1. Scope & Data Controller
This Policy applies to the Service operated by DalaliConnect. If you reside in the EEA/UK, the data controller is [Insert legal entity & address]. If you are in other regions, the responsible entity is [Insert entity]. For Turkey or other local jurisdictions, regional disclosures may apply in addition to this Policy.
2. Data We Collect
We collect information that falls into these categories:
- Account & Identity: name, email, phone, password (hashed), role (agent/individual), verification docs (where applicable).
- Profile & Preferences: saved searches, alerts, preferred locations, price ranges, property types (e.g., houses, villas, vehicles, land plots).
- Listing Content: photos, videos, descriptions, floor plans, location, amenities, pricing, availability, metadata.
- Usage & Device: app version, device identifiers, IP address, browser type, OS, crash diagnostics, pages/screens viewed, session duration.
- Location: coarse or precise location if you grant permission (e.g., “near me” search, map radius).
- Communications: messages with agents, support tickets, call/meeting metadata (not call audio unless you consent and where lawful).
- Payments & Billing: subscription tier, invoices, payment method tokens (handled by our payment processors).
- Marketing & Ads: referral codes, campaign and attribution data, ad interaction events.
3. Sources of Data
- You: forms, uploads, messages, settings.
- Automatically: cookies/SDKs, server logs, analytics events.
- Partners: payment processors, identity/anti-fraud providers, ad networks, map providers, and (for agents) verification providers.
- Public & Third-Party: publicly available property records or developer feeds where applicable and lawful.
4. How We Use Data
- Provide and operate the Service (accounts, listings, search, saved items).
- Match seekers with relevant properties and verified agents; enable messaging.
- Personalize results, alerts, recommendations, and content.
- Process payments, subscriptions, and invoices.
- Measure performance; fix bugs; prevent spam, abuse, and fraud.
- Comply with legal obligations and enforce our Terms.
- Marketing with your consent or as permitted by law (opt-out available).
5. Legal Bases (GDPR/UK GDPR)
- Contract: to provide the Service you request.
- Legitimate Interests: security, fraud prevention, service improvement, analytics, limited direct marketing.
- Consent: non-essential cookies/SDKs, precise location, certain marketing.
- Legal Obligation: tax, accounting, regulatory requests.
- Vital Interests/Public Task: only where applicable and lawful.
7. Analytics, Ads, Maps & Payments
- Analytics: We use analytics tools (e.g., event tracking) to understand usage and improve search quality and performance.
- Advertising: We may use ad networks and measurement partners to show and measure relevant ads. Non-essential ad cookies/SDKs load only with consent where required.
- Maps & Media: Map tiles, geocoding, and embedded media may be provided by third parties and may process your IP and location if you permit it.
- Payments: Payments are processed by third-party processors; we do not store full card numbers. Billing data may be shared with tax and accounting tools.
See also our Cookie Policy for details on technologies used.
8. International Transfers
If data is transferred outside your country/region (e.g., to the EEA/UK/US/Türkiye), we implement appropriate safeguards such as Standard Contractual Clauses, and where applicable, supplementary measures, or rely on adequacy decisions and local legal frameworks.
9. Retention
We retain personal data only as long as necessary for the purposes described above, including to comply with legal, accounting, or reporting requirements. Typical examples:
- Account data: retained while your account is active, then deleted or anonymized within a reasonable period.
- Listings & media: retained while published and for backup/audit logs thereafter.
- Billing records: retained per tax/accounting laws.
- Consent logs & security logs: retained to evidence compliance and protect the Service.
10. Security
We use technical and organizational measures including encryption in transit, access controls, least-privilege policies, and regular reviews. No method of transmission or storage is 100% secure; we cannot guarantee absolute security.
11. Your Rights
Your rights vary by region and may include:
- Access, rectify, or update your data.
- Delete your data and/or close your account.
- Portability of certain data you provided.
- Object to or restrict processing based on legitimate interests.
- Withdraw consent at any time (does not affect prior lawful processing).
- Lodge a complaint with a supervisory authority (e.g., your local DPA).
To exercise rights, see Contact & Requests. We may need to verify your identity and, for agent accounts, confirm authority.
CCPA/CPRA (California): You may have rights to know/access, delete, correct, and opt-out of sale/share or certain profiling. We do not “sell” personal information as defined by CCPA; where “sharing” for cross-context behavioral advertising applies, you can opt-out via cookie preferences.
12. Children’s Privacy
The Service is not directed to children under 16 (or the age required by local law). We do not knowingly collect personal data from children. If you believe a child provided data, contact us to delete it.
13. Automated Decisions/Profiling
We may use limited profiling to personalize search results, alerts, or ads (e.g., property type or budget). We do not make decisions with legal or similarly significant effects solely using automated processing.
14. Communications & Preferences
You can manage marketing preferences in your account or via unsubscribe links. Service and transactional messages (e.g., account, billing, security) are necessary and may still be sent.
16. Changes to this Policy
We may update this Policy from time to time. Material changes will be communicated via in-app notice, email, or by updating the “Last updated” date. Continued use indicates acceptance of the revised Policy.
17. Contact & Requests
To ask questions or exercise your rights, contact:
Email: privacy@dalaliconnect.com
Legal/Privacy Address: [Insert company address]
DPO/Privacy Officer (if applicable): [Insert contact]
If you are in the EEA/UK, you may also contact your local supervisory authority.