Last Revised on 10.06.2024
Privacy Policy shall be referred to as the “Policy”
Mulki (“Mulki”, “Company”, “we”, “us” or “our”) respects your privacy and is committed to protecting your personal data. This Policy will inform you about how we look after your personal data when you interact with, or use the services on, our website
https://mrc-baghdad.online/home-
and our mobile application Mulki (together, the “Site”) regardless of where you visit or access them from, and tell you about your privacy rights and how the law protects you. By using our Site or any of our services, you agree and consent that the Company may collect, use and process your data. If you do not agree to this Policy, please cease from using our Site and/or services in any way
Profile Dataincludes details collected when you generate a user profile such as username and password.
ersonal data, or personal information, means any information about an individual from which that person can be identified, and in some jurisdictions include information pertaining to deceased
individuals. It does not include data where the identity has been removed (anonymous dat
Where applicable to the services offered on the Site, we may collect and process different kinds of personal data about you which we have grouped together as follows:
Identity Data includes first name, last name or similar identifier and title
Contact Data includes your email address
Settings Data includes preferences set by you on the customisable configurations of our Site.
Site Usage Data includes information regarding when and how you use or interact with our Site, user behavior and site metadata. This may also include all user inputs such as information regarding any of your real estate property, its specifications, location, photos, corresponding payment schedules and any other information which assist us in maintaining and further developing the features of our Site
Marketing and Communications Data wherein marketing data includes your preferences in receiving marketing materials from us and our third-party service providers should we opt to onboard such service providers in the future, and communications data refers to your preferences with regards to receiving Site support and updates from us.
Third-Party Data derived from third-party service providers engaged in market data enrichment and advertising services and includes information such as the nature of our individual account holders as well as user responses to advertisements presented on the Site, if any. This also includes third-party credential data which may be collected when registering with, and logging into, our Site through single sign-in authentication services such as those provided by Facebook and Google. Hence, where you opt to register or log in on the Site through such services, we will collect your personal data as provided by such third-party service providers to the extent permitted by this Policy and the law.
We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Site Usage Data to calculate the percentage of users accessing a specific Site feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Policy
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences
we only collect data from and about you through:
Direct interactions. You may give us your Identity, Contact and Profile Data by filling in forms or by corresponding with us by email. This includes personal data you provide when you:
avail the services on our Site;
subscribe to our newsletter
give us feedback or contact us.
You may also provide us the personal data of third parties while using our Site, during which you are deemed to have their consent to do so.
However, we may in the future use additional methods to collect data from and about you, including through:
Automated technologies or interactions. As you interact with our Site, we may automatically collect Technical Data about your equipment browsing actions and patterns. We collect this personal data by using cookies, server logs, web beacons and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please click here to see our cookie policy for further details.
Third-party or publicly available sources. We may receive certain categories of personal data about you including Identity, Contact and Technical Data from various credible third-party and public sources and software tools such as Google Analytics, Ad Words, Double Click and/or Ad sense tracking codes.
We will only collect and use your personal data to generate your user account which will allow you to use our Site and services. Where we use your personal data outside such scope, we will only do so to the extent permitted by law and subject to receiving your express consent. Most commonly, we may use your personal data in the following circumstances:
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. Legitimate interests have been detailed in the table below on Purposes for Which We Will Use Your Personal Data and in the Glossary.
Where it is necessary to fulfil our own marketing purposes and those of our third-party partners, should we opt to onboard any, for the promotion of our Site. Cookies, server logs and similar technology may also be used to display third-party advertisements across our Site should we allow our partners to do so in the future. We do not utilise content created during your use of our Site such as information regarding your real estate properties, contracts and files you have uploaded onto the Site for any marketing purposes.
We do not intend to disclose your personal data to any other party for any other purposes than those stipulated in this Policy. Nevertheless, should our business operations require any such disclosure to be made in the future, we will request for your express consent as required by applicable laws before sharing your personal data with the selected parties set out below for the purposes addressed in the table Purposes for Which We Will Use Your Personal Data above.
Internal Third Parties as set out in the Glossary.
External Third Parties as set out in the Glossary.
Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Policy.
Where we have engaged any third party service provider, we will require them to respect the security of your personal data and to treat it in accordance with the law. We do not intend to allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
INTERNATIONAL TRANSFERS
Our Site is available to users globally. Regardless, we do not currently transfer your personal data outside of the United Arab Emirates.
Should we expand the operations of our Company, we may transfer your personal data to any future internal or external third parties which may be located outside the data’s initial country of origin for storage and processing as necessary and permitted under this Policy and subject to your express consent. We will endeavour to ensure your personal data is protected by requiring all our future affiliates to follow the same rules stipulated under this Policy when processing your personal data. Otherwise, we may amend this Policy to reflect any changes in our corporate structure which we foresee will significantly impact the way we collect, process and store your personal data and you will be notified of the same should the case arise.
Should we partner with external third parties in the future, such parties may operate internationally so their processing of your personal data may involve a transfer of data outside your country.
The countries to which the international transfers may be made may have different regulations which provide lesser protection than that of your country. Therefore, where we are legally authorised to transfer your personal data, we will safeguard it by ensuring that a sufficient degree of protection is afforded through the implementation of at least one of the below rules:
We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
Where personal data of users in the European Economic Area, Switzerland and the UK are transferred to countries outside regions which have not been deemed to provide an adequate level of personal data protection, we will adopt appropriate measures to ensure that the transfer is governed by the European Commission’s standard contractual clauses.
Where we use certain service providers, we may utilise specific contracts approved for use in the country of data processing which give your personal data adequate protection.
As we do not currently conduct any international transfers of your personal data, we do not have the mechanisms in place to do so. However, should we proceed to process your personal data internationally in line with this section, you may contact us for further information on the specific mechanisms used by us for this purpose.
We have put in place appropriate physical, electronic and administrative security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Our security safeguards will be applied depending on the nature of the data (for example, where it is in transit or at rest).
In addition, your personal data will be encrypted to ensure privacy and security. Where required to use or process such data, we will limit access to your personal data to those employees, agents, contractors and other third parties (if applicable) who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach immediately where we are legally required to do so in accordance with the applicable laws.
DATA RETENTION AND DISPOSAL
How Long Will You Use My Personal Data For?We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider its amount, nature and sensitivity, the potential risk of harm from unauthorised use or disclosure of your personal data, the length of our relationship with you (such as the period until you cease interacting with or utilising our services or our Site and/or delete or cancel your account with us), the purposes for which we process your personal data and whether we can achieve those purposes through other means, the applicable legal, regulatory, tax and accounting laws as well as any other requirements as applicable.
In some circumstances, you can ask us to delete your data: see Your Legal Rights below for further information.
Once the purposes for which your personal data was collected have been achieved, we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you. Otherwise, where there is no longer a legitimate interest and legal basis in retaining your personal data, it will be destroyed and deleted from our data centres.
YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
Request Access to Your Personal Data.
Request Correction of Your Personal Data.
Request Erasure of Your Personal Data.
Object to Processing Of Your Personal Data.
Request Restriction of Processing Your Personal Data.
Request Transfer of Your Personal Data.
Right to Withdraw Consent.
If you wish to exercise any of the rights set out above, please contact our DPO. You will not be discriminated against for doing so.
No Fee Usually RequiredYou will not have to pay a fee to access your personal data (or to exercise any of the other rights). Alternatively, we may refuse to comply with your request to the extent allowed by applicable laws if your request is clearly unfounded, repetitive or excessive.
What We May Need From YouWe may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you for further information in relation to your request to speed up our response.
Time Limit to RespondWe try to respond to all legitimate requests within a reasonable timeframe. Occasionally, it could take us longer if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you update