Privacy Policy
Privacy Policy for the BrokerPromote platform, operated by Broker Promote (a Digistromer company).
This Privacy Policy explains how Broker Promote, a Digistromer company (Office 3101, Vision Tower, Business Bay, Dubai, UAE), collects, uses, discloses, and protects personal data when you use brokerpromote.com and app.brokerpromote.com and our related services (the “Services”). We process personal data in accordance with applicable law, including UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (the “PDPL”).
1. Who We Are and Scope
This Policy applies to personal data we process about visitors to our websites, users of the Platform, our customers and their staff, and prospects. It does not change the terms of any separate data-processing agreement we may have with a customer.
| Our role | What it means |
|---|---|
| Controller | For personal data about our own customers, website visitors, account users, and marketing contacts (e.g. brokerage owners, admins, agents), we act as the data controller. |
| Processor | For personal data a customer collects from its own leads, buyers, and contacts and processes through the Platform (Customer Content), the customer is the controller and we act as a processor on the customer’s behalf. |
2. Personal Data We Collect
We collect the categories of personal data set out below. Where you provide data about other individuals (for example, leads or agents), you confirm you have a lawful basis and the right to share it with us.
| Category | Examples | Purpose |
|---|---|---|
| Account & identity | Name, email, phone, company/brokerage name, role, login credentials | Create and manage your account, authenticate users, provide support |
| Billing | Plan, billing contact, transaction records (card data is handled by payment processors, not stored by us) | Process subscriptions, renewals, invoicing, and tax compliance |
| Usage & device | IP address, browser/device type, pages viewed, feature usage, logs, cookies | Operate, secure, and improve the Services; analytics |
| Customer Content | Listings, media, CRM records, leads and contacts you upload or generate | Provide the Services at your direction; processed on your behalf |
| Communications | Support tickets, WhatsApp and email correspondence, feedback | Respond to enquiries, provide support, service notices |
| Marketing | Contact details and preferences of prospects who opt in | Send updates where you have consented; opt out anytime |
3. How We Use Personal Data (Purposes and Legal Bases)
We use personal data to: provide, operate, and maintain the Services; authenticate users and secure accounts; process payments and manage subscriptions; provide customer support; communicate service and administrative notices; improve and develop the Services and analytics; send marketing where permitted; and comply with legal obligations and enforce our terms.
Depending on the circumstances, our legal bases under the PDPL and applicable law include: performance of a contract with you; your consent (which you may withdraw at any time); compliance with a legal obligation; and our legitimate interests in operating and securing our business, where not overridden by your rights.
4. AI Features
Certain features use automated processing to generate marketing assets, qualify and score leads, and draft suggested replies from information you provide. These outputs are tools to assist you; you remain responsible for reviewing content before it is published or sent. We do not use your Customer Content to train third-party foundation models except as described in this Policy or with your instruction. We do not permit our AI sub-processors to use your Customer Content to train their models.
5. Cookies and Similar Technologies
We use cookies and similar technologies to run the Platform, remember preferences, measure usage, and improve performance. You can control non-essential cookies through your browser settings or any cookie banner we provide. Disabling some cookies may affect functionality. See our Cookie Policy for details.
6. How We Share Personal Data
We do not sell personal data. We share it only as needed: with service providers and sub-processors who host, secure, analyse, and support the Platform (including cloud hosting, payment processing, messaging, and analytics providers), under appropriate confidentiality and data-protection obligations; with third-party integrations you enable (such as developer/MLS feeds, WhatsApp, and social or property portals), according to your instructions; where required by law, regulation, or valid legal process; and in connection with a corporate transaction such as a merger or acquisition, subject to this Policy.
7. International Transfers
We and our service providers may process personal data outside the UAE, including where our engineering team and cloud infrastructure operate. Where we transfer personal data internationally, we take the steps required by the PDPL to ensure an adequate level of protection, including appropriate contractual safeguards such as the standard contractual clauses recognised by the UAE Data Office.
8. Data Retention
We retain personal data for as long as needed to provide the Services, comply with legal, tax, and accounting obligations, resolve disputes, and enforce our agreements. When data is no longer required, we delete or anonymise it. Customer Content is retained and deleted in line with your instructions and our Terms, subject to a reasonable post-termination retention period.
9. Security
We implement technical and organisational measures designed to protect personal data against unauthorised access, loss, or misuse, including access controls, encryption in transit, and monitoring. We are pursuing ISO 27001, ISO 42001, and SOC 2 (in progress). No system is completely secure, and we cannot guarantee absolute security.
10. Your Rights
Subject to applicable law, you may have the right to: access the personal data we hold about you; request correction of inaccurate data; request erasure; object to or restrict certain processing; withdraw consent; request portability; and lodge a complaint with the competent supervisory authority. To exercise these rights, contact us using the details in Section 13.
Where we process personal data as a processor on a customer’s behalf, we will refer requests to the relevant customer (the controller) and support them in responding.
11. Marketing Communications and WhatsApp
We send marketing communications only where permitted by law and, where required, with your consent. WhatsApp and similar messaging for marketing requires prior opt-in. You can unsubscribe at any time using the opt-out mechanism in the message or by contacting us. Service and transactional messages are not marketing and may still be sent while your account is active.
12. Children
The Services are intended for business users and are not directed to children. We do not knowingly collect personal data from anyone under 18. If you believe a child has provided us personal data, contact us and we will take appropriate steps.
13. Contact Us
For questions about this Policy or to exercise your rights, contact us at:
Broker Promote (a Digistromer company)
Office 3101, Vision Tower, Business Bay, Dubai, United Arab Emirates
Phone / WhatsApp: +971 50 644 5205
Email: [email protected]
Web: brokerpromote.com
14. Changes to this Policy
We may update this Policy from time to time. We will post the updated version on the Platform and revise the “Last updated” date. Material changes will be notified by reasonable means. Your continued use of the Services after changes take effect constitutes acceptance of the updated Policy.