Privacy Policy

Effective date: 17 November 2019

Your data protection and privacy are our highest priority.

Land Sterling cares about and respects your privacy and the data you share with us, and want you to understand how we are using and protecting the data we collect about you. We adopt the best practices in compliance with the applicable privacy law and regulations, including the international standards of General Data Protection Regulation (“GDPR”).

The policy set forth below is provided in English to avoid any misinterpretations caused by a language translation. If necessary, please seek the proper advice or do not use this website.

LANDSTERLING.COM

Land Sterling (“us”, “we” or “our”) operates the website at landsterling.com (“Site”). We respect the privacy of each user of this Site (“you”, “your” or “user”), whether you are just beginning your real estate investment and consultancy search or have previously visited this Site. This Privacy Policy (“Policy”) gives you specific information about how we protect your privacy, how we use aggregated information, and how we treat your Personal Data (if applied or provided). By using this Site, you accept this Policy and agree to the collection and use of your Personal Data in accordance with this Policy. If you do not agree to this Policy, you cannot use this Site. Land Sterling reserves the right to modify this Policy at any time by posting a notice on this Site’s homepage (if we consider it appropriate, then we may also provide additional notice of significant changes). Your use of this Site after the date of the last modification mentioned at the beginning of this Policy indicates to us that you agree to the changes. This Site may contain links to third-party websites, including that of our “Regional Offices” (Land Sterling | KSA and Land Sterling | UK), and our affiliate company/ies. When you click on those links, you will go to a third-party site where you will be subject to that site’s privacy policy and we encourage you to read that privacy policy. Please be aware that we are not responsible for the privacy practices of those other websites and we expressly disclaim liability for their actions, including actions related to the use and disclosure of Personal Data by those third parties.

LOCATION OF SERVERS

This Site is hosted on servers in Asia. With reference to the country or general location, United Arab Emirates (“UAE”), wherein this Site is mostly expected to be accessed, then this Site is governed by the UAE law. If you are located outside of the UAE, you adhere to use this Site in accordance with this Policy and the UAE law.

SCOPE OF THIS POLICY

This Policy applies to your use of this Site only. Accordingly, this Policy does not apply to the Land Sterling | KSA and Land Sterling | UK websites or to their collection, use, storage, and disclosure of your Personal Data (if required or provided).

WHAT DATA DO WE COLLECT?

Land Sterling may collect information about you from a variety of sources. This includes information we collect directly from you; information we collect when you visit this Site; view our online content or use our mobile applications (if any) or other services; and information we collect about you from other sources.

Data we collect directly from you

Land Sterling collects information directly from you when you choose to participate in our offers, enquire about our services and products, register on our online forms, call or email us, or otherwise provide information directly to us. The following are examples of information we may collect directly from you:

First name

Last name

Email address

Postal address

Landline or mobile number

Date of birth

Demographic information

Future communication preferences

Telephone number and recordings when you call our call center

Job title or designation

Employer or company name

Employer of company address

Employer or company website

Work email address

Work landline or mobile number

Data we collect when you visit this Site, view our online ads or promotions, or other services

Land Sterling uses cookies and other technologies to collect information when you visit this Site, view our online advertisements or promotions, or use our mobile applications (if any) or other services. The following are examples of information we may collect with these technologies:

Internet Protocol (“IP”) address

The region or general location of a computer or device accessing the internet

Browser type

Operating system

Page view history

Browsing search history

Links you click

Land Sterling emails you open

Other usage information

However, to the extent that any cookie can uniquely identify a computer, mobile device, or tablet (“Device”), or the person using that Device, under the GDPR, this is Personal Data. Therefore, this Policy shall apply to such Personal Data collected by us. In some cases, we may ask you to provide additional professional information such as the size of the company you work for and the industry type. To enhance and/or update the information that you have provided to us, we may combine it with professional or personal data that we collect from third-party sources. The Personal Data that we refer to in this Policy is the personal and professional information you provide, as well as the information that we obtain from third-party sources, both of which we typically combine as one user record.

HOW DO WE COLLECT YOUR PERSONAL DATA?

Land Sterling may collect your Personal Data when you register to receive any of the services, products and/or content offered by us, our Third-Party Sponsors (“Sponsors”) and/or our Strategic Partners (“Partners”), such as reports, publications, subscriptions, contests, offers, newsletters, memberships, premium content, webcasts, video, white papers, online seminars, conferences, and events.

WHAT HAPPENS IF YOU DO NOT PROVIDE YOUR PERSONAL DATA?

In order for Land Sterling to provide the services, products and/or content you requested, we need your Personal Data. Therefore, if you do not provide such Personal Data, we cannot deliver the services, products and/or content.

HOW DO WE PROTECT YOUR PERSONAL DATA?

Security of your Personal Data

Land Sterling maintains safeguards, which include technical and organizational security measures to protect your Personal Data from loss, misuse, unauthorized use, access, inadvertent disclosure, alteration, and destruction, and we require the third parties we contract with to support our business operations to employ reasonable security measures as well (please refer to WHEN AND HOW WE SHARE YOUR PERSONAL DATA WITH OTHERS? below). We update and test safeguards on an ongoing basis and restrict access to your Personal Data to only those who need to know in order to provide our services, products and/or content to you.

Storage of your Personal Data

Land Sterling may store your Personal Data using our own secure onsite servers or other internally-hosted technology. Your Personal Data may also be stored by third parties via cloud-based services or other technologies. These third parties do not use or have access to your Personal Data other than for cloud-based storage and retrieval, and we require such parties to employ at least the same level of security that we use to protect your Personal Data (please refer to the aforementioned Security of your Personal Data).

HOW WILL WE USE YOUR PERSONAL DATA?

Land Sterling uses the Personal Data that we collect to:

• Communicate with you

Land Sterling may use your Personal Data to send you important notices, such as communications about your registration, transactions and changes to our terms, conditions, policies, and /or other internal purposes.

• Deliver your request

Land Sterling may use your Personal Data to provide the services, products and/or content that you requested. If you enter a promotion or contest, we may use your Personal Data to administer such activity.

• Improve our service

Land Sterling may use your Personal Data for auditing, data analysis and research to improve our services, products and/or content.

• Present offers that may be of interest to you

Land Sterling may contact you to offer you additional or third-party services, products and/or content that may be of interest to you.

THE LEGAL BASIS WE HAVE FOR PROCESSING YOUR PERSONAL DATA

The GDPR requires data collectors to have a legal basis to use the Personal Data of the residents. Therefore, this section shall apply to any such Personal Information collected by us.

Land Sterling uses the Personal Data that you provide to supply you with high-quality services, products and/or content as you requested, to send important notices, and for internal purposes, such as auditing, data analysis and research to provide you with the information you need to make the most informed technology purchasing decisions.

Land Sterling may also use your Personal Data to offer you services, products and/or content that may be of interest to you, based upon your interests or the preferences you shared with us, and may share your Personal Data with Sponsors or Partners of services, products, content, reports, publications, subscriptions, contests, offers, newsletters, memberships, premium content, webcasts, video, white papers, online seminars, conferences, and/or events.

The legal basis for processing your Personal Data is your consent. In certain circumstances, we may otherwise process your Personal Data if we have a legitimate interest in doing so and we are not infringing any of your rights and freedoms.

Our legitimate business interests do not override your interests. We will not use your Personal Data in circumstances where your rights and freedoms override our legitimate interests, unless we have your consent or are otherwise required or permitted to by law.

WHEN AND HOW WE SHARE YOUR PERSONAL DATA WITH OTHERS?

Land Sterling may share your Personal Data to deliver services, products and/or content from this Site, Regional Offices, affiliate company/ies, Sponsors, Partners, and third parties’ services, products and/or content that might interest you, including sponsored content and events, for business operations and to comply with valid legal processes.

• For services, products and/or content that may interest you or that you requested

As aforementioned, your Personal Data may be shared within the network of communications of Land Sterling to provide you with information about services, products and/or content that might interest you and for internal analytical and business development purposes.

We may also share your Personal Data with third parties to deliver third-party-sponsored services, products and/or content that you requested (please refer to Third-party-sponsored services, products, and/or content below).

• For business operations

Land Sterling may also share your Personal Data with third parties we have contracted with to support our business operations, including delivery, fulfillment, payment processing, email deployment, suppression list management, and data processing.

• For third-party-sponsored services, products and/or content

Land Sterling collaborates with Sponsors and Partners to make available a large library of content to our users, such as white papers, professional events (live or online) as well as other services, products and/or offers. In return for access to such content, we may ask you to provide us with your Personal Data as part of the registration.

We reserve the right to share your Personal Data with our Regional Offices, affiliated company/ies, Sponsors, and Partners as permitted by law in order to fulfill our commitment to providing you with a full-service real estate investment and consultancy firm.

We do share your Personal Data under the following circumstances:

• Third-party vendors we engage to provide services on our behalf have access to Personal Data, but they have agreed not to disclose the Personal Data or to use it for any purpose other than providing the requested services, products and/or content

• There may arise special circumstances where it is necessary for us to disclose and use Personal Data and Non-Personal Data, such as:

To enforce this Policy or any other part of our Terms of Use

To protect our property or rights

To protect the safety of anyone

To investigate, prevent or take action regarding illegal or improper activities

To carry out a merger or consolidation with another entity, a sale or transfer of some or all of our assets, or any similar transaction/s

For other reasons we determine in good faith are necessary, appropriate or required by law, such as when we respond to subpoenas, court orders or other legal or administrative process

This Site may contain links to third-party websites, including that of our Regional Offices and our affiliate company/ies. If you hold your mouse over a link, it will indicate whether clicking the link will send you off this Site. When you click on those links, you will go to a third-party site where you will be subject to that site’s privacy policy and we encourage you to read that privacy policy.

We may use your Personal Data to send you the services, products and/or content you requested. In addition, your Personal Data may be shared with the sponsor/s or partner/s of the services, products and/or content to communicate with you regarding the services, products, content and other information or offers that may be of interest to you.

Please note that once your Personal Data is shared with the sponsor or partner, the sponsor or partner’s privacy policy, including information on how to opt-out in the future, will apply to your Personal Data.

Please be aware that we are not responsible for the privacy practices of those other websites and we expressly disclaim any liability for their actions, including actions relating to the use and disclosure of Personal Data by those third parties.

We remind you to be aware when you leave this Site and enter a third-party website, including that of our Regional Offices and our affiliate company/ies, and again encourage you to read the privacy policy on any website that collects your Personal Data.

SECURITY

Our hosting service maintains its systems in accordance with reasonable industry standards to reasonably secure the information of its clients against unauthorized access, accidental orientational manipulation, and loss. However, no data transmission over the internet can be guaranteed to be 100% secure and you use this Site at your own risk.

AS REQUIRED BY LAW

Your Personal Data may be shared when authorized by law or necessary to comply with a valid legal process.

IN THE EVENT OF NEW OWNERSHIP

Land Sterling may share your Personal Data if the composition of the firm changes in the future:

• We may choose to sell, transfer or merge parts of our business or our assets, or we seek to acquire other businesses or merge with them.
• During such process, we may share your Personal Data with other parties. We will only do this if they agree to keep your Personal Data safe and private.
• If the change to our firm happens, then other parties may use your Personal Data in the same way as set out in this Policy.

HOW LONG DO WE KEEP YOUR PERSONAL DATA?

Land Sterling retains your Personal Data for the duration of your business relationship with us, and we hold your Personal Data only as long as necessary for each purpose we use it, unless we have obtained your consent to use for another or similar purpose.

YOUR RIGHTS AND PREFERENCES

If you inform us that you want your Personal Data deleted or that you no longer wish for us to communicate with you for business or marketing purposes, or to otherwise restrict our processing of your Personal Data, we may retain some basic information in order to avoid sending you unwanted materials in the future and to keep a record of your request and our response.

CONTACTING LAND STERLING

If you contact us, then we collect Personal Data – including, without limitation, name, address, contact number/s, and email address – which is retained or referred to our Regional Offices and/or “Network of Professionals” (Land Sterling | KSA Network of Professionals, Land Sterling | UAE Network of Professionals and Land Sterling | UK Network of Professionals – our business insignia for all our team members, locally and globally, comprising of the management, employees, surveyors, consultants, valuers, business partners, affiliates, and sales associates), depending on the nature of your enquiry

If you are looking for a real estate consultant or sales associate, then your Personal Data is referred to our Regional Offices and/or our Network of Professionals. If your enquiry or complaint requires a response from us, then it is referred to the appropriate department for research and a response. The information we collect is not used in any other way.

NON-PERSONAL DATA

Even if you do not send us any Personal Data, we collect information about how you use this Site (“Non-Personal Data”). This information cannot be used to identify you personally and is explained in more detail below.

Like many sites, we obtain Non-Personal Data such as IP addresses, browser types, the name of your ISP (internet service provider), information about where a user comes from before arriving at this Site, what pages a user visits, the order of those pages, and the amount of time spent on each. A vendor may perform this service for us by sending a cookie to gather this information, compile it and report to us.

Use of Non-Personal Data

Land Sterling uses Non-Personal Data to:

• Customize the marketing content you see
• Improve our services
• Conduct research
• Provide anonymous aggregated reporting for internal audits and third parties

MARKETING

Land Sterling would like to send you information about our services and products that we think you might be interested in, as well as those of our Regional Offices, Sponsors, Partners, and affiliate company/ies. If you have agreed to receive marketing, you may always opt out at a later date.

You have the right at any time to stop Land Sterling from contacting you for marketing purposes or giving your data to our Regional Offices, Network of Professionals, Sponsors, Partners, and affiliate company/ies.

If you no longer wish to be contacted for marketing purposes, please contact us by sending an email to marketing@landsterling.com.

SOCIAL NETWORKS AND THIRD-PARTY PLUG-INS

This Site may include plugins from social networks or other third parties (example plugins are the LinkedIn and Facebook follow, like or subscribe buttons). Where legally permitted, these plugins may communicate with and send information to the party that provided the plugin, even if you do not click on the plugin. This information may include your IP address, information about your browser and device, and the address of the web page you are visiting on this Site. Loading, using or clicking the plugins may also place, read and transmit cookies. These cookies may contain a unique identifier the social network or third-party assigns to you. The loading, functionality and your use of the plugins are governed by the privacy policy and terms of the party that provided the plugin..

CO-BRANDING/COLLABORATIONS WITH CAREFULLY SELECTED PARTNERS

Land Sterling, from time to time, may collect personal and other information for a co-branding, co-promotion or joint program with a Partner and share your Personal Data with that Partner. For these programs, we will make clear at the point of collection that the Personal Data will be shared with Land Sterling and the participating Partner.

CO-BRANDING/COLLABORATIONS WITH CAREFULLY SELECTED PARTNERS

Land Sterling would like to make sure that you are fully aware of all your data protection rights. Every user is entitled to the following:

• The right to access

You have the right to request Land Sterling for copies of your Personal Data. We may charge you a small fee for this service.

• The right to rectification

You have the right to request that Land Sterling corrects any information you believe is inaccurate. You also have the right to request Land Sterling to complete the information you believe is incomplete.

• The right to erasure

You have the right to request that Land Sterling erases your Personal Data, under certain conditions.

• The right to restrict processing

You have the right to request that Land Sterling restricts the processing of your Personal Data, under certain conditions.

• The right to object to processing

You have the right to object to our firm’s processing of your Personal Data, under certain conditions.

• The right to data portability

You have the right to request that Land Sterling transfers the data that we have collected to another organization, or directly to you, under certain conditions. If you make a request, we have one (1) month to respond to you. If you would like to exercise any of these rights, please contact us by sending an email to marketing@landsterling.com.

COOKIES

A cookie is a small data file, often including an anonymous unique identifier that is sent from a website’s computer and stored on your computer’s hard drive. The use of cookies is common on the internet. A website can send its own cookie to your browser if your browser’s preferences allow it, but – to protect your privacy – your browser permits a website to access only the cookies it has already sent to you, not the cookies sent to you by other sites. You can configure your browser to:

– Accept all cookies

– Reject all cookies

– Notify you when a cookie sent (each browser is different, so check the “Help” menu of your browser to learn how to change your cookie preferences) You can reset your browser to refuse all cookies or indicate when a cookie is being sent. But if you refuse cookies, some parts of this Site will not function properly and may not provide services or information you have requested. For example, without cookies, we will not be able to provide you with searches that you have asked us to save.

CHILDREN

This Site is not directed to any individual under the age of 13 (“Children”), and we do not knowingly collect any information, including Personal Data, from Children.

If you are a parent or guardian and you are aware that your Children has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from Children without verification of parental consent, we take steps to remove that information from our servers.

THE DATA PROTECTION AND ANTI-CYBER CRIME LAWS IN THE UAE

In general, there is no specific data protection law in UAE. Therefore, in the absence of specific provisions on data protection, the Saudi Arabian courts and adjudicatory bodies will interpret data privacy violations under general Sharīʿah Principles, which are often expressed in general terms and afford courts and adjudicatory bodies considerable discretion. We understand, however, that a new personal data protection law is under review by the Consultative Assembly of Saudi Arabia (“Shura Council”).

Data protection under Sharīʿah Principles

Sharīʿah Principles protect each individual’s right to privacy and prohibit any invasions thereon. Under Shaiah Principles, disclosure of secrets is prohibited except inter alia where the owner of the relevant secret agrees to such disclosure or if the public interest requires so.

The Holy Qu’ran and the Sunnah do not stipulate a penalty for disclosure of secrets. However, as explained above, such disclosure may be punishable by a penalty that a judge, in his discretion, deems appropriate and equitable. Such penalty may include a fine, imprisonment or deprivation of certain rights such as suspension of a practicing license.

Secular regulations passed by the government

There are certain secular regulations passed by the government, which, although not dedicated as a whole to data privacy or protection, contain specific provisions governing the right to privacy and data protection in certain contexts. Specific regulations applicable to the real estate industry in the UAE may be available.

PRIVACY POLICIES OF OTHER WEBSITES

This Site may contain links to third-party websites, including that of our Regional Offices and our affiliate company/ies. Please note that our Policy applies only to this Site. When you click on those links, you will go to a third-party site where you will be subject to that site’s privacy policy and we encourage you to read that privacy policy.

CHANGES TO OUR PRIVACY POLICY

Land Sterling keeps this Policy under regular review and shall update this Policy at its sole discretion from time to time.

We will post changes to this Policy and indicate the effective date when this Policy is updated. If we make any material changes to this Policy, we may notify you by email, and by posting notice of the changes on this Site. Changes to this Policy are effective once published on this Site.

You are encouraged to check this Site for changes in the Policy and to stay informed about how your Personal Data is protected by us, and you acknowledge and agree that it is your responsibility to review this Policy periodically and become aware of any modifications.

By using this Site, you signify your acceptance of this Policy as may be modified from time to time. Your continued use of this Site after we make changes is deemed to be acceptance of those changes, as they are binding on you. You are advised not to access this Site if you do not agree with our Policy and practices.

HOW TO CONTACT LAND STERLING?

If you have any questions about this Policy, the Personal Data we hold on you, or you would like to exercise one of your data protection rights, please do not hesitate to contact us by sending an email to marketing@landsterling.com.