this Privacy Policy;
“Comply with a Legal or Regulatory Obligation” means processing your Personal Data where it is necessary for compliance with a legal or regulatory obligation that we are subject to;
“Data” means Personal Data and/or non-personal User’s data that is submitted, generated, featured and displayed through the Platform, collected from the use of the Service and stored on Sakani’s servers;
“Legitimate Interest” means the interest of our business in conducting and managing our Platform Services to enable us to give you the best service and the best and most secure experience. We consider and balance any potential impact on you and your rights before we process your Personal Data for our legitimate interests;
“Performance of Our Services” means processing your Data where it is necessary for the performance of our Platform Services;
“Personal Data” means information that specifically identifies an individual (such as a name, address, photo, telephone number, mobile number, e-mail address, date of birth, office location, professional and personal interests, company name, title department, spoken languages) or information about that individual that is directly linked to personally identifiable information;
“Platform” means any online tool provided, processed and/or maintained by Sakani (including, but not limited to, through Sakani’s website, all subpages and subdomains, all Content, Platform Services, and other products and services available at or through the Platform located at www.sakanihomes.com or any related domain or any mobile application offering access to, or facilitating the provision of, the Platform Services);
“Privacy Policy” means all of the privacy policies, practices and notices contained or referenced in this document (as amended from time to time) and all other Sakani rules, policies available on the Platform that may be published from time to time on the Platform;
“Sakani’s General Terms and Conditions” means all of the terms, conditions and notices contained or referenced in Sakani’s General Terms and Conditions and all other Sakani rules, policies available at www.sakanihomes.com/terms-and-conditions as amended from time to time;
“User”, “You” and “Your” collectively mean the person, company, or organization that has visited and/or is browsing and/or using the Platform and/or the Platform Services in any capacity. A User may be, without limitation, a seller, buyer, tenant or landlord of a Property, an Agent, all or none of them.
2. Important Information
2.1 Purpose of This Privacy Policy:
This Privacy Policy aims to give you information on how Sakani collects and processes your Personal Data through your use of the Platform, including any Data you may provide through the Platform when you register an Account, use any Platform Services and/or sign up to our newsletter, as well as installing and signing up to any Sakani mobile application.
Our Platform is not intended for minors (persons under the age of 18) and we do not knowingly collect Data relating to minors. If you are a minor, you must have your parent or legal guardian read and agree to this Privacy Policy prior to you using or accessing the Platform or Platform Services.
This Privacy Policy applies to your use of our Platform and/or Platform Services and all information we collect through our Platform Services. By accessing and using the Platform, you (i) agree irrevocably and without condition to this Privacy Policy, and (ii) consent to your Personal Data being collected, processed, used and shared in accordance with this Privacy Policy, and (iii) agree that we may provide notices to you on the terms and conditions set forth in this Privacy Policy and Sakani’s General Terms and Conditions.
It is important that you read this Privacy Policy together with the Sakani’s General Terms and Conditions available at www.sakanihomes.com/terms-and-conditions which may be amended from time to time, and any fair processing notice we may provide on specific occasions when we are collecting or processing Personal Data about you so that you are fully aware of how and why we are using your Data. This Privacy Policy supplements the other notices and is not intended to override them.
Real Estate Agencies are independent of Sakani and may have privacy policies which differ from this Privacy Policy. Real Estate Agencies are responsible for their own privacy policies and privacy practices. Please contact Real Estate Agencies directly for further information on their privacy policies.
2.2 Changes to the Privacy Policy and Your Duty to Inform Us of Any Changes in Your Personal Data.
You agree that Sakani may amend this Privacy Policy from time to time, and in Sakani’s sole discretion. Although we will use our best endeavors to notify you of any amendment to this Privacy Policy, we will not be required to provide you with prior notification of such amendments or changes to this Privacy Policy.
Upon any amendment or change to this Privacy Policy, we will publish the amended Privacy Policy on the dedicated link available at our Platform. Your continued use of the Platform and/or the Platform Services after the publication date of a revised version of this Privacy Policy constitutes your acceptance of its terms.
You agree and undertake to review our Privacy Policy each time you visit our Platform and/or prior to your use of any Platform Services. If you do not agree to our Privacy Policy, as updated from time to time, you undertake to cease using our Platform and/or Platform Services immediately.
Please note that it is crucial to the Performance of our Services and correct working of the Platform that the Personal Data we hold about you is accurate and current. Please keep us informed and updated if your Personal Data changes during your relationship with us.
2.3 Third-Party Links
Our Platform may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share Data about you. We do not control these third-party websites, plug-ins and applications, whether or not they operate on top of the Platform or on an external website, and are not responsible for their privacy statements. When you engage such third-party website, plug-in or application, whether or not you have also left our Platform, we encourage you to read the privacy policy of each website, plug-in or application you visit or engage.
3. The Data We Collect about You
3.1 What is Personal Data?
3.1.1 Depending on which of our Platform Services you use and how you interact with our Platform, we collect different kinds of information from or about you. We may collect, use, store and transfer different kinds of Personal Data about you which we have grouped together as follows:
a) Identity Data includes first name, last name, address, username or similar identifier, title, date of birth, nationality, marital status, profession and gender;
b) Contact Data includes address, location, email address and/or telephone numbers;
c) Technical Data includes internet protocol (IP) address, your login data, browser type and version, make and model (mobile phones only), operating system, hardware version, platform, device settings and other technology identification on the devices used to access our Platform, file and software names and types, device identifiers, time zone setting and location, device locations such as through GPS, Bluetooth or WiFi signals, browser plug-in types and versions, operating system and platform, connection information such as the name of your mobile operator or ISP, browser type, language and time zone, mobile phone number and IP address;
d) Profile Data includes any User profile information, profile picture, any User’s username and password, interests, preferences, feedback and survey responses, rating history and review history;
e) Property Data includes any information about Properties that you may wish to buy, sell or rent, including Property photos, Property location (building name, community, and geographical coordination), building amenities (shared pool and gym), Property metadata (build date, elevator count and floors), apartment amenities (walk-in closet, air condition), apartment metadata (square footage or flooring) and previous transaction history.
f) Usage Data includes information about how you use our Platform, the Platform Services and other products and services and how you use your devices to access our Platform, including the screens you visit and searches you make.
g) Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences
h) Other Data includes:
i. photos or other data uploaded onto any part of our Platform by you or shared with other Users of our Platform by you via our Platform;
ii. communications with us via social media platforms, email, electronic messages and other electronic and non-electronic communications;
iii. third party partner information related to how you use our third-party partners, such as your reviews of Real Estate Agencies;
iv. your networks and connections made available to us, depending on the permissions you have granted, from your mobile and desktop devices' address book contacts, and other social media such as Facebook, Instagram and Twitter.
3.1.2 We also get information about you and your activity outside the Platform from our affiliates, advertisers, partners and other third parties we work with. For example, online advertisers or third parties share information with us to measure, report on or improve the performance of ads, or to figure out what kinds of ads to show you.
3.1.3 We also collect, use and share aggregated Data such as statistical or demographic Data for any purpose. Such aggregated Data could be derived from your Personal Data but is not considered Personal Data as this Data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. We may provide aggregate information to our partners about how our Users, collectively, use our site, so that our partners may also understand how often Users use their services and our Platform Services. However, if we combine or connect aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat such combined Data as Personal Data which will be used in accordance with this Privacy Policy.
3.1.4 We do not collect any Personal Data about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, or genetic and biometric data. Nor do we collect any information about criminal convictions and offenses.
3.2 What Personal Data Do We Collect?
3.2.1 Personal Data You Provide Us With: We receive and store any information you enter on our Platform or that you provide us with in any other way. The types of Personal Data collected may include your name, mobile number, nationality, e-mail address, date of birth, gender, marital status, profession, office location, residential address, company name, job title, department, use information regarding your use of our Platform Services and Platform, and browser information.
The Personal Data you provide is used for purposes such as allowing you to set up an Account, improving the content of the Platform Services, generating Data products and services including recommended communities and Properties, answering customer support or technical questions, customizing any advertising and Content you see, and communicating with you about the Agents and Properties, and our new features. We may also draw upon this Personal Data in order to adapt the Platform Services of our community to your needs, to research the effectiveness of our network and Platform Services, and to develop new tools for the community.
3.2.2 Information Collected Automatically: When you use the Platform Services, Sakani automatically receives and records information on our server logs from your browser or mobile platform, including your location, IP address, cookie information, and the page you requested. We treat this data as non-Personal Data, except where we are required to do otherwise under Applicable Law. Sakani only uses this Data in aggregate form. We may provide aggregate information to our partners about how our customers, collectively, use our site, so that our partners may also understand how often people use their services and our Platform Services.
3.2.3 If You Fail to Provide Personal Data: Where we need to collect Personal Data by Applicable Law, or under the terms of a contract we have with you and you fail to provide that Personal Data when requested, we may not be able to perform our Platform Services. In this case, we may have to cancel the Platform Services which you have with us, provided that we will notify you if this is the case at that time.
4. How Is Your Personal Data Collected?
We use different methods to collect Data from and about you including through:
a) When you communicate with us in writing, by telephone, fax, email or through the Platform or other forms of electronic communication. In this respect, we may monitor, record and store any such communication;
b) From publicly available sources or from third parties;
c) Your devices and how you interact with our Services. You may give us your Personal Data by filling in forms or by corresponding with us by post, phone, and email or otherwise. This includes Personal Data you provide when you:
i. visit or interact with the Platform;
ii. use our Platform Services;
iii. interact with Agents;
iv. subscribe to our publications;
v. enter a competition, promotion or survey;
vi. enter data for installing or using any Sakani powered application and/or installing;
vii. correspond with us (online or offline including via email addresses and phone numbers), if you contact us;
viii. elect to receive marketing communications from us;
ix. post Content on our Platform; and
x. give us feedback and/or review our Platform Services.
d) Automated technologies or interactions. As you interact with our Platform, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this Personal Data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
e) Third parties or publicly available sources. We may receive Personal Data about you from various third-parties and public sources as set out above and Technical Data from the following parties:
i. analytics providers such as Google;
ii. advertising networks/agencies;
iii. search information providers.
f) Our group companies or affiliates; and
g) Contact Data from technical service providers.
5. How Do We Share Your Information?
5.1 Information Shared with Real Estate Agencies: If you interact with an Agent through the Platform, we may share your name, phone number, location and email address with the respective Real Estate Agencies in order for them to provide the Real Estate Services.
5.2 Partners and Service Providers: We may share your Personal Data with partners and service providers we work with, including our data hosting and data storage partners, chatbot providers, analytics and advertising providers, service providers that help us run our marketing and advertising campaigns, contests, special offers, or other events or activities and technology support and data security service providers. We may also share information with professional advisers, such as auditors, law firms, and accounting firms. We require all our partners and service providers to respect the security of Personal Data and to treat it in accordance with Applicable Law. We do not allow our service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions.
5.3 Other Third-Parties: We may share your Personal Data with other third parties with your consent or at your direction to do so, including if you authorize an account connection with a third-party account or platform. For the purposes of this Privacy Policy, an "account connection" with a third party is a connection you authorize or enable between your Account with us and any other account or platform that you lawfully control or own (“Account Connection”). When you authorize such a connection, we may receive information from the third-party about you and your use of the third-party’s service and we may share your Personal Data and other information, to be used in accordance with such third party’s privacy policy. Examples of account connections include, without limitation, linking your Account to an API provider, social media account or social messaging service. Information that we share with a third-party based on an Account Connection will be used and disclosed in accordance with the third-party’s privacy practices. Before authorizing an Account Connection, you should review the privacy notice of any third-party that will gain access to your Personal Data as part of the Account Connection.
5.4 Information Shared with Our Affiliates and Group Companies: We may share your Personal Data with our affiliates and group companies to understand how you engage with our products, to improve our Platform Services, and to help us build Platform Services tailored to your preferences.
5.5 Business Transfer: In the event that Sakani is involved in a merger, acquisition, reorganization, sale of assets or bankruptcy, your information may be sold or transferred as part of that transaction. The promises in this Privacy Policy will apply to your information as transferred to the new entity.
5.6 Protection of Sakani and Others: We may release Personal Data when we believe in good faith that release is necessary to comply with a legal or regulatory obligation or the Applicable Law; enforce or apply Sakani Terms and Conditions and other agreements; or protect the rights, property, or safety of Sakani, our employees, our Users, or others.
5.7 Aggregated and Anonymized Information: We may share aggregated and anonymized information that does not specifically identify you or any other User of our Platform with Real Estate Agencies and Agents or other third parties.
6. How We Use Your Personal Data
6.1 We will only use your Personal Data when the Applicable Law allows us to do so.
6.2 Most commonly, we will use your Personal Data in the following circumstances:
a) Where we need to in order to perform the Platform Services.
b) Where it is necessary for our Legitimate Interests (or those of a third party), and your interests and fundamental rights do not override those interests.
c) Where we need to comply with a legal or regulatory obligation.
6.3 Purposes for Which We Will Use Your Personal Data:
6.3.1 Performance of Our Services
a) We process your Personal Data because it is necessary for the performance of the Platform Services. In this respect, we use your Personal Data for the following:
i. To answer any questions you may have;
ii. To deal with any complaints or feedback you may have;
iii. To develop machine learning based tools to better serve you;
iv. To issue reports/analytics on a no name basis for business and marketing purposes; and
v. For any other purpose for which you provide us with your Personal Data.
6.3.2 Legitimate Interests
a) We also process your Personal Data because it is necessary for our Legitimate Interests, or sometimes where it is necessary for the legitimate interests of another person. In this respect, we use your Personal Data for:
i. The administration and management of our business, such as for archiving or statistical analysis;
ii. Seeking advice on our rights and obligations, such as where we require legal advice;
iii. Contacting you to resolve disputes;
iv. Protecting your, our, or our other Users' rights or property, or the security or integrity of our Platform Services; and
v. Verifying or maintaining the quality and safety of our Platform Services.
6.3.3 Legal Obligations
a) We also process your Personal Data for our compliance with a legal obligation which we are under. In this respect, we will use your Personal Data for the following:
i. To meet our compliance and regulatory obligations, such as compliance with anti-money laundering laws; and
ii. As required by tax authorities or any competent court or legal authority.
6.3.4 Marketing
a) We may send you marketing about the Platform Services we provide which may be of interest to you, as well as other information in the form of alerts, newsletters and invitations to the events or functions which we believe might be of interest to you or in order to update you with information (such as legal or commercial news) which we believe may be relevant to you. We may communicate this to you in a number of ways including by post, telephone, email or other digital channels.
b) You have the right to withdraw/unsubscribe your consent to marketing emails/newsletters at any time by contacting us.
6.3.5 Promotional Offers from Us
a) We may use your Identity Data, Contact Data, Technical Data, Usage Data and Profile Data to form a view on what we think you may want or need, or what may be of interest to you, either manually or by the use of digital information systems. This is how we decide which Services, and offers may be relevant for you. You may receive marketing communications from us if you have requested information from us or purchased services from us and, in each case, you have not opted out of receiving that marketing.
6.3.6 Third-Party Marketing
a) We will get your express opt-in consent before we share your Personal Data with any company outside Sakani for marketing purposes.
b) You may ask us or third parties to stop sending you marketing messages at any time by logging into the Platform and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting us at any time at contact@sakanihomes.com.
6.3.7 Cookies
a) Our Platform uses web technologies such as cookies to distinguish you from other users of our Platform. This helps us to provide you with a good experience when you browse our Platform and also allows us to improve our Platform.
b) We use the following cookies:
i. Strictly necessary cookies. These are cookies that are required for the operation of our Platform. They include, for example, cookies that enable you to log into secure areas of our Platform or make use of e-billing services.
ii. Analytical/performance cookies. They allow us to recognize and count the number of Users and to see how Users move around our Platform when they are using it. This helps us to improve the way our Platform works, for example, by ensuring that Users are finding what they are looking for easily.
iii. Functionality cookies. These are used to recognize you when you return to our Platform. This enables us to personalize Content for you, greet you by name and remember your preferences (for example, your choice of language or region).
iv. Targeting cookies. These cookies record your visit to our Platform, the pages you have visited and the links you have followed. We will use this information to make our Platform and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
c) While we set some of these automated technologies ourselves, some of them are set by third-parties who provide services to us. For example, we may use other companies’ web analytics services such as Google Analytics, which use automated technologies to help us evaluate how our Users use our Platform.
d) You can set your browser to refuse all or some browser cookies or to alert you when our Platform sets or accesses cookies. If you disable or refuse cookies, please note that some parts of our Platform may become inaccessible or not function properly.
6.3.8 Change of Purpose
We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by Applicable Law.
7. Data Security
7.1 We have put in place appropriate security measures to limit the possibility of your Personal Data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality.
7.2 We implement and maintain appropriate technical, security and organizational measures in relation to the processing of your personal data so that the processing will meet the requirements of Applicable Law and ensure the protection of your rights.
7.3 Although we aim to create a safe and secure environment, we cannot guarantee absolute security of the transmission or storage of your information. To the extent permitted by the Applicable Law, we expressly exclude any liability arising from any unauthorised access to your Personal Data.
7.4 We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so under Applicable Law.
7.5 Please contact us at contact@sakanihomes.com immediately if you become aware of any unauthorised use of your Account by anyone else or any other breach of security.
8. Data Retention
We will only retain your Personal Data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements. In some circumstances, we may anonymize your Personal Data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
9. Transfers
9.1 The Personal Data that we collect from you may be transferred to, and stored at, a destination outside of the United Arab Emirates in accordance with the Applicable Law. By using the Platform and availing the Platform Services, you agree that your Personal Data may be transferred to, and stored at, a destination outside of the United Arab Emirates.
9.2 Your Personal Data may also be processed by staff operating outside the United Arab Emirates who work for us or for one of our service providers. Such staff may be engaged in, among other things, the fulfilment of the Platform Services and the provision of support services. Your Personal Data may be transferred, stored, processed and used by our affiliated companies and/or non-affiliated service providers in one or more countries outside the United Arab Emirates.
9.3 Depending on the circumstances we may also need to transfer Personal Data to other kinds of third parties, for example regulators, government authorities, law enforcement authorities (such as police) as necessary.
10. Your Rights
10.1 You may have certain rights under Applicable Law in relation to your Personal Data, including the right to receive information about the Personal Data being processed, the right to request transfer of Personal Data, the right to correction or erasure of Personal Data, the right to correction or completion of inaccurate Personal Data, the right to restrict Personal Data processing, and the right to stop Personal Data processing.
10.2 To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Personal Data (where consent is our legal basis for processing your Personal Data), please contact us at contact@sakanihomes.com.
10.3 You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
10.4 We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you.
10.5 We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
11. Your Choices
11.1 You May Change Your Personal Information
Depending on the type of the information, you may access, review, change, or correct such information by logging into your Account (in your Account settings) at any time or by making a request to us by contacting us at contact@sakanihomes.com. We may require additional information to verify your identity before granting access or otherwise changing or correcting your information.
11.2 You May Deactivating Your Account
If you wish to deactivate your Account, you can do so by emailing us at contact@sakanihomes.com.
12. Privacy Disputes
You will resolve any claim, cause of action or dispute (claim) you have with us arising out of or relating to this Privacy Policy exclusively before the Courts of Dubai. The laws of the United Arab Emirates will govern this Privacy Policy, as well as any claim that might arise between you and us, without regard to conflict of law provisions.
13. Questions?
If you have any questions or need to contact us regarding our Privacy Policy or anything set out above you may contact us at contact@sakanihomes.com.
Effective as of the 23rd of February, 2023.