ANAX DEVELOPMENTS L.L.C.
PRIVACY POLICY

INTRODUCTION

We, Anax Developments L.L.C. (“Anax”, “we”, “us”, or “our”) are a Real Estate Development Company incorporated under the laws of Dubai, UAE. Our Services may be accessed through our Website www.anaxdevelopments.com and/or our mobile application. 

This Privacy Policy (“Privacy Policy”) is intended to explain how we collect, use, process, disclose, share, transfer and protect personal information obtained through us and our service providers when accessing the Services and related information available on our Website and mobile application. 

ACCEPTANCE OF THIS PRIVACY POLICY

You must carefully read the full content of this Privacy Policy to understand the practices being followed for handling and treating your personal data. When visiting our Website, regardless of whether you register or log in to access the Website or the mobile application for Services provided by Anax, you acknowledge, understand, and consent to all clauses described in this Privacy Policy. 

We will not use your personal information for any purpose not covered in this Privacy Policy. At any time, if you do not agree with this Privacy Policy, you may discontinue accessing the Website and/or mobile application and cease to avail our Services.

This Privacy Policy applies to personal information or data processed by us in our systems, including on our Website, mobile applications, and Services. This Policy applies to all our departments, groups, divisions, subsidiaries, affiliates, and or branches.

When we ask for certain personal information from you, it is because we are required by Applicable Laws or directive from the Authority or enforcement agencies to collect such information or it is relevant for purposes as specified in section 2.

SUPERVISORY AUTHORITY

Office of the Director General, UAE Data Office is the regulatory authority under Data Protection Law.

This Privacy Policy has incorporated with all applicable elements from the UAE Data Protection Law (“DP Law”) and we act with utmost care and in accordance with the principles laid down under the DP Law relating to processing of personal data. 

• PERSONAL INFORMATION WE COLLECT

1. 1. 1. The categories of personal information we collect depend on whether you are a ‘Client’, ‘Broker’, ‘applicant’ or ‘visitor’, and the requirements of the Applicable Law. 

• Personal information you provide to us

1. 1. Account Creation. We may collect the following information from you when you create an account with us and use our Services:

1. Identification information: Full Name, date of birth, place of birth, nationality, gender, phone number, email, government identification number, tax identification, and passport number and/or other information necessary to verify your identity to comply with our regulatory obligations under financial or anti-money laundering laws;
2. Personal identification documents: Passport, photograph, signature, government issued proof of identity, proof of residential address, utility bill, etc.
3. Financial details: Bank account details, payment card details, transaction statement, tax information (Taxpayer identification number), proof of income/ funds/ wealth, salary certificate, pay slips, and such other documents required to comply with our regulatory obligations. 
4. Corporate information: If you are a body corporate, we may collect your legal entity name, company registration number (or comparable number issued by a government), proof of legal formation (Articles, Memorandum or Certificate of Incorporation), and personal identification information for all material beneficial owners, Relevant Persons;
5. Employment information: Office location, job title, description of role of any authorised representative you may appoint, salary details; etc.
6. Correspondence: Information provided to our marketing support services team such as, responses, feedback, information provided to market support team; etc.

1. Transaction information: Information about the transactions made, any deposits of Currency, Client ID, the amount; etc.
2. Communications:  We collect personal information from you such as email address, phone number, messages or mailing address when you request information about our Services, request customer or technical support, apply for a job or otherwise communicate with us.
3. Surveys:  We may contact you to participate in surveys.  If you decide to participate, you may be asked to provide certain information which may include personal information.
4. Automatic Collection of Information: When you visit our website or use our Services, we may collect certain information automatically.  This information may include your Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, details about your browser, operating system or device, location information, Internet service provider, pages that you visit before, during and after using the Services, information about the links you click, and other information about how you use the Services.  Information we collect may be associated with accounts and other devices.

Also, we may automatically collect data regarding your use of our Services, such as the types of content you interact with and the frequency and duration of your activities.  We may combine your information with information that other people provide when they use our Services, including information about you when they tag you.

1. Cookies, Pixel Tags/Web Beacons, Analytics Information, and Interest-Based Advertising technologies:  We, as well as third parties that provide content, advertising, or other functionality on the Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through the Services.  Technologies are essentially small data files placed on your computer, tablet, mobile phone, or other devices that allow us and our partners to record certain pieces of information whenever you visit or interact with our Services.
2. Information collected from Third Parties: As required or permitted by the Applicable Law, we may obtain information about you from third party sources from time to time which includes:

1. Public databases, Credit Bureaus & ID Verification Partners: Third party ID verification providers appointed by us obtain information about you from public databases for purposes of verifying your identity in accordance with Applicable Law. Our third party ID verification partners verify your identity with a combination of government records and publicly available information about you. Such information may include your name, address, job role, public employment profile, credit history, status on any sanctions lists maintained by public authorities, and other relevant data. We obtain such information to comply with our legal obligations, such as anti-money laundering laws. In some cases, we may process additional data about you to ensure our Services are not used fraudulently or for other illicit activities. In such instances, processing is necessary for us to continue to perform our contractual obligations with you and others.
2. Blockchain Data: We may analyse public blockchain data to ensure parties utilising our Services are not engaged in any illegal or prohibited activity, and to analyse transaction trends for research and development purposes.
3. Joint Marketing Partners & Resellers: Information shared with us about you by our joint marketing partners or resellers for our better understanding about our Services which you may show interest.
4. Advertising Networks & Analytics Providers: We work with these providers to provide us with de-identified information about how you found our websites and how you interact with the sites and Services. This information may be collected prior to account creation.
5. Anonymised and Aggregated Data: Anonymisation is a data processing technique that removes or modifies personal information so that it cannot be associated with a specific individual. Except for this section, none of the other provisions of this Privacy Policy applies to anonymised or aggregated customer data (i.e. information about our customers that we combine together so that it no longer identifies or references an individual customer).
6. Anax may use anonymised or aggregate customer data for any business purpose, including to better understand customer needs and behaviours, improve our products and services, conduct business intelligence and marketing, and detect security threats. We may perform our own analytics on anonymised data or enable analytics provided by third parties.
7. Types of data we may anonymise include, transaction data, click-stream data, performance metrics, and fraud indicators.

1. Information collected from Third Parties Sources: We may obtain information about you from other sources, including through third party services and organizations to supplement information provided by you.  For example, if you access our Services through a third-party application, such as an app store, a third-party login service, or a social networking site, we may collect information about you from that third-party application that you have made public via your privacy settings.  Information we collect through these services may include your name, your user identification number, your username, location, gender, birth date, email, profile picture, and your contacts stored in that service.  This supplemental information allows us to verify information that you have provided to us and to enhance our ability to provide you with information about our business, products, and Services. 

• HOW WE USE YOUR INFORMATION

1. 1. Your personal information will be used for our following business activities but not limited to:

• To provide our services, maintain and fulfil our contractual obligations with you, such as:

1. Handling your personal data and accounts;
2. Providing access to the functionalities and features of our Services;
3. Communicating with you about your account, activities on our Services and policy changes;
4. Undertaking activities to verify or maintain the quality or safety of a service or device;
5. Processing your financial information and other payment methods for products or Services purchased;
6. Providing promotional, advertising, analytics and marketing services;
7. Processing applications and transactions; and
8. Allowing you to register for events.

• To improve our Services such as:

1. Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity and taking appropriate action against those responsible for that activity;
2. Undertaking research for technological development and demonstration;
3. Research and development of products, services, marketing or security procedures to improve their performance, resilience, reliability or efficiency;
4. Improving, upgrading or enhancing our Services or device or those of our Providers;
5. Developing new products and Services;
6. Ensuring internal quality control;
7. Verifying your identity and preventing fraud;
8. Debugging to identify and repair errors that impair existing intended functionality;
9. Enforcing our terms and policies; and
10. Complying with our legal and regulatory obligations, protecting your vital interest, or as may be required for the public good.

• To provide additional comforts and Services, such as:

1. Provide you with tailor made materials about offers, products, and Services that may be of interest, including new content or Services;
2. Interactions, transactions and other compliance activities; and
3. Notifications when you provide personal information.

1. Profiling: We may use automated decision making or profiling technologies.  Unless such a decision is necessary as part of agreement we have with you, we have your consent, or we are permitted by law to use such technology, we will not make automated decisions about you that would significantly affect you.  
2. Use De-identified and Aggregated Information:  We may use personal information and other data about you to create de-identified and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access our Services, or other analyses we create.
3. Referral Services:  We may offer various other services, tools and functions. You may provide information about your friends through our referral services.  Our referral services may allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services.
4. How We Use Automatic Collection Technologies:  We, as well as third parties that provide content, advertising, or other functionality on the Services, may use cookies, pixel tags, local storage, and other technologies to automatically collect information through the Services.  Our uses of these Technologies fall into the following general categories:

1. Operationally Necessary: This includes Technologies that allow you access to our Services, applications, and tools that are required to identify irregular site behaviour, prevent fraudulent activity and improve security or that allow you to make use of our functionality;
2. Performance Related: We may use Technologies to assess the performance of our Services, including analytics to help us understand how our visitors and Clients use the Website and Services. For example, we may track your activity on the Services, including recording your interactions with the Services;
3. Functionality Related: We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services.  This may include identifying you when you sign into our Services or keeping track of your specified preferences, interests, or past items viewed;
4. Advertising or Targeting Related: We may use first party or third-party Technologies to deliver content, including ads relevant to your interests, on our Services or on third party sites.

1. Cross-Device Tracking:  Your browsing activity may be tracked across different websites and different devices or apps.  For example, we may attempt to match your browsing activity on your mobile device with your browsing activity on your laptop.  To do this our technology partners may share data, such as your browsing patterns, geo-location and device identifiers, and will match the information of the browser and devices that appear to be used by the same person.
2. Notice Regarding Third Party Websites, Social Media Platforms and Software Development Kits:  The Services may contain links to other websites, and other websites may reference or link to our website or other Services.  These other websites are not controlled by us.  We encourage our users to read the privacy policies of each website and application with which they interact.  We do not endorse, screen or approve and are not responsible for the privacy practices or content of such other websites or applications.  Visiting these other websites or applications is at your own risk.
3. Our Services may include publicly accessible blogs, forums, social media pages, and private messaging features:  By using such Services, you assume the risk that the personal information provided by you may be viewed and used by third parties for any number of purposes.  In addition, social media buttons such as Facebook, Linked In, Google, etc. (that might include widgets such as the “share this” button or other interactive mini-programs) may be on our site.  These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly.  These social media features are either hosted by a third party or hosted directly on our site.  Your interactions with these features apart from your visit to our site are governed by the privacy policy of the company providing it.
4. APIs and SKDs: We may use third party APIs and software development kits (“SDKs”) as part of the functionality of our Services.  APIs and SDKs may allow third parties including analytics and advertising partners to collect your personal information for various purposes including to provide analytics services and content that is more relevant to you.  For more information about our use of APIs and SDKs, please contact us as set forth below.

• DISCLOSING YOUR INFORMATION TO THIRD PARTIES

1. 1. Your personal information that we may share with the following categories of third parties:

1. Service Providers:   Any personal information we collect about you, may be shared with our third-party service providers.  The categories of service providers (processors) to whom we entrust personal information include IT and related services, banks, payment processors, customer service providers, and vendors to support the provision of the Services.
2. Business Partners:  We may provide personal information to business partners with whom we jointly offer products or services.  
3. Affiliates:  We may share personal information with our affiliated companies.
4. Advertising Partners:  Through our Services, we may allow third party advertising partners to set Technologies and other tracking tools to collect information regarding your activities and your device (e.g., your IP address, mobile identifiers, page(s) visited, location, time of day).  We may also combine and share such information and other information (such as demographic information and past purchase history) with third party advertising partners.  These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit third party websites within their networks.  This practice is commonly referred to as “interest-based advertising” or “online behavioural advertising.  We may allow access to other data collected by the Services to share information that may be useful, relevant, valuable or otherwise of interest to you. 
5. Disclosures to Protect Us or Others:  We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to comply with law enforcement requests and legal process, such as a court order; protect your, our or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.
6. To Facilitate Corporate Acquisitions, Mergers, or Transactions: We may process any information regarding your Client Account and use of Services as is necessary in the context of corporate acquisitions, mergers, sale of assets, or transition of service to another provider or other corporate transactions. In such an event, your information may be transferred as part of such a transaction, as permitted by law, memorandum of agreement.
7. You acknowledge that all information processed by us may be transferred, processed, and stored anywhere in the world, which may have data protection laws that are different from the laws where you reside or where we process.  We have taken appropriate safeguards to require that your personal information will remain protected and require our third-party service providers and partners to have appropriate safeguards as well.

• YOUR RIGHTS AND PRIVACY CHOICES

1. 1. You have certain choices about your personal information: Where you have consented to the processing of your personal information, you may withdraw that consent at any time and prevent further processing by contacting us as described above.  Even if you opt out, we may still collect and use non-personal information regarding your activities on our Services and for other legal purposes as described above.
   2. Email and Telephone Communications: If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails.  Note that you will continue to receive transaction-related emails regarding products or Services you have requested.  We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding the Services or updates to our terms of client agreement or this Privacy Policy).
   3. We process requests to be placed on do-not-mail, do-not-phone and do-not-contact lists as required by applicable law.
   4. Mobile Devices: We may send you push notifications through our mobile application.  You may at any time opt-out from receiving these types of communications by changing the settings on your mobile device.  We may also collect location-based information if you use our mobile applications.  You may opt-out of this collection by changing the settings on your mobile device.
   5. “Do Not Track.”: Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers.  Please note that we do not respond to or honour DNT signals or similar mechanisms transmitted by web browsers.
   6. Your Privacy Rights: In accordance with applicable law, you may have the right to access personal information about you consistent with legal requirements including: 

1. confirming whether we are processing your personal information; 
2. obtaining access to or a copy of your personal information in a structured, commonly used, and machine readable format; and 
3. receiving an electronic copy of personal information that you have provided to us or asking us to send that information to another company in a structured, commonly used, and machine-readable format (the “right of data portability”). 

1. Request correction of your personal information where it is inaccurate or incomplete:  In some cases, we may provide self-service tools that enable you to update your personal information, or we may refer you to the Controller of your personal information who is able to make the correction.
2. Request deletion of your personal information, subject to certain exceptions prescribed by law.
3. Request restriction of or object to processing of your personal information, including the right to opt in or opt out of the sale of your personal information to third parties, if applicable, where such requests are permitted by law.
4. Withdraw your consent to our processing of your personal information.
5. If you would like to exercise any of these rights, please log into your account or contact us as set forth below.  We will process such requests in accordance with applicable laws.  To protect your privacy, we will take steps to verify your identity before fulfilling your request.

• RETENTION OF DATA

1. 1. 1. Retention period depends upon type and aspect of information as under:
         1. We retain all the collected personal information for the entire duration of your Client Account with Anax and for 6 more years after the account is closed.
         2. Personal data collected to comply with our legal obligations under financial or anti-money laundering laws may be retained after account closure for as long as required under such laws.
         3. Your contact details that provided to us such as name, email address and telephone number for marketing purposes is retained until you unsubscribe. Subsequently, we will move your details to our list of destruction.
         4. Our telephonic call records with you will be retained for a period of 6 years.
         5. Data captured via cookies, webpage counters and other tools is kept for a period of one year from expiry of the cookie.
         6. Content that you post on our Website (support desk comments, photographs, videos, blog posts, etc.) may be kept after you close your account for audit and crime prevention purposes (e.g. to prevent a known fraudulent actor from opening a new account).

• HOW PROTECT AND SECURE YOUR INFORMATION

1. 1. 1. Your personal information is stored securely and in accordance with this Privacy Policy.  Since, no system providers guarantee the security, we cannot ensure or warrant the security of any information you provide to us.  
      2. Your personal information is stored using fault-tolerant secured storage with industry standard encryption and have implemented several security measures to ensure that your information is not lost, abused or altered.
      3. Materials containing your personal information will be stored in a locked place.
      4. Computer data containing your personal information will be stored in the computer systems and storage media that are subject to strict log-in restrictions.
      5. Only authorized employees are permitted to come into contact with your personal information and such employees must comply with our internal confidentiality rules for personal data. We have also imposed strict physical access controls to buildings and files.
      6. Encryption technology such as PCI Scanning and Secured Sockets Layered Encryption may be used to transmit and store your personal information. 
      7. We use various currently available general security technologies and supporting management systems to minimize the risks that your information may be disclosed, damaged, misused, accessed without authorization, disclosed without authorization, or altered.
      8. Other Measures
      9. Our web server is protected by the “firewall”.
      10. You agree that we shall not be liable for any information leakage and other losses not caused by our intention or gross negligence, including but not limited to hacker attack, power interruption, or unavoidable technical failure, to the maximum extent permitted by law.
      11. If you suspect that your personal information has been compromised, especially account and/or password information, please lock your Account and immediately contact Anax Customer Support team at [email protected].
      12. We do not accept liability for unintentional disclosure to the extent permitted by Applicable Law.
      13. By using the Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services.  If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Website, by mail or by sending an e-mail to you.

• INTERNATIONAL DATA TRANSFERS

1. 1. All information processed by us may be transferred, processed, and stored anywhere in the world, which may have data protection laws that are different from the laws of your country of nationality or country of residence. We endeavour to safeguard your information consistent with the requirements of applicable laws.
   2. You understand that we have the right to have all or some of the collected personal information transferred to or stored in other countries or regions or the country where the server is, without your specific consent, under the following circumstances:

1. if it is necessary to protect, process, analyse, reasonably use the personal information,
2. if it is necessary to enforce the Client Agreement and other agreements with our clients,
3. if it is necessary for the public interest,
4. if it is necessary to establish, exercise or defend the rights of us, our partners, or other clients,
5. other circumstances required by law or government orders.

• CHILDREN’S INFORMATION

1. 1. 1. The Services are not directed to children under 18 (or other age as required by law), and we do not knowingly collect personal information from children.  If you learn that your child has provided us with personal information without your consent, you may contact us as set forth below.  If we learn that we have collected any personal information in violation of applicable law, we will promptly take steps to delete such information and terminate the child’s account.

• CHANGES TO OUR PRIVACY POLICY

1. 1. 1. From time to time, we may revise this Privacy Policy to reflect changes in law or our personal-data collection, processing, and use practices. Changes to this Privacy Policy will be notified by posting on our website. You shall regularly review the Privacy Policy and pay attention to its revisions. If you do not agree with the revised content, you shall stop accessing immediately. When an updated version of the Privacy Policy is notified, and you continue to access our Services means that you will be deemed to have accepted the updated content and agree to abide by the updated Privacy Policy.

• HOW TO CONTACT US

1. 1. We respect the rights of all our Clients. Should have any questions, queries, enquiries or concerns regarding this Privacy Policy or if you would like to make a data protection request, please refer to our Frequently Asked Questions and contact us at [email protected]