Sobha Privy Collection – Luxury Villas & Penthouses in Dubai

Welcome to Sobha Realty’s privacy notice which is effective from 4 August 2019. Sobha LLC (UAE) and its group companies, including Sobha Real Estate UK Limited (Collectively “Sobha Group”), are committed to protecting your personal data. This privacy notice provides information about what to expect when Sobha Group collects and processes your personal information. You will also be informed about your privacy rights and how the law protects you.

GLOSSARY

Legitimate Interest is our lawful interest in conducting and managing our business to enable us to give you the best service/product.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Third Parties means:

Companies within the Sobha Group other than the ones to whom you are providing your personal data.
Organisations we need to share your personal information with to provide you with the product or service you have chosen.
Revenue & Customs, regulators, and other authorities.
Fraud prevention and law enforcement agencies.
Companies that we introduce to you.
Agents and advisers who we use to help run your relationship with us, collect what you owe, and explore new ways of doing business.
Companies we have a joint venture or agreement to co-operate with.
Organisations that introduce you to us.
Companies you ask us to share your data with.

We may also share your personal information if the composition of Sobha Group changes in the future:

We may choose to sell, transfer, or merge parts of our business, or our assets. Or we seek to acquire other businesses or merge with them.
During any such process, we may share your data with other parties. We will only do this if they agree to keep your data safe and private.
If the change to our Group happens, then other parties may use your data in the same way as set out in this notice.

1. IMPORTANT INFORMATION

Purpose of this privacy notice

This privacy notice aims to give you information on how Sobha Group collects and processes your personal data, including any data you may provide through this website. It is important that you read this privacy notice so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Controller

Sobha LLC (UAE) is the controller and responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice). We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this Privacy Notice or our privacy practices please contact us at: DPO@sobha-me.com. You have the right to make a complaint at any time to the Information Commissioner’s Office (the “ICO”), the UK’s supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Third-party links

This website 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 and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website or application you visit.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract. We will notify you if this is the case.

Updating your personal data with us

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

2. THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store, and transfer different kinds of personal data about you which include:

Identity Data, which includes first name, maiden name, last name or similar identifier, marital status, title, date of birth, gender, country of residence, and nationality.
Documentary Data, which includes copies of your passport, driver’s licence, ID card, proof of address, etc.
Contact Data, which includes billing address, delivery address, email address, and telephone numbers.
Financial Data, which includes bank account and payment card details.
Contractual Data, which includes details about the products or services we provide to you.
Transaction Data, which includes details about payments to and from you and other details of products and services you have purchased from or through us.
Open Data, which includes details about you that are in public records, and information about you that is openly available on the internet.
Social Relationships Data, which includes your family, friends, and other relationships.
Location Data, which includes data we get about where you are.
Technical Data, which includes internet protocol (IP) address, your login data (where applicable), browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our websites.
Communications Data, which includes what we learn from you from letters, emails (and other forms of electronic communication), and conversations between us.
Profile Data, which includes your username and password (if any), purchases or services requested by you, your interests, preferences, and feedback.
Usage Data, which includes information about how you use our website, products, and services.
Marketing and Communications Data, which includes your preferences in receiving marketing from us and your communication preferences.
Special Category Data, which includes details about your race or ethnicity and information about criminal convictions and offences. We will only collect and use these types of data if the law requires or allows us to do so.

We also collect, use, and share Anonymous Data such as statistical or demographic data for any purpose. Anonymous Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity.

3. HOW IS YOUR PERSONAL DATA COLLECTED

We may collect personal information about you (or your business) from these sources: Data you give us:

When you apply for our services or purchase our products;
When you talk to us on the phone;
When you use our website;
In letters, emails, and other forms of electronic communication;
In customer surveys or promotions;
If your business is looking to enter into or has entered into a business arrangement with us;
When you make payments to us in relation to the services or products we are providing to you.
Companies that introduce you to us;
Fraud prevention and law enforcement agencies;
Retailers;
Social networks;
Public information sources such as Companies House;
Agents working on our behalf;

4. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data:

Where we need to perform a contract we are about to enter into or have entered into with you.
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.
Where we need to comply with a legal or regulatory obligation including any obligation arising out of applicable anti-money laundering regulations.
Where we want to use your personal data for purposes similar to the one for which the personal data is provided.

Where we send direct marketing communications to you, or if we process any Special Category Data we will rely on your consent. For all other purposes, we generally do not rely on consent. You have the right to withdraw your consent at any time by contacting the DPO.

Purposes for which we will use your personal data

We usually collect your data for the following purposes:

To register you (or your business) as a new customer or supplier
To deliver our services/products including:
To process your instructions and requests
To Manage payments and fees/charges
To Collect and recover money owed to us
To manage our relationship with you which will include:
Notifying you about changes to our terms and conditions or privacy policy
Studying how our customers use products and services from us and other organisations
Developing and carrying out marketing activities
To develop and manage our brands, products, and services and to manage how we work with other companies that provide services to us and our customers
To manage risk for us and our customers, to obey laws and regulations that apply to us, and to respond to complaints and seek to resolve them
To run our business in an efficient and proper way. This includes managing our financial position, business capability, planning, communications, technical, and corporate governance
To exercise our rights set out in agreements or contracts
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
To use data analytics to improve our website, products/services, marketing, customer relationships, and experiences
To make suggestions and recommendations to you about goods or services that may be of interest to you.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact the DPO if you need details about the specific legal ground we are relying on to process your personal data. We make sure we consider and balance any potential impact on you and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

Promotional offers from us We may use your Identity, Contact, Technical, Usage, and Profile Data to form a view of what we think you may want or need, or what may be of interest to you. This is how we decide which products, services, and offers may be relevant for you. You will receive marketing communications from us (or from another company within the Sobha Group or third-party vendor appointed by us) if you have requested information from us, if you have provided your express consent for receiving that marketing, or, in certain cases if it is in our legitimate interest.

Third-party marketing We will not share your personal data with any company outside the Sobha Group for marketing purposes.

For Opting out You can ask us to stop sending you marketing messages by contacting the DPO at any time. Where you opt out of receiving these marketing messages, you will still receive important information such as changes to your existing services or products purchased from us.

Cookies

You can set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.

Telephone Calls

We may monitor and/or record your telephone calls to us, or ours to you, or a third-party vendor appointed to do so, to ensure consistent servicing levels (including staff training) and account operation, to assist (where appropriate) in dealing with complaints or disputes, and to assist us in ensuring we comply with our legal obligations.

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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact the DPO.

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 law.

5. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below:

Companies within the Sobha Group.
External Third Parties as set out in the Glossary.
Third parties to whom we may choose to transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party 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.

6. INTERNATIONAL TRANSFERS

We share your personal data within the Sobha Group. This may involve transferring your data outside the European Economic Area (EEA). Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring that we use specific contracts or have robust policies which give personal data the same protection it has in Europe. Companies within the Sobha Group are expected to comply with the group’s Data Protection Policy with is applicable to all employees within the group. Please contact the DPO if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7. DATA SECURITY

We have implemented appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised 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. We have put in place procedures to deal with any personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

The safety and security of your information also depend on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for the circumvention of any privacy settings or security measures contained on the Website.

8. DATA RETENTION

We will only retain your personal data for as long as necessary to fulfil 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 unauthorised 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. Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting the DPO. 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. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include:

Requesting access to your personal data.
Requesting correction of the personal data that we hold about you
Requesting erasure of your personal data.
Objecting to processing of your personal data.
Requesting restriction of processing of your personal data.
Requesting the transfer of your personal data to you or to a third party
Withdrawing consent at any time where we are relying on consent to process your personal data.

If you wish to exercise any of the rights set out above, please contact us on DPO@sobha-me.com. Note, however, that while we will generally comply with your requests, in certain scenarios we may be able to comply with your request for specific legal reasons which will be notified to you, if applicable, at the time of your request.

No fee usually required

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 unreasonable, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

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.

Time limit to respond

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 and keep you updated.

PRIVACY POLICY UK & EU