documentation

Privacy Policy

Last updated on 22 March 2021

1. Agreement to our Privacy Policy

Thank you for choosing to avail our services! 

When you visit our website at http://www.agent-view.com (Website), and more generally, use any of our services to provide or experience a safe, fully digital tour of one or multiple real estate property(ies) (Services), we appreciate you trusting us with your personal information. Personal information includes any information which may, by itself, or in collaboration with other information be able to identify you. We take your privacy very seriously; and so this Privacy Policy (Policy) as amended from time to time sets out how Think Lab DMCC with Commercial License No. DMCC187308, including all subsidiary and affiliated entities (hereinafter referred to as the Company, Agent View, we, us or our as the context requires) collects, processes, uses, maintains, stores, transfers, discloses, erases or destroys your confidential and personally identifiable user data, obtained from and through our platforms and related services offerings, via the Agent View website, mobile application and its platforms or portals and any other features or content related, linked, or otherwise connected thereto (Site). The specific data points which we collect from you are explained below in this Policy. We are committed to protecting your (user, you or your) personal information and right to privacy. 

The Site is hosted in AWS EU West 1. It is important that you read this Policy in full, so that you are fully aware of how and why we are using your data. If there are any terms in this Policy that you do not agree with, please discontinue use of our Services immediately.

This Policy together with our Terms of Use, and Disclaimer Policy govern your access to and use of the Site. By using the Site, you agree to be bound by these policies, which supplement and are incorporated into our Terms of Use. This Policy does not intend to override any of our Terms of Use. 

2. Changes to this Privacy Policy

From time to time, we may revise, amend or supplement this Policy to reflect necessary changes in law, our personal data collection and usage practices, the features of our Services or Sites, or certain advances in technology. If any material changes are made to this Policy, the changes may be prominently posted on the relevant or affected Sites. However, this is not obligatory for us; the onus is on you to occasionally familiarize yourself with the contents of this Policy, for your own information; and particularly to do so every time you access our Sites or make use of our Services.

Changes to this Policy are effective when they are published.

3. Data processing principles followed

Users’ data collected and processed through, the United Arab Emirates (UAE), the European Union (EU) and/or European Economic Areas (EEA), or the United Kingdom (UK) is done so in accordance with the relevant principles, including: lawfulness, fairness and transparency; purpose limitation; data minimisation; accuracy; storage limitation; integrity and confidentiality (security) and accountability; with all relevant laws and regulations considered; and however applicable. 

4. Consent for legal obligations and legitimate interests

You provide consent to your personal data (whether provided directly by you, whether collected by us, or received by us from third parties or otherwise) being processed to satisfy all legal obligations arising from any contracts entered into/ with/ involving you or to deliver any services to you; or to take steps at your request prior to entering into a contract with you; or for our legitimate interests to protect our property, rights or safety of either the Company, its users, customers, clients, other persons or other entities. 

The specific data points which we collect, the method by which we collect such data, the purposes for which we collect such data, how we share such data, and how long we retain such data is explained individually, specifically for your specific, informed and unambiguous consent below in this Policy.

5. The data we collect

The information you provide, or which we obtain from other sources will be used by us, in accordance with this Policy, read in conjunction with our other policies and the applicable laws, and the General Data Protection Regulation (GDPR). 

The table below specifies which data points we collect, by what method and for what purposes.

S.No.
1.
What Data We Collect
  1. First name; 
  2. Family name (including any personal information about your race or ethnicity, religious or philosophical beliefs, political opinions, trade union membership, information which may be revealed from the same).
  3. Marital status;
  4. Title;
  5. Phone number; 
  6. Email ID; 
  7. Date of birth; 
  8. Nature of Job (i.e. Job Title); 
  9. Mailing address; 
  10. Billing address; 
  11. Debit/Credit card number, wallet identification details, wire payment identification details; 
  12. Payment instrument number; 
  13. Transaction data which includes details about payments to and from you and other details of products and services you have purchased from us;
  14. Security code associated with your payment instrument;
  15. Agent View username; 
  16. Agent View password; 
  17. Feedback and surveys; and
  18. Marketing and communications preferences.
How we collect data
  1. Users provide it directly to us when the users register for an account with Agent View (Account). 
  2. Users provide it directly to us when the users communicate with our agents/ customer care support staff and/ or administrative staff through the Sites. 
  3. Users provide it directly to us when they post messages, participate in online forums, enter competitions, provide feedback, post comments etc. 
  4. Users provide it directly to us when the users purchases / use Agent Views services.
Why we collect data

Agent View collects personal information for the purposes of:

  1. Entering into and fulfilling our obligations under your contract with Agent View, including in conjunction with personal information collected from authorised third parties;
  2. To prudently identify you and assess the qualification of your application.
  3. Protecting our legitimate interests, where our doing so will not unduly affect your rights;
  4. Facilitating the Account creation and management of Accounts; 
  5. Sending administrative information/ provide administrative support; 
  6. To request feedback on and respond to inquiries regarding our Sites and or Services; 
  7. Responding to enquiries/ customer support;
  8. Marketing and promotional communications; 
  9. Administering prizes and competitions; 
  10. Posting testimonials; and
  11. Facilitating necessary agreements / partnerships with third party providers to continue providing the services;
  12. To notify you about important changes or updates to the Services;
  13. To effectively conduct internal compliance checks and external compliance checks by certified vendors (where applicable);
  14. Processing your payment if you make purchases; and
  15. Fulfilling and mange users order (payments, returns and exchanges).
S.No.
2.
What Data We Collect
  1. Information from linked accounts used to register with Agent View; and
  2. Personal information supplied by third-party entities (including governmental authorized entities, mandated entities or other users) and service providers / agents in the outsourcing of Services, including, but not limited to third party identity verification sources and services.
How we collect data
  1. We collect it from third party partners who have your consent to provide us this data, and if you have given us consent to collect such data.
  2. We will gather information from third parties and service providers who you have authorized to collect, process and share your personal information with.
Why we collect data

Agent View collects personal information for the purposes of:

  1. Facilitating the Account creation and management of Accounts; and 
  2. Protecting our legitimate interests where our doing so will not unduly affect your rights.
S.No.
3.
What Data We Collect
  1. Operating System information;
  2. User Internet Protocol (IP) address;
  3. Geo-location (country, location); and
  4. Browser, browser type and version, browser plug-in types and versions. 
How we collect data
  1. We collect it through the users’ IP address, internet browser and device. 
  2. We collect it through automated technology when users are visiting and navigating the Sites. 
  3. We collect it through GPS and other technologies.
  4. We collect it through third-party marketing partners who you have given consent to share your personal information with other parties in limited necessary cases.
Why we collect data

Agent View collects personal information for the purposes of:

  1. Agent View collects this personal information for the purposes of: 
  2. Providing you the Services;
  3. Rectifying any errors you face when trying to access our Services;
  4. Maintaining security and operation of the Sites; 
  5. To improve the quality of your user experience when you interact with the Services;
  6. To request feedback on and respond to inquiries regarding our Website and or Services; 
  7. To deliver advertising and or develop and display personalised content and advertisements tailored to your interests and or location, which include measuring the effectiveness of our targeted advertising. 
  8. Internal record keeping, analytics and reporting purposes; 
  9. We use information from log files to analyse trends; operate, administer and maintain the facilities; track users’ movements and activity around and within the Sites; gather demographic information about our user base as a whole, and better tailor our Sites to our users’ needs;
  10. To notify you about important changes or updates to the Services;
  11. Logging and using service-related diagnostic, usage and performance information on Agent View’s servers; and
  12. Protecting our legitimate interests, where our doing so will not unduly affect your rights.

You undertake that all personal information provided to us by you is true, complete and accurate and you must notify us of any changes to such personal information.  

All credit/debit cards’ details and personally identifiable information will NOT be stored, sold, shared, rented or leased to any third parties.‍

www.agent-view.com will not pass any debit/credit card details to third parties.

We do not collect data about actual or alleged criminal offences.

6. We process and use aggregated, anonymised and de-identified data

We may also create, process, collect, use and share aggregated, anonymised or de-identified data such as statistical or demographic data for any purpose which may be derived from your personal data. We may use this data to comply with legal or regulatory obligations. 

We may share your data with members of our group, service providers and our key partners. Some of these third parties may be in a jurisdiction outside the laws as stated in this Policy, in which case we will take all necessary steps to ensure that your personal information is treated securely and that such transfers are permitted under the applicable data protection laws. 

We may also use any or all of the personal information above to administer and manage our business in general, to detect and prevent misuse of our Services (including fraud and unauthorised payments), and to enforce our Terms of Use or any other contract to which we may be a party to. 

7. Your refusal, failure, inability to provide us with necessary personal information

If you fail, neglect and/ or refuse to, or are unable to provide us any personal information which we necessarily need to provide you with the Services or which we need to collect by law, we may not be able to perform the Services. In this case, we have the right to discontinue the Services and/or may close your Account or disapprove your Service request. In such a situation, we will notify you of our inability to provide you the Service at the earliest.

8. We do not collect personal information of minors

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 Sites, you represent that you are at least 18 years. 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 data from our records.

9. 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.

10. We collect your data for market research and promotional information; you may opt out from this

We provided you with choices regarding the personal data we use, particularly concerning any market research and/or subsequent marketing, advertising and promotion. Towards this, we have established these personal information control mechanisms:

  1. Promotional offers from us: We may use your personal information to determine what may be of interest to you. This is how we decide which products, services, and offers may be relevant and of interest to you. By using our Sites and Services, registering an Account, contacting us, requesting information from us, you expressly opt-in to receive marketing communications from us. We may communicate with you by e-mail, fax or telephone‍
  2. Opting out: You can ask us or third parties to stop sending you marketing related material and/ or communications at any time by following the opt-out links on any marketing message sent to you or by contacting us info@agent-view.com.

11. We may share you personal information with third parties

We may have to share your personal information with a selected and trusted group of third party/parties to fulfil our obligations under our contract with you, to meet government, regulatory and law enforcement requests, and to continue providing you with the Services. We will only disclose your personal information to third party service providers under strict terms of confidentiality. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions. 

We may have to share or transfer your personal information in the specific circumstances listed below:

  1. Applicable law, government requests, etc.: Where we are legally required to do so, we may disclose your personal information to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements), or where we find it is necessary to investigate, prevent or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved disclose your personal information. Additionally, we may disclose your personal information to enforce our Terms of Use, or to protect the rights, safety, and security of the Company, our users, other persons or the public;
  2. Merger, acquisition etc.: In connection with, or during negotiations of, any merger, sale of company assets, financing, acquisition of all or a portion of our business to another company, any dissolution transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets. In the event of an insolvency, bankruptcy, or receivership, your personal information may also be transferred as a business asset forming part of our good will. If another company acquires us, our business or assets, that company will possess the personal information collected by us and will assume the rights and obligations held by us regarding your personal information, as described in this Policy.
  3. Advertisements: Where we use third party advertising companies to serve ads when you visit or use the Sites. These companies may use information about your visits to our Sites and other websites that are contained in web cookies and other tracking technologies in order to provide advertisements about goods and services of interest to you, provided you have consented to the same; 
  4. Affiliates: We may share your personal information with our affiliates, in which case we will require those affiliates to honour this Policy. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us. We may share your information with our business partners to offer you certain products, services or promotions; and,
  5. With select third party vendors: In connection with the performance of our Services, we may share your personal information with third-party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples of such third parties include payment processing, customer relationship management, data analysis, email delivery, hosting services, customer service, quality assurance testing, technical support, operational support and maintenance services and marketing efforts. We have provided a list of such third-party vendors below.

12. Links to third-party websites

Our Services, Sites or communications may contain links to other third-party websites which are not owned or operated by us and are regulated by their own privacy policies. If you click on a third-party link, you will be directed to that third party’s site. We strongly advise you to review the privacy policy of every site you visit. We are not responsible for the privacy policies of these third-party websites, regardless of whether they were accessed using the links from our Sites. We have no control over and assume no liability for the content, privacy policies or practices of any third-party sites or services.

We specifically recommend that you, as the user (under this Policy) visit, familiarize, understand the below entity policies, as they are our partners in providing services under the facilities to you, however  even if not done as mandated herein, you undertake that you as the user accept that through the application for the creation of an Account, you accept their terms and conditions, their individual privacy policies, cookies policies, , as third-party service providers to us. While not a closed, comprehensive, or exhaustive list these are our third-party vendors:

13. You have rights as to your personal information under various laws

If you are a citizen of the EU, then you have these rights under the GDPR: 

Right to be informed: This means you have a right to know:

  1. The identity and the contact details of the Company and its European representative; 
  2. The contact details of our data privacy officer; 
  3. The purposes of the processing your personal information as well as the legal basis for the processing; 
  4. The legitimate interests pursued by us or by a third party who processes your personal information; 
  5. The recipients or categories of recipients of your personal information; 
  6. Our intention to transfer your personal information to a third country or international organisation and the existence or absence of an adequacy decision by the relevant supervisory authority, or where applicable, reference to the appropriate safeguards and the means to obtain their copy. 
  7. The period for which your personal information will be stored, or if that is not possible, the criteria used to determine that period; 
  8. Whether the provision of personal information is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obligated to provide the personal information and of the possible consequences of failure to provide such data; 
  9. The existence of automated decision-making, including profiling and meaningful information about the logic involved. 
  10. Where we intend to further process your personal information for a purpose other than that for which the personal information was collected for, we must apprise you, prior to such further processing, with information on those other purposes and with any other relevant information.‍

Right of access: This is your right to see what personal information is held about you by us. Particularly you have the right to:

  1. Receive confirmation as to whether or not your personal information is being processed; 
  2. Access your personal information which we are processing along with the purposes of processing; the categories of personal information being processed; the recipients or categories of recipient to whom the personal information has been or will be disclosed; the envisaged period for which the personal information will be stored, or, if not possible, the criteria used to determine that period; where the personal information are not collected from you, any available information as to their source.
  3. Where your personal information is transferred to a third country or to an international organisation, you have the right to be informed of the appropriate safeguards relating to the transfer; 
  4. A copy of your personal information being processed; and
  5. Any further copies requested by you, upon paying a reasonable fee.

Right to rectification: This is your right to have your personal information corrected, rectified or amended, if what is held by us or a third party onboarded by us is incorrect/ inaccurate in some way. 

Right to erasure: This is your right, under certain circumstances to ask for your personal information to be deleted. This would apply if your personal information is no longer required for the purposes it was collected for, or your consent for the processing of that data has been expressly withdrawn, or where your personal information has been unlawfully processed. Once deleted all your personal data will be removed from our systems and will not be recoverable.

Right to restrict processing: This is your right to ask for a temporary halt or pause in processing your personal data, such as in the case where a dispute or legal case must be concluded, or the data is being corrected. 

Right to data portability: This is your right to ask for your personal information supplied directly to us, which we have processed pursuant to your consent, under a contract, or by automated means, to be provided to you in a structured, commonly used, and machine-readable or electronic format. 

Right to object: 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 profiling, automation and direct marketing. 

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 to lodge a complaint with the supervisory authority: You have the right to lodge a complaint with the supervisory authority of the member state in which you are habitually resident, or with the supervisory authority of the member state in which you work or in which your rights under the GDPR have been infringed if you believe such infringement has taken place.

Automated decisions: You may contest any automated decision by us, which has been made about you and where this has a legal or similar significant effect and ask for it to be reconsidered.

We aim to respond to all legitimate requests without undue delay and within two (2) calendar months of receipt of any request from you. Occasionally it may take us longer than two (2) calendar months, 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).

If you wish to exercise any of the rights set out above, please contact us at info@agent-view.com. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This security measure is to ensure that your personal information is not disclosed to any person who has no right to receive it. 

14. How to update your information

Whenever possible, you can update your personal information, subject to verification by us. If you wish for us to update your personal information, please contact us at info@agent-view.com to make the required changes. We will retain your personal information for as long as your Account has not been closed or as may be needed to provide you access to your Account and/ or Services, and in compliance with the law.

15. Data retention and records

We retain information on your behalf, including customer data, transactional data and other session data, linked to your Service usage or Account; and all access or use of the Services.

We adhere to all applicable legislative provisions and data protection laws of each jurisdiction we operate in. Should any further information be required, please contact us at info@agent-view.com. 

Your personal information will be stored, retained, and processed for no period longer than as required by us for the purposes it was collected for, for the purposes of availing the Services, and for meeting any legal, accounting, reporting, government, regulatory or law enforcement requirements. Unless required for any of the purposes specified above, we will delete personal information related to closed Accounts every twelve (12) calendar months.

To determine the appropriate retention period for your personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements. 

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

16. Data storage and data transfers

Your personal information is stored and transferred in compliance with the applicable legislation or regulations of every jurisdiction in which we operate.

We store and process your personal information in data centers within AWS EU West 1, wherever we have our premises, wherefrom we provide Services or where our third-party service providers are located.

If you are based in the UK, the EU or the EEA, any storage, processing and transfer of your data outside these territories will adhere to the relevant legal requirements, particularly the GDPR, as and however applicable and/or required.

Many of our external third-party service providers may also be based outside of the UK, EU, or EEA, so their processing, storage and transfer of your personal information will involve the transfer to and from and storage of data outside such. We reiterate that by using our Services you accept the terms of their individual privacy policies, cookies policies, as well as terms and conditions.

Some of the international organisations and countries to which your personal information may be transferred do not benefit from an appropriate data protection regulatory framework. For such international organisations and countries, we shall transfer your personal information, only upon ensuring that a suitable degree of protection is afforded to it through the implementation of the necessary safeguards, such as an adequacy decision by the relevant authority, adequate binding corporate rules or through the inclusion of standard contractual clauses in our agreements with such organisations and countries. We shall notify you with regards to the specific safeguard we shall adopt in transferring your personal information to such an international organisation and/or country if you must require such data. 

In respect of GDPR compliance (if applicable): we may use specific contracts approved by the European Commission which give personal information the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of Personal Data to third countries. 

Please contact us at info@agent-view.com if you want further information on the specific mechanism used by us when transferring your personal information.

17. Data privacy officer

We have appointed a Data Privacy Officer (DPO), who is responsible for overseeing any data-related matters, to address any questions in relation to personal information and this Policy. If you have any questions in relation to your personal information and/or this Policy, including requests to exercise your rights related to personal information, please contact us via email on privacy@agent-view.com.

18. Legal recourse to relevant authorities

If you are based in the UK, EU or the EEA region, then you have the right to make a complaint at any time to a supervisory or regulatory authority, in particular within the UK, or a member state in the EU or EEA where you are habitually resident, where we may be based (if applicable), or where an alleged infringement of any data protection law has taken place. 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. Please contact us via email on privacy@agent-view.com

19. How to close your user account

If you wish to close your Account, please contact us at info@agent-view.com. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our Terms available at https://www.agent-view.com/terms.

20. Security precautions and measures exercised by us for protection of your personal information data

We are committed to ensuring that your information is secure. To prevent unauthorised access or disclosure we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online. We use industry-standard technical mechanisms and ensure that our affiliates or vendor entities use data encryption technology while implementing restrictions related to the storage of and the ability to access your personal information. 

Our facilities are scanned on a regular basis for security holes and known vulnerabilities, to best ensure its security.

Your personal information is contained behind secured networks and is only accessible by a limited number of individuals who have special access rights to such systems and are required to keep the information confidential. 

No guarantee

Please note that no transmission over the Internet or any method of electronic storage can be guaranteed to be absolutely 100% secure, however, our best endeavours will be made to secure data and the ability to access your personal information. 

Without prejudice to our efforts on protection of your data, nothing contained in this Policy constitutes a warranty of security of the facilities, and you agree to transmit data at your own risk. 

Please note, that we do not guarantee that your data may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.

Please, always check that any website on which you are asked for financial or payment information in relation to our reservations or services is in fact legitimately owned or operated by us. The risk of impersonating hackers exists and should be taken into account when using our Sites and/or Services.

If you do receive any suspicious communication of any kind or request, do not provide your information and report it us by contacting our offices immediately at privacy@agent-view.com. Please also immediately notify us at privacy@agent-view.com if you become aware of any unauthorised access to or use of your Account. 

Since we cannot guarantee against any loss, misuse, unauthorised acquisition, or alteration of your data, please accept that you play a vital role in protecting your own personal information, including the adoption of sufficient safety measures such as your choosing of an appropriate password of sufficient length and complexity and to not reveal this password to any third-parties. 

Furthermore, we cannot ensure and do not warrant the security or confidentiality of data transmitted to us, or sent and received from us by Internet or wireless connection, including: email, phone, or SMS, since we have no way of protecting that information once it leaves and until it reaches us. If you have reason to believe that your data is no longer secure, please contact us privacy@agent-view.com. 

Lastly, please note that should your personal information is 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 privacy@agent-view.com for further information and for further advise on how to mitigate 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.

21. General

In the case of abuse or breach of security, we are not responsible for any breach of security or for any actions of any third parties which receive the information illegally. 

We will not distribute customer information to be used in mailing lists, surveys, or any other purpose other than what is required to perform our services.

If you choose to restrict the collection or use of your confidential and personal information, please elect the option stated as “Do Not Proceed & Exit Our Website”.

22. Contacting us

If you have any questions about our Policy as outlined above, or if you have any complaints, please contact us privacy@agent-view.com.

If you have any queries or issues pertaining to your information or our Policy or personal information, then please do write to us at any time by emailing us via privacy@agent-view.com.