Privacy Policy

Last updated: Pending publication

Template content — not yet legally reviewed. This document is a structural starting point only. It must be reviewed and completed by a qualified legal advisor covering UAE law and, because the site targets European and UK buyers, GDPR/UK GDPR. Remove the needsLegalReview prop on this page once that is done.

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:

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].

  • LION TECH SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ
  • NIP: 5213917848
  • REGON: 387990445
  • ul. Główna 54
  • 05-502 Kamionka, Poland
  • Email: [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. We do not record or store your IP address.

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.

[For legal review — the balancing test supporting the legitimate-interests basis above should be documented before launch, and this wording confirmed against it.]

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.

[For legal review — name the actual processors and where each stores data once the CRM and email provider are connected, and either name the partner brokerages here or link to a maintained list. The GDPR requires recipients, or at minimum the categories of recipient, to be identified.]

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.

[For legal review — confirm the transfer mechanism relied on before launch. If transfers are to be routine rather than occasional, Article 49 consent is generally not an adequate long-term basis and Standard Contractual Clauses with a transfer impact assessment will be required instead.]

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.

[For legal review — a specific retention period must be stated here before launch. The GDPR requires either the period or the criteria used to determine it; "as long as needed" alone is not sufficient.]

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 tracking

This website sets one cookie: a functional cookie that remembers the language you chose, so the site stays in that language as you move between pages. It contains no identifier and is not used to track you.

We do not use analytics, advertising or social-media tracking cookies, and there are no third-party tracking scripts on this site. Because the only cookie is strictly necessary to provide a feature you asked for, no consent banner is required for it.

If analytics or advertising tools are added in future, this section will be updated and a consent mechanism will be put in place before any such cookie is set.

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.

[For legal review — confirm the applicable age threshold for the markets targeted; Poland sets the digital-consent age at 16, but other EEA states set it as low as 13.]

11. Changes to this policy

We may update this policy from time to time. The date at the top of this page shows the last revision.