Online Data Protection Policy
CO_OWN REAL TECH LTD and/or its affiliates and entities (collectively “CO-OWN REAL TECH LTD”, “we” or “us”) values your security and privacy. CO-OWN REAL TECH LTD, as a DIFC registered entity, must comply with Data Protection Law, DIFC Law No. 5 of 2020 (the “DP Law”), and may for certain types of personal data processing, be subject to laws from other jurisdictions.
Scope and Application This Policy applies to persons anywhere in the world who access or use CO-OWN REAL TECH LTD’s Website Services or in the future the App (“Users”).
Collection of Information
Information you give us and information we collect about you and your device
This is the information you give us about you by providing information or filling in forms on any CO-OWN REAL TECH LTD-owned Website Services, on the web App, or by corresponding with us (for example, by telephone, e-mail or any other digital or electronic form).
• information you provide when you register using the CO-OWN REAL TECH LTD-provided online client portal form, or download and register to use the App in the future, search for the App in app stores (including but not limited to Apple App Store and Google Play Store), share data via the social media functions, and when you report a problem with any of our Website Services or App.
• If you contact us, CO-OWN REAL TECH LTD will keep at least an electronic record of such correspondence, including personal information shared at that time.
• technical information, including the type of desktop or mobile device you use, the Internet protocol (IP) address used to connect your computer to the Internet, a unique device identifier (for example, mobile network information, your mobile operating system, the type of mobile browser you use, device token, device type, time zone setting (“Device Information”);
• details of your use of our Website Services or App including, but not limited to traffic data, weblogs and other communication data, and the resources that you access (“Log Information”)
• We may use software tools to measure and collect session information, including page response times, length of visits to certain pages, page interaction information, and methods used to browse away from the page.
• The personal information you give us may include your name, address, e-mail address and phone number, certain device information, username, password, residential building, work address, photograph and other registration information you choose to provide (“Personal Information” or “Personal Data”). If you wish to use the particular feature, you may be asked to consent to your data being used for this purpose. You can alter your consent and sharing selections at any time via your mobile device settings.
Registration and Your Information
If you want to use certain features of the Services you'll have to create an account ("Account"). You can do this via the Site or through your account with certain third- party social networking services such as Facebook (each, an "SNS Account"). If you choose the SNS Account option we'll create your Account by extracting from your SNS Account certain personal information, such as your name and email address and other personal information that your privacy settings on the SNS Account permit us to access. Your SNS Account may not allow you to the full functionality of the Services and additional information may be necessary to take advantage of all Services. It's important that you provide us with accurate, complete and up-to-date information for your Account and you agree to update such information, as needed, to keep it accurate, complete and up-to-date. If you don't, CO-OWN REAL Tech LTD may suspend or terminate your Account. You agree that you won't disclose your Account password to anyone and you'll notify us immediately of any unauthorized use of your Account. You're responsible for all activities that occur under your Account, whether or not you know about, or consent to, them.
The Website Services or App collect and process Personal Data for specific, lawful purposes only, or for the performance of tasks carried out in the interests of CO-OWN REAL TECH LTD.
We do not knowingly collect data from, or market to, children below the legal age as established under their relevant domestic laws, but in no event from children below the age of 18 years. By using the Platform, you represent that you are at least 18 years or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Platform. If we learn that personal information from users who are less than 18 years of age has been collected, we will deactivate the Account and take reasonable measures to promptly delete such personal information from our records.
We may process some of your personal information without your consent
We may collect and process some of your personal information without your knowledge or consent; and only where this is required or permitted by law. We may be compelled to surrender your personal information to legal authorities without your express consent, if presented with a court order or similar legal or administrative order, or as required or permitted by the laws, rules and regulations of any nation, state or other applicable jurisdiction.
3. Use of Personal Data information
We may use Personal Data which you provide to us or we collect from you to:
Provide, maintain, and improve our Website Services and future App development, including, for example, to facilitate payments, send receipts, provide products and services you request (and send related information about them), develop new features, provide customer support to Users, authenticate users, and send administrative messages, whether information or required by applicable law;
Perform internal administration and operations, including, for example, to prevent fraud and abuse of our Website Services; to troubleshoot software bugs and operational problems; to conduct data analysis, testing, and research; and to monitor and analyze usage and activity trends;
Send you communications we think will be of interest to you, including information about products, services, promotions, news, and CO-OWN REAL TECH LTD events, where permissible under DIFC Laws and according to any other applicable laws; and to process contest, sweepstake, or other promotion entries and fulfill any related awards;
to understand your needs and preferences;
improving the content, appearance and utility of the Platform;
to manage and develop infrastructure and business operations;
to administer the Account which you open with us;
to comply with our internal policies and procedures;
to respond to queries or feedback;
to facilitate necessary agreements/ partnerships with third party providers to continue providing the Services;
Notify you about changes to our Website Services and App;
Allow you to participate in any interactive features of our Website Services and App;
Keep our Website Services and App safe and secure; and
Personalize and improve the Website Services, including to provide or recommend features, content, social connections, referrals, and advertisements.
4. Processing, Storage and Transfer of Personal Data
Our company is hosted on the Wix.com platform. Wix.com provides us with the online platform that allows us to sell our products and services to you. Your data may be stored through Wix.com’s data storage, databases and the general Wix.com applications. They store your data on secure servers behind a firewall.
We will take all steps reasonably necessary to ensure your data is processed fairly and lawfully, in accordance with the DP Law, other applicable laws and this Policy. By submitting your Personal Data (including Log, Device and / or Demographic Information), you agree to such transfer, storing or processing in order for CO-OWN REAL TECH LTD to perform its general administrative and regulatory functions, including but not limited to responding to inquiries you raise via the Website Services or App, or maintaining contacts for future informational or promotional activities. Unless otherwise notified, CO-OWN REAL TECH LTD does not ordinarily engage in automated decision making when processing your Personal Data.
You agree that we have the right to transfer the Personal Data described in this Policy to and from, and process and store it in, the United Arab Emirates and (where applicable or required) with processors in other countries, some of which may have less protective privacy laws than those where you reside. Where this is the case, we will take appropriate security measures to protect your Personal Data in accordance with this Policy. All information security policies are strictly enforced.
To preserve the integrity of our databases, to carry out on-going Website Services on behalf of all Users, for research, analytics and statistics purposes and to ensure compliance with applicable laws and regulations, we retain Personal Data submitted by Users for a reasonable length of time unless otherwise prescribed by applicable law. CO-OWN REAL TECH LTD is not responsible for the accuracy of the information you provide, and will modify or update your Personal Data in our databases upon your request, as further outlined below. We will erase or archive from active use your Personal Data upon request, unless we are required to retain it in accordance with CO-OWN REAL TECH LTD or other applicable laws or to perform agreed services. By accessing or using the Website Services or App, you do hereby represent and warrant that you understand that all information submitted by you through the Website Services or App or otherwise to CO-OWN REAL TECH LTD may be used by CO-OWN REAL TECH LTD in accordance with applicable laws and its policies.
4.1 Sharing of Personal Data
We may share Personal Data which we collect about you as described in this Policy or as described at the time of collection or sharing, including as follows:
Through Our Website Services or the App we may share your Personal Data:
With third parties to provide you a service you requested through a partnership or promotional offering made by a third party or us;
With third parties with whom you choose to let us share your Personal Data, for example other apps or websites that integrate with our API or Website Services, or those with an API or Service with which we integrate; and
Other Types of Data Sharing. We may share your Personal Data:
With CO-OWN REAL TECH LTD subsidiaries and affiliated entities;
With vendors, consultants, marketing and advertising partners, and other service providers who need access to such Personal Data to carry out work on our behalf or to perform a contract we enter into with them;
In response to a request for information by a competent authority or government entities if we determine that such disclosure is in accordance with, or is otherwise required by, any applicable law, regulation, or legal process;
With law enforcement officials, government entities or authorities, or other third parties as required by applicable law;
With third parties in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company;
If we otherwise notify you and you consent to the sharing;
With third parties in an aggregated and/or anonymized form which cannot reasonably be used to identify you
All sharing of Personal Data aligns to the extent possible with the Government Data Sharing Policy, which is an internal CO-OWN REAL TECH LTD policy that governs fair and lawful sharing of Personal Data requested by government entities within the UAE and elsewhere.
Types of cookies we drop and the information collected using them include:
• Google Tag Manager - helps make tag management simple, easy and reliable by allowing marketers and webmasters to deploy website tags all in one place.
• Google Analytics - gives website owners the digital analytics tools needed to analyze data from all touchpoints in one place, for a deeper understanding of the customer experience.
• Pingdom - monitors sites and servers on the internet, alerting the website owners if any problems are detected.
• Hotjar - by combining both analysis and feedback tools, Hotjar helps website owners understand what users want, care about and interact with on their website by visually representing their clicks, taps and scrolling behavior.
• Salesforce Chat Solution - lets website owners chat with customers and give them real-time support.
• DoubleClick - a subsidiary of Google which develops and provides Internet ad serving services.
• Twitter Advertising - enables website owners to track and measure the actions users take after viewing or engaging with ads on Twitter.
• Facebook Advertising - lets website owners measure, optimise and build audiences for advertising campaigns.
• LinkedIn Analytics – enables website owners to promote their company updates to targeted audiences on desktop, mobile, and tablet.
Most browsers accept and maintain Cookies by default. Check the ‘Help’ or ‘Settings’ menu of your browser to learn how to change your Cookie preferences. You can choose to alter Cookies settings related to the use of our Website Services, but this may limit your ability to access certain areas of the Website.
Alternatively you may wish to visit an independent source of information, www.aboutcookies.org, which contains comprehensive information on how to alter settings or delete Cookies from your computer as well as more general information about Cookies. For information on how to do this on the browser of your mobile phone you will need to refer to your handset manual or network operator for advice.
We may also use analytics programs such as Google Analytics for web analytics purposes to manage and improve the Platform and/or our Services. Features of Google Analytics that we may use include Remarketing with Google Analytics, Google Display Network Impression Reporting, and Google Analytics Demographics and Interest Reporting. Accordingly, your personal information may be collected for reports such as impression reporting, demographic reporting, interest reporting and to assist with tailoring our online advertising to provide you with a better experience. You may refer to https://policies.google.com/technologies/partner-sites for more information about how your personal information is collected through Google Analytics.
We and our third-party vendors, including Google, use first-party cookies (such as the Google Analytics cookie) or other first-party identifiers, and third-party cookies (such as Google advertising cookies) or other third-party identifiers together, to inform, analyse, optimise, and serve custom ads based on your interests, searches and prior usage patterns when visiting our Platform, and for other market research analysis purposes such as impression reporting and to understand how your interactions with these ads are related to visits to the Platform, amongst others. Therefore, third party vendors may show our ads on other websites or mobile applications. We neither support nor endorse the goals, causes or statements of these websites or mobile applications which display our ads.
Using the Google Ad Settings, you may control the ads you view, block specific advertisers, learn how ads are selected for you, and opt-out of Google Analytics for Display Advertising. To opt out from any collection or use of information by Google Analytics, please download and install the Google Analytics Opt-Out Browser Add-on available here. By opting out, you will not be subject to online advertising or marketing analysis by Google Analytics and you will no longer receive ads tailored to your browsing patterns and usage preferences.
A pixel tag, also known as a web beacon, is an invisible tag placed on certain pages of our Platform but not on your computer. Pixel tags are usually used in conjunction with cookies and are used to monitor the behaviour of users visiting a website.
You may set up your Platform to block cookies which will in turn disable the pixel tags from monitoring your Platform visit.
4.3 External Links
The Website and the App may contain links to other websites on the Internet that are owned and operated by our partners or third parties (the "External Sites"). These links are provided solely as a convenience to you and not as an endorsement by CO-OWN REAL TECH LTD of the contents of or reliability on such External Sites. You acknowledge that CO-OWN REAL TECH LTD is not responsible for the availability of, or the information and content of any External Site. You should contact the site administrator or webmaster for those External Sites if you have any concerns regarding such links or the content located on such external Sites. If you decide to access linked third party websites, you do so at your own risk. CO-OWN REAL TECH LTD does not accept liability, and shall not be liable to you for any loss or damage arising from or as a result of your acting upon the content of another website to which you may link from the Website Services or the App.
5. Your Rights and Choices
Under the Data Protection Law, the Office of the Commissioner of Data Protection of the DIFC is responsible for administering the Data Protection Law. You (in so far as these laws have application) broadly have these rights under the Data Protection Law:
Right to be informed: This means that you may ask us to provide you information on what personal information provided by you we are processing, why, and who else the data may be passed/ transferred to or shared with.
Right to withdraw consent: If you wish for us to stop processing your personal information, it is your right to withdraw consent, preventing us from further processing the same personal information.
Right to rectification: If you have provided your personal information to us, you have the right to request that we correct, or rectify your personal information if the same is incorrect, or outdated. We will endeavor to confirm or verify the information in question, then correct verified inaccuracies and respond to the original inquiry. We will endeavor to send a correction notice to businesses or others whom we know to have received the inaccurate data, where required and / or appropriate. However, some third parties and third party sites may continue to process inaccurate data about you until their databases and display of data are refreshed in accordance with their update schedules, or until you contact them personally to ensure the correction is made in their own files.
Right of access: This is your right to see what data is held about you by us. Any access request generally comes at no cost to you, but may, where permissible, be subject to a fee to meet any extraordinary administrative costs in providing you with details of the information we hold about you.
Right to erasure: This is your right, under certain circumstances, whereby you can ask for your personal information to be deleted. This would apply if the personal information is no longer required for the purposes it was collected for, or your consent for the processing of that personal information has been expressly withdrawn, or where personal information has been unlawfully processed. Some exceptions may apply to your exercise of this right.
Right to object to processing: This is your right to object to the further processing of your personal information which is inconsistent with the primary purpose for which it was collected, which includes processing for profiling, automation and direct marketing.
Right to restrict processing: This is your right to ask for a temporary halt or pause in processing of personal information, such as in the case where a dispute or legal case must be concluded, or the information is being corrected.
Right to data portability: This is your right to ask for any of your personal information, which you have provided your consent for us to process, and which we have processed using automated means, to be provided to you in a structured, commonly used, and machine-readable or electronic format.
Rights in relation to automated decision making and profiling: This is your right not to be subject to a decision based solely on automated processing.
Right not to be discriminated against: This is your right not to be discriminated against by us. This right ensures that your personal information will not influence or affect us and you are not denied any of our Services, charged a different rate for the Services, provided with a different quality of Service simply because of your personal information.
If you wish to exercise any of the rights set out above or any other laws concerning personal information (in so far as same is applicable), please contact us at firstname.lastname@example.org We may need to request specific information from you to help us confirm your identity. This security measure is to ensure that your personal information is not disclosed to any person who has no right to receive it.
We aim to respond to all legitimate requests without undue delay and within one (1) calendar month of receipt of any request from you. Occasionally it may take us longer than one (1) calendar month, if your request is particularly complex, or if you have made duplicated or numerous requests. In this case, we will notify you of receipt of such request(s) and keep you updated as to the status of progress concerning such request(s).
Marketing and Opting Out
CO-OWN REAL TECH LTD supports Users’ legal rights to opt-out of receiving communications from us and our partners. You may change your preferences at any time.
Please note that we may continue to send you transactional or service-related e-mails despite your desire to not receive promotional or marketing e-mail messages. Additionally, please note that if you elect to opt-out of receiving promotional e-mails from one of our Website Services or the App, you may continue to receive promotional emails from our other websites, providers or other, non-affiliated marketers whose services you may have accessed via CO-OWN REAL TECH LTD Website Services or App.
Finally, while we may remove your individual contact information from our professional contacts database, please be aware that if such information is in a different third party's marketing directory through your request or election, you will need to request removal with such third party directly.
6. Changes to this Policy
We may change this Policy from time to time and without notice. If we make significant changes in the way we treat your Personal Data, or to the Policy, we will endeavor to provide you notice through the Website Services or the App or by some other means, such as email. Your continued use of the Website Services or the App after such notice constitutes your acceptance of the changes. We encourage you to periodically review this Policy for the latest information on our privacy practices. We provide links to it through:
Website Services or the App
Incorporating it into our contracts, agreements, and other documents as necessary or appropriate
7. Security Precautions
CO-OWN REAL TECH LTD makes every effort to ensure that your Personal Data is secure on its system. CO-OWN REAL TECH LTD has staff dedicated to maintaining our data protection and security policies, periodically reviewing them and making sure that CO-OWN REAL TECH LTD employees are aware of our data protection and security practices. Unfortunately, no data transmission over the internet can be guaranteed to be 100% secure. As a result, CO-OWN REAL TECH LTD cannot warrant or guarantee the security of any Personal Data you transmit to us, and you do so at your own risk.
CO-OWN REAL TECH LTD has established policies and procedures for securely managing information and protecting Personal Data against unauthorized access. We continually assess our data privacy, information management and security practices. We do this in the following ways:
Establishing policies and procedures for securely managing information;
Limiting employee access to viewing only necessary information in order to perform his or her duties;
Protecting against unauthorized access to Personal Data by using data encryption, authentication and virus detection technology, as required;
Requiring service providers with whom we do business to comply with relevant data privacy legal and regulatory requirements;
Monitoring our websites through recognized online privacy and security organizations;
Conducting background checks on employees and providing training to our employees.
Please note that should your personal information be breached, and the security of your rights be at high risk, we shall promptly and immediately communicate to you the nature of the breach which has taken place, the likely consequences of such a breach and shall describe thoroughly the measures we have implemented to address the breach and to mitigate any and all adverse effects to you and your rights. In the unlikely event of a breach occurring, please reach out to us at email@example.com for further information and further advice on mitigating the potential adverse effects of such a breach.
We also aim to conduct all applicable security risk assessments to ensure the availability of risk mitigation controls, to better safeguard the integrity of User data.
LEGAL RECOURSE TO RELEVANT AUTHORITIES
You have the right to make a complaint at any time to the Commissioner appointed under the DIFC Data Protection Law. However, we would appreciate the opportunity to address your concerns before you approach any such authority. Please contact us in the first instance so that we may try to resolve your complaint swiftly and satisfactorily.
If you have any questions, comments and requests related to this Policy, or if you have any complaints related to how CO-OWN REAL TECH LTD processes your personal data, please contact relevant team at:
CO-OWN REAL TECH LTD
License no 5120
Gate Avenue - South Zone, Level 1, Dubai International Financial Centre, Dubai, United Arab Emirates
Telephone: +971 557950062
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