01 Who we are
Darrap ("Darrap", "we", "us", "our") is a real-estate intelligence service for the Dubai property market, operated by [LEGAL ENTITY NAME], a company registered in [JURISDICTION — e.g. Lithuania / Portugal, EU] under registration number [REG. NO.], with registered address at [REGISTERED ADDRESS].
For the purposes of the EU General Data Protection Regulation (GDPR), the UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (the "UAE PDPL"), and — where applicable — the DIFC Data Protection Law No. 5 of 2020, we act as the data controller for the personal data described in this policy.
Questions about this policy or your data can be sent to [privacy@darrap.com]. Our Data Protection Officer / contact is [DPO NAME OR "not appointed — see Section 11"].
02 What this policy covers
This policy explains what personal data we collect through our website darrap.com and our application at app.darrap.com, why we collect it, how we use and share it, how long we keep it, and the rights you have. Our use of cookies and similar technologies is described in our Cookie Policy, which forms part of this policy.
03 The data we collect
| Category | Examples | Source |
|---|---|---|
| Account & contact | Email, WhatsApp number, role (buyer/broker), name (if provided) | You, when you register or contact us |
| Preferences | Budget range, areas of interest, saved goals and tracked properties | You, while using the app |
| Conversation | Messages you send to the assistant, voice input you choose to record | You |
| Usage & device | Pages viewed, approximate location (from IP), device/browser type, referrer, campaign parameters (UTM) | Automatically, subject to your cookie consent |
| Technical | IP address, log data, security signals (e.g. reCAPTCHA) | Automatically |
We do not ask for and ask you not to send us sensitive identity documents (passport, Emirates ID) or bank/payment-card details through the website or chat. Property and market figures we show are derived from official Dubai Land Department records and are not personal data about you.
04 Why we use it & legal basis
Under GDPR we rely on the following legal bases (the UAE PDPL recognises equivalent grounds — consent, contract, legitimate interest and legal obligation):
| Purpose | Legal basis |
|---|---|
| Provide the service, answer your questions, save your goals and portfolio | Performance of a contract / your request |
| Respond to enquiries and connect you with a property specialist | Your request / legitimate interest |
| Send service and (where you opt in) marketing messages | Consent / legitimate interest |
| Analytics to understand and improve the site | Consent (cookie banner) |
| Advertising measurement (Meta Pixel, campaign tracking) | Consent (cookie banner) |
| Security, fraud prevention, keeping records | Legitimate interest / legal obligation |
Where our basis is consent, you may withdraw it at any time — see Cookie settings or contact us. Withdrawal does not affect processing done before withdrawal.
05 Cookies & tracking
We do not load analytics or advertising cookies until you give consent through our cookie banner. Strictly necessary cookies, which keep the site working and secure, are always active. Full details and your controls are in the Cookie Policy.
06 Who we share data with
We do not sell your personal data. We share it only with:
- Service providers (processors) who run parts of our service under contract — for example hosting and infrastructure ([Cloudflare, Google Firebase]), email delivery ([Mailjet]), messaging ([Twilio / WhatsApp]), analytics and advertising ([Google, Meta] — only with your consent).
- Property specialists / brokers we work with, where you ask to be contacted or to be connected about a property. A licensed Dubai brokerage may receive your enquiry to follow up.
- Authorities where required by law, or to protect our rights, safety, or property.
07 International transfers
We operate across the EU and the UAE, and some of our providers are located outside your country. Where personal data of EU/UK individuals is transferred outside the EEA/UK, we rely on appropriate safeguards such as the European Commission's Standard Contractual Clauses or an adequacy decision. Transfers under the UAE PDPL are made only to jurisdictions with adequate protection or under the safeguards the law permits. You can request details of the safeguards we use.
08 How long we keep it
We keep personal data only as long as needed for the purposes above: account and preference data for as long as your account is active and for a reasonable period afterwards; enquiry and conversation data for up to [e.g. 24 months]; and analytics data for the retention period set in the relevant tool. We then delete or anonymise it.
09 Your rights
Subject to the applicable law, you have the right to: access your data; correct it; delete it; restrict or object to processing; receive it in a portable format; and withdraw consent. EU/UK individuals may lodge a complaint with their supervisory authority; UAE individuals may complain to the UAE Data Office (and DIFC residents to the DIFC Commissioner of Data Protection).
To exercise any right, contact [privacy@darrap.com]. We respond within the timeframes the law requires (one month under GDPR, unless extended).
10 Children
Darrap is intended for adults and is not directed at anyone under 18. We do not knowingly collect data from minors. If you believe a minor has provided us data, contact us and we will delete it.
11 Security & changes
We use technical and organisational measures appropriate to the risk to protect your data, and separate marketing, operational and analytics datasets. No system is perfectly secure, and we cannot guarantee absolute security.
We may update this policy; the "last updated" date will change and, for material changes, we will take reasonable steps to notify you.
12 Contact
[LEGAL ENTITY NAME]
[REGISTERED ADDRESS]
Email: [privacy@darrap.com] · Support: support@smartdubaiproperties.com