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Privacy Policy

Draft, under legal review

This document is a working draft. It has not yet been reviewed by a lawyer and some details, such as the named data controller, are not filled in yet. It is published so you can see the terms we intend to operate under. It is not yet our final policy.

Who we are

Provera Real Estate LLC (“Provera”, “we”, “us”) is a real estate company licensed in Dubai by the Department of Economy and Tourism, commercial licence no. 1536845, with its office at The Burlington Tower, Office 2201, Business Bay, Dubai. Property purchases in the United Arab Emirates and the United Kingdom are handled by our own consultants. Golden visa applications in Greece, Hungary, Portugal and the UAE are prepared and filed through authorised, licensed professionals in each country, such as law firms and licensed agencies, under that country's official rules.

The controller of your personal data is:

Company
Provera Real Estate LLC
Licence
Commercial licence no. 1536845, issued by the Department of Economy and Tourism, Dubai
Office
The Burlington Tower, Office 2201, Business Bay, Dubai
Data controller
Provera Real Estate LLC
Privacy enquiries
admin@smartdecisionproperties.com

Please contact us through the channels listed on this website. We do not deal with enquiries through any other channel.

What this policy covers

This policy explains what personal data we collect when you use this website, why we collect it, who we share it with, and what rights you have.

The most important thing to understand is in the section headed “Golden visa enquiries”. Please read that section before submitting an enquiry.

What we collect

When you submit an enquiry or request an appointment:

  • Name
  • Email address
  • Telephone number
  • Country you are interested in
  • What you are trying to achieve (investment, relocation, holiday home, residency, resale)
  • Budget range, if you choose to provide it
  • Anything you write in the message field
  • The page you were on when you submitted
  • The language you were using

Budget is optional. You can complete an enquiry without it.

When you create an account:

  • Name and email address
  • Password, stored in hashed form. We never see or store your password in readable form
  • Properties you save
  • Searches you save
  • Enquiries you have made

Automatically, when you browse:

  • IP address
  • Browser and device type
  • Pages viewed and time spent
  • Referring website
  • Approximate location derived from your IP address, used to set your default currency and to show you the right contact details

Some of this is collected only if you consent to analytics or marketing cookies. See our Cookie Policy.

We do not collect payment card details, bank details, passport or identity document copies, or financial statements. We are not a party to your purchase transaction and we do not need this information. If anyone claiming to represent us asks you for these through this website, do not provide them and contact us.

Why we use it, and on what legal basis

What we doWhyLegal basis
Respond to your enquiryTo answer the question you askedSteps taken at your request before entering a contract
Match you with the right person on our team, or route a golden visa enquiry the right wayThis is the service you asked forSteps taken at your request; our legitimate interest in operating our business
Share a golden visa enquiry with the licensed professional preparing your applicationSo they can prepare your applicationSteps taken at your request; our legitimate interest
Run and secure the websiteTo keep the service working and safeOur legitimate interest
Understand how the site is usedTo improve itYour consent, through analytics cookies
Send you marketingTo tell you about relevant properties or guidanceYour consent
Show advertising on other sitesTo reach people who may be interestedYour consent, through marketing cookies
Keep records of enquiries and consentsTo meet legal obligations and defend claimsLegal obligation; our legitimate interest

Where we rely on legitimate interest, we have considered whether our interest is outweighed by your rights. You can object to this processing at any time using the contact details above.

Golden visa enquiries

This is central to how our service works, and you should understand it before you enquire.

When you submit an enquiry, we review it ourselves first. An enquiry about property in the United Arab Emirates or the United Kingdom stays with our own team and is not passed to anyone outside it.

An enquiry about a golden visa is passed to the authorised, licensed professional in the country concerned, a law firm or licensed agency, who will contact you and prepare your application under that country's rules.

What we share: your name, contact details, the programme you are interested in, your stated goal, your budget range if you provided one, and your message.

When we share it: only once we have reviewed your enquiry and confirmed the right route for it. Nobody outside our team can browse enquiries, and nobody sees yours before that point.

What happens then: the professional becomes an independent controller of your data. They will contact you directly, and their own privacy policy applies to how they handle your data from that point, alongside ours. Your data is passed on only for the purpose of your application, and only to professionals with appropriate data protection arrangements in place.

If you do not want this: tell us in the message field, or contact us before enquiring, and we will discuss your enquiry with you without passing it on. Please note we may not be able to provide the service in that case.

Who else we share data with

RecipientPurpose
Hosting and infrastructure providersRunning the website
Email service providersSending you confirmations and replies
Customer relationship management systemManaging enquiries
Analytics providersUnderstanding site usage, only with your consent
Advertising platformsShowing relevant advertising, only with your consent
Professional advisersLegal and accounting advice where necessary
AuthoritiesWhere we are legally required to disclose

If you reached us through a link shared by one of our affiliates, that affiliate can follow your enquiry in their panel. They can see your name, the date you contacted us, the page or form you used, the property or service you are interested in and your budget, how far your enquiry has progressed and its value, other details recorded on it such as the listing, unit and dates, and the name of the consultant handling it. They cannot see your phone number, email address or WhatsApp, your documents, or any messages, notes or emails between you and us; contact details that appear in other text are hidden from them.

We do not sell your personal data.

We may also disclose personal data:

  • To comply with a court order, a law or a request from a regulator or other authority
  • To enforce our Terms of Use, or to protect the rights, property or safety of our clients, our team or others, including to prevent fraud
  • To a successor if our business, or the part of it that holds your data, is reorganised, merged or transferred; your data would remain protected by this policy

We may share information that has been combined and made anonymous, so that it no longer identifies anyone, for example figures on how many people searched in a given market.

International transfers

Our own team is in the United Arab Emirates and the United Kingdom. Golden visa applications are prepared in Greece, Hungary, Portugal and the United Arab Emirates.

Greece, Hungary and Portugal are in the European Union, and the United Kingdom has a data protection framework recognised in Europe. The United Arab Emirates does not currently have an adequacy decision from the European Commission or the UK government.

Where we transfer your data to a professional or service provider outside the UK or European Economic Area, we put appropriate safeguards in place. You can ask us for details of the safeguards that apply to your data using the contact details above.

Marketing messages, and how to stop them

We send marketing only with your consent. Every marketing email carries an unsubscribe link, and on WhatsApp you can reply to tell us to stop. You can also withdraw consent at any time using the contact details above.

Your telephone number, and your consent to be contacted by phone or WhatsApp, are never shared with third parties for their own marketing.

Other websites

This site links to websites and services we do not run, such as official government sources, developers' sites and messaging apps. This policy does not cover them, and their own privacy policies apply when you use them.

How long we keep it

DataRetention
Enquiries that did not lead to a purchase24 months from last contact
Enquiries that led to a purchase7 years, for legal and tax record keeping
Account dataUntil you delete your account, then 30 days
Consent records7 years, as evidence that consent was given
Analytics data26 months
Marketing preferencesUntil you withdraw consent, plus a record that you did

Your rights

Depending on where you are, you have the right to:

  • Ask what data we hold about you and get a copy
  • Have inaccurate data corrected
  • Have your data deleted in certain circumstances
  • Restrict how we use your data
  • Receive your data in a portable format
  • Object to processing based on legitimate interest
  • Withdraw consent at any time, including for marketing and cookies
  • Complain to a data protection authority

To exercise any of these, contact us using the details above. We will respond within one month.

If your data has already been passed to the professional preparing your golden visa application, you may also need to contact them directly for data they hold. We will tell you who they are and how to reach them.

Complaints: you can complain to the data protection authority where you live or work, or where you believe the problem arose. In the UK that is the Information Commissioner's Office. In the European Union it is the authority of your member state. In Türkiye it is the Kişisel Verileri Koruma Kurumu.

Security

We use encryption in transit, access controls, and hashed password storage. No system is completely secure, and we cannot guarantee absolute security. If a breach occurs that is likely to affect your rights, we will notify you and the relevant authority as required by law.

Security also depends on you. If you have an account, keep your password to yourself and tell us straight away if you think someone else has used it.

Children

This service is not directed at people under 18 and we do not knowingly collect their data.

Changes

We may update this policy. The date at the top shows when it was last changed. If we make a significant change, we will tell you.

Questions about this document

Talk to us