Privacy Policy

Propefy Pro is a workspace in which a licensed broker prepares documents for their own clients and shares them with named recipients by link, or downloads them as images to publish under the broker's own licence and permit. Propefy publishes no listings and posts nothing on the broker's behalf.

1. Who we are, and what this policy covers

1.1 Propefy LLC ("Propefy", "we", "us") is the controller of the personal data described here, except where we say we act as a real-estate professional's processor (clause 5.4).

1.2 What it covers. Propefy Invest — our free website at propefy.io: UAE property market statistics computed from government open data, optional accounts, saved lists and portfolios, shareable reports, and the "Ask Propefy" AI assistant. Propefy Pro — our paid service for UAE-licensed real-estate professionals: AI-assisted branded materials, tracked share links, a light client record ("Clients") and a brand kit. It also covers visitors who open a page an agent has shared.

1.3 Our source data is not about you. The market statistics in both products are computed by us from Dubai Land Department open data (data.dubai), published ADREC market reports and other public sources. Ingestion applies a strict field whitelist that drops personal data, and we do not attempt to re-identify anyone from it.

1.4 Language and law. This policy is in English during the beta. The Arabic text is in preparation: it will be legally reviewed and published with a language toggle on the legal pages. The policy is governed by the laws of the United Arab Emirates. Your rights under Federal Decree-Law 45/2021 (the PDPL) are statutory; the forum for disputes under the contract that applies to you is in the Propefy Terms and Conditions.

2. Summary — what we process, why, on what basis, for how long

UAE data protection law has no "legitimate interests" basis, so every purpose below is mapped to contract necessity, consent, a legal obligation, or statistical (anonymised) processing.

Automated decisions. We do not make decisions about you by automated means alone that produce legal effects or similarly significantly affect you, and we do not profile you for that purpose. Our AI assistant writes text and market estimates; it does not score you or decide your access to anything. Propefy Pro applications are approved by a person.

3. Information we collect

3.1 Propefy Invest. You can read most of Invest without signing in; we still process a hashed form of your IP address for rate limiting, and product analytics events (clause 9.2). If you create an account (email and password, with email confirmation) we store your email, display name, role, plan and display preferences, plus your watchlist, portfolio entries and saved reports. The marketing checkbox at sign-up is unticked by default, and ticking it is the only thing that puts you on our mailing list.

3.2 Propefy Pro. Sign-up is email and password. We store your workspace type, plan, trial dates and quota; a founder reviews and approves new workspaces. Your brand kit holds your agency name, emirate, licence number(s) and type, ORN, contact name, title, phone, email, WhatsApp, Instagram, LinkedIn, languages and specialisation — this is the material that appears on your published outputs and in their vCard QR code. Your logo is stored in a public storage bucket so it can render on share pages and exported files: treat it as public. Licence numbers are shown exactly as you entered them; we do not verify them. Your Clients records hold a display name, type, phone, email, areas of interest, budget, notes, tags and provenance; anonymous clients cannot have contact details, and the client form asks you to record the client's consent before personal details are saved; the consent record is time-stamped and cannot be changed through the app.

3.3 Visitors to a shared page. When you open a page an agent has shared, we record the event type and time, a non-reversible daily-salted hash of your IP address and a device class (mobile, tablet, desktop or unknown). We do not store your raw IP address, your browser's user agent or your location, and we do not learn your name from a view. Because Pro share links are per-recipient, an agent who sent a link to one named person can infer that that person opened it. Every share page carries a notice that views are counted for the agent. Your contact details reach the agent only if you fill in the lead form and tick "I agree the agent may contact me about this property"; you can skip it and still read the page. On Propefy Invest, if you are signed in to a Propefy account when you open a shared report, we record that your account opened it and show that to the agent who shared it — not merely a count. The on-page notice telling a viewer that this happens is not shown on the report page itself today. We do not give them your email address. We also copy into the same record the marketing-consent flag you gave Propefy at sign-up, which the sharing agent can read. Shared pages can be opened by anyone holding the link. Propefy Pro share pages ask search engines not to index them; a shared Propefy Invest report can be found by search engines.

4. How we use your information

4.1 To provide, secure and support the Services: run your account, deliver the features you use, meter Pro usage, send service messages, prevent abuse and fraud, fix faults, and meet our legal and tax obligations. We do not sell personal data, and we do not use Pro client data for our own marketing.

4.2 "Ask Propefy" (Invest). We do not store your messages. Your question goes to the model to produce an answer and is not written to our database (our AI provider keeps it for up to 30 days — clause 6.1). We keep an answer cache — the answer text stored against a hash of the normalised question, with no link to you or your account, purged after 30 days — so repeat questions are answered quickly and cheaply. We record content-free telemetry (intent, emirate, model tier, latency, success or failure) with no message text. Every answer carries the notice "Information only — not investment advice". Please do not type personal details into the assistant; we do not need them.

4.3 The Pro assistant. Your conversations are stored so you have a history in your workspace, and they are visible only to the person who created them. Before your message reaches the model and before it is stored, we automatically remove email addresses and UAE telephone numbers and tell you we have done so. That removal applies to what you type. Names are not reliably detected, and a client's display name can reach the model: when you ask for a document addressed to a named client, the assistant looks that client up, and the name is sent to the model and saved in the conversation. Their phone number and email address are not. Your agency name and brand details are sent, because the assistant uses them to draft your material, and any listing screenshot you upload is sent to the model so it can read it. Do not put Emirates ID, passport, bank or payment details into the assistant or into a client record's name field.

4.4 No training; improvement only on de-identified data. We do not use your prompts, conversations, client records, uploads or outputs to train or fine-tune AI models, and our AI provider is contractually bound not to. We improve our products using de-identified or aggregated information only. Our staff open a conversation only for support you have asked for, to investigate abuse or a security incident, or where your workspace has granted recorded access.

4.5 Emails we send. Service messages (verification, security, billing, changes to the terms) go to your account address while you hold an account. Pro follow-up reminders go to you, the agent, and contain a client's display name only. Founder-approval and account-deletion confirmations go to your account address. Marketing email is sent only if you opted in (clause 12).

5. Who we share it with

5.1 We do not sell personal data. We share it with the service providers below, with the agent who shared a link with you (as described in clause 3.3), within your Pro workspace under its roles — where administrators and managers can see materials, share links and engagement events created in the workspace, while client contact details and assistant conversations stay visible only to their creator — with authorities where the law requires it and professional advisers under confidentiality, and with a buyer or successor if we are ever acquired or reorganised, with notice and the same protections.

5.2 Sub-processors.

This table lists the providers we use today.

5.3 Each provider processes data for us under a contract imposing PDPL-equivalent protections. We give Pro customers at least 30 days' notice before a new sub-processor starts processing their client data.

5.4 Roles in Propefy Pro. For your agent account, workspace, brand kit, billing, usage, security logs and assistant conversations, Propefy is the controller. For the Clients, leads and share-link recipients in your workspace, you are the controller and Propefy is your processor, on the terms of section 12 of the Propefy Terms and Conditions. You are responsible for having a lawful basis and consent for that data, for its accuracy, and for answering the people it is about. For the record of who opened a report you shared on Propefy Invest, you are likewise the controller and Propefy is your processor, and you are responsible for the relationship with the recipient.

5.5 If an agent holds your details in Propefy. An agent using Pro may hold your name and contact details in their own workspace; they, not Propefy, decide how those are used. We host the record for them, so we cannot answer a request about it ourselves — contact the agent, or write to privacy@propefy.io and we will pass it on and help them respond. The same applies to a lead you submitted on a shared page and to a contact list an agent imported.

6. International transfers

6.1 No personal data is stored in the UAE today. Our database, authentication and file storage run on Supabase on AWS in eu-central-1 (Frankfurt, Germany) for both products. Our code runs on Vercel in fra1, Frankfurt, for both products; Vercel's global network carries each request from the point of presence nearest you to Frankfurt, so that location handles your connection first. AI processing is by Anthropic in the United States, which retains inputs and outputs for up to 30 days for safety and abuse purposes and does not train on them. Email (Resend), analytics (PostHog) and maps (Mapbox) are in the United States; error monitoring is provided by Sentry.

6.2 The UAE has not issued an adequacy list under PDPL Art. 22. We therefore rely on Art. 23: contracts with each recipient imposing protections equivalent to the PDPL (their data processing agreements, and standard contractual clauses where EU data is involved), the necessity of the transfer to perform our contract with you, and your agreement at sign-up.

7. How long we keep data

7.1 The periods are in the retention column of the clause 2 table. When a period ends we delete the data or irreversibly anonymise it.

7.2 Where we must keep something longer, such as tax records, we keep only what that purpose needs.

7.3 Deleting a Pro account erases your workspace or your own rows — conversations, clients, leads, engagement events, materials, snapshots, share links and consents — sweeps stored files, deletes your sign-in record and emails you a confirmation. Deleting your account does not cancel billing.

8. Your rights

8.1 Under the PDPL you may ask us to: give you a copy of your data and information about how we process it; give it to you in a portable format; correct it; erase it; restrict or stop processing; object to direct marketing; and withdraw consent at any time, which does not affect processing already carried out. You may also object to decisions taken solely by automated processing — although, as clause 2 says, we do not take them.

8.2 How to ask. Email privacy@propefy.io from the address on your account, or use the in-product controls where they exist. We respond within 30 days and may ask you to confirm your identity first. If your request concerns data an agent holds about you in Propefy Pro, we pass it to that agent as controller and help them answer it.

8.3 In-product controls today. Pro customers can export their Clients to CSV and delete client records themselves; leads, materials, share links and their engagement events cannot yet be deleted individually — email privacy@propefy.io and we will action it. Invest has no self-service deletion or export yet: email privacy@propefy.io to ask us to delete your account and data, or to send you a copy, and we will action it within 30 days.

8.4 Is giving us your data optional? Where a field is optional we say so, and the only consequence of leaving it blank is that the related feature will not work. The marketing checkbox and the consent box on the question-by-email form are optional, and an agent's lead form can be skipped.

8.5 If you are in the EU/EEA or UK. Where the GDPR applies, our bases map as follows: contract necessity → Art. 6(1)(b); consent → Art. 6(1)(a); legal obligation → Art. 6(1)(c); security, abuse prevention and aggregate product improvement → Art. 6(1)(f). Transfers out of the EEA rely on the European Commission's Standard Contractual Clauses in our providers' agreements. You have the GDPR rights of access, rectification, erasure, restriction, portability and objection, and may complain to your local supervisory authority.

8.6 If you are in California. We do not sell or share your personal information, and have not done so in the preceding 12 months.

9. Cookies and similar technologies

9.1 Strictly necessary — always on. Invest: a sign-in cookie, and cookies and local-storage entries that keep your language, theme and watchlist. Pro: Supabase sign-in cookies; pf_locale (your language, 1 year); propefy-pro.theme (your theme choice, 1 year — absent when you follow your system theme); pro_recovery_grant (a 10-minute cookie set only while you reset your password); the local-storage entries propefy-pro.sidebar-collapsed and propefy-pro.recent-areas (your sidebar state and the areas you last searched, on this device only); and session-storage entries that resume an interrupted upload and open the chat you started from a gallery card, cleared when the tab closes. These keep you signed in or remember a choice you made on this device; none is used for analytics or advertising, and they cannot be switched off separately.

9.2 Analytics (Invest only). Invest uses PostHog (US cloud) to record page views, page-leave events, clicks and form interactions, and JavaScript errors, linked to your account ID if you are signed in or to a random device ID if not. Invest has no analytics off-switch in the product yet. Pro has no analytics tracker. You can delete cookies in your browser, which signs you out and resets your preferences.

9.3 Other browser-side third parties. Vercel processes request data, including your IP address, to deliver pages and block attacks, and sets no analytics cookies. Mapbox serves map tiles on Invest directly to your browser, so it receives your IP address and the map area you are viewing. Propefy Pro share pages (`/s/…`) set no cookies at all. A shared Propefy Invest report opens inside propefy.io, so the strictly necessary cookies in clause 9.1 apply — including your sign-in cookie, which is how we know that your account opened it.

10. Security and personal data breaches

10.1 We protect data with encryption in transit, row-level security so records are readable only by the account that owns them or, inside a Pro workspace, by the roles described in clause 5.1, hashed share-link tokens, hashed IP addresses, rate limiting, least-privilege service credentials and access controls on staff accounts. No system is perfectly secure.

10.2 If a personal data breach occurs that would prejudice your privacy, confidentiality or security, we will notify the UAE data protection authority without undue delay and, where the breach is likely to prejudice you, notify you too — describing the breach, its likely consequences and what we are doing about it. Our internal target is to assess and report within 72 hours of becoming aware. Where a breach affects a Pro customer's client data, we notify that customer immediately upon confirmation and in any event within 48 hours.

11. Children

Both products are for adults: you must be 18 or over. We do not knowingly collect personal data from anyone under 18, and will delete it if we learn that we have. If you believe a child has given us data, contact privacy@propefy.io.

12. Marketing

We send marketing email only if you have opted in. You can object at any time by emailing privacy@propefy.io; we act on it without charge and without asking why. Service messages you cannot opt out of while you hold an account are limited to security alerts, billing notices and changes to our terms. Pro follow-up reminders are service notices about your own clients; they are sent only for clients where you set a follow-up date.

13. Changes to this policy

We update this policy when our processing changes; the version number and effective date are at the top. For material changes we give notice in the product and, for Pro customers, by email at least 30 days beforehand. If a material change reduces the protection you have today, you may stop using the service and close your account before it takes effect, and for a paid plan we refund the unused part of any period you have paid for. We do not change this policy retroactively. Earlier versions are kept and available on request.

14. Contact and complaints

• Privacy and data requests: privacy@propefy.io
• Legal notices: legal@propefy.io
• Support: support@propefy.io (Propefy Invest) · pro@propefy.io (Propefy Pro)
• Post: Propefy LLC, Sharjah Media City (Shams), United Arab Emirates

Please contact us first — we would like the chance to put things right. You also have the right to complain to the UAE data protection authority (the UAE Data Office or its successor).