We take your privacy seriously and are committed to safeguarding your personal information at FLT Samar LLC. (which term includes all subsidiaries of FLT) referred as (“Company”, “we” or “us” or “FLTr”). We value you as our customer, respect your privacy and are committed to protecting it through our compliance with this policy.

This policy describes the sources of your personal information that we may collect from you or that you may provide to us, our purposes for collecting and processing your information, and our practices for collecting, using, maintaining, retaining, protecting and disclosing that information.

If you have any questions or concerns about this privacy policy or your personal information, please contact us at info@fltcommunities.com

The sources of your personal data collected (collectively referred to as “Platforms” in this policy) may include without limitation the following:

• FLT websites: These are websites we created for you that are operated by us, they include websites operated by FLT under our own domains and web addresses (URLs) and our own micro-sites that are part of a third-party social media networks such as Facebook, Twitter, or Instagram.
• Emails, text messaging services, and other electronic messages: These are the electronic text-based interaction between you and FLT.
• FLT mobile applications: These are smartphone applications created for you and operated by FLT or one of our partners.
• FLT customer service: Any communication between you and our customer service center (e.g. phone, chatbot, email, WhatsApp etc.).
• Online / Offline registration forms: These include printed/digital registrations, surveys, or questionnaires FLT collects via registration forms, contests, events, and various promotions when you participate in one of our events or visit our promotional stands in malls to enquire about our properties
• Advertising: You might interact with one of our or our partners’ advertisements on our websites and apps and we might receive and collect this information.
• Career Portal: These includes recruitment portal across FLT.
• Data we create: FLT may also create data about you, when you avail our services.
• Data from other sources: These include social media networks, market research agencies, FLT third party sales agents, registered brokers, FLT promotional partners (such as Banks,  Government entities), public sources, and data received when we acquire other companies.
• FLT Loyalty Program: Once you register for our loyalty program, we collect and process your personal information and transaction history.
• FLT Public Wi-Fi: Any usage of the FLT public Wi-Fi network at our registered offices.

This policy does not apply to information collected:

• through any other means, including any other website operated by any third party; or
• by any third party, including through any application or content (including advertising) that may link to the Website.

WHAT INFORMATION WE COLLECT ABOUT YOU AND HOW WE USE YOUR PERSONAL INFORMATION?

The type of personal information we collect on or through our platforms, why we collect and how we use the personal information are explained in the following:

We would use your personal data to help us respond to your queries or expression of interest and to ensure we help you find the right property that suits your needs. We may receive your personal data through one of the following channels:

When you send us an enquiry, via our website/social media page/call/WhatsApp, regarding one of our properties; When you participate in one of our events or visit our stands to enquire about our properties; When you may have expressed interest about our properties through our third-party agents; When you visit our sales office or contact our sales advisors regarding any property you wish to purchase.

We collect the following personal information: name, email address, phone number, nationality and details of your enquiry pursuant to our legitimate business interests. In certain cases, your enquiry may relate to a specific service request, for example: raising an enquiry regarding a specific property. For such requests, we need to use your personal information to help us respond to your request and to fulfill our contractual obligations under the requested service. Additionally, when you call our customer service centre, we would maintain a record of the communications, including call recordings, in pursuit of our legitimate business interest to monitor and improve the quality of our customer support.

TO ENTER INTO OR TO CONCLUDE A SALES PURCHASE AGREEMENT:

Once you have decided to move forward to purchase of a property with FLT, we collect personal data such as name, passport, visa details, address, national ID, contact to conclude the contractual arrangements to finalize the property sale and to facilitate property registrations, handover and payment arrangements. Additionally, to conclude property sales, we are required to carry out a security clearance of our customer in compliance to local laws and pursuant to our legitimate business interest to combat any fraudulent transactions.

TO REQUEST YOUR FEEDBACK, AND TO RESPOND TO COMPLAINTS:

Your satisfaction is our utmost priority and we proactively take necessary steps to ensure you are well satisfied with our services. To help us respond to your feedback or complaints, we collect the following personal information: name, email ID, transaction details (such as service you availed) and your feedback/ complaints in the “We Care submission form”, through a survey conducted after you complete a transaction or after the completion of your call with our customer service team. We collect and use your personal information in pursuit of our legitimate business interests to address your concerns and to take necessary steps towards continual improvement.

TO FACILITATE EMAIL CAMPAIGNS CARRIED OUT BY OUR SALES AND MARKETING DEPARTMENTS:

As part of our email campaigns, we track whenever you receive, open, click a link, or download any attachments from an e-mail you receive from FLT. We will carry out automated profiling of such information to evaluate your interest in our service offerings or promotions. This processing will enable us to identify and target potential customers or business partners, tailor our marketing and provide you with relevant and timely content based on your interests, in pursuit of our legitimate business interests

TO FACILITATE ADVERTISEMENTS:

FLT uses the personal information you provide us for a commercial purpose to help us tailor and show advertisements to you. We may partner with third parties to help us display relevant advertising and to manage our advertising across multiple channels including social media platforms. Our third-party partners may use cookies and non-cookie-based technologies to help us show you advertising based upon your browsing activities and interests

TO FULFILL ANY MAINTENANCE/ SERVICE REQUESTS YOU RAISE USING OUR ‘E-SERVICES’ OR ‘EMAAR-ONE’ APPLICATION:

We provide various services to our property owners and residents such as Move-In and NOC requests, manage any service fees and installment payments, facilitate any amenities booking, facilitate home service bookings etc. As part of these services we may process your personal information such as name, contact details, details of your requests in accordance to our contractual obligations to provide you the requested the fulfillment of your service and to assign the right professionals to assist your needs.

TO SERVICE THE COMMUNITIES, WE MANAGE:

Under FLT Community Management, our primary objective is to manage and enhance the wellbeing of the property and lifestyle of the residents in our care. We serve a portfolio of six Master Communities, each comprising smaller sub-communities. These six covers a range of properties, which present their own unique set of characteristics and challenges. For more information please contact us. As part of the FLT Community Management, we provide various services such as association management, customer service, site management, financial management etc. We collect and process personal data of the residents of the communities to facilitate ‘Move in permits’, ‘Access Permits’ and any maintenance/ service requests to fulfil our contractual obligations and pursuant to our legitimate business interests towards ensuring safety and comfort  to the residents of our communities.

TO ESTABLISH A WORKING RELATIONSHIP WITH OUR TENANTS, THIRD PARTY AGENTS AND BUSINESS PARTNERS:

We collect/ receive personal information about you through one of the following channels:

When you send us an enquiry for Tenancy or if you were previously engaged under a Tenancy arrangement with us; When you participate in any of our sales, marketing and thought leadership events (including webinars) organized or hosted by FLT; When our sales executive or business leaders visit events organized by external organizations (including the company you represent); We collect from our sales executives or business leaders who share a professional/ personal relationship with you; or We collect from publicly available information that you have shared on professional networking platforms such as LinkedIn.

We collect the following personal information: name, email ID, contact number, designation, and the company you represent. We use this information for the purposes, listed below, in pursuit of our legitimate business interests to share information relating to FLT services, and possible tenancy opportunities; to invite you to future events, that may be of interest to you and/ or the company you represent; and to establish a working relationship with the company you represent.

TO ENTER INTO, RENEW OR FULFILL SERVICE CONTRACTS WITH OUR TENANTS, THIRD PARTY AGENTS AND BUSINESS PARTNERS:

We collect and use personal information such as name, email ID, contact number and in certain cases passport/ government ID proof to facilitate the performance of the tenancy contract between FLT and the Organization you represent. We may also collect personal information (such as Name, contact details, passport/ government ID etc.,) of the employees of your Organization that would be stationed within our malls/ facilities for sales events to facilitate security pass clearance pursuant to our legitimate business interest and to fulfill our contractual obligations.

TO ENTER, COMMERCIAL OR INVESTMENT RELATIONSHIP:

We collect and use Information when you enter a commercial or investment relationship (as a shareholder or buyer of one or more assets from the Group’s portfolio) with an FLT Group company. It is in accordance with Contractual obligations to collect the following Data either directly from you, or from the company that you work or represent: Name, contact details, phone number, postal address, email address, date and place of birth, percentage of capital and voting rights held, other data but strictly linked to the investment, etc.

TO COMPLY WITH LEGAL REQUIREMENTS AND EXERCISE OR DEFEND LEGAL CLAIMS:

We may need to process and retain your personal information to comply with legal requirements to which we are subject (for example in relation to licensing, health and safety). It is in our legitimate interests to process personal information for the purposes of exercising and defending legal claims. Processing personal information may also be necessary to ensure compliance with the relevant legal and regulatory obligations.

TO PROCESS YOUR PAYMENTS AND PROTECT AGAINST FRAUDULENT TRANSACTIONS:

We may need to process your personal information to keep your payments safe and secure and protect against fraudulent transactions. It is in our legitimate interests to process personal information to keep your payments secure and to prevent fraud. We may also require your personal information to send payment reminders and legal intimations in case of overdue payments. Processing personal information in this way may also be necessary to ensure compliance with the relevant legal and regulatory obligations.

TO COMPLY WITH ANY OPT-OUT OR DO NOT DISTURB REQUESTS WE RECEIVE FROM YOU:

We understand that you may not prefer for us to contact you with any offers, promotions or details of our products and services. In the event you opt-out, we may be required to maintain information such as name, email ID/contact number and the subscription(s) that you have opted out of to ensure compliance with your requests. Also, in the future, if you wish to hear from us, you may at any time, contact us to opt-in and we would be happy to keep you posted about our latest offers, promotions and/ or details of our products and services.

TO COMPLY WITH HEALTH AND SAFETY OBLIGATIONS:

We may be required to process your medical information or any other health related information in the event of an accident or injury at our residential units or the communities we manage. It is our legitimate interest for the management of accidents and injuries occurring in our managed facilities. This information would also be required for the improvement of the accident prevention system (including fire protection and prevention against foreseeable natural and technological risks). It could also possibly be required for legal purposes or to prepare for and defend against legal claims.

OTHER INFORMATION WE COLLECT

There is other information we may collect that does not directly reveal your specific identity or does not directly relate to you as an individual. We may automatically collect the following information pursuant to our legitimate business interests when you visit our website or utilize our services:

• Your equipment, browsing actions and patterns collected automatically as you navigate through our websites.
• Usage details, time of requests, browser types, operating system, IP addresses and information collected through cookies, web beacons and other tracking technologies.
• Details of your visits to our website, including traffic data, location data, logs and other communication data and the resources that you access and use on the website.

The information we collect automatically is statistical data. It helps us to improve our Website and to deliver a better and more personalized service by enabling us to:

• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize our Website according to your individual interests.
• Speed up your searches and recognize you when you return to our Website.

The technologies we use for this automatic data collection may include:

• Cookies: A cookie is a small piece of data, which includes an identifier made of letters and numbers that is sent by a web browser and stored on your computer. Cookies are used as a reliable mechanism to remember information about you, so your interaction with our website is seamlessly simple. Cookies typically do not contain any information that personally identify you, but personal information that we store about you may be linked to the information stored in and obtained from cookies. Please click here for details on Cookie Policy.
• Flash Cookies: Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies.
• Web Beacons: Pages of the Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs. pixel tags and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an e-mail and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

We use these cookies for the following purposes:

• To identify you when you visit our platforms and to help you navigate through our platforms;
• To help determine if you are logged into our platforms:
• To store information about your preferences and to personalize our platforms for you;
• To secure and protect your user account and our platforms; and

INFORMATION WE RECEIVE FROM OTHERS

We work closely with third parties and receive information about you from them as well. We also collect personal information from individuals who may refer you as a friend to our loyalty schemes or third-party agents (to whom you may have expressed interest about our properties) or products or services. We ask these individuals to confirm that you are happy to hear from us.

HOW TO OPT OUT?

1. Email: You can click on the unsubscribe link provided in the email you receive from us.
2. SMS: You can follow the instruction provided in the messages you receive from us
3. Applications: You may use the “opt out” option provided within the FLT applications
4. Contact us: You may contact us using the details provided in Section – ‘How do you contact us?’.

WHO MIGHT WE SHARE THIS INFORMATION WITH?

We may disclose personal information that we collect, or you provide as described in this privacy policy:

• We may share your personal information with any member of the FLT, including subsidiaries, affiliates and holding companies, in order to enable you to request our services, to process your payments, understand your preferences, conclude a sale, facilitate any maintenance/ service requests, send you information about products and services that may be of interest to you and conduct the other activities described in this privacy policy. 
• We may use carefully selected third parties to perform services on our behalf or to assist us with the provision of services to you. For example, we may engage third party agents, distribution partners cloud service providers, IT service providers and other third parties to support and facilitate property sales and bookings, property handover, security services, brand promotions, marketing, advertising, communications, to personalize and optimize our service, to analyze and enhance data (including data about users’ interactions with our services), and to provide legal, accounting, insurance, audit and other professional services.  While providing such services, these third parties may have access to your personal information.
• We may share your personal information with select business partners in sectors including banking, travel, entertainment, lifestyle, and other industries to enable our customer to avail special offers. For example, our partnership with banks enables our customers to avail home financing options.
• Where required or permitted by law, personal information may be provided to others, such as regulators and law enforcement agencies.
• We may share to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by the Company about our Website users is among the assets transferred.
• We may share with government or regulatory authorities upon request to comply with any court order, law or legal process
• We may share with other companies and organizations for the purposes of fraud protection and credit risk reduction if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers or others.

HOW LONG DO WE KEEP INFORMATION ABOUT YOU?

We will only keep your personal information for as long as is reasonably necessary taking into consideration our need to answer queries or resolve problems, any other purpose outlined above or to comply with legal requirements under applicable law(s). This means that we may retain your personal information for a reasonable period, for example, till the end of the leasing contract with the organization you represent, or after your query has been addressed. In certain cases, we may retain your personal information for a longer period where extended retention periods are required by law or regulation and to establish, exercise or defend our legal rights. We will ensure that it is disposed in a secure manner when it’s no longer needed.

For more information on where and how long your personal information is stored, and for more information on your rights of erasure and portability, please contact us 

HOW SECURE IS YOUR INFORMATION?

Your personal data security is an important concern to us. We provide the utmost care in secure transmission of your personal information from your computer, smartphone, and other electronic devices to our servers. We use industry security standards to safeguard the confidentiality of your information (e.g. firewalls, Transport Security Layer (“TLS”) etc.) and to make sure that your personal information is secure with us.

We have implemented and maintained appropriate technical and organizational security measures, policies and procedures to protect your personal information from the accidental loss, unauthorized access, use, alteration and disclosure. All information you provide to us is stored on our secure servers behind firewalls. All payment transactions are encrypted using TLS technology. Ex: Measures we take includes:

• Placing confidentiality requirements on our staff and service providers;
• Restriction of access to your personal information to employees and third parties strictly on a need to know basis, such as to respond to your enquiry or request;
• Destroying or anonymizing personal information if it is no longer needed for the purposes for which it was collected; and
• Using secure communication channels for transmitting personal data.

The safety and security of your information also depend on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

WHAT ARE YOUR RIGHTS?

If you are subject to laws that provide you with such rights, you may have certain rights in relation to your personal information given below.

If you wish to access any of these rights, we may ask you for additional information to confirm your identity and for security purposes, before disclosing personal information to you. We reserve the right to charge a fee where permitted by law, for example, if your request is manifestly unfounded or excessive.

If you would like to access the below rights, you may contact us by mailing us at info@fltcommunities.com or sending us a communication to Data Privacy Office, PO Box 9440, Dubai, United Arab Emirates . We shall aim to comply with all requests within reasonable time in-line with applicable laws. We may not always be able to fully address your request, for example,

• if it would impact the confidentiality we owe to others, or
• if we are legally entitled to deal with the request in a different way. or
• if your request involves deletion of information that are required to comply with the legal requirements.

We will make every reasonable effort to honor your request in-line with applicable laws. In the event we require additional time due to the complexity of the request, we shall promptly inform you of the same.

THE RIGHT TO ACCESS

You have the right to obtain confirmation as to whether we process personal data about you, receive a copy of your personal data held by us, and obtain certain other information about how and why we process your personal data (like the information provided in this privacy statement).

THE RIGHT TO RECTIFICATION

You have the right to request for your personal data to be amended or rectified where it is inaccurate (for example, if you change your name or address) and to have incomplete personal data completed.

THE RIGHT TO RESTRICT PROCESSING OF PERSONAL DATA

You have the right to restrict our processing of your personal data in the following cases:

• Temporarily for a period when you have contested for the accuracy of the personal data;
• Temporarily for a period when you have objected for the legitimate interest identified by us,
• Your personal data have been unlawfully processed and you request the restriction of processing instead of deletion;
• The personal data are no longer necessary in relation to the purposes for which they were collected and processed but the personal data are required by you to establish, exercise or defend legal claims;

We can continue to use your personal information following a request for restriction, where:

• we have your consent; or
• to establish, exercise or defend legal claims; or
• to protect the rights of another natural or legal person.

THE RIGHT TO ERASURE (ALSO KNOWN AS ‘THE RIGHT TO BE FORGOTTEN’)

You have the right to obtain deletion of your personal data in the following cases:

• The personal data are no longer necessary in relation to the purposes for which they were collected and processed;
• Our lawful basis for processing is consent, you withdraw consent and we have no other lawful basis for the processing;
• Our lawful basis for processing is that the processing is necessary for a legitimate interest pursued by us, you object to our processing and we do not have overriding legitimate grounds;
• You object to our processing for direct marketing purposes;
• Your personal data have been unlawfully processed; and
• Your personal data must be erased to comply with a legal obligation under EEA to which we are subject.

We are not required to comply with your request to erase personal information if the processing of your personal information is necessary:

• For compliance with a legal obligation; or
• For the establishment, exercise or defense of legal claims.

THE RIGHT TO OBJECT TO THE PROCESSING OF PERSONAL DATA

You have the right to object to our processing of your personal data in the following cases:

• our lawful basis for processing is that the processing is necessary for a legitimate interest pursued by us; and our processing for direct marketing purposes.

THE RIGHT TO DATA PORTABILITY

You have the right to receive your personal data provided to us and have the right to send the data to another organization (or ask us to do so if technically feasible) where our lawful basis for processing the personal data is consent or necessity for the performance of our contract with you and the processing is carried out by automated means.

THE RIGHT TO WITHDRAW CONSENT AT ANY TIME (WHERE PROCESSING IS BASED ON CONSENT)

Where we process personal data based on consent, individuals have a right to withdraw consent at any time.

THE RIGHT TO LODGE A COMPLAINT WITH A SUPERVISORY AUTHORITY

If you are not content with how we manage your personal information, you can lodge a complaint with a supervisory authority in your country of residence, place of work or the country in which an alleged infringement of data protection law has occurred within the EEA. We sincerely hope that you will never need to, but if you do want to complain about our use of personal data, you can contact us in one of the ways mentioned in Section – ‘How do you contact us?’. We will look into and respond to any complaints we receive.

UPDATES ON POLICY

This policy may change from time to time. Your continued use of our platforms after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates