Privacy policy

1. Introduction

This Privacy Policy explains how Clear Rate Mortgage FZE LLC ("ClearRate", "we", "us") collects, uses, discloses, and protects personal data when you use clearrate.ae and related services (the "Platform"). It should be read together with our Terms of Use and Cookie Policy.

ClearRate acts as the data controller for personal data collected directly through the Platform, as defined under UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data ("PDPL").

2. Personal Data We Collect

2.1 Sellers

• Full name, Emirates ID number, date of birth, and nationality.
• Contact details: mobile number and email address.
• UAE Pass digital identity data (where UAE Pass is used to register), limited to the fields UAE Pass shares with us upon your consent.
• Property ownership documents (e.g. title deed or equivalent instrument), and property details including location, size, photographs, price, and reason for sale or rent.
• Payment and billing details, processed via Tap Payments (see Section 5).
• Account activity, including listings created, enquiries received, and login history.

2.2 Buyers

• Mobile number submitted for OTP verification via SMS.
• Email address, if voluntarily provided.
• Browsing activity on the Platform, including listings viewed and enquiries submitted.
• Blind Offer submissions, where applicable, including offer amount and contact details shared with the relevant Seller.

2.3 All Users

• Device and usage data collected automatically, including IP address, browser type, device identifiers, and general location inferred from your IP address.
• Cookie and similar tracking data, as described in our Cookie Policy.
• Communications you send to ClearRate support, including WhatsApp and email correspondence.

3. How We Use Personal Data

• To verify Seller identity and ownership, and Buyer mobile numbers, before enabling use of the Platform.
• To create, publish, and display Listings, and to deliver enquiries and Blind Offers between Sellers and Buyers.
• To process payments for Listing fees and the PRO Documentation Service.
• To operate, maintain, and improve the Platform, including fraud prevention and security monitoring.
• To send transactional communications (OTP codes, listing confirmations, renewal notices, receipts) and, with consent, marketing communications.
• To comply with legal and regulatory obligations, including responding to lawful requests from UAE authorities.
• To produce aggregated, non-identifying statistics (such as days-on-market, market pulse, and area-level listing activity) displayed on the Platform.

4. Legal Basis for Processing

We process personal data on the basis of your consent (for example, where you register via UAE Pass or opt in to marketing communications), the necessity of processing to perform our contract with you under these Terms, our legitimate interests in operating a secure and functioning Platform (including fraud prevention), and compliance with our legal obligations under UAE law.

5. Sharing of Personal Data

5.1 Between Users

When a Buyer submits an enquiry or Blind Offer, ClearRate shares the Buyer's verified contact details with the relevant Seller so that the Seller may respond directly. Sellers' published Listing details, and the contact information necessary to receive enquiries, are visible to registered, OTP-verified Buyers.

5.2 Service Providers (Data Processors)

We share personal data with the following categories of service providers, who process data on our behalf and under our instructions:

• UAE Pass — identity verification for Seller registration.
• Twilio — delivery of SMS one-time passwords (OTP).
• Tap Payments — processing of listing and service fee payments.
• Supabase — database hosting and storage infrastructure.
• Vercel — application hosting and content delivery.
• Mapbox — display of location and mapping features.

These providers are contractually required to protect personal data and to use it only for the purposes for which it was shared. We do not sell personal data to third parties.

5.3 Legal and Regulatory Disclosure

We may disclose personal data where required by UAE law, in response to a valid request from a competent authority (including law enforcement or a land department), or where necessary to protect the rights, property, or safety of ClearRate, our Users, or the public.

6. International Data Transfers

Some of our service providers may process or store data outside the United Arab Emirates. Where personal data is transferred internationally, we take steps to ensure an adequate level of protection consistent with PDPL requirements, including through contractual safeguards with the relevant provider.

7. Data Retention

We retain personal data for as long as your account remains active, and for a reasonable period thereafter to comply with legal, tax, and regulatory recordkeeping obligations, resolve disputes, and enforce our agreements. Listing content and transaction records relating to the PRO Documentation Service are retained for the period required under applicable UAE recordkeeping requirements.

8. Data Security

We apply administrative, technical, and organisational measures designed to protect personal data against unauthorised access, loss, misuse, or alteration, including encryption in transit, access controls, and OTP-based verification. No system is completely secure, and we cannot guarantee absolute security of information transmitted to or from the Platform.

9. Your Rights

Subject to the conditions and exceptions set out in PDPL, you may have the right to request access to, correction of, or deletion of your personal data; object to or restrict certain processing; withdraw consent previously given; and request a copy of your data in a portable format. We may need to verify your identity before actioning a request.

10. Children's Privacy

The Platform is not directed at, and is not intended for use by, individuals under 18 years of age. We do not knowingly collect personal data from minors. If we become aware that we have inadvertently collected data from a minor, we will take steps to delete it.

11. Marketing Communications

With your consent, we may send you updates about new Listings, features, or promotions by SMS, email, or push notification. You may opt out at any time using the unsubscribe link in our communications or via your account settings.

12. Cookies

The Platform uses cookies and similar technologies as described in our separate Cookie Policy, which forms part of this Privacy Policy.

13. Consumer Privacy Notice

A short-form Consumer Privacy Notice, summarising the key points of this Policy in plain language, is available separately for quick reference and should be read alongside this full Privacy Policy.

14. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. We will post the updated version on the Platform and update the "Last updated" date below. Material changes will be notified via email or in-app notice.

15. Contact Us

For privacy-related questions or to exercise your rights, contact hello@clearrate.ae, or by post to Clear Rate Mortgage FZE LLC, BC-890348, 26th Floor, Amber Gem Tower, Sheikh Khalifa Street, Ajman, United Arab Emirates.