Privacy Policy
1. Who we are and who controls your data
Lion Casa is a trading name. The company that operates this website, and the data controller for the personal data described in this policy, is:
- LION TECH SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ
- NIP: 5213917848
- REGON: 387990445
- ul. Główna 54
- 05-502 Kamionka, Poland
- Email: [email protected]
We are a property enquiry and referral service. We understand what buyers are looking for and introduce them to independent property advisors and licensed partner brokerages in the Dubai market. You can contact us about anything in this policy at [email protected].
2. What information we collect
When you submit an enquiry form on this website, we collect:
- Your full name
- Your email address
- Your phone number, and the country code you selected with it
- The emirates you are interested in
- Your budget range and the property types you are interested in (optional)
- Your preferred language for us to reply in (optional)
- Any message you choose to send us (optional)
- If you asked for a consultation, your preferred date, time and time zone; if you asked for a document, which project and document you requested
We also record, together with your enquiry, your browser's user-agent string, the page that referred you, and any campaign parameters present in the URL you arrived on. This tells us which marketing channels work. No IP address is stored with your enquiry. The optional analytics described in section 8 store a truncated IP address only, and only if you have accepted them.
We do not ask for, and have no use for, special categories of personal data such as health, religion or political opinions. Please do not include such information in the free-text message field.
3. Why we use it, and on what legal basis
We use the information you give us:
- To respond to your enquiry and provide the consultation you asked for
- To understand what you are looking for and introduce you to an appropriate property advisor
- To send you property information matching the criteria you gave us
- To comply with our legal and regulatory obligations
- To measure and improve the performance of our marketing
Under the GDPR, our legal bases are:
- Your consent (Article 6(1)(a)) — for passing your enquiry to an independent property advisor or partner brokerage, and for sending you property information. You give this by ticking the consent box on the enquiry form, and you can withdraw it at any time.
- Our legitimate interests (Article 6(1)(f)) — for responding to you, for keeping a record of enquiries, and for understanding which marketing channels work. Our interest is in operating and improving a referral service; we consider this does not override your rights, and you may object at any time.
- Legal obligation (Article 6(1)(c)) — where we are required to retain or disclose information by law.
4. Who we share it with
Independent property advisors and partner brokerages
We are not a single brokerage selling one portfolio. Our role is to understand what you are looking for and introduce you to a property specialist suited to it. To do that, we share the details you submit with an appropriate independent property advisor or licensed partner brokerage so they can help with your search and contact you about it.
These advisors are independent — they are not our employees. Once your enquiry is passed to them, they handle your information as an independent data controller under their own privacy policy, and you can ask them directly how they use it. We only pass on enquiries where you have given consent, and only the details you provided: your name, contact details, and what you told us you are looking for.
If you would rather we did not introduce you to an advisor, contact us at [email protected] and we will handle your enquiry ourselves or delete it.
Service providers
We also share your details with service providers who help us operate: our website hosting provider, and — once connected — our customer relationship management system and email provider. These act on our instructions as processors under a written agreement. We do not sell your personal data.
5. International transfers
We are established in Poland, within the European Economic Area. The independent property advisors and partner brokerages we introduce you to are located in the United Arab Emirates, which is outside the EEA.
The European Commission has not adopted an adequacy decision for the United Arab Emirates. Where your enquiry is passed to an advisor there, that transfer happens because you asked us to introduce you and gave your explicit consent on the enquiry form. You can withdraw that consent at any time, though it will not undo a transfer already made.
6. How long we keep it
We keep enquiry records for as long as needed to respond to you, to make an introduction, and to keep a record that the introduction and your consent took place.
7. Your rights
If you are in the EEA or the UK, you have the right:
- To be told what personal data we hold about you, and to receive a copy of it (Article 15)
- To have inaccurate data corrected (Article 16)
- To have your data erased (Article 17)
- To restrict how we process it (Article 18)
- To receive your data in a portable format, or have it sent to another controller (Article 20)
- To object to processing based on our legitimate interests, and to object to direct marketing at any time (Article 21)
- To withdraw your consent at any time, without affecting processing carried out before you withdrew it (Article 7(3))
To exercise any of these, write to [email protected]. We will respond within one month, as the GDPR requires. We do not carry out automated decision-making or profiling that produces legal or similarly significant effects.
If you believe we have handled your data unlawfully, you can complain to the Polish supervisory authority: the President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych), ul. Stawki 2, 00-193 Warsaw, Poland. If you live in another EEA country or the UK, you may instead complain to your own national supervisory authority.
8. Cookies and analytics
By default this website uses only strictly necessary storage: a cookie that remembers the language you chose, and — once you have answered the cookie notice — a cookie that records your choice, the version of the notice and the time. Neither contains an identifier, neither is used to track you, and no consent is required for them. Every cookie and storage item, with its purpose and lifetime, is listed in our Cookie Policy.
We also use first-party analytics to understand how this site is used — which pages hold attention, where people stop reading, which enquiry fields get abandoned — so we can improve it. It runs on opt-in consent (Article 6(1)(a)): nothing is measured, and no analytics cookie or browser storage is written, until you choose “Accept analytics” on the cookie notice. If you choose “Use essential only”, or simply ignore the notice, no measurement takes place at all.
If you accept, we record the pages you view, how long you spend on them, how far you scroll, where you click and move the pointer, and which form fields you start and finish. We do not record what you type. For free-text fields only the fact that a field was filled and how many characters it contained is kept — never the contents — and fields marked as sensitive, along with anything of a password type, are skipped entirely. We do not use this to identify you, we do not use it for advertising, and we do not sell or share it with data brokers or advertising networks.
Your IP address is truncated before it is stored — the final block is replaced with zeroes, so it identifies a region and not a household or a person. Measurement is stored under a random identifier held in your browser (av_an_device and av_an_session in local storage) together with your decision (av_analytics_consent). Detailed event records are deleted after 30 days and the aggregate reports after 90.
The analytics are provided by Avyndo, which acts as our processor under a data processing agreement and stores the data on servers in the European Union. It is not shared with anyone else.
You can change your mind at any time using the Cookie settings link in the footer of any page. Choosing “Use essential only” after having accepted stops collection immediately and removes the analytics identifiers from your browser.
9. Security
The site is served over an encrypted connection, and enquiry data is transmitted over that connection. Documents that require an enquiry are held in private storage and released through short-lived, single-use links rather than public URLs.
10. Children
This website is not directed at children, and we do not knowingly collect personal data from anyone under 16. If you believe a child has sent us their details, contact us at [email protected] and we will delete them.
11. Changes to this policy
We may update this policy from time to time. Any changes will be published on this page.