Privacy Notice

Updated on 8th April 2025

Privacy and security hold the utmost importance to us at Proptech Systems Ltd (PropSpace, we, our, or us) and we are committed to protecting and respecting your privacy.

This privacy notice (“Privacy Notice”) is meant to help you understand how your personal data, as defined in the Data Protection Law DIFC Law No. 5 of 2020 (as amended from time to time) ("Personal Data) and information is collected, used and disclosed when you use our services pursuant to a contract with us, or access or use our website (located at: www.propspace.com), any related websites, social media platforms owned or operated by us and associated mobile applications (the “Sites”).

Please read this Privacy Notice carefully to understand our views and practices regarding your Personal Data and how we will treat it.

If you do not wish for your Personal Data to be processed, stored, and used in the manner set out by the terms of this Privacy Notice please do not provide any Personal Data or information to us.

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DATA PROCESSOR VERSUS DATA CONTROLLER

Under the Data Protection Law DIFC Law No. 5 of 2020 (the "Law"), we acts as either a Data Controller or a Data Processor, depending on the nature of the personal data processed and the purposes for which it is used.

When We Acts as a Data Processor:

  1. Our function as a Data Processor when providing its real estate CRM services to our Customers. In this capacity, we process personal data on behalf of the Customer, who determines the purposes and means of processing. This includes, but is not limited to:
    1. Personal data related to the Customer’s clients (property owners, landlords, sellers, buyers, tenants, or prospective tenants and buyers, etc.) is entered into the CRM system.
    2. Property-related information is associated with identifiable individuals.
    3. Communications between the Customer and its clients within the CRM platform.

As a Data Processor, we process this data solely in accordance with the Customer’s instructions, subject to the terms of any data processing agreement entered into between us and the Customer, in compliance with the Law.

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When PropSpace Acts as a Data Controller:

We function as a Data Controller when it determines the purposes and means of processing personal data for its own business operations. This includes:

  • Personal data of the Customer’s representatives or employees provided during account registration, contract negotiation, or customer support interactions.
  • Personal data submitted through our website, social media platforms, or other communication channels (e.g., inquiries regarding services, job applications, or marketing subscriptions).
  • Data collected for fraud prevention, security monitoring, or compliance with legal obligations.

As a Data Controller, we are responsible for ensuring that such data is processed in accordance with the principles set out in the Law, including transparency, purpose limitation, and data subject rights.

Obligations and Responsibilities

Where we act as a Data Processor, it will:

  • Process personal data only on documented instructions from the Customer, unless required otherwise by law.
  • Implement appropriate technical and organizational measures to ensure data security.
  • Assist the Customer in fulfilling its obligations under the Law, including responding to data subject rights requests.

Where we acts as a Data Controller, it will:

  • Ensure that personal data is collected and processed lawfully, fairly, and transparently.
  • Provide individuals with clear information about how their data is used.
  • Uphold data subject rights as set out in the Law, including the right to access, rectify, and erase personal data.

For further details on how we process personal data, please refer to the other sections of this Privacy Notice.

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LEGAL BASIS

The legal basis for processing personal data depends on the specific circumstances under which it is collected and used. We rely on the following legal bases for processing personal data:

1. Legal Obligation

Where the processing of personal data is required to comply with a legal or regulatory obligation to which we are subject, the legal basis for processing will be compliance with a legal obligation. This may include:

  • Compliance with record-keeping, anti-money laundering, or regulatory reporting requirements.
  • Responding to requests from law enforcement, regulatory bodies, or government authorities where required by law.
  • Fulfilling obligations related to fraud prevention, cybersecurity, and data protection.

2. Contractual Necessity

Where a contract exists between us and the data subject, we process personal data on the basis of contractual necessity. This applies where processing is necessary to:

  • Provide our services as agreed under a contract.
  • Manage customer relationships, including account registration, service delivery, and customer support.
  • Administer billing, payments, and other contractual obligations.

3. Consent

Where there is no legal obligation or contractual relationship, we process personal data based on the data subject’s consent. By voluntarily providing personal data, the data subject consents to the processing of their data for the specified purposes. This includes:

  • Submitting inquiries through our website, social media platforms, or other communication channels.
  • Providing personal data for job applications or marketing communications.
  • Engaging with optional features of our Sites that require the collection of additional personal data.

Data subjects have the right to withdraw their consent at any time by contacting us by email to: support@propspace.com..  Such requests are subject to legal or regulatory requirements that may continue to apply.

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INFORMATION WE COLLECT FROM YOU

The Personal Data and information we may collect and process are:

  1. Information you give us
    1. When you sign up to our Sites or create an account, we gather registration details, including your name, email, login credentials, address, country and phone number (for multi-factor authentication and important notifications). Additionally, we may collect any additional information you provide, such as a profile picture.
    2. When you contact us via contact forms, phone, email, chat services, or other means for questions about our services, customer support or when you participate in surveys, user interviews, or respond to queries, we will collect the Personal Data and information you provide in these interactions, including (without limitation) contact details, uploaded images, and message content.
    3. We may employ vendors to offer interactive features on our Sites, and any information you submit through these features may be retained by us. For example, our chat service may capture and store chat transcripts for customer support purposes. Please refrain from sharing sensitive data through these channels unless specifically requested as part of our service provision. By providing such information directly, you consent to its processing by us and our vendors.
    4. Occasionally, we may collect biometric data through vendors for identity verification and fraud prevention. Your biometric data will be managed by our vendors in compliance with relevant laws and policies.
    5. For payment processing, analytics, and other services, we utilise providers like Stripe (or other similar providers from time to time), who may collect personal data such as your name, address, phone number, bank account, credit card and debit card details (as applicable), including transactional and device information, to enhance service quality, prevent fraud, and conduct analytics.
    6. When using our real estate CRM services, you may input, upload, or transmit personal data related to your clients, including property owners, landlords, buyers, tenants, or prospective tenants and buyers. This may include:
      1. Contact details and identification data of property owners, landlords, buyers, and tenants.
      2. Property-related details, including addresses, transaction history, and financial information relevant to real estate transactions.
      3. Communications between Customers and their clients facilitated through our CRM platform, such as messages, emails, or notes regarding property inquiries, negotiations, and contract discussions.
  2. Information we collect about you
    1. Throughout your visits to our Sites, we may automatically gather the following details:
      1. Technical Information:
        1. Internet protocol (IP) address used to connect your device to the internet.
        2. Login details, browser type, version, and time zone settings.
        3. Browser plug-in types, operating system, and platform.
      2. Visit Information:
        1. Full Uniform Resource Locators (URL) clickstream, including date and time.
        2. Pages and listings viewed or searched for.
        3. Page response times, download errors, and length of visits to specific pages.
        4. Page interaction details such as scrolling, clicks, and mouse-overs.
        5. Methods used to navigate away from pages and any phone number used to contact customer service.
      3. Device & Usage Information:
        When you interact with us through our services, we automatically receive certain information from the devices you use to access them. This passive collection of data includes geolocation details, internet browser or mobile device specifications, originating website, operating system, and location data through your IP address, indicating the location of your login.
      4. Location Information:
        To access our services, you may need to provide specific details regarding your place of residence. We also utilize your location data as outlined in this Privacy Notice, including its use in aggregate form.
      5. Cookies and Other Electronic Technologies:
        We employ cookies and similar technologies to enhance your experience on our Sites and more information can be found in our Cookies Policy found at: www.propspace.com/terms
      6. Analytics:
        We utilise web analytics vendors, like Google Analytics, to understand how users interact with our services and improve them accordingly. This includes tracking user behaviour, website origins, and providing features such as dynamic remarketing and interest-based advertising.
      7. Mobile Device Settings:
        When accessing our Sites using a mobile device, we may also receive and collect identification numbers associated with your device, mobile carrier, device type and manufacturer, and, if enabled, geographical location data (including GPS).  Please note that some of the Personal Data and information we collect, for example an IP address, can sometimes be used to approximate a device's location.

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USE AND DISCLOSURE OF PERSONAL DATA

  1. We use your Personal Data in the following ways:
    1. To fulfil services and meet obligations from contracts between you and us. This includes delivering requested information and services.
    2. To inform you about services similar to those you've already inquired about, as well as to provide suggestions, information and recommendations about other offerings we believe may interest you.
    3. To contact you for administrative purposes, such as providing customer support, responding to inquiries or resolving issues.
    4. To send communications related to our services and our Sites, including updates, event notifications, and feedback requests.
    5. To communicate via email, SMS or WhatsApp message regarding your account. You can opt out by emailing us at: support@propspace.com.
    6. To operate, maintain, improve, optimise and enhance our services and Sites, including enabling access and facilitating transactions.
    7. To secure our services, verify identity, prevent fraud, and improve security features. This includes multi-factor authentication and withdrawal setups.
    8. For Customization and marketing purposes, such as personalising content based on user interaction and location.
    9. For internal operations, troubleshooting, data analysis, testing, research, statistical and survey purposes to ensure optimal functioning and presentation of content on our Sites.
    10. To facilitate interactive features of our services and maintain the safety and security of our Sites.
    11. To defend legal rights, comply with laws, and enforce our Terms of Service, policies, or other contracts that we may have with you.
    12. In scenarios such as corporate sales, mergers, or reorganisations, your Personal Data and user information may be part of the transferred assets.
  2. We may disclose your Personal Data and information in the following manner:
    1. among our related entities for various purposes, including providing services, marketing, customer support, and improving services.
    2. with third-party companies to perform business-related functions on our behalf, such as marketing, data storage, security, and payment processing.
    3. with third-party organisations if you consent to such disclosure.
    4. We may anonymize, or de-identify collected Personal Data and information to create reports to understand usage trends, preferences, and demographics and for research purposes and may disclose such data to affiliates, partners, or third parties.
    5. as outlined in the relevant section regarding cookies and similar electronic technologies.
    6. to other users of our services if you choose to make it publicly available in areas such as comments.
    7. to credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you.
    8. via transferring such data to a third-party in relation to an acquisition or reorganisation of PropSpace.
  3. 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 or is permissible by law. If we wish to use your Personal Data for any other purpose, we will notify you and we will explain the need. We may process Personal Data without your consent, in compliance with the above rules, where this is required or permitted by law.

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VOLUNTEERED INFORMATION

  1. We also collect Personal Data and information through forums and communities, surveys and customer support communications, your communication to us of ideas for new products or modifications to existing products, feedback and other solicited or unsolicited submissions (“Volunteered Information”).
  2. By sending us Volunteered Information, you further  agree that we are under no obligation of confidentiality, express or implied, with respect to the Volunteered Information. This section shall survive any termination of your account or the services we offer you.

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SECURITY

While no organisation can guarantee perfect security, PropSpace has implemented and seeks to continuously improve technical and organisational security measures to protect the Personal Data and information provided via the services from loss, misuse, unauthorised access, disclosure, alteration, or destruction.

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RETENTION OF YOUR PERSONAL DATA AND INFORMATION

  1. We retain your Personal Data and information for as long as we deem necessary for the purpose for which that information was collected and for our legitimate business operations; provided, however, that your Personal Data and information is only retained to the extent permitted or required by applicable laws. Further details of the periods for which we retain data are available on request.
  2. When we no longer need to retain your Personal Data and information, we will take reasonable steps to remove it from our systems and records and/or take steps to anonymize it so that you can no longer be identified from it in accordance with our internal document retention policies. When determining the retention period for your Personal Data and information, we take into account various criteria, such as the type of products and services requested by or provided to you, the nature and length of our relationship with you, possible re-enrolment with our products or services, the impact on the services we provide to you if we delete some of your Personal Data and information and mandatory retention periods provided by law.

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WHERE WE STORE YOUR PERSONAL DATA

  1. We will store your Personal Data and information in one or more of the United Arab Emirates, England, or Ireland.  Our servers are located in England and may be changed from time to time.
  2. As a global company, we may transfer your personal data to our affiliates, service providers, or other third parties located outside the United Arab Emirates for the purposes outlined in this Privacy Notice. Such transfers may involve the processing of your personal data in countries with data protection laws that may differ from those in the United Arab Emirates.
  3. We will only transfer your Personal Data internationally where permitted by applicable data protection laws and where we have implemented appropriate safeguards to ensure the protection and security of your Personal Data.
  4. We take the security of your personal data seriously and implement reasonable technical, physical, and organisational measures to protect your personal data during international transfers. However, please note that no method of transmission over the internet or method of electronic storage is completely secure, and we cannot guarantee the absolute security of your personal data during international transfers.
  5. If your personal data is transferred internationally, you may have the right to request access to, rectification, erasure, or restriction of processing of your personal data in accordance with applicable data protection laws. In some cases you may also have the right to object to the processing of your personal data. You can lodge a complaint with the relevant data protection authority if you believe that your rights have been violated.
  6. Please contact us if you want further information on the countries to which we may transfer Personal Data and the specific mechanism used by us when transferring your Personal Data outside the United Arab Emirates.
  7. By submitting your Personal Data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Notice.
  8. All Personal Data and information you provide to us are stored on our secure servers. Any payment transactions will be encrypted. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Sites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
  9. Unfortunately, the transmission of Personal Data and information via the internet is not completely secure. Although we will do our best to protect your Personal Data, We cannot guarantee the security of your data transmitted to our Sites; any transmission is at your own risk. Once we have received your Personal Data and information, we will use strict procedures and security features to try to prevent unauthorised access.

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YOUR RIGHTS

  1. We will not retain data longer than is necessary to fulfil the purposes for which it was collected or as required by applicable laws or regulations.  
  2. If permissible by the applicable laws, you may request that we delete your Personal Data by contacting us at: support@propspace.com. However, if the retention of certain Personal Data is essential for the fulfilment of obligations under any applicable laws we may retain such data.
  3. If you would like to access or have a copy of the Personal Data we hold about you, please contact us at support@propspace.com. Please provide as much information as you can about the information you are looking for so that we can deal with your request as quickly as possible.
  4. You have the right to ask us not to process your Personal Data for marketing purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data.  You can also exercise the right at any time by contacting us at: support@propspace.com.

UPDATING YOUR DETAILS

  1. Should any of the Personal Data and information you have provided to us undergo changes, such as; alterations to your email address, name, payment details, or any other provided information or if you harbour concerns regarding the accuracy of Personal Data or account information held on the Sites, please do not hesitate to contact us at: support@propspace.com.
  2. We are committed to promptly reviewing and updating our records to ensure their accuracy and relevance.

THIRD PARTY LINKS AND WEBSITES

  1. Our Sites may, from time to time, contain links to and from the websites of our partner networks, advertisers, and affiliates.  
  2. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies.  Please check these policies before you submit any Personal Data to these third party websites.

PROTECTION OF CHILDREN’S PRIVACY

  1. Our Sites are not directed to individuals under the age of eighteen (18), and we request that these individuals do not provide Personal Data through our Sites.
  2. We do not knowingly collect Personal Data and information from children under 18 without parental consent.  

MARKETING OPT OUT

  1. Every email marketing communication we send will include instructions allowing you to opt out of receiving future marketing messages. Moreover, should you decide at any point that you no longer wish to receive such communications or wish to have your name removed from our mailing lists, please reach out to us at: support@propspace.com.
  2. Even if you choose to opt out of marketing communications, we can still send you emails concerning your account or any services you have requested or received from us.

COMPLAINTS

You may submit a written complaint about how we handle your Personal Data and information to our Data Protection Officer at: support@propspace.com. If you are not satisfied with our handling of your complaint or we have not replied to you within a reasonable period of time, then you are entitled to make a complaint to a data protection authority or supervisory authority.

HOW TO CONTACT US‍

  1. Ensuring transparency and accountability regarding data privacy is paramount to us, and we are committed to providing comprehensive assistance to you regarding any questions or queries you may have about how your Personal Data and information is collected, used, and stored.
  2. Our dedicated support team is readily available to address any concerns and provide detailed explanations regarding the collection methods, purposes, and security measures employed to safeguard your Personal Data and you may contact us at: support@propspace.com.

CHANGES TO OUR PRIVACY NOTICE

  1. Any changes we may make to this Privacy Notice will be posted at https://www.propspace.com/legals/privacy-policy and may in some circumstances in our sole discretion be notified to you by email.
  2. Continued use of our Sites or services whether by contract or not, after any such changes to these conditions implies acceptance of the revised privacy notice.