Privacy Notice

This Privacy Notice explains how Insiders Platform Real Estate L.L.C (“Insiders”, “we”, “us”, or “our”) handles personal information across the Platform. It forms part of, and should be read together with, our Terms of Use.

1. Purpose of this Privacy Notice

This Privacy Notice explains:

1. what personal information we collect;
2. how and why we use it;
3. who we may share it with;
4. how long we retain it;
5. how we protect it; and
6. the rights available to individuals.

Insiders acts as the controller of personal information collected for its own Platform, transaction, compliance and business purposes.

In some situations, an Agency Partner or another organisation may separately control information uploaded by its users. Each organisation remains responsible for its own lawful collection and use of personal information.

2. Personal information we collect

Depending on how the Platform is used, we may collect:

2.1 Account information

• name;
• email address;
• telephone number;
• profile image;
• country and location;
• language;
• job title;
• account type;
• login credentials; and
• communication preferences.

2.2 Agency and business information

• company name;
• registration number;
• licence information;
• registered address;
• agency size;
• administrator details;
• authorised-user list;
• billing contact; and
• tax information.

2.3 Identity and compliance information

• passport or Emirates ID information;
• date of birth;
• nationality;
• residence;
• signature;
• proof of address;
• beneficial ownership information;
• source-of-funds or source-of-wealth information;
• sanctions and politically exposed person screening results; and
• other KYC or AML information.

2.4 Client and Opportunity information

Information uploaded or supplied by Users may include:

• Client name;
• contact details;
• nationality and residence;
• property requirements;
• budget;
• preferred areas;
• family or occupancy requirements;
• investment objectives;
• payment-plan preferences;
• communications;
• Opportunity and transaction history;
• booking and contract documents; and
• compliance information.

2.5 Transaction information

• selected property;
• unit and project information;
• booking details;
• payment confirmations;
• contracts;
• transaction status;
• developer communications;
• commission amounts;
• payout status; and
• bank or invoice information.

2.6 Subscription and payment information

• selected plan;
• billing address;
• invoices;
• payment status;
• transaction identifiers;
• partial payment-card information received from payment providers; and
• renewal or cancellation records.

We generally do not store complete payment-card numbers where payment is processed by an external payment provider.

2.7 Platform and technical information

• IP address;
• device type;
• browser;
• operating system;
• login activity;
• pages and features used;
• search and filter activity;
• AI prompts and responses;
• marketing-generator activity;
• timestamps;
• crash and diagnostic data;
• approximate location; and
• cookie or similar-technology identifiers.

2.8 Communications

• emails;
• support messages;
• chat messages;
• call notes;
• meeting records;
• feedback;
• complaints; and
• correspondence with account managers or closing teams.

2.9 Information from third parties

We may receive information from:

• Agency Partners;
• Authorised Users;
• Clients;
• developers;
• banks;
• mortgage providers;
• payment processors;
• KYC and sanctions providers;
• service providers;
• public databases;
• regulators; and
• other transaction participants.

3. How we use personal information

We may use personal information to:

1. create and manage accounts;
2. authenticate Users and protect account security;
3. provide Platform functions;
4. manage Agency Accounts and seats;
5. process Client Opportunities;
6. match Clients with properties;
7. facilitate developer registrations and bookings;
8. complete KYC, AML and sanctions screening;
9. prepare and process transaction documents;
10. coordinate with developers and transaction providers;
11. track commissions and payouts;
12. process subscriptions and billing;
13. provide customer support and account management;
14. operate AI and marketing tools;
15. personalise Platform content;
16. send project, launch and offer updates;
17. improve and develop the Platform;
18. monitor performance and usage;
19. prevent fraud, misuse and security incidents;
20. comply with legal, regulatory and professional obligations;
21. establish, exercise or defend legal claims; and
22. send marketing where permitted.

4. Legal bases for processing

Depending on the circumstances, we process personal information where:

1. the individual has given consent;
2. processing is necessary to perform or prepare a contract;
3. processing is required to comply with legal or regulatory obligations;
4. processing is necessary to protect legitimate interests, provided those interests do not improperly override individual rights;
5. processing is necessary to establish or defend legal claims;
6. processing is necessary to protect public interest; or
7. another lawful basis applies.

The UAE Personal Data Protection Law generally prohibits processing without consent unless a recognised legal exception applies.

Where consent is the legal basis, consent may ordinarily be withdrawn, but withdrawal does not invalidate processing already lawfully completed and may affect our ability to provide certain services.

5. Client information uploaded by Users

A User or Agency Partner uploading Client information is responsible for ensuring that:

1. the information was collected lawfully;
2. an appropriate privacy notice was provided where required;
3. required consent or another lawful basis exists;
4. the information is relevant and not excessive;
5. it is accurate to the User’s knowledge; and
6. the Client is not being uploaded merely for bulk marketing or speculative registration.

We use uploaded Client information only for the purposes described in these terms, including processing the relevant Opportunity, providing requested services, compliance and transaction completion.

We do not intentionally use uploaded Client data to bypass the User or for unrelated marketing without an appropriate legal basis.

6. AI processing and automated tools

6.1 AI prompts and responses

When Users interact with AI features, we may process:

1. prompts;
2. uploaded Client requirements;
3. property preferences;
4. Platform data used to generate a response;
5. generated responses; and
6. User feedback.

Users should avoid entering personal information that is not necessary for the requested task.

6.2 Human review

AI output may be reviewed by authorised personnel or service providers where reasonably necessary for:

1. support;
2. quality improvement;
3. security;
4. error investigation; or
5. compliance.

6.3 Automated decisions

We do not intend to make legally significant decisions about individuals solely through automated AI processing without appropriate safeguards.

The UAE Personal Data Protection Law provides rights concerning decisions resulting from automated processing, including profiling.

7. Sharing personal information

We may share personal information with:

7.1 Insiders personnel

Employees, brokers, closing managers, account managers, compliance personnel and authorised contractors who need access for their work.

7.2 Developers and sellers

For project enquiries, Client registration, unit confirmation, booking, contracting, commission and transaction management.

7.3 Transaction providers

Including:

• banks;
• mortgage advisers;
• conveyancers;
• trustees;
• escrow parties;
• valuation providers;
• KYC providers;
• payment processors;
• legal advisers;
• visa providers; and
• other service providers requested by the User or Client.

7.4 Technology providers

Including providers of:

• cloud hosting;
• databases;
• email;
• messaging;
• analytics;
• cybersecurity;
• customer support;
• payment processing;
• electronic signatures; and
• AI technology.

7.5 Agency Partners

Agency Administrators may have access to activity, Clients, Opportunities, deals and reporting connected to their Agency Account.

7.6 Authorities and legal recipients

We may disclose information to:

• government bodies;
• courts;
• regulators;
• law-enforcement authorities;
• tax authorities;
• sanctions authorities; and
• professional advisers,

where required or permitted by law.

7.7 Corporate transactions

Information may be shared in connection with a proposed or completed merger, investment, acquisition, restructuring, financing or sale of assets, subject to appropriate safeguards.

7.8 No sale of personal data

We do not sell personal information as a standalone commercial product.

8. International transfers

Because Insiders works with international Users, Clients, developers and service providers, personal information may be processed outside the individual’s country of residence.

Where required, we will use appropriate safeguards for international transfers, which may include:

1. transfers to jurisdictions recognised as providing appropriate protection;
2. contractual protections;
3. consent where valid and appropriate;
4. transfers necessary for a contract or transaction; or
5. another legally permitted transfer mechanism.

9. Retention

We retain personal information only for as long as reasonably necessary for:

1. the purposes for which it was collected;
2. account and subscription administration;
3. active and historical transactions;
4. commission and payment records;
5. KYC, AML and regulatory requirements;
6. tax and accounting obligations;
7. fraud prevention;
8. legal claims; and
9. security and audit records.

Retention periods vary by information type and legal obligation.

When information is no longer required, we may securely delete, anonymise or aggregate it.

Account deletion does not require immediate deletion of information we must retain for legal, compliance, accounting, transaction or dispute purposes.

10. Data security

We use reasonable technical and organisational measures designed to protect personal information, including measures such as:

1. access controls;
2. authentication;
3. encrypted transmission where appropriate;
4. monitoring and logging;
5. secure cloud infrastructure;
6. employee confidentiality obligations;
7. restricted access to sensitive documents; and
8. incident-response procedures.

No system is completely secure, and we cannot guarantee that unauthorised access, loss or misuse will never occur.

Users are responsible for maintaining secure passwords, devices and account credentials.

11. Data breaches

Where a personal-data breach occurs, we will investigate and take reasonable steps to:

1. contain the incident;
2. assess its effects;
3. reduce potential harm;
4. restore security; and
5. notify affected individuals or authorities where legally required.

Users and Agency Partners must immediately notify us of any suspected loss, unauthorised access, disclosure or misuse involving Platform or Client information.

12. Individual privacy rights

Subject to applicable law and relevant exceptions, individuals may have the right to:

1. obtain information about processing;
2. request access to personal information;
3. request correction of inaccurate or incomplete information;
4. request deletion where appropriate;
5. request restriction or suspension of processing;
6. object to certain processing;
7. withdraw consent where processing relies on consent;
8. request transfer of information in a structured, machine-readable format where applicable;
9. object to certain automated decisions; and
10. complain to the relevant authority.

The UAE Personal Data Protection Law includes rights concerning correction or erasure, restriction of processing, data portability and automated decisions.

To submit a request, contact privacy@insidersofdubai.com.

We may request information necessary to verify identity and authority before completing a request.

Some rights may be limited where retention or processing is required for legal, regulatory, transaction, security or legal-claim purposes.

13. Marketing preferences

Users may manage optional marketing preferences through:

1. unsubscribe links;
2. account settings;
3. email requests; or
4. communication preferences made available by Insiders.

Even after opting out of marketing, we may continue to send essential communications concerning:

• security;
• billing;
• transactions;
• Client activity;
• account administration;
• legal notices; and
• requested services.

14. Cookies and similar technologies

We may use cookies, pixels, local storage and similar technologies to:

1. maintain login sessions;
2. remember preferences;
3. protect security;
4. understand Platform performance;
5. diagnose errors;
6. analyse usage;
7. personalise content; and
8. support marketing where permitted.

Cookie controls may be made available through the Platform or browser settings.

Disabling essential cookies may prevent parts of the Platform from functioning correctly.

15. Children

The Platform is intended for professional and business users aged 18 or older.

Users must not knowingly upload personal information concerning a child unless it is genuinely required for a lawful transaction or service and the appropriate parent, guardian or legal authority has provided any required permission.

16. Third-party links and websites

The Platform may link to developer websites, social-media services, payment pages or other third-party services.

Their privacy practices are governed by their own notices.

Users should review third-party privacy terms before providing information directly to them.

17. Changes to this Privacy Notice

We may update this Privacy Notice to reflect:

1. changes to the Platform;
2. new processing activities;
3. new service providers;
4. legal or regulatory developments; or
5. changes to our operations.

Material changes will be communicated through the Platform, email or another reasonable method.

The effective date will be shown at the top of the document.

18. Contact information

Questions, requests or complaints concerning these terms or privacy may be sent to:

General support — support@insidersofdubai.com
Privacy — privacy@insidersofdubai.com
Legal and formal notices — finance@insidersofdubai.com

Insiders Platform Real Estate L.L.C
Office 1705/1706, Marina Plaza
Dubai Marina, Dubai
United Arab Emirates