Privacy Policy

1. GENERAL

1.1. This Privacy Policy (the “Policy”) explains how SHELLGROW HOLIDAY HOMES L.L.C (the “Company”, “we”, “our”, “us”) collects, uses, stores, discloses and protects personal data when you visit or use https://partners.shellgrow.com (the “Partners Website”) and when you communicate with us as a prospective or existing partner (the “User”, “you”, “your”).

1.2. This Partners Website is intended for partner applications and communications with real estate agents, brokers, and other prospective partners. By using the Partners Website or submitting personal data through the Partners Website or other channels (including WhatsApp, email, social media, phone calls), you acknowledge that you have read and understood this Policy.

1.3. We process personal data in accordance with applicable data protection laws of the United Arab Emirates, including, where applicable, Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (“UAE PDPL”), and other relevant regulations.

2. PERSONAL DATA WE COLLECT

2.1. Data you provide to us

• (a) Identification and contact data: full name, phone number (including WhatsApp), email address (if provided).
• (b) Partner application data: information you submit in the application form and communications (e.g., professional role, company/agency name, areas of activity, comments, referral details).
• (c) Communications: messages and correspondence with us (WhatsApp, email, phone calls, social media messages, contact forms).

2.2. Data we collect automatically (technical and usage data)

• (a) Device and log data: IP address, browser type/version, device identifiers, operating system, language, date/time of visits, pages viewed, referring URLs, clickstream data.
• (b) Cookies and similar technologies data (see Section 8).

2.3. Data received from third parties

We may receive personal data from:

• (a) Advertising platforms (e.g., Meta/Facebook) where you interact with our ads or submit lead forms;
• (b) Analytics and measurement providers;
• (c) Business partners who refer you to us.

2.4. We do not intentionally collect special categories of personal data (e.g., health, religion, political opinions) unless required by law and only with appropriate legal basis.

3. PURPOSES OF PROCESSING

We process your personal data for the following purposes:

3.1. Partner onboarding and communications

• (a) to review partner applications and contact you about cooperation;
• (b) to respond to your inquiries and provide support;
• (c) to manage the relationship with partners and maintain internal records.

3.2. Website operation and improvement

• (a) to operate, secure, maintain and improve the Partners Website;
• (b) to monitor performance, diagnose issues, prevent fraud and abuse.

3.3. Marketing and advertising

• (a) to measure and improve our advertising campaigns;
• (b) to show you relevant ads and content, including via remarketing where permitted by law and based on your cookie preferences/consent (see Section 8);
• (c) to send marketing communications via WhatsApp Business, email, SMS or other channels, where permitted by law and subject to your choices (see Section 5).

3.4. Compliance and legal

• (a) to comply with applicable laws and regulations, accounting and audit requirements;
• (b) to establish, exercise or defend legal claims.

4. LEGAL BASIS FOR PROCESSING

We process personal data based on one or more of the following legal bases, as applicable:

• (a) your consent (e.g., marketing communications; non-essential cookies);
• (b) steps taken at your request prior to entering into a contract and/or performance of a contract (e.g., processing a partner application and cooperation arrangements);
• (c) compliance with legal obligations;
• (d) legitimate interests (e.g., security, fraud prevention, improving our services and website), provided such interests do not override your rights.

5. MARKETING COMMUNICATIONS (INCLUDING WHATSAPP)

5.1. Where permitted by law, we may send you marketing and informational communications about our partner program, services, offers, events, and updates through channels such as WhatsApp Business, email, SMS, and social media.

5.2. Opt-out

You can opt out of marketing communications at any time:

• (a) by emailing us at support@shellgrow.com with “Unsubscribe” in the subject; and/or
• (b) by using the opt-out method described in the message (e.g., replying “STOP” in WhatsApp where applicable).

5.3. Opting out of marketing messages does not affect service/transactional messages that are necessary to respond to your application or manage the partner relationship.

6. SHARING OF PERSONAL DATA

6.1. We may share your personal data with:

• (a) Service providers (processors) that support our operations, such as hosting providers, CRM systems, email/SMS tools, analytics providers, IT/security providers.
• (b) Advertising/measurement partners to measure campaign performance and provide advertising services (subject to your cookie preferences).
• (c) Professional advisors (legal, auditors, consultants) when necessary.
• (d) Government authorities and law enforcement when required by applicable law or official requests.

6.2. We take reasonable steps to ensure that recipients protect personal data and use it only for the purposes described in this Policy.

7. INTERNATIONAL TRANSFERS

7.1. Some service providers and technology partners may be located outside the UAE. This may result in international transfers of personal data.

7.2. Where international transfers occur, we take appropriate measures to ensure an adequate level of protection in accordance with applicable UAE data protection requirements.

8. COOKIES, PIXELS AND ANALYTICS

8.1. We use cookies and similar technologies (including pixels and SDKs where applicable) to:

• (a) ensure website functionality and security;
• (b) remember preferences;
• (c) analyze traffic and user behavior;
• (d) measure advertising performance and deliver relevant ads.

8.2. Our Partners Website uses (or may use) the following tools:

• (a) Google Analytics (Google LLC) – analytics and performance measurement.
• (b) Meta Pixel (Meta Platforms, Inc.) – advertising measurement and remarketing.
• (c) Yandex.Metrica (Yandex) – analytics and performance measurement (including session replay/“webvisor” features if enabled).

8.3. Consent and controls:

• (a) Where required, we request your consent for non-essential cookies via a cookie banner/consent tool.
• (b) You can change cookie settings at any time via [Cookie Settings] on the Partners Website (if implemented) or through your browser settings.
• (c) Disabling certain cookies may affect website functionality.

9. DATA RETENTION

9.1. We retain personal data in identifiable form only as long as necessary for the purposes set out in this Policy, including:

• (a) while evaluating your partner application and communications;
• (b) for the duration of the partner relationship (if established);
• (c) as required by statutory retention periods and limitation periods for legal claims.

9.2. When data is no longer required, we delete or anonymize it, unless we are legally required to retain it longer.

10. YOUR RIGHTS

10.1. Subject to applicable UAE data protection laws, you may have rights including:

• (a) to be informed about processing;
• (b) to access your personal data;
• (c) to correct or update inaccurate data;
• (d) to request deletion/erasure in certain circumstances;
• (e) to restrict processing in certain circumstances;
• (f) to withdraw consent where processing is based on consent;
• (g) to object to certain processing, including direct marketing;
• (h) to request transfer of your personal data where applicable.

10.2. To exercise your rights, contact us using the details in Section 11. We may request additional information to verify your identity.

11. CONTACT DETAILS

Data controller:
SHELLGROW HOLIDAY HOMES L.L.C.

Registered address:
Office 3108, Al Salam Tecom Tower, Internet City, Dubai, UAE

Phone:
+971 50 346 3933

Email (general):
info@shellgrow.com

Email (privacy / unsubscribe):
support@shellgrow.com

12. CHANGES TO THIS POLICY

12.1. We may update this Policy from time to time. The updated version will be published on: https://partners.shellgrow.com/privacy-policy (or another URL we specify) and will be effective from the date of publication unless otherwise stated.

12.2. We encourage you to review this Policy periodically.