Privacy Policy

1. Individuals Covered by this Policy

• Service Users: Natural persons who use the Company’s services.
• Service Requesters: Natural persons requesting or intending to request the Company’s services.
• Corporate Representatives: Directors, shareholders, employees, or authorized representatives of corporate customers or business organizations that partner with the Company.
• Other Individuals: Natural persons with whom the Company interacts or establishes a relationship, or who provide personal data directly or indirectly through any channel.

2. Legal Basis and Purpose for the Collection, Use, and Disclosure of Personal Data

1. Performance of a Contract
   To fulfill contractual obligations to which you are a party or to take steps before entering into a contract. This includes:
   • evaluating and analyzing information related to the provision of the company’s services;
   • verifying your identity for transactions with the company;
   • providing services, resolving technical issues, and offering assistance related to the company’s services; and
   • communicating with you regarding service usage, answering questions, providing relevant information, follow-ups, and other relevant activities.
2. Public Interest or State-Authorized Duties
   To perform tasks carried out in the public interest or exercise official authority vested in the Company, including compliance with state missions.
3. Legitimate Interests
   For the legitimate interests of the Company or third parties, provided these do not override your fundamental rights relating to personal data protection. Examples include:
   • improving service quality and enhancing user experience;
   • handling complaints, claims, and disputes.
4. Legal Compliance
   To comply with applicable laws, such as rules, regulations, or orders from competent authorities (e.g., court orders, regulatory agencies, or authorized officers).
5. Protection of Vital Interests
   To prevent or mitigate risks to your life, body, or health in situations of necessity.
6. Consent
   For purposes as defined in the consent.

3. Personal Information That the Company Collects, Uses, or Discloses

1. 3.1
   Personal information
   Personal information refers to any data that can directly or indirectly identify you, including but not limited to:
   • Identity information: name, surname, and any applicable suffix.
   • Contact information: telephone number, email address, social media,instant chat messaging details, and address.
   • Technical information: IP address, cookies, and browsing behavior.
   • Financial and Transaction information: bank account, transaction history and proof of payment
   • Property information: title deed, property location, and property right status
2. 3.2
   Sensitive personal data
   The Company does not collect, use, or disclose your sensitive personal data unless express consent is provided. Sensitive personal data includes, as defined by law, information such as race, religion, biometric data, and other similar categories.
3. 3.3
   Personal data of any other third parties
   If you provide the personal data of any third parties—such as family members, references, or individuals mentioned in transaction documents—you must:
   • Inform them of the details outlined in this Policy, and
   • Obtain their consent, if necessary, or establish another legal basis to allow the Company to collect, use, and/or disclose their personal data lawfully.

4. Disclosure of Personal Data to Third Parties and Collection from Other Sources

1. 4.1
   Affiliated companies
   The Company may share your personal data with its affiliated companies to support business operations and provide services in line with the purposes described in this Policy.
2. 4.2
   Service Providers
   The Company may engage service providers, both domestic and international, who process your personal data on behalf of the Company as instructed. Before disclosing any personal data, the Company ensures that these service providers adhere to this Policy and applicable data protection laws.
3. 4.3
   Auditors and Regulatory Authorities
   The Company may disclose your personal data to auditors, external auditors, government agencies, and other relevant authorities as required to comply with legal obligations, respond to regulatory requirements, or exercise or defend legal claims.
4. 4.4
   Business Partners and Contractual Counterparties
   The Company may disclose personal data to business partners, entities, or individuals with whom the Company has entered into contracts or maintains legal relationships. These entities or individuals may independently decide on the processing of personal data and are required to comply with relevant personal data protection laws. For their specific privacy policies, please refer to their respective communication channels.
5. 4.5
   Transferees of Businesses or Assets
   In the event of a merger, acquisition, sale, or transfer of all or part of the Company’s business or assets, your personal data may be transferred to the relevant parties involved.

5. Retention Period for Personal Data

6. Data Security

7. Data Subject Rights

• the right to withdraw consent;
• the right to access your personal data;
• the right to request a copy of your personal data;
• the right to correct inaccurate or incomplete personal data;
• the right to object to the processing of your personal data;
• the right to request data portability for personal data stored in a format that is readable or commonly used by automated tools or equipment, including the right to transfer such data to other data controllers;
• the right to request the deletion or de-identification of your personal data when processing is no longer necessary;
• the right to request the suspension of personal data processing; and
• the right to file a complaint with relevant authorities.

8. Cookies Policy

1. 8.1
   The Company uses cookies to ensure the proper functioning of several sections of its website, to facilitate your use of the site, and to provide the services you request. The Company will use cookies only when necessary and will comply with applicable information security standards. Information collected through cookies will not be disclosed to third parties, except when cookies are operated by external service providers or when the Company has a legal basis to do so.
2. 8.2
   Types and Purposes of Cookies
   The Company uses cookies for different purposes, categorized as follows:
   • Strictly Necessary Cookies: These cookies are required for the website to function properly and provide its core services to users.
   • Functionality Cookies: These cookies remember your preferences (e.g., language, account settings) to personalize your experience on the website.
   • Performance Cookies: These cookies help evaluate and monitor the performance of the website. External service providers may operate some of these cookies.
   • Advertising Cookies: These cookies are used to deliver relevant advertising based on your preferences. External service providers may also manage these cookies.

9. Company contact information

10. Amendment of the Policy