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Privacy Policy

Effective Date: 14 MAY 2025

This Privacy Policy describes how www.a2a.ae ("we," "us," or "our"), located in No. 5 DEP, Dubai UAE, collects, uses, and shares personal information of users ("Real estate Brokers" or "you") who register for and use our online social media platform dedicated to real estate brokers (the "Platform"). This Privacy Policy is governed by and construed in accordance with the laws of the United Arab Emirates, including Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (PDPL). We are committed to protecting your privacy and ensuring the security of your personal information. This policy also outlines your rights regarding your personal data under the PDPL.

1. Information We Collect

We collect the following personal information from Brokers when they register for and use the Platform:

  • Account Information:
    • Name
    • Contact Information (e.g., phone number, email address)
    • Company Details (e.g., brokerage name, address)
    • User Roles (e.g., agent, manager)
    • WhatsApp number (if you explicitly consent to share it for networking purposes)
    • Social media links (if you explicitly consent to share them for networking purposes)
    • Profile information you choose to share (e.g., specialization, profile picture)
    • Username and password
  • Content You Share:
    • Property listings, including descriptions, images, and relevant details.
    • Client requirements and related information you share in posts or messages.
    • Communications you exchange with other Brokers on the Platform, including messages, comments, and forum posts.
    • Transaction-related information (e.g., deal details, parties involved), to the extent you choose to record these on the platform.
  • Usage Information:
    • Information about your interactions with the Platform, such as the pages you visit, the features you use, and the actions you take.
    • Log data, including your IP address, browser type, operating system, access times, and referring URLs.
    • Device information, including device type and unique device identifiers.
  • Information from Third-Party Sources:
    • In limited circumstances, we may collect information from third-party sources, such as professional networking platforms (e.g., LinkedIn) or CRM systems, but only if you have connected those accounts to our platform, or where we have a legitimate basis to do so.

2. Legal Basis for Processing Personal Data

We process your personal data based on one or more of the following legal bases as permitted under the PDPL:

  • Consent: For the processing of your contact information (WhatsApp number, social media links) for the purpose of enabling direct networking with other Brokers, we rely on your explicit consent, which will be obtained during the registration process or when you choose to share this information in your profile. You have the right to withdraw your consent at any time through your account settings.
  • Contractual Necessity: Processing of your name, contact information, and company details is necessary for the performance of the contract you enter into with us when you register and use the Platform to access its core functionalities and facilitate transactions with other brokers.
  • Legitimate Interests: We may process certain usage data for our legitimate interests in improving the Platform, ensuring its security, and understanding user behavior to enhance our services for Brokers, provided that such interests do not override your rights and freedoms.
  • Legal Obligations: We may process your personal data to comply with applicable laws and regulations in the United Arab Emirates.

3. How We Use Your Information

We use your personal information for the following specified and legitimate purposes:

  • To Provide and Maintain the Platform:
    • To create and manage your account.
    • To enable you to share property listings and client requirements.
    • To facilitate communication and networking between Brokers.
    • To personalize your experience on the Platform.
    • To provide user support and respond to your inquiries.
    • To monitor and improve the functionality and performance of the Platform.
  • To Facilitate Communication and Networking (Based on Consent):
    • To allow other Brokers to view your profile information (including name and contact details, WhatsApp number, and social media links only if you have provided explicit consent) to connect with you.
    • To enable you to contact other Brokers based on their shared information.
    • To send you notifications and updates related to the Platform and other Brokers' activities (based on your preferences).
  • To Facilitate Transactions:
    • To enable Brokers to record and manage transaction details on the platform, if you choose to use those features.
  • To Ensure Platform Integrity and Security:
    • To detect, prevent, and address fraud, security breaches, and other harmful activity, in accordance with the UAE Cybercrime Law.
    • To enforce our Terms of Service.
  • For Analytics and Improvement:
    • To analyze Platform usage trends and user behavior to improve our services and offerings for our business users (Brokers) (based on legitimate interests).
    • To develop new features and functionalities tailored to the needs of real estate brokers.
    • To generate aggregated and anonymized data for market analysis and reporting.

4. Sharing Your Information

We may share your personal information with the following categories of recipients, ensuring we do so in accordance with the PDPL:

  • Other Brokers on the Platform: Information you share in your profile (including name, contact details, WhatsApp number, and social media links only if you have provided explicit consent), company details, property listings, client requirements, and communications will be visible to other registered Brokers on the Platform.
  • Service Providers: We may engage third-party service providers located within or outside the UAE to assist us with various functions, such as hosting, analytics, customer support, payment processing (if applicable), and security. We will ensure that these service providers have appropriate data protection agreements in place that comply with the PDPL, particularly regarding cross-border data transfers if applicable.
  • Professional Advisors: We may disclose your personal information to our professional advisors, such as lawyers, accountants, and auditors, where necessary for the purposes of obtaining professional advice or managing legal claims.
  • Legal Compliance and Protection: We may disclose your personal information if required to do so by law, legal process, or governmental request in the UAE, or when we believe in good faith that disclosure is necessary to protect our rights, property, or safety, or the rights, property, or safety of others, in compliance with UAE law.
  • Business Transfers: In the event of a merger, acquisition, or sale of all or a portion of our assets, your personal information may be transferred to the acquiring entity, in accordance with applicable UAE laws. We will provide notice to you before your personal information is transferred and becomes subject to a different privacy policy.

5. Your Choices and Rights under the PDPL

As a data subject in the UAE, you have certain rights regarding your personal data under the PDPL:

  • Right to Access: You have the right to request access to your personal data held by us.
  • Right to Rectification: You have the right to request the correction of inaccurate or incomplete personal data.
  • Right to Erasure (Right to be Forgotten): Under certain circumstances, you have the right to request the erasure of your personal data.
  • Right to Restriction of Processing: You have the right to request the restriction of the processing of your personal data under certain circumstances.
  • Right to Data Portability: You may have the right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit it to another controller.
  • Right to Object: You have the right to object to the processing of your personal data in certain situations, including for direct marketing purposes.
  • Right to Withdraw Consent: Where processing is based on your consent, you have the right to withdraw your consent at any time. The withdrawal of your consent will not affect the lawfulness of processing based on consent before its withdrawal.

To exercise any of these rights, please contact us using the contact information provided in Section 12. We will handle your requests in accordance with the PDPL.


6. Data Security

We implement appropriate technical and organizational measures designed to protect your personal information against unauthorized access, use, disclosure, alteration, or destruction, in line with Article 15 of the PDPL. These measures include:

  • Encryption of sensitive data during transmission and storage.
  • Secure servers located within the UAE or in jurisdictions with adequate data protection safeguards.
  • Access controls based on roles and responsibilities, with strict limitations on who can access personal data.
  • Regular security audits and vulnerability assessments.
  • Implementation of firewalls and intrusion detection/prevention systems.
  • Employee training on data protection best practices and the requirements of the PDPL.
  • Data loss prevention (DLP) measures.

However, no method of transmission over the internet or electronic storage is completely secure, and we cannot guarantee absolute security. In the event of a data breach, we will take steps to comply with any applicable data breach notification requirements under UAE law.


7. Data Retention

We will retain your personal information only for as long as necessary to fulfill the specified purposes for which it was collected, or as required by applicable laws in the UAE, including the PDPL's storage limitation principle. We will establish and implement a data retention policy that outlines the retention periods for different categories of personal data, taking into account the following factors:

  • The length of time you use our Platform.
  • Any legal obligations that require us to keep data for a certain period.
  • The necessity of retaining data to resolve disputes, enforce our agreements, and protect our legal rights.

8. Cross-border Data Transfers

If we transfer your personal data outside the United Arab Emirates, we will do so in compliance with Chapter 7 of the PDPL, ensuring that the recipient country or territory provides an adequate level of data protection as determined by the relevant authorities in the UAE, or that appropriate safeguards are in place, such as:

  • Binding Corporate Rules (BCRs).
  • Standard contractual clauses approved by the relevant authorities in the UAE.
  • Adherence to an approved code of conduct or certification mechanism.

9. Third-Party Links

Our Platform may contain links to third-party websites or services. We are not responsible for the privacy practices of those third-party websites. We encourage you to review the privacy policies of any third-party websites you visit.


10. Children's Privacy

Our Platform is intended for use by real estate brokers and is not directed to individuals under the age of 18. We do not knowingly collect personal information from children. If you become aware that a child has provided us with personal information, please contact us, and we will take steps to delete such information in accordance with UAE law.


11. Compliance with TRA Guidelines

We are committed to ensuring that all content and activities on our Platform comply with the guidelines issued by the Telecommunications Regulatory Authority (TRA) in the UAE, including regulations concerning prohibited content that may be against public order, public morals, or otherwise illegal under UAE law.


12. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our data practices or legal requirements in the UAE. We will notify you of any material changes by posting the new Privacy Policy on the Platform or by other means, such as email. Your continued use of the Platform after the effective date of the revised Privacy Policy constitutes your acknowledgment and acceptance of the changes.


13. Contact Us

If you have any questions or concerns about this Privacy Policy or our data practices, or if you wish to exercise your rights under the PDPL, please contact us at:

support@a2a.ae

By registering for and using our Platform, you acknowledge that you have read, understood, and agree to the terms of this Privacy Policy, which is governed by the laws of the United Arab Emirates.