Tranquil Infra Developers LLC and its affiliates (collectively, “we”) are engaged in the business of development and sale of residential and commercial properties. This Policy outlines our practices in relation to the collection, storage, usage, processing, and disclosure of personal data that you have consented to share with us when you access, use, or otherwise interact with our website available at www.tranquilinfra.com (collectively, “Platform”) or avail of products or services that Tranquil Infra Developers offers you on or through the Platform (collectively, the “Services”).
In this Policy, the services offered to you through the Platform are referred to as “Property Development and Sales Services”. At Tranquil Infra Developers, we are committed to protecting your personal data and respecting your privacy. To provide you with services, we have to collect and otherwise process certain data about you. This Policy explains how we process and use personal data about you. Please note that unless specifically defined in this Policy, capitalized terms shall have the same meaning ascribed to them in our Terms and Conditions, available at www.tranquilinfra.com/terms-and-conditions (“Terms”).
We collect your personal information and process your personal data in accordance with UAE laws and other applicable data protection regulations.
Please read this Policy in conjunction with the Terms. By using the Services, you confirm that you have read and agree to be bound by this Policy and consent to the processing activities described under this Policy.
1. DEFINITIONS AND KEY CONCEPTS
In this Privacy Policy, the following definitions are used:
Data: Personal information, including sensitive personal information and special category personal data (as defined under Data Protection Laws) about you, which we collect, receive, or otherwise process in connection with your use of our website/App and/or the Platform.
Cookies: A small file placed on your device by our website/App or the Platform when you either visit or use certain features of our website/App or the Platform. A cookie generally allows a website or mobile application to remember your actions or preferences for a certain period of time.
Data Protection Laws: Any applicable law for the time being in force relating to the processing of Data.
Partners: Select third parties with whom we have contracts for the businesses described in this Privacy Notice.
Service Providers: Includes entities which provide services to us and to whom we may disclose your Data for a specific purpose pursuant to a written contract.
User or you: The natural person who accesses or uses the Services through our website/App or the Platform.
Our status as controller or processor:
Our business involves:
(a) Development of residential and commercial properties
(b) Sale of residential and commercial properties
For the purposes of certain applicable Data Protection Laws, we will act as a "controller" when we use your Data for our own purposes and a "processor" when we use your Data for and under the instructions of a Partner or other participating entity.
This Privacy Policy primarily explains how we use your personal data when we act as a controller of your Data. Where we act as a "processor" on behalf of a Partner or other participating entity (i.e. the “controller”), this Policy still applies.
2. WHAT DATA DO WE COLLECT ABOUT YOU
We collect Data for various purposes set out in this Privacy Notice. This Data includes, without limitation, the following categories:
Contact information: First and last name, email address, postal address, country, phone number, and other similar contact data.
Financial information: Payment instrument information, transactions, transaction history, preferences, method, mode and manner of payment, spending patterns or trends, and other similar data. It is clarified that we do not store any of your card details i.e., credit and debit card in our Application or website.
Technical information: Website, device and mobile app usage, Internet Protocol (IP) address, and similar information collected via automated means, such as cookies, pixels, and similar technologies.
Product and service information: Your website/App or Platform account membership number, registration information, and program-specific information, when you request products and/or services directly from us or participate in marketing programs.
Your reviews, feedback, and opinions: Your reviews, feedback, and opinions about our products, programs, and services.
Transaction information: Date of the transaction, transaction amount, transaction history, and related details.
Other information: Age, sex, date of birth, marital status, nationality, occupation, or any other personal information provided by you.
Location information: Personal data collected during the usage of services provided by us such as maps and navigation or any other similar services which require processing of such data.
3. HOW WE COLLECT DATA
We collect Data in the following ways:
a. Information You Give Us: We receive and store any information you enter on our website/App or the Platform or give us in any other way.
b. Automatic Information We Collect: We use “cookies”, pixels, and similar technologies to receive and store certain types of information whenever you interact with us.
c. E-mail Communications: We often receive confirmation when you open an email from us or click on a link in the email. You can choose not to receive marketing emails from us by clicking on the unsubscribe link in any marketing email.
d. Customer Care Support: We store data provided by you to our customer care support team including but not limited to call recordings.
e. Information from Other Sources: We may obtain information from other sources. An example is where we receive your Data from Partners in connection with the Platform.
4. DATA SHARED BY YOU
We may collect your Data in several ways from your use of our website/App or the Platform. For instance:
a. When you register with us to receive our products and/or services.
b. When you conduct a transaction or attempt a transaction on our website/App or Platform.
c. When you complete surveys conducted by or for us.
d. When you elect to receive any communications (including promotional offers) from us.
e. From the information gathered by your visit to our website or the
Platform.
5. DATA THAT IS COLLECTED AUTOMATICALLY
a. We automatically collect some information when you visit our website/App or the Platform. This information helps us to make improvements to our content and navigation. The information collected automatically includes your IP address.
b. Our web servers or affiliates who provide analytics and performance enhancement services collect IP addresses, operating system details, browsing details, device details, and language settings. This information is aggregated to measure the number of visits, average time spent on the site, pages viewed, and similar information. We use this information to measure site usage, improve content, and ensure safety and security, as well as enhance the performance of our website/App or the Platform.
c. We may collect your Data automatically via Cookies, pixels, and similar technologies in line with settings on your browser.
6. OUR USE OF DATA
We use the information collected through this App, as described in this policy, and we may use your information to:
I. Improve our services, App, and how we operate our business.
II. Understand and enhance your experience using our App,products, and services.
III. Personalize our products or
services and make recommendations.
IV. Provide and deliver
products and services you request.
V. Process, manage, complete,
and account for transactions.
VI. Provide customer support and
respond to your requests, comments, and inquiries.
VII. Create
and manage the online accounts you manage on our App.
VIII. Send
you related information, including confirmations, invoices,
technical notices, updates, security alerts, and support and
administrative messages.
IX. Communicate with you about
promotions, upcoming events, and news about products and
services.
X. We may process your personal information without
your knowledge or consent where required by applicable law or
regulation for verification of identity or for prevention,
detection, or investigation, including of cyber incidents,
prosecution, and punishment of offenses.
XI. Protect,
investigate, and deter against fraudulent, unauthorized, or
illegal activity.
XII. Protecting against, and preventing,
fraud, illegal activity, harm, financial loss, and other legal
or information security risks.
XIII. Providing marketing and
promotional campaigns to you based on your profile.
XIV. In connection with loyalty programs owned and operated by us or by
other Partners.
XV. Create a user profile based on data provided
by you on using the application.
Where processing your Data is necessary for us to carry out our obligations arising from any contracts entered into between you and us: If you enter into a contract with us in relation to any of our product or service offerings, we may process certain Data about you in order to perform our obligations under this contract, including to enable us to communicate with you about such products and/or services and to process your payment transactions.
Where processing your personal information is within our legitimate interests: We can process certain Data where it is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of yours which require protection of your Data.
Where you give us your opt-in consent to process your personal information: In certain circumstances, where required under relevant Data Protection Laws, we will seek to obtain your consent before we undertake certain processing activities with your Data.
Where required under relevant Data Protection Laws (e.g. under direct marketing legislation), we will obtain your opt-in consent prior to sharing your Data with third parties and carrying out certain marketing activities (unless we are permitted by relevant Data Protection Laws to contact you without your opt-in consent in relation to goods and services which are similar to those which you have already purchased, used, or interacted with).
You have the right to withdraw your consent to these activities. You can do so at any time, and details of how to do so can be found in the section below, titled "Your Rights and Choices".
Where processing your personal information is necessary for our compliance with a legal obligation: In certain circumstances, we may disclose your Data for the purposes of compliance with a legal obligation (for example, to comply with a law, regulation, or compulsory legal request). We do not think that any of the above activities prejudice you in any way. However, you do have the right to object to us processing your personal information in certain circumstances. If you would like to know more about these circumstances and how to object to our processing activities, please see the section below, titled "Your Rights and Choices".
Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your Data.
Further, where required under relevant Data Protection Laws, we will only process special category personal data (as defined under Data Protection Laws) if there is a valid legal basis, which might involve obtaining your explicit consent.
Where we use or share or otherwise process your Data as a processor on behalf of a Partner or other participating entity (i.e., the controller) for the purposes of offering you access to Third Party Applications on the Platform or as part of any services that we provide to that entity, we do so under the instructions of that entity and that entity is responsible for ensuring that there is a legal basis for us to use or share your Data on its behalf (if such legal basis is required under relevant Data Protection Laws).
7. PERMISSIBLE AGE
a. The Services are not intended for users under the age of 18, unless permitted under applicable local laws (Permissible Age) or under the involvement of a parent or guardian. We do not knowingly collect any personal information from users or market to or solicit information from anyone under the Permissible Age. If we become aware that a person submitting personal information is under the Permissible Age, we will delete the account and any related information as soon as possible. If you believe we might have any information from or about a user under the Permissible Age, please contact us at privacy@tranquilinfra.com.
b. This website is not directed at children under the age of 18 and We cannot distinguish the age of persons who access and use our website. If a minor (according to applicable laws) has provided us with Customer Data without parental or guardian consent, the parent or guardian should contact us (see Section 20) to remove the relevant Customer Data and unsubscribe the minor. If we become aware that Customer Data has been collected from a person under the age of 18 without parental or guardian consent, we will delete this Customer Data and, where that minor has an account, terminate the minor’s account.
8. SHARING OF DATA
We may share your Data in the following ways (and for the purposes of relevant Data Protection Laws, we may do so either as a controller in our own right or as a processor on behalf of and under the instructions of another entity in accordance with our obligations under our agreement with that entity):
a. We share your data with your consent or to complete any transaction or provide any product or service you have requested or authorized. We also share data with our affiliates and subsidiaries, and with vendors working on our behalf.
b. We may employ other companies and individuals to perform functions on our behalf. The functions include fulfilling orders for products or services, delivering packages, sending e-mails, removing repetitive information from customer lists, providing marketing assistance, providing search results and links (including paid listings and links), processing payments, transmitting content, scoring credit risk, and providing customer service.
c. Business Transfers: As we continue to develop our business, we might sell or buy subsidiaries or business units. Your Data may be transferred as part of such transactions.
d. Protecting Us: We may release Data when we believe that
disclosure is reasonably necessary
(a) to comply with a law,
regulation, or compulsory legal request;
(b) to protect our
intellectual property rights;
(c) to protect us against harm or
financial loss;
(d) when we believe disclosure is necessary to
protect individuals’ vital interests, or
(e) in connection
with an investigation of suspected or actual fraudulent or
illegal activity. This may include exchanging information with
other companies and organizations for fraud protection, risk
management, and dispute resolution.
e. Third Parties: We may also share your Data with other third parties where:
f. We reserve our right to share the information collected within Tranquil Infra Developers and internal departments for promotional and marketing activities and communications.
a) You request or authorize us to do so.
b) We need to comply with applicable law or respond to valid legal processes.
c) We need to operate and maintain the security of our website/App or
Platform, including to prevent or stop an attack on our computer
systems or networks.
d) The sharing of your Data will be in line
with the processes set out in this Privacy Policy.
9. DATA SECURITY
We will use technical and organizational measures to safeguard your Data and we store your Data on secure servers. Technical and organizational measures include measures to deal with any suspected data breach. If you suspect any misuse or loss or unauthorized access to your Data, please let us know immediately by contacting us by email.
The security of your Platform account depends on you keeping your account password(s), PINs, and other access information confidential. If you share your Platform account information with a third party, they will have access to your account and your Data.
It is your responsibility to control access to your mobile device and the Platform on your device, including keeping your password(s) and/or PIN confidential and not sharing it with anyone. It is also your responsibility to alert us if you believe that the security of your Data in the Platform has been compromised.
10. ANALYTICS AND TAILORED ADVERTISING
To help us better understand your use of the Services, we may use third-party web analytics on our Services, such as Google Analytics. These service providers use the sort of technology described in the "Automatically-Collected Information" Section above. The information collected by this technology will be disclosed to or collected directly by these service providers, who use the information to evaluate our users' use of the Services. We also use Google Analytics as described in the following section. To prevent Google Analytics from collecting or using your information, you may install the Google Analytics Opt-Out Browser add-on.
Tailored Advertising
Third parties whose products or services are accessible or advertised via the Services may also use cookies or similar technologies to collect information about your use of the Services. This is done in order to help them:
Inform, optimize, and serve ads based on past visits to our website and other sites and
Report how our ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to visits to our website.
We also allow other third parties (e.g., ad networks and ad servers such as Google Analytics, and other pragmatic/adTech players) to serve tailored ads to you on the Services, and to access their own cookies or similar technologies on your computer, mobile phone, or other devices you use to access the Services. We neither have access to, nor does this Privacy Policy govern, the use of cookies or other tracking technologies that may be placed by such third parties. These parties may permit you to opt-out of ad targeting. If you are interested in more information about tailored browser advertising and how you can generally control cookies from being put on your computer to deliver tailored advertising (i.e., not just for the Services), you may visit the Network Advertising Initiative's Consumer Opt-Out Link, and/or the Digital Advertising Alliance's Consumer Opt-Out Link to opt-out of receiving tailored advertising from companies that participate in those programs. To opt-out of Google Analytics for Display Advertising or customize Google Display Network ads, you can visit the Google Ads Settings page. Please note that to the extent advertising technology is integrated into the Services, you may still receive ads even if you opt-out of tailored advertising. In that case, the ads will just not be tailored to your interests. Also, we do not control any of the above opt-out links and are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms.
When accessing the Services from a mobile application you may also receive tailored in-application advertisements. Each operating system: iOS, Android, and Windows Phone provides its own instructions on how to prevent the delivery of tailored in-application advertisements. You may review the support materials and/or the privacy settings for the respective operating systems in order to opt-out of tailored in-application advertisements. For any other devices and/or operating systems, please visit the privacy settings for the applicable device or operating system or contact the applicable platform operator.
11. RETENTION OF DATA
We retain Data for as long as necessary for the use of our products and/or services or to provide access to and use of our website/App or the Platform, or for other essential purposes such as complying with our legal obligations, resolving disputes, enforcing our agreements, and as long as processing and retaining your Data is necessary for our legitimate interests. Because these needs can vary for different data types and purposes, actual retention periods can vary significantly. Even if we delete your Data, including on account of an exercise of your right under Clause 12 below, it may persist on backup or archival media for audit, legal, tax, or regulatory purposes.
12. YOUR RIGHTS AND CHOICES
Depending on which country’s laws are applicable to you, you may have various rights in relation to the Data that we hold about you. To get in touch with us about any of your rights under Data Protection Laws, please use the contact details set in the section below, titled “How to Contact Us”. We will seek to deal with your request without undue delay, and in any event, within any time limits provided for in Data Protection Laws (subject to any extensions to which we are lawfully entitled). Please note that we may keep a record of your communications to help us resolve any issues which you raise. Where we are legally permitted to do so, we may refuse your request.
You may be entitled to the following rights in relation to your Data:
a) Right to Confirmation and Access: You may ask us to confirm what Data we hold about you at any time, and request us to modify, update, or delete such Data. You may also request a copy of the Data we hold about you.
b) Right to Rectification: You have the right to request that we rectify any inaccurate or incomplete Data that we hold about you, including by means of providing a supplementary statement.
c) Right to Erasure: You have the right to request that we "erase" your Data in certain circumstances.
d) Right to Restrict Our Use of your Data: You have the right to request that we restrict our processing of your Data in certain circumstances, for example, if you dispute the accuracy of the Data that we hold about you or you object to our processing of your Data (including where we process your Data for our legitimate interests, where permitted under applicable law).
e) Right to Object: This right enables you to object to us processing your Data where we do so for certain reasons.
f) Right to Data Portability: You have the right to request that we transfer your Data to another third party. This right of data portability only applies to certain types of Data.
g) Right to Withdraw Consent: Where we have obtained your consent to process your Data for certain activities, you may withdraw this consent at any time and we will cease to carry out that particular activity that you previously consented to unless we consider that there is an alternative legal basis to justify our continued processing of your Data for this purpose.
h) Right to File Complaints: You have the right to lodge a complaint with the relevant supervisory authority in your jurisdiction.
To get in touch with us about these rights, or for more information about managing your Data and promotional communications, please use the contact details set out in the section below, titled “How to Contact Us”.
It is important that the Data we hold about you is accurate and current. Please keep us informed if your personal information changes during the period for which we hold it.
13. PROCESSING YOUR DATA
We take steps to ensure that your Data is processed according to the provisions of this Privacy Notice and the requirements of applicable law.
14. SEVERABILITY
If any court or competent authority finds that any provision of this Privacy Policy (or part of any provision) is invalid, illegal, or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this Privacy Policy will not be affected.
15. LINKS TO THIRD-PARTY SITES/APPS
Our App may, from time to time, contain links to and from other Apps/websites of third parties. Please note that if you follow a link to any of these Apps/websites, such Apps/websites will apply different terms to the collection and privacy of your personal data, and we do not accept any responsibility or liability for these policies. When you leave our Site, we encourage you to read the privacy policy of every App/Website you visit.
16. COOKIES
a. To optimize our App presence, we use cookies. These are small text files stored on your device. These cookies are deleted after you close the App. Other cookies remain on your device (long-term cookies) and permit its recognition on your next visit. This allows us to improve your access to our site. This helps us to learn more about your interests and provide you with essential features and services for additional purposes, including:
I. Keeping track of items stored in your shopping basket.
II.Conducting research and diagnostics to improve the content,products, and services.
III. Preventing fraudulent activity.
IV.Improving security.
b. Our cookies allow you to take advantage of some of our essential features. For instance, if you block or otherwise reject our cookies, you will not be able to add items to your shopping basket, proceed to checkout, or use any products or services that require you to sign in.
c. Approved third parties also may set cookies when you interact with our services.
d. Third parties include search engines, providers of measurement and analytics services, social media networks, and advertising companies.
e. Third parties use cookies in the process of delivering content, including ads relevant to your interests, to measure the effectiveness of their ads, and to perform services on behalf of us.
f. You can prevent the storage of cookies by choosing a "disable cookies" option in your device settings. But this can limit the functionality of our services.
17. CHANGES TO THIS POLICY
We may change this policy from time to time. If we make any changes to this policy, we will change the "Last Updated" date above. You agree that your continued use of our services after such changes have been published to our services will constitute your acceptance of such revised policy. We will notify you and seek additional consent before using your personal data for a new purpose that is inconsistent with the original purpose for which we collected it.
18. HOW TO CONTACT US
To request to review, update, or delete your personal information or to otherwise reach us, please submit a request by emailing us at privacy@tranquilinfra.com . You may contact us for information on Service Providers, Partners, and other entities with whom we may share your Data in compliance with this Privacy Policy and applicable law. We will respond to your request within 30 days.
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