1. Introduction
We, Pure Value Technologies Ltd (the “Company”, “we”, “our”, “us”), are committed to safeguarding your privacy and protecting your personal data. This Privacy Policy explains how we collect, use, disclose and safeguard personal data in connection with our platform and services (the “Services”) for automated valuations of residential real estate in the United Arab Emirates (UAE).
By using our Services, you acknowledge you have read and understood this Policy and you consent to the processing of your personal data as described herein.
2. Scope & Applicability
- This Policy applies to personal data of natural persons (“Data Subjects”) whose personal data we collect or otherwise process in the context of providing our Services in or from the UAE.
- Under the PDPL, “personal data” means any data relating to an identified or identifiable natural person, including name, voice, image, identification number, online identifier, geolocation or one or more physical, physiological, economic, cultural or social characteristic.
- The PDPL applies to companies located in the UAE, as well as companies outside the UAE that process the personal data of individuals in the UAE.
- Please note that this Policy may not cover processing by entities in certain free zones that are subject to their own data-protection laws (e.g., Dubai International Financial Centre (DIFC) or Abu Dhabi Global Market (ADGM)).
3. Definitions
- Controller means the person or organisation that determines the purposes and means of processing personal data.
- Processor means the person or organisation that processes personal data on behalf of the controller.
- Data Subject means the natural person to whom the personal data relates.
- Automated Valuation Service means the service we provide which uses algorithms, models and data analytics to generate residential real-estate valuations.
- Personal Data means any information relating to a Data Subject as defined above.
- Sensitive Personal Data means personal data that is particularly intrusive (e.g., biometric data, health data, race, religion). The PDPL treats this category with additional caution.
4. What Personal Data We Collect
Depending on your interaction with our Services, we may collect and process the following categories of personal data:
- Contact and identity data: name, email address, telephone number, postal address, national identification number or passport number (if voluntarily provided).
- Property-related data: address of residential property, ownership status, property size, property type, transaction history, market comparables, geolocation or map coordinates of the property.
- Usage data: information about how you use our website, platform or mobile application, including IP address, device identifiers, browser type, operating system, login times, clicks and navigation patterns.
- Automated decision-making / profiling data: data derived from your input and external data sources to produce the automated valuation.
- Third-party data: public records, third-party real-estate databases, market data providers, data crowdsourcing platforms.
- (Where applicable) If you register for an account or submit a property valuation request: username, password (hashed/stored securely), payment/billing information (if relevant, through our payment provider).
Important note: We only collect personal data that is necessary for the purpose of providing our automated valuation Services. This is in line with the data-minimisation principle under PDPL.
5. How We Use Personal Data
We use your personal data for the following purposes:
- To provide you with the automated valuation report for residential real estate.
- To enable your access to our platform, manage your account, authenticate you, provide customer support.
- To analyse market trends, improve our algorithmic models, conduct internal research and development, enhance our Services.
- To comply with legal obligations, including anti-money-laundering or regulatory requirements (if applicable).
- To send you service-related communications (such as updates about the valuation service, platform changes, notifications). If you have consented, we may also send you marketing communications; you may withdraw consent at any time.
- To detect, prevent and respond to fraud, abuse, security incidents and misconduct.
- To anonymise or aggregate your data for statistical or analytical purposes, where individual identification is eliminated.
We will not process your personal data for purposes incompatible with those stated above unless we first notify you and obtain any required consents.
6. Legal Basis for Processing
Under the PDPL, we must ensure a lawful basis for processing personal data. These include:
- Your explicit consent (where required) – freely given, specific, informed and unambiguous.
- The necessity of processing for the performance of a contract to which you are party (for example, where you request a valuation service).
- Compliance with a legal obligation to which we are subject.
- Processing being in our legitimate interests where permitted – note: the PDPL does not explicitly include “legitimate interests” as a lawful basis in the same way as some other jurisdictions.
7. Automated Decision-Making and Profiling
Because our Services involve algorithmic/automated valuations, we provide details as follows:
- Your personal data may be processed automatically to generate a valuation of your residential property (this is automated decision-making).
- You have the right to obtain human intervention, express your point of view and contest the automated decision.
- We ensure that the algorithmic process is based on objective criteria and data inputs, and we apply appropriate safeguards to avoid unfair outcomes or bias.
- If you wish to exercise your right to object to automated processing, please contact us using the contact details set out below.
8. Sharing and Transfer of Personal Data
8.1 Recipients
We may share your personal data with:
- Service providers and processors who assist us in providing the Services (e.g., cloud providers, hosting, payment processors, analytics firms).
- Third-party data providers (real-estate databases, market data aggregators).
- Regulatory or governmental authorities as required by law or to defend our legal rights.
- Affiliates or business partners, where you have consented or this is necessary for the Services.
8.2 Cross-Border Transfers
If your personal data is transferred outside the UAE, we will ensure compliance with the PDPL’s requirements for cross-border data flows:
- Transfers to a country that provides adequate data protection are permitted.
- If the destination country does not provide adequate protection, then we will implement appropriate safeguards (e.g., contractual terms, employee confidentiality obligations, encryption) and obtain your explicit consent if required.
- Where necessary, we will notify you and document the transfer as required under the PDPL’s accountability obligations.
9. Data Retention
We retain your personal data only for as long as is necessary for the purposes set out in this Policy (including to satisfy any legal, accounting, or reporting requirements).
When your data is no longer necessary, we will either securely delete it or anonymise it such that it can no longer be associated with you.
We maintain internal records of data processing activities, retention schedules and destruction procedures, consistent with our accountability obligations under the PDPL.
10. Data Subject Rights
Under the PDPL, you have the following rights as a Data Subject:
- Right of access: to request access to the personal data we hold about you.
- Right to correction/rectification: if your personal data is inaccurate or incomplete.
- Right to erasure (“right to be forgotten”): under certain circumstances you may request deletion of your Personal Data.
- Right to restriction of processing: where the accuracy is contested, processing is unlawful, or you object to processing.
- Right to objection: you may object to processing of your personal data, including profiling or automated decision-making.
- Right to data portability: to receive your personal data in a structured, machine-readable format and transmit it to another controller.
- Right to withdraw consent: where processing is based on consent, you may withdraw it at any time (but this does not affect the lawfulness of processing prior to withdrawal).
- Right to complain: you may lodge a complaint with the UAE Data Office (the federal regulator) or another competent authority.
If you wish to exercise any of the rights above, please contact us using the details below. We will respond within a reasonable timeframe in line with PDPL requirements.
11. Security Measures
We take appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure or destruction. These may include:
- Encryption of data at rest and in transit.
- Pseudonymisation or anonymisation where feasible.
- Access controls and authentication procedures.
- Regular security assessments, audits and penetration testing.
- Implementing incident response and breach-notification procedures.
- Ensuring that our service providers and processors are bound by contractual obligations regarding confidentiality, data security and approved data-handling practices.
These steps reflect the PDPL’s requirement for controllers and processors to implement appropriate safeguards.
12. Data Breach Notification
In the event of a personal-data breach that may result in a risk to the rights and freedoms of Data Subjects, we will notify the UAE Data Office and the affected Data Subjects as required under the PDPL or its Executive Regulations (once issued).
13. Cookies and Similar Technologies
Our website/platform may use cookies and similar tracking technologies to enhance your experience, track usage patterns, optimise performance and provide targeted content. You will be presented with a cookie banner (or equivalent notice) at your first visit and may manage your preferences at any time.
Details about the cookies we use, their purpose and retention periods are available in our Cookie Policy (if applicable) or upon request.
14. Children
Our Services are not intended for children under the age of 18. We do not knowingly collect personal data of children. If we become aware that we have inadvertently collected such data, we will take steps to delete it.
15. Changes to this Privacy Policy
We may update this Privacy Policy from time to time (for example, to reflect changes in the PDPL, the execution of relevant regulations, our business model or services). We will notify you of material changes (e.g., by email or via our platform). We recommend that you review this Policy periodically.
The “Effective Date” at the top of the Policy indicates the date of the current version.
Effective Date: 9/11/2025
Last Updated: 9/11/2025