Consent to Personal Data Processing

I, the personal data subject, by ticking the box "I consent to the processing of my personal data for the purpose of contacting me about my request" in a form on the website housebook.global or its subdomains (the "Site") and submitting the form, freely, of my own will and in my own interest give my specific, informed, conscious and unambiguous consent to the processing of my personal data on the terms set out below. Ticking the box and submitting the form are recognised as an action allowing the fact of receipt of consent to be confirmed (part 1 of article 9 of Federal Law No. 152-FZ of 27.07.2006 "On Personal Data", the "Personal Data Law"). I confirm that I am at least 18 years old.

Consent is given voluntarily. Without it the Operator will not be able to accept and process my request; refusal has no other consequences.

1. Operator

HOUSEBOOK INVESTMENT L.L.C., a limited liability company registered in Dubai (UAE), commercial licence No. 1061992 issued by the Dubai Department of Economy and Tourism; TRN 104558732400003; address: Office 2502-01, Marina Plaza Tower, Al Marsa Street, Dubai Marina, Dubai, UAE (the "Operator"). Contacts for personal data matters: vf@housebook.ae, +971 52 298 8804.

2. What data

• name;
• phone number;
• email address;
• messenger username (Telegram, WhatsApp), if I chose that way of contact;
• the country and property I am interested in, budget and the text of the request, if I provided them;
• details of the Operator's partner (agent) whose referral link brought me to the Site;
• technical data transmitted when the form is submitted: date and time, IP address, browser and device information, page address and advertising campaign tags;
• cookie identifiers and data of the web analytics service Google Analytics 4, only if I have allowed its use in the Site cookie banner; visit statistics of the Rybbit service on the Operator's own server in Germany (OVH hosting, Frankfurt am Main), only if I have allowed analytics in the Site cookie banner.

3. Purposes of processing

• to contact me about my request and answer questions;
• to select properties and pass the request to developers, agencies and partners working with the chosen property or country;
• to support a transaction, if I ask for it;
• to record the request in the records system and identify the partner (agent) whose link I used, including to calculate that partner's remuneration;
• to protect the Site and requests from spam and abuse, including by automated checking of requests; no decisions producing legal effects for me are taken based solely on automated processing (article 16 of the Personal Data Law);
• to analyse Site traffic and advertising effectiveness, as regards web analytics data and only with my permission in the cookie banner.

4. Operations with data

Collection, recording, organisation, accumulation, storage, updating (revision, change), retrieval, use, transfer (provision, access), anonymisation, blocking, deletion, destruction. Processing is carried out with and without automated means.

5. Who data may be disclosed to

• the Operator's affiliate HOUSEBOOK REAL ESTATE L.L.C. (licence No. 1128098, Office No. 2502-01, Marina Plaza, Dubai Marina, Dubai, UAE) for brokerage support of a transaction;
• developers, real estate agencies, local partners and brokers in the country of the property I am interested in, to contact me and support the transaction;
• the Operator's partner (agent) whose link brought me to the Site: my name and details of the request, without my full phone number and email address; if that partner was invited to the programme by another partner of the Operator, the inviting partner in Telegram: my name, partially masked phone number and email address, the property of interest;
• persons processing data on the Operator's behalf (list below);
• the messengers Telegram and WhatsApp, if I chose such a way of contact;
• legal and financial advisers, banks and payment organisations, only if I ask for transaction support;
• public authorities and courts upon lawful request.

Persons processing data on the Operator's behalf, as of the date of this edition:

• Google LLC (Firebase and Google Cloud services): Site hosting and request database, hosting region Singapore;
• Bitrix24 (operator of the cloud service ALAIO ME W.L.L., Bahrain): request records system, data hosted in the USA;
• Unisender Smart LLC (Russia): sending emails;
• OVH SAS (France, server in Frankfurt am Main, Germany): hosting of the Operator's own Rybbit visit statistics server;
• Telegram: service notifications to the Operator's employees and partners about a request;
• Anthropic PBC (USA): automated spam check of requests;
• JSC "MTT" (MTS Exolve service, Russia), VoxAI L.L.C-FZ (Voice-Tele service, UAE), LPT LLC (LPTracker service, Russia), Twilio Inc. (USA): telephony and call recording;
• Google LLC (Google Analytics, USA): web analytics, only with my permission in the cookie banner;
• Wazzup LLC (Russia): sending WhatsApp messages, if this channel is used.

The Operator provides the current list of recipients on my request.

6. Transfer outside the Russian Federation

I have been informed and agree that the Operator is located in the UAE, that some recipients are located in Singapore, the USA, Germany, Turkey, Cyprus and the country of the property I am interested in, and that my data will be processed in those countries. The UAE and the USA are not on the list of foreign states ensuring adequate protection of the rights of personal data subjects, so the level of protection of my rights in those countries may differ from that established by the legislation of the Russian Federation.

7. Term

This consent is valid for 3 (three) years from the date of the last contact with me about the request, unless I withdraw it earlier. When the purposes of processing are achieved or the term expires, data is destroyed or anonymised within 30 (thirty) days, except data the Operator is required by law to keep. If I asked for transaction support, documents and data on the transaction are kept for the document retention period established by the tax and other applicable legislation of the UAE. The record confirming receipt of this consent is kept for the term of the consent and for 3 (three) years after it ends.

8. Withdrawal of consent

I may withdraw consent at any time without giving reasons by sending an email to vf@housebook.ae with the subject "Withdrawal of consent" and stating the name and the phone number or email address I left on the Site. The Operator stops processing and destroys the data within 30 (thirty) days of receiving the withdrawal (part 5 of article 21 of the Personal Data Law), except where the Personal Data Law or another law allows processing to continue without consent (part 2 of article 9 of the Personal Data Law). Withdrawal does not affect the lawfulness of processing before it is received.

9. My rights

I have the right to obtain information on the processing of my data, including on recipients and cross-border transfer, to require its correction, blocking or destruction if it is incomplete, outdated, inaccurate, unlawfully obtained or not needed for the stated purposes, to withdraw consent, and to challenge the Operator's actions before the Federal Service for Supervision of Communications, Information Technology and Mass Media (Roskomnadzor) or a court. The Operator responds to my request within 10 (ten) working days of receipt; this period may be extended by no more than 5 (five) working days with notice to me of the reasons (articles 14 and 20 of the Personal Data Law).

10. Applicable law

If I am a citizen of the Russian Federation, the Personal Data Law applies to the processing of my data (part 1.1 of article 1). If I am not a citizen of the Russian Federation, the processing of my data is governed by UAE law (Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data, the "PDPL") and, where applicable, the EU General Data Protection Regulation (GDPR), as described in the Operator's Privacy Policy; in that case this document confirms my consent and informs me of the procedure for processing.

11. Relationship with the Policy

The procedure for processing personal data is described in detail in the Operator's Privacy Policy: housebook.global/en/privacy. This consent is drawn up separately from other documents (part 1 of article 9 of the Personal Data Law) and is not part of the Policy, the offer or any other terms.

Consent to receive marketing mailings is given in a separate document (housebook.global/en/marketing-consent) and is not a condition for processing my request.