Draft — pending legal review
This document is a draft prepared on 2026-04-21. It has not yet been reviewed by a licensed legal counsel. Do not rely on it for legal purposes.
Data Controller
in5 Tech DDA Free Zone LLC ("DealPilot", "we", "us") is the data controller for all personal data collected through the DealPilot platform.
Registered address: in5 Tech, Knowledge Building, Dubai Silicon Oasis, Dubai, UAE.
Data Protection Officer: founder@dealpilot.ae
What We Collect
We collect the following categories of personal data:
- Account data: Name, email, phone number, company name, RERA license number.
- Lead data: Name, phone, email, budget, preferred location, conversation logs.
- Deal data: Property details, transaction values, contract documents, party data.
- Compliance data: KYC documents, sanctions screening results, consent records.
- Usage data: Access logs, session data, device information.
How We Use It
- Providing and operating the platform services
- Complying with RERA, TDRA, and UAE AML law requirements
- Improving AI models (anonymized data only)
- Sending product updates and security notifications
- Responding to support requests
Storage & Data Residency
All customer data is stored in Google Cloud Platform — europe-west1 region (Belgium). We are migrating to me-central2 (Dubai) when fully available.
[REVIEW] Confirm actual GCP region before publishing.
Encryption: AES-256-GCM for PII at rest. TLS 1.3 in transit.
Sub-Processors
We use the following sub-processors to deliver the service:
| Processor | Purpose | Location |
|---|---|---|
| Anthropic | AI natural language processing | USA |
| OpenAI | AI natural language processing | USA |
| Google Cloud | Infrastructure & storage | EU / UAE |
| Meta (WhatsApp Business API) | WhatsApp messaging | USA |
| SendGrid (Twilio) | Transactional email | USA |
| Photoroom | Property photo enhancement | France |
| Virtual Staging AI | Virtual staging | USA |
| Stripe | Payment processing | USA |
Data Retention
- AML records: 7 years (UAE AML Law)
- KYC documents: 5 years after relationship ends
- Conversation logs: 2 years
- System logs: 90 days
- Account data: until deletion + 30 days
Your Rights
Under UAE PDPL and GDPR, you have the following rights:
- Access: Request a copy of your personal data
- Rectification: Correct inaccurate data
- Erasure: Request deletion (subject to legal retention requirements)
- Portability: Receive your data in machine-readable format
- Objection: Object to certain processing
To exercise these rights, contact: founder@dealpilot.ae
International Transfers
Some data may be transferred to sub-processors outside the UAE (see list above). We ensure appropriate safeguards per UAE PDPL Article 26, including Standard Contractual Clauses where applicable.
Children's Privacy
Our services are intended for professionals aged 18 or older. We do not knowingly collect data from children.
Changes to This Policy
We will notify you of material changes via email or in-platform notice at least 30 days before they take effect.
Contact Us
in5 Tech DDA Free Zone LLC
Knowledge Building, Dubai Silicon Oasis, Dubai, UAE
Email: founder@dealpilot.ae