Privacy Policy

1. Who we are

INOVO Real Estate Agency ("INOVO", "we", "us", "our") is the data controller responsible for the personal data described in this policy.

• Trading name: INOVO Real Estate Agency
• Address: Ontario Tower, Business Bay, Dubai, UAE
• RERA / ORN: 38515
• Data protection contact: enquiries@inovorealestate.ae

This policy covers inovorealestate.ae and the lead forms we run on Meta platforms (Facebook and Instagram). It is written to meet both the UK GDPR and the EU GDPR; where the two differ, we apply the stricter standard.

2. What personal data we collect

We collect only what you give us. We do not buy personal data, and we do not collect special category data (such as health, religion or biometric data).

Through a Meta lead form (Facebook / Instagram)

• Full name
• Email address
• Phone number
• Which market you are interested in (Dubai, Bali, Thailand, Cyprus, UK, or not sure)
• The budget band you are working with
• Your purchase timeline

Meta pre-fills your name, email and phone number from your Facebook or Instagram profile. You can edit or delete any of it before you submit the form.

Through an enquiry form on this website

• Name, email address, phone number, and the subject or message you write

When you contact us directly

• Whatever you choose to include when you email, call, message us on WhatsApp, or book a call through our scheduling link

We never ask for passport or ID documents, bank details or payment card numbers through this website or through a Meta form.

3. How we collect it

Three ways, and only these:

• Meta instant forms — you submit the form inside Facebook or Instagram and the lead is passed to us.
• Website enquiry forms — the form on this site submits in place and shows you a confirmation message without navigating away.
• Direct contact — email, phone, WhatsApp, or a booked call.

4. Cookies, analytics and tracking

We want to be precise about this, because most privacy policies are not.

This website runs no analytics and no advertising trackers. There is no Google Analytics, no Google Tag Manager, and no Meta Pixel on any page of this site. We do not build advertising profiles from your visit and we do not track you across other websites.

Two small items are stored by your own browser purely so the site works as you left it. Neither identifies you and neither is shared with anyone:

• inovoCur — remembers the currency you chose to view prices in.
• inovoIntro — remembers that you have already seen the intro animation, so it does not replay on every page.

Third-party content embedded in some pages. Certain pages include content served by other companies, and those companies may set their own cookies when the embedded content loads:

• Google Maps — an embedded location map appears on individual property pages. Google may set cookies through that embed. See Google's privacy policy.
• YouTube — a small number of pages embed a project film. Where we can, we use YouTube's privacy-enhanced youtube-nocookie.com mode.
• Calendly — if you follow our booking link, Calendly sets its own cookies on its own site.

Because we set no analytics or advertising cookies of our own, we do not show a cookie consent banner. If we ever add a Meta Pixel, analytics, or any advertising tracking, we will update this policy and put a consent mechanism in place before switching it on.

5. Why we use your data, and our lawful basis

Under the UK and EU GDPR we must have a lawful basis for each purpose. Ours are:

• Responding to your enquiry — answering your question, sending the property or market information you asked about, and arranging a call or viewing.
  Lawful basis: legitimate interests (Article 6(1)(f)) — you contacted us and would reasonably expect a reply.
• Sending you marketing — property launches, availability and market updates that you did not specifically ask for.
  Lawful basis: your consent (Article 6(1)(a)), which you can withdraw at any time without affecting anything we sent before.
• Keeping business records — a record of enquiries and introductions.
  Lawful basis: legitimate interests, and legal obligation where a law requires us to keep a record.

6. Who we share it with

We do not sell your personal data. We share it only with the service providers below, each of which processes it on our instructions:

• Meta Platforms (Meta Platforms Ireland Ltd for UK/EU users) — runs the instant lead forms and delivers our advertising. Meta retains lead form data in its own systems for approximately 90 days before deleting it; we retrieve leads into our own systems within that window.
• Web3Forms (api.web3forms.com) — receives and forwards submissions from the enquiry forms on this website.
• Brevo — our email and CRM platform, used to store enquiry records and send email.
• Calendly — used to schedule calls when you book one.

We may also pass your details to a specific property developer or their sales office where you have asked us to introduce you to that development. We do not pass your details to developers you have not asked about.

We may disclose data if we are legally required to do so, or to establish or defend a legal claim. If you would like the current list of our processors, email enquiries@inovorealestate.ae.

7. International transfers

We are based in the United Arab Emirates, and some of our processors are based in the United States. This means personal data collected from the UK or the EEA is transferred outside those areas.

Neither the UAE nor the United States is covered by a general UK or EU adequacy decision for these transfers. Where we transfer personal data out of the UK or the EEA we rely on appropriate safeguards — the EU Standard Contractual Clauses, and for the UK the International Data Transfer Agreement or UK Addendum — together with the transfer terms published by each processor.

You can ask us which safeguard applies to a particular transfer, and we will tell you.

8. How long we keep it

• Enquiry and lead data: 24 months from our last meaningful contact with you. After that we delete it or irreversibly anonymise it.
• Meta lead forms: Meta deletes the lead from its own systems after approximately 90 days, independently of our retention period.
• If you withdraw consent or ask us to stop: we stop immediately. We keep a minimal suppression record — usually just your email address — so that we do not contact you again by mistake. That record is kept indefinitely for that purpose only.
• Records we must keep by law (for example accounting records) are kept for the period the law requires.

9. Your rights

Under the UK and EU GDPR you have the right to:

• Access — get a copy of the personal data we hold about you.
• Rectification — have inaccurate or incomplete data corrected.
• Erasure — ask us to delete your data ("the right to be forgotten").
• Restriction — ask us to pause using your data while a concern is resolved.
• Portability — receive the data you gave us in a structured, commonly used, machine-readable format, or have it sent to another controller.
• Objection — object to processing based on legitimate interests. Where you object to direct marketing, that right is absolute and we will stop immediately.
• Withdraw consent — at any time, where we rely on consent.
• Not be subject to automated decision-making — we do not carry out automated decision-making or profiling that produces legal or similarly significant effects.

To exercise any of these, email enquiries@inovorealestate.ae and tell us what you want. It is free, and we will respond within one month. We may ask you to confirm your identity first so that we do not disclose your data to someone else.

10. Complaints

If you are unhappy with how we have handled your personal data, please tell us first — we would like the chance to put it right.

You also have the right to complain to a supervisory authority:

• United Kingdom — the Information Commissioner's Office (ICO), ico.org.uk, helpline 0303 123 1113.
• European Union — your national data protection authority. The full list is published by the European Data Protection Board at edpb.europa.eu.

Complaining to us first does not affect your right to complain to a regulator.

11. Opting out of marketing

You can opt out at any time, and it is always free:

• Click unsubscribe at the bottom of any marketing email we send; or
• Email enquiries@inovorealestate.ae with "unsubscribe" in the subject line; or
• Reply to any message from us and tell us to stop.

We action opt-outs without undue delay. You may still receive a reply to a specific enquiry you have made — that is not marketing.

12. Changes to this policy

If we change how we handle personal data, we will update this page and change the "last updated" date below. If the change is significant — for example if we introduce advertising tracking — we will make that clear and, where the law requires it, ask for your consent before the change takes effect.