1. Introduction

Fly & Buy Dubai Real Estate (hereinafter also referred to as “the company,” “we,” “our,” or “us”) is the operator of the website flybeforeyoubuy.com (hereinafter also referred to as “the website,” “the site,” or “the platform”). The company is committed to protecting your privacy rights and making our practices regarding the processing of Personal Data (as defined below) more transparent and fair.

This Privacy Notice (‘Policy’) was created to help you understand what information we collect, use, and share when you use our services, visit our website, or otherwise access our services. You are not legally obliged to provide us with any personal information, but without it, we would not be able to provide you with most of our services or offer you a better experience when using them. By using our website or mobile application, you agree to the terms of this Privacy Notice. If you do not agree to these terms, we ask that you cease using our website or services.

2. Information We Collect

Types of Information

We collect two types of data from you: Personal Data, which refers to information that may identify you, such as your name, email address, and phone number; and Non-Personal Data, which includes technical information about your device, such as the browser you use, its operating system, language preferences, and more. This section details how and when we collect these types of data from you.

Contact Information

When you register to use our services, we collect certain information, such as your email address. If you log in via another account, such as a social media profile, we may collect specific information from those profiles, including your username and any public information you have shared.

Transaction Information

Some purchases you make through the app will be processed by our platform providers, such as Google, Apple, or Facebook. We do not store your financial details, but we may receive information related to your purchases, such as your name, registered email address, or the packages purchased. This information is solely for processing your orders and for accounting purposes.

Usage Information

We collect data whenever you use our services, including your geolocation, clicks, pages visited, time spent on pages, and other activities on our site. Additionally, we collect information about your device, such as its operating system, browser, language, and unique identifiers.

Communication Information

When you contact us via email or the support channels of our services, we collect the personal data you provide. This may include your name, email address, and any additional information you choose to share.

3. Partners and Affiliates

We work with business partners, affiliates, subcontractors, subsidiaries, hosting providers, publishers, web developers, and others. They may receive information about you to facilitate their work, just as we may receive information from them, all in accordance with this Policy and applicable law.

Partners may share information about your activity on our platform, such as traffic analytics or fraud prevention data. We combine this information with data we already collect to provide better services. Partners understand and acknowledge that the internet and communications through it may not always be secure, and that connection to it carries the risk of unauthorised access to systems and stored data. Information transmitted online or stored on related equipment may not remain confidential. We make no guarantees regarding the privacy, security, authenticity, or integrity of such information and accept no responsibility for any consequences or losses arising from internet use.

3.1 Processing of Personal Data

We rely on the partner’s consent to process personal data and/or on the partner’s confirmation that it has obtained the explicit consent of its customers and/or users. In other cases, we may process Personal Data to fulfil contractual obligations, comply with legal requirements, or pursue legitimate interests that do not override the individual’s data protection rights (which may vary by jurisdiction).

The partner acknowledges that data provided to us may contain personally identifiable information or personal data as defined by applicable laws, including the European Union’s (‘EU’) Data Protection Act and UAE legislation.

3.2 Protection of Third-Party Data

If the use of our services requires the partner to process the Personal Data of its customers or end-users via third-party platforms (e.g., Apple, Google, Facebook), the platform acts as the controller and the partner as the processor. The partner agrees to:

• Comply with the platform’s instructions.
• Avoid processing data for purposes other than those specified in the service agreement.
• Implement technical and organisational measures to prevent unauthorised use or loss of data.
• Ensure the reliability of personnel with access to the data.
• Adhere to data protection laws applicable to each platform.
• Report any suspicious activity to the platform immediately.
• Obtain prior consent from the platform before subcontracting any obligations.
• Avoid processing data outside the European Economic Area unless prior written consent is obtained and all platform requirements are met.
• Ensure users have opted in to marketing communications and provide a means to unsubscribe.

4. Cookies

Cookies enhance your experience on our site by storing small data files on your device. They improve functionality, analyse site performance, and personalise content. You may withdraw or modify your cookie consent at any time via your device settings. However, disabling cookies may affect the functionality of some services on our site.

We use Necessary Cookies to support key functionality, Customization Cookies to store your preferences and make a better experience for you when using our services, Advertising Cookies to display tailored ads, and Usage Analytics Cookies to track your interactions on the site to enhance our website features.

5. The Purpose of Processing Your Personal Data

We will only handle personal data if there is a valid legal reason to do so. These reasons may include:

• (i) You have given explicit consent for processing your data for specified purposes;
• (ii) It is essential for fulfilling a contract you are involved in or to take steps before entering such a contract;
• (iii) It supports legitimate interests, such as improving our platform or defending against legal claims;
• (iv) It is necessary to meet agreements with our partners or third-party service providers.

How and Why We Use Personal Data

• Customer Support: Your personal data, such as contact details, is used to assist you with enquiries and customer service needs.
• Enhancing Services: We collect and study data about how you interact with our Services to improve their functionality and user experience.
• Order Processing: We receive non-financial data from payment processors to complete transactions and for accounting purposes.
• Legal Compliance: We may be required to process your personal data to meet regulatory or legal obligations.

6. Sharing Your Data

• Affiliates and Partners: We may share your personal data with our affiliated companies and partners as outlined in this Policy.
• Third-Party Providers: Information may be shared with service providers like data storage companies, who act on our instructions and cannot use the data for other purposes.
• Advertising: Your data may be shared with partners to provide targeted ads or promotional materials that align with your preferences.
• Legal Obligations: We may disclose your information to authorities or others as required by law, or to address unethical or illegal activity.
• Consultants and Auditors: External professionals, such as lawyers or accountants, may access your data to ensure compliance with regulations.
• Business Transactions: If involved in mergers or acquisitions, your data may be transferred but will remain subject to the terms of this Policy.

Transfers of personal data outside the EEA are safeguarded through legally approved mechanisms like adequacy decisions or standard contractual clauses. You can request further details via email.

7. Marketing

We or authorised third parties may use your personal data for promotional purposes. These may include emails, postal correspondence, app notifications, or text messages about our Services or those offered by our Marketing Affiliates.

You can opt out of receiving such communications by contacting us at support@flybeforeyoubuy.com. However, service-related updates may still be sent to you.

8. Data Protection Rights

Certain jurisdictions provide users with specific legal rights concerning their personal data. Subject to legal exceptions and with appropriate identification, you may be entitled to exercise some or all of the following rights:

• Obtain confirmation about whether your personal data is being processed and access the stored data, along with supplementary details.
• Receive a copy of the personal data you voluntarily provided, in a structured, commonly used, and machine-readable format.
• Request corrections to inaccurate or incomplete personal data under our control.
• Request the deletion of your personal data.
• Object to the processing of your personal data by us.
• Request the restriction of the processing of your personal data.
• Submit a complaint to a supervisory authority.

Please note that these rights are not absolute and may be subject to our legitimate interests or regulatory requirements.

To exercise any of these rights, contact us at: support@flybeforeyoubuy.com

When processing your request, we may require additional information to verify your identity, which could include personal data. We will aim to respond within a reasonable time. If you are dissatisfied with our response, you may escalate the matter to the relevant data protection supervisory authority.

9. International Transfers of Personal Data

We may transfer your personal data to third parties, as outlined in this Policy. These recipients may be located in different jurisdictions globally. Where required by law, we implement contractual safeguards to ensure that your personal data is protected. For instance, recipients must adopt effective technological and organisational security measures and limit the use of your data strictly to the purposes for which it was disclosed.

10. How We Protect Your Data

We employ administrative, technical, and physical measures to protect your personal data against unauthorised access, use, or disclosure. Although we strive to ensure confidentiality, we cannot guarantee the absolute security of information.

We encourage you to use discretion when sharing personal data, as transmitting information over the Internet carries inherent risks. Despite our security measures, there is always a possibility that security systems could be breached.

11. Retention and Disposal

Your personal data will be retained for as long as necessary to operate our Website, Mobile Application, or provide the requested Services. We may also retain data to comply with legal obligations, resolve disputes, or enforce our policies.

Retention periods will depend on the type of data and its purpose, taking into account applicable legal requirements and the need to dispose of outdated information promptly. Records such as account opening documents, communications, and transaction details may be retained for as long as required by law.

When a user’s account is terminated, or our partnership with a third party ends, any associated personal data collected through our platform will be deleted in compliance with legal requirements.

You may withdraw your consent for the processing of your personal data at any time by contacting us at the email address below. However, if consent is withdrawn, we may no longer be able to provide certain Services or deliver them as intended. You will have no grounds for complaint in such cases.

The processing of your data will only continue if it is necessary for legitimate interests pursued by us or a third party, provided that these interests do not override your fundamental rights and freedoms.

To inquire about the justification for processing your personal data, contact us at the email address below.

12. Data Collection by Third Parties

When you share your information with other parties, websites, or applications through our Services or on external platforms, the terms and conditions, as well as privacy policies of those third parties, will apply. We encourage you to review the privacy practices of each third party with whom you interact.

This Privacy Notice does not govern the practices of companies we do not own or control, or individuals we do not employ or manage, including third parties to whom we disclose data as described in this Policy.

13. Our Legal Obligation to Disclose Personal Data

We are permitted to disclose personal data when we have reasonable grounds to believe that such disclosure is required by law. Personal data belonging to a visitor, user, and/or Partner may be shared without prior consent in situations where we believe it is necessary to establish the identity of, contact, or initiate legal proceedings against an individual or individuals suspected of violating rights or property belonging to us or others. This includes instances where the activities of the visitor, user, and/or Partner, whether knowingly or unknowingly, are believed to harm or infringe upon such rights and property.

14. Minors

We do not knowingly collect or request personal data from individuals below the age of consent, as defined by the laws of the relevant jurisdiction (“Age of Consent”).

By accessing, using, or interacting with our Services, you confirm that you are at least 18 years old and have reached the Age of Consent in the applicable jurisdiction, including your country of residence and citizenship.

If we become aware that personal data has been collected from an individual under the Age of Consent without verified parental consent, we will take immediate steps to delete the information. Should you suspect that we may hold information regarding an individual under the Age of Consent, please notify us at support@flybeforeyoubuy.com .

15. Updates to This Policy

We assume that all visitors, users, and/or Partners have thoroughly reviewed this Privacy Notice and agree to its terms. If you do not accept this Policy, you are advised to refrain from using our Website and/or Services.

By continuing to use our Services after any revisions to the Privacy Notice become effective, you are acknowledging and agreeing to be bound by the updated terms.

We reserve the right to revise this Policy at any time. The most recent version will always be available on our Website, as indicated by the “Last Updated” date. We encourage you to regularly review this Privacy Notice for any changes.

16. How to Contact Us?

If you have any questions regarding this Privacy Notice, or how we collect and use your data, please feel free to reach out to us at support@flybeforeyoubuy.com .