Privacy Policy

1. Introduction

Hadar Real Estate (“Company,” “we,” “us,” or “our”) is a real estate company operating in the Emirate of Dubai, United Arab Emirates.

This Privacy Policy explains how we collect, use, disclose, retain, and protect your personal data when you interact with our website, AI-powered chat and voice services, WhatsApp communications, and any other digital platforms operated by Hadar (collectively, the “Services”).

We are committed to complying with the UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (“UAE PDPL”), the Dubai International Financial Centre (DIFC) Data Protection Law No. 5 of 2020, the EU General Data Protection Regulation (“GDPR”) where applicable, and all other relevant data protection legislation.

2. Data Controller

The data controller responsible for your personal data is:

3. Personal Data We Collect

We collect and process the following categories of personal data:

3.1 Information You Provide Directly

• Identity Data: Full name, title, nationality, date of birth
• Contact Data: Email address, phone number(s), WhatsApp number, mailing address
• Financial Data: Budget range, investment capacity, proof of funds documentation (when applicable for property transactions)
• Property Preference Data: Preferred areas, property types, purpose (investment/residence), timeline, specific requirements
• Communication Content: Messages, voice call transcripts, chat conversations, emails, and any attachments you send to us
• Identity Verification Documents: Passport copies, Emirates ID, visa copies (required for property transactions under UAE law)

3.2 Information Collected Automatically

• Technical Data: IP address, browser type and version, operating system, device identifiers, time zone setting
• Usage Data: Pages visited, time spent on pages, click patterns, referral sources, search queries
• AI Interaction Data: Chat session logs, voice call recordings (with consent), AI-generated lead qualification data, conversation metadata
• Cookie Data: Session cookies, analytics cookies, preference cookies (see our Cookie Policy)
• Location Data: Approximate geographic location derived from IP address

3.3 Information from Third Parties

• Property listing data from developers and public sources
• Credit and financial verification data from authorized financial institutions (with your consent)
• Public records from government databases

4. Legal Basis for Processing

We process your personal data on the following legal bases:

• Consent (Article 5, UAE PDPL / Article 6(1)(a), GDPR): Where you have given clear consent for us to process your personal data for specific purposes, including AI-powered communications and voice call recording.
• Contractual Necessity (Article 6(1)(b), GDPR): Processing necessary for the performance of a contract to which you are a party, such as property search, viewing arrangements, and transaction facilitation.
• Legal Obligation (Article 4, UAE PDPL / Article 6(1)(c), GDPR): Processing necessary to comply with UAE Anti-Money Laundering (AML) regulations and tax obligations.
• Legitimate Interests (Article 6(1)(f), GDPR): Processing necessary for our legitimate interests, including improving our AI services, preventing fraud, and marketing similar services to existing clients.

5. How We Use Your Data

We use your personal data for the following purposes:

5.1 Service Delivery

• Responding to property inquiries via AI chat, voice calls, and WhatsApp
• Qualifying leads and matching clients with suitable properties
• Scheduling property viewings and site visits
• Facilitating property transactions, including Sales and Purchase Agreements (SPAs)
• Processing reservations, deposits, and payments

5.2 AI and Automation

• Training and improving our AI conversational agents to better serve clients
• Automated lead qualification based on stated preferences and budget
• Natural language processing to detect client language and respond accordingly
• Sentiment analysis to improve service quality
• Generating property recommendations based on stated preferences
• Nationality and cultural context inferred from conversations may be stored and used to personalize AI responses and property recommendations

Important: Our AI systems do not make autonomous decisions that produce legal effects or similarly significantly affect you. All property transactions require human review and your explicit confirmation.

5.3 Communication

• Sending property updates, market reports, and new listings matching your criteria
• Transaction-related communications (viewing confirmations, document requests)
• Service announcements and updates
• Marketing communications (only with your explicit consent, with opt-out available)

5.4 Legal and Compliance

• Anti-Money Laundering (AML) and Know Your Customer (KYC) verification
• Regulatory compliance and transaction reporting
• Dispute resolution and legal proceedings
• Regulatory audits and inspections

6. AI-Specific Disclosures

Our Services employ artificial intelligence in the following ways:

• AI Chatbot: An AI-powered conversational agent processes your text messages to provide real estate information, qualify inquiries, and connect you with human specialists. Chat transcripts are stored securely and used to improve service quality.
• AI Voice Agent: Our AI voice agent handles incoming phone calls using natural language processing and speech-to-text technology. Calls may be recorded for quality assurance and service improvement. You will be notified of recording at the start of each call.
• WhatsApp Automation: Automated responses are sent via the WhatsApp Business API. Your messages are processed to provide relevant property information.
• Lead Scoring: Our AI assigns qualification scores based on stated budget, timeline, and preferences. This scoring assists human agents in prioritizing follow-ups but does not restrict your access to our services.
• Cross-Session Memory: Our AI system may retain contextual memory of your preferences, inquiries, and prior conversations across separate chat sessions to provide a more personalized and consistent experience. This memory is stored securely and associated with your lead profile. You may request deletion of this memory at any time by contacting us.

You have the right to request human intervention at any point during AI interactions, to express your point of view, and to contest any AI-assisted decisions.

7. Data Sharing and Disclosure

We may share your personal data with the following categories of recipients:

• Property Developers: To facilitate inquiries, viewings, and transactions for off-plan and ready properties
• Government authorities: For transaction registration, compliance, and regulatory purposes as required by law
• Financial Institutions: Banks and mortgage providers, only with your explicit consent and for transaction facilitation
• Legal and Professional Advisors: Lawyers, conveyancers, and auditors involved in property transactions
• Technology Service Providers: Cloud hosting providers, AI model providers, CRM platforms, and communication APIs — all bound by strict data processing agreements
• Government Authorities: When required by law, court order, or regulatory request

We do not sell, rent, or trade your personal data to third parties for their marketing purposes.

8. International Data Transfers

As a technology-driven company, some of your data may be processed by service providers located outside the UAE, including:

• Cloud infrastructure providers (servers in the EU, US, and Asia)
• AI model providers for natural language processing
• Communication platform providers (WhatsApp/Meta, email services)

Where personal data is transferred internationally, we ensure appropriate safeguards are in place, including:

• Standard Contractual Clauses (SCCs) approved by the European Commission
• Data Processing Agreements (DPAs) with all processors
• Adequacy decisions where available
• Encryption in transit (TLS 1.3) and at rest (AES-256)

9. Data Retention

We retain personal data for the following periods:

After the applicable retention period, personal data is securely deleted or anonymized.

10. Your Rights

Under applicable data protection laws, you have the following rights:

• Right of Access: Obtain confirmation of whether we process your data and request a copy
• Right to Rectification: Request correction of inaccurate or incomplete data
• Right to Erasure: Request deletion of your data where there is no compelling reason for continued processing
• Right to Restriction: Request limitation of processing in certain circumstances
• Right to Data Portability: Receive your data in a structured, machine-readable format
• Right to Object: Object to processing based on legitimate interests or for direct marketing
• Right to Withdraw Consent: Withdraw consent at any time without affecting the lawfulness of prior processing
• Rights Related to Automated Decision-Making: Not be subject to a decision based solely on automated processing that significantly affects you, and to request human review

To exercise any of these rights, contact us at privacy@hadar-ai.com. We will respond within 30 days.

11. Data Security

We implement robust technical and organizational measures to protect your data, including:

• Encryption in transit (TLS 1.3) and at rest (AES-256)
• Secure, access-controlled cloud infrastructure
• Regular security assessments and penetration testing
• Role-based access controls with multi-factor authentication
• Data Processing Agreements with all third-party processors
• Employee training on data protection and confidentiality
• Incident response procedures and breach notification protocols

12. Children's Privacy

Our Services are not directed at individuals under the age of 18. We do not knowingly collect personal data from children. If we become aware that we have collected data from a child, we will take steps to delete it promptly. If you believe a child has provided us with personal data, please contact us at privacy@hadar-ai.com.

13. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will post the revised policy on this page with an updated “Last Updated” date. Material changes will be communicated via email or prominent notice on our website.

14. Complaints

If you are unsatisfied with how we handle your data, you have the right to lodge a complaint with the relevant supervisory authority:

• UAE: UAE Data Office (once established under UAE PDPL)
• DIFC: Commissioner of Data Protection, DIFC
• EU: Your local Data Protection Authority (if GDPR applies)

15. Contact Us