Privacy Policy
This is the Privacy Policy of P A A Commercial Information Services DWC – LLC (‘Company’), holding license No. 12125. (‘we’, ‘our’, or ‘us’) sometimes referred to as Educate Property.
At the Company, we value your data and protect and store it in the highest regard. This Privacy Notice will display the type of data we collect from each registered customer and user (‘you’; ‘users’; ‘your’), including but not limited to Arbitrage Mastery and Hostly (‘the Service/s’), how we use it, how and who it is shared with, and how long it is held for.
This Privacy Notice shall be applicable to products and Services offered by the Company, including but not limited to Arbitrage Mastery and Hostly (“the Service/s”) or any other name as may be designated by the Company from time to time.
If you have any questions or queries regarding this Privacy Notice or any matter regarding the uses of your personal data, please feel free to contact our data protection officer at support@educateproperty.com.
1. Personal data we collect
1.1. The information you provide may include:
1.1.1. Email address
1.1.2. Phone number
1.1.3. Name & Surname
1.1.4. Address
2. Why we collect your personal data?
2.1. Collecting personal data allows us to facilitate program access, manage billing and payments, provide tailored coaching services, track progress, and send relevant program updates and resources.
2.2. By accessing and using the website, software, and/or services of the Company, you acknowledge and consent to the collection of technical information, which may include your device’s IP address, mobile device identifier, operating system, browser name and version, referring web page, and requested page. This information may be reasonably utilized for analysis and interpreting the overall usage patterns of our website and software.
2.3. We employ third-party analytics tools to assess your usage of our website. These tools may collect information transmitted by your device or our service, including your interactions with our software, website, and/or services, which aids us in enhancing our service.
3. Purpose for data collection
3.1. Communication – Communication of our service will be facilitated through our collection of personal data. This will be expressed directly and/or indirectly through email and/or SMS, which may include verification procedures conducted, additional services provided, existing and new paid features, and any promotional material.
3.2. Progress – Progress tracking shall be facilitated through our collection of your personal data to ensure accurate logging of achieved key performance indicators (KPI) and participation records.
3.3. Compliance – Compliance with the community guidelines, course rules, and money-back guarantee scheme is facilitated through the collection of personal data, ensuring accurate and tailored data is being tracked and processed. This allows a seamless user experience for all users on the service.
3.4. Due Diligence – Personal data will facilitate our due diligence in the interest of our users, allowing for the maximal user experience. Moreover, this will aid in the improvement of services, providing a seamless, tailored user experience. The personal data utilized for due diligence is strictly used internally and is anonymized and pseudonymized when shared with third parties.
3.5. Tailored Recommendations and Personalization – We use your personal data to analyze and recommend features and services that might be of interest to you, identify your preferences, and personalize your experience with us.
3.6. Transaction Services – Your personal data is employed to assist payments conducted through our third-party provider to permit access to the services.
3.7. Disclosure of Your Personal Data – We prioritize the security of your personal data and adhere to a stringent policy prohibiting the sale, sharing, or leasing of your personal data to unauthorized and/or unrelated third parties, except as required by law and/or competent legal authorities or with your explicit consent. When personal data is disclosed, it is solely for the purpose of optimizing our services as disclosed within our Privacy Policy. We may, as deemed reasonable, disclose personal data to the following entities:
3.7.1. Third Party Service Providers – We utilize third-party companies to perform specific functions and features provided on services. These entities may be involved in, but are not limited to, payment processing, user identification services, and product access. While these third parties may have access to personal data as necessary to perform their functions and services, they are prohibited from negligent and unauthorized use. Additionally, they are contractually obligated to process personal data in compliance with applicable data protection legislation.
3.7.2. Legal Authorities – In specific instances, we may be required by law or court order to disclose specific information, including but not limited to personal data about users or any engagement and communication related to you. This includes, but is not limited to, regulatory bodies, law enforcement agencies, or other competent authorities. Such disclosures are made only to the extent required by law and/or to enforce our legal rights or prevent fraud.
3.7.3. Business Transfer – As our company evolves, we may partake in mergers, acquisitions, and/or sale of services involving other companies and businesses. In such transactions, user information is typically transferred as a company asset but remains subject to the commitments outlined in any existing Privacy Policy, unless the user provides explicit consent to alternative terms. Additionally, if the Company or a substantial portion of its assets is acquired by a third party, user information will be included among the transferred assets.
4. Your rights
4.1. Request Access – You have the right to request access to your personal data, commonly known as a “data subject access request.” This enables you to receive a copy of the personal data stored by us and to verify its lawful processing. Additionally, you have the right to request detailed information regarding the purpose of processing, the categories of personal data we process, and the recipients or categories of recipients to whom the personal data have been or will be disclosed.
4.2. Request Correction – You are able to modify your personal data by contacting us at support@educateproperty.com.
4.3. Request Erasure – You have the right to request the deletion of your personal data when there is no valid reason for us to continue processing it or when you have exercised your right to object to processing. To submit a deletion request, please email our Data Protection Officer (DPO) at support@educateproperty.com with “Deletion of my Personal Data” in the subject line. Our DPO will verify your ability to access that email, and we will make reasonable efforts to respond to your request within 30 business days upon receipt and verification of the request.
4.4. Object – You may have the right to object to the processing of your personal data if it is conducted in violation of any applicable data protection legislation. Should you exercise this right, the data will be retained in storage and will not be subject to further processing unless we obtain your explicit consent. However, please be aware that if you object to the processing of your personal data, we may be unable to provide the services offered by the Company.
4.5. Opt-Out – If you receive marketing communications and wish to opt out, you may request the withdrawal of your consent for the use of your personal data in marketing communications by sending an email to support@educateproperty.com with the subject line “Withdrawal of my consent for marketing communications.” Please note that these choices will not affect mandatory communications from the Company that are essential to the provision of our services.
5. Failing to provide personal data
5.1. In instances where the collection of personal data is required by applicable law, under the terms and conditions, or the privacy policy, and you decline to provide this data when requested, we may not be able to perform the services listed in clause 4. In this case, access to the service provided by the Company may be restricted. Should you opt not to provide us with your personal data for processing in the way displayed in this Privacy Policy, please note we may and/or will provide a restricted user experience due to the lack of required personal data.
5.2. You have the option to decline providing non-mandatory personal data, which has been marked and identified within the website as non-mandatory. However, please note that doing so may restrict partial, entire, and/or whole usage of the service, thereby impacting the intended user experience.
5.3. The Company may reasonably request you to provide information through feedback on features on our website and/or services; email communication shall be sent out regarding feedback or products and services offerings; and/or we may ask you for information concerning support of our products or services. Your response to these communications may require you to submit personal information and opinions but shall not restrict nor terminate access to any services.
6. Special personal data
6.1. We refrain from processing any personal data falling within the category of special personal data as defined by applicable legislation, specifically referring to United Arab Emirates (“UAE”) Law.
7. Minors' Data
7.1. We do not enable any persons under the age of 16 to use the Services of the Company and we do not knowingly collect personal data from children under 16.
8. Retaining and deleting your data
8.1. We will retain personal data for the duration necessary to accomplish the purposes outlined for its collection, including but not limited to what is included within this Privacy Policy. In establishing the appropriate retention period for data storage, we evaluate factors such as the nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure, the purposes for which we utilize personal data, and whether the Company can achieve those purposes through alternative means, alongside applicable legal obligations.
8.2. Once a user is no longer an active user, we will retain and/or securely destroy personal information in accordance with applicable laws and regulations.
9. Data Security
9.1. We have enacted suitable security protocols to prevent the unauthorized access, accidental loss, misuse, unauthorized alteration, or modification of your personal data. The personal data collected and stored is in compliance with applicable laws and is governed by our secured procedures. These procedures are put in place to deal with any suspected breach, storage, and unauthorized distribution, and we will reasonably notify you and any applicable regulator of a breach where we are reasonably legally obligated to do so.
10. Changes to our privacy policy
10.1. We retain the right to alter, amend, revise, and/or adjust any segment of this Privacy Policy at any time as deemed reasonably necessary. Any substantial alteration, amendment, and adjustment will be communicated to you through the revised Privacy Policy. Additionally, we may, if deemed reasonably necessary, notify you about the modifications of processing your personal information through means of communication such as email and mobile SMS. We encourage you to review this Privacy Policy regularly for the latest information on our privacy practices and the uses and storage of personal data; any and all continued use of the services and/or website shall constitute your acceptance of modifications.
12. Contact
11.1. General questions or comments regarding this Privacy Notice and/or the services shall be submitted to support@educateproperty.com with a subject containing a brief regarding the question or comments.