1. Introduction
SPACE AND PLACE - FZCO (the "Platform," "we," "us," or "our"), a UAE-based platform. We offer our registered users as well as guest users (the “Users”) AI-powered services, including real estate analysis, semantic property search, and market intelligence insights (the “Services”).
This Privacy Policy sets out the principles governing the collection, use, storage, and processing of personal data (PD) by the Platform, and outlines the rights and obligations of Users in connection therewith. This Privacy Policy is also considered an integral part of the Terms of Service.
Where required under applicable data protection laws, we will designate a representative in the relevant jurisdiction and provide the corresponding contact details in this Privacy Policy. Until such details are made available, Users may contact the Platform directly at hello@spacenplace.ai.
This Privacy Policy may be translated into other languages and made available on the Platform. In this case the English version shall prevail.
2. Scope
This Privacy Policy applies to the Users, and any individuals whose personal data is processed in connection with the Platform.
3. Governing Law
This Privacy Policy and any disputes arising out of or in connection with it shall be governed by and construed in accordance with the laws of the Abu Dhabi Global Market (ADGM), without regard to conflict of law principles.
Notwithstanding the foregoing, the Company will comply with applicable mandatory data protection and privacy laws to the extent they apply to its processing of personal data, including, where relevant, the General Data Protection Regulation (GDPR) and the UK GDPR. Nothing in this Privacy Policy is intended to limit or exclude any rights that users may have under such applicable laws.
4. Data Processed
We process PD only as needed for services. PD includes information identifying or relating to you or your device.
We may process the following categories of PD:
Users’ Data
- Name
- Email address (corporate/personal)
- Company name
- Search preferences/history
- Communications and interactions on the Platform
- Other PD if directly provided by the User or obtained legally from third-party sources
- Miscellaneous PD in User Content (as defined by the Terms of Service), including bank details, residence address etc.
Technical Data
- Cookies
- IP address and device information
- Browser type and usage data
- Log data and interaction history
PD in AI-Generated Data
- PD in data generated from User Content
- Behavioral and usage-based inferences
We do not process sensitive PD (e.g., health, race, biometric data).
We do not process PD of children under 18.
5. Purposes of Processing
We process PD for the following purposes:
- To provide, operate, and maintain the Platform
- To render the Services as listed in the Terms of Service
- To improve and develop our services and algorithms
- To communicate with Users (including service-related communications)
- To ensure security, prevent fraud, and enforce the Terms of Service
- To comply with legal and regulatory obligations
6. Legal Bases for Processing
Where required under applicable law, we rely on the following legal bases:
- Performance of a contract
- Legitimate interests:
- Operating, maintaining, and improving the Platform
- Ensuring the security and functionality of the Platform
- Developing and enhancing our matching and recommendation systems
- Identifying and including publicly available or licensed information about real estate listings from open publicly accessible or licensed sources in order to facilitate discovery by Users, including where such information is displayed on the Platform without a direct account relationship with the relevant real estate agency or developer, where permitted under applicable law and subject to appropriate safeguards
- Consent
- Compliance with legal obligations
Where multiple legal bases apply to the same processing activity, the Platform reserves the right to continue processing on the basis of any other applicable legal ground, notwithstanding that one of the legal bases may no longer apply.
7. AI and Automated Processing
The Platform uses automated systems, including artificial intelligence, to process PD. The AI-generated content on the Platform may contain PD.
To generate reports, memos and other kinds of output encompassed by the Services, we use third-party AI tools to analyze uploaded User Content. AI outputs may contain errors or omissions due to model limitations.
We do not use AI for significant decisions affecting Users but for informational matching only.
Some processing is performed through third-party providers that follow their own security and privacy practices.
8. Collection of the Personal Data
We collect personal data from the following sources, in accordance with applicable data protection laws:
- Directly from Users: personal data provided by Users when creating an account, using the Platform, or otherwise interacting with us;
- User Content: personal data contained in materials uploaded to, submitted through, or generated on the Platform, including content processed by automated systems;
- Publicly Available and Licensed Sources: personal data obtained from publicly accessible sources or from third parties that are authorized to provide such data, in accordance with applicable law;
- Communications between Users and Platform, including messages, inquiries, and support requests.
Where personal data is not obtained directly from the data subject, we process such data in accordance with applicable legal requirements, including providing appropriate information to the data subject within the timeframes prescribed by law, unless an exemption applies.
Where the provision of individual notice would involve disproportionate effort or is otherwise not required under applicable law, we may instead provide this information through publicly available means, including this Privacy Policy, while taking appropriate measures to protect the rights and freedoms of data subjects.
9. Methods of Processing
We may process your personal data through any operation or set of operations, including collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.
We do not process PD in a way violating public order or public morals.
11. International Data Transfers
Your personal data may be transferred to and processed in countries outside your jurisdiction, including countries that may not be regarded as providing the same level of data protection by your local authorities.
In all cases we implement appropriate safeguards, such as standard contractual clauses, prior research and ongoing monitoring of the data protection level in jurisdictions we transfer the PD to.
12. Data Retention
We retain personal data only for as long as necessary to fulfill the purposes described in this Privacy Policy.
Upon account deletion:
- PD may be deleted or anonymized
- Certain PD may be retained where necessary to:
- Comply with legal obligations
- Resolve disputes
- Enforce agreements
- Prevent fraud or abuse
- Maintain backups or archives
Retention periods vary by data category and purpose, but are typically no longer than 30 days after the last legal base for its processing ceases to apply.
AI-generated data and User content is retained only as long as required for the Services and deleted upon request.
13. Your Rights
Depending on your jurisdiction, you may have the following rights:
- Right to access your personal data
- Right to correct inaccurate data
- Right to request deletion
- Right to restrict processing
- Right to data portability
- Right to object to processing
- Right to withdraw consent (where applicable)
To exercise your rights, please contact us at: hello@spacenplace.ai. We may take steps to verify your identity before responding to your request. We do not discriminate based on rights exercise.
14. Communications
We may send you communications related to your use of the Platform.
Service-related communications are necessary for the operation of the Platform. Other communications, including marketing messages, are sent in accordance with applicable laws, and you may opt out at any time in accordance with applicable laws.
We will respond to requests, inquiries, or communications submitted under this Privacy Policy without undue delay and in any event within a reasonable period of time, and where required by applicable law within the time limits prescribed by such law. This timeframe may be extended where permitted by law, taking into account the complexity and number of requests.
15. Marketing Communications and Opt-Out
We may send you marketing and promotional communications relating to the Platform, including updates, newsletters, and information about features or services that may be of interest to you.
Where required under applicable law, such communications will be sent only on the basis of your consent or another valid legal basis (including legitimate interest as defined in Section 6 hereinabove). You may opt out of receiving marketing communications at any time by following the unsubscribe instructions included in such communications or by adjusting your account settings, where available.
Please note that opting out of marketing communications will not affect the receipt of transactional or service-related communications that are necessary for the operation of the Platform (such as account notifications, security updates, or administrative messages).
Withdrawal of consent to receive marketing communications shall not affect the lawfulness of processing carried out prior to such withdrawal.
17. Security
We implement appropriate technical and organizational measures designed to protect personal data against unauthorized access, loss, misuse, or alteration. In particular, we use encryption, access controls, and audits. No absolute security guaranteed.
18. Dispute Resolution
Any disputes arising out of or in connection with this Privacy Policy shall be resolved in accordance with the dispute resolution provisions set out in the Terms of Service, unless otherwise required by applicable law.
19. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. Updated versions will be made available on the Platform, and where required, we will notify you of material changes. The Users should review this Policy on regular basis. Continued use constitutes acceptance.