Privacy Policy

This Privacy Policy (the "Policy") describes what personal data Housebook processes when operating the website housebook.global and its subdomains (the "Website"), for what purposes and on what basis, to whom we disclose it, how long we keep it and how you can exercise your rights. The Policy is prepared in accordance with UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (the "PDPL"), the EU General Data Protection Regulation (GDPR) where it applies and, for citizens of the Russian Federation, Federal Law No. 152-FZ of 27 July 2006 "On Personal Data" ("152-FZ"), see section 15.

1. Who we are

The operator (controller) of your personal data and the operator of the Website is 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 "Company", "we", "us"), represented by General Director Vasily Yurievich Fetisov.

The Company's affiliate, HOUSEBOOK REAL ESTATE L.L.C. (licence No. 1128098, Office No. 2502-01, Marina Plaza, Dubai Marina, Dubai, UAE), carries out brokerage activity and receives data to the extent needed to support a transaction (section 6).

For personal data matters: vf@housebook.ae, +971 52 298 8804.

2. Who this Policy applies to

This Policy applies to visitors of the Website and to clients who have left a request or receive property selection services from us.

Data of partners (agents, sourcers) in the partner programme is processed under the public offer HB-SO-2026/01 and the document "Personal Data Consent and Privacy Notice for Partners" HB-SO-2026/01-PD. If those documents differ from this Policy as regards partner data, they prevail.

3. What data we process and where it comes from

We process only the data needed for the purposes in section 4:

• data you provide yourself in forms on the Website: name, phone number, e-mail address, messenger username (Telegram, WhatsApp) if you chose that way of contact, the country and property you are interested in, budget and the text of your request;
• data you give us by phone and in messengers: the content of correspondence and the history of enquiries; phone calls may be recorded, and you are told so at the start of the call;
• details of the partner (agent) whose referral link brought you to the Website;
• technical data transmitted when you submit a form and visit the Website: date and time, IP address, browser and device information, page address and advertising campaign tags;
• cookie identifiers and web analytics data from Google Analytics 4: only if you have allowed them in the Website cookie banner. Cookieless visit statistics are kept on the Company's own server.

Sources: you (forms, calls, messengers), your device (technical data and cookies), and the partner whose referral link brought you to the Website. We do not process special categories of data (health, religion, biometrics, etc.) and ask you not to include them in your request.

If you do not provide the data we need, we will not be able to accept and process your request.

4. Purposes and legal bases

• to contact you about your request, answer questions, select properties and pass the request to developers, agencies and partners working with the chosen property or country; basis: your consent and taking steps at your request prior to entering into a contract, and performance of the contract once concluded;
• to support a transaction if you ask us to; basis: performance of a contract and steps prior to entering into it;
• to record requests and identify the partner whose link you used, including to calculate that partner's remuneration; basis: the Company's legitimate interest in recording requests and meeting its obligations to partners, and, for citizens of the Russian Federation, your consent;
• to protect the Website and requests from spam and abuse, including automated checking of requests; basis: the Company's legitimate interest in the security of the Website and prevention of abuse;
• to analyse Website traffic and advertising effectiveness using Google Analytics; basis: your consent given in the cookie banner;
• to send you marketing and informational mailings (selections, news); basis: your separate consent, see section 5;
• to comply with legal requirements, respond to requests from public authorities and courts, and keep accounting, tax and other mandatory records; basis: compliance with a legal obligation;
• to protect the Company's rights and interests in disputes; basis: the Company's legitimate interest.

5. Marketing mailings

We send marketing and information communications (e-mail, SMS, messengers, calls including automated calls, push notifications) only with your separate consent. It is given through a separate optional checkbox, unticked by default, and a separate document (/en/marketing-consent). Consent to process your request, acceptance of the Terms of Use and acceptance of cookies do not mean consent to mailings, and declining mailings does not affect the handling of your request.

You can opt out at any time: via the "Unsubscribe" link in every e-mail or by writing to vf@housebook.ae. We stop mailings immediately on receiving your opt-out and keep only a record of it so that we do not write to you again.

6. Automated checks

We automatically check requests for spam and abuse, including with the artificial intelligence service of the provider named in section 7. We do not take decisions that produce legal effects for you or otherwise significantly affect your rights based solely on automated processing. If a request is wrongly flagged as spam, you may write to vf@housebook.ae and a staff member will review it.

7. Who we disclose data to

We do not sell personal data. Data may be disclosed to the following categories of recipients:

• the affiliate HOUSEBOOK REAL ESTATE L.L.C., for brokerage support of a transaction;
• developers, real estate agencies, local partners and brokers in the country of the property you are interested in, to contact you and support the transaction;
• the partner (agent) whose link brought you to the Website: your name and details of the request, without your full phone number and e-mail address; if that partner was invited to the programme by another Housebook partner, the inviting partner receives a Telegram notice of the request: your name, partially masked phone number and e-mail, the property of interest and the name of the invited partner;
• the messengers Telegram and WhatsApp, if you chose such a way of contact;
• legal and financial advisers, banks and payment organisations, only if you ask for transaction support;
• persons processing data on our behalf (list below);
• public authorities and courts upon lawful request and, in a reorganisation or sale of the business, the successor on the same protection terms.

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

• Google LLC (Firebase and Google Cloud services): Website 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 e-mails, the "Unsubscribe" link and unsubscribe records;
• OVH SAS (France, server in Frankfurt am Main, Germany): hosting of the Company's own Rybbit visit statistics server;
• Telegram: service notifications to the Company'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 if you allow it in the cookie banner;
• Meta Platforms Inc. and Google LLC (USA): advertising tools (Meta Pixel, Google advertising tags), if connected, and only with your consent to the "Advertising" category;
• Wazzup LLC (Russia): sending WhatsApp messages, if this channel is used.

We provide the current list of recipients on request at vf@housebook.ae.

8. Transfers of data outside your country

The Company is located in the UAE, so data is processed in the UAE. In addition, because of the recipients listed in section 7 and the nature of our business, data may be processed in Singapore (hosting), the USA (request records system, analytics, spam-check service, Twilio), Russia, and the country of the property you are interested in (developer, agency, local partner), as well as in other countries where the recipients from section 7 are located.

Not all of these countries offer the same level of data protection as your country. We transfer data subject to safeguards: compliance with the PDPL rules on cross-border transfers, contractual data protection terms with recipients (including standard contractual clauses where applicable) and, in other cases, your consent. For citizens of the Russian Federation see also section 15.

9. Retention periods

• Requests, correspondence and enquiry history: 3 years from the last contact with you; then deleted or anonymised within 30 days.
• Transaction data and related documents: for the document retention period required by UAE tax and other applicable law.
• Recordings of phone calls: 1 year from the date of the call.
• Consent to processing and its evidence (date, text version, IP address): for the whole term of the consent and 3 years after it ends.
• Marketing consent and opt-out: while the consent is valid; the record of an opt-out is kept for 3 years so that we do not write to you again.
• Web analytics and cookie data: for the periods stated in the Cookie Policy (/en/cookies).
• Technical logs and anti-spam data: 1 year.

When the purposes are achieved, the period expires or consent is withdrawn, data is deleted or anonymised within 30 days, except data we are legally required to keep.

10. Security measures

We apply technical and organisational protection measures: encryption of data in transit (SSL/TLS); access limited on a need-to-know basis; individual staff accounts; contractual data protection obligations of recipients; regular analysis of system security. Complete protection against all risks is not possible; in an incident affecting your rights we will notify you and the competent authority as provided by law.

11. Your rights

Depending on the applicable law, you have the right to: obtain information on whether we process your data and access to it; require correction of inaccurate data; require deletion, blocking or restriction of processing; object to processing; receive your data in a portable format where provided; withdraw consent at any time; not be subject to a decision based solely on automated processing where it produces legal effects; and complain about our actions.

How to exercise your rights: send a request to vf@housebook.ae stating the name and phone or e-mail you left on the Website; we may ask you to confirm your identity. We respond within 30 days, and to citizens of the Russian Federation within the periods stated in section 15. Deletion of data or handling of a consent withdrawal is carried out within 30 days of receiving the request, unless the law requires us to keep the data.

Complaints: the UAE Data Office; the supervisory authority of the EEA state where you live or work; for citizens of the Russian Federation, Roskomnadzor (section 15). We would appreciate it if you write to us first.

12. Cookies

We use cookies and similar technologies. Necessary cookies always work, including partner and UTM tags used to attribute a request to the inviting partner. Analytics (Google Analytics 4, Google Tag Manager (if connected) and the Company's own Rybbit counter on its server in Germany) loads only after your consent to the "Analytics" category, and advertising tools (Meta Pixel and Google advertising tags), if connected, only after consent to the "Advertising" category. You choose in the cookie banner ("Customize", "Only necessary", "Accept all"); the choice is stored on your device for 12 months and can be changed at any time via the "Cookie settings" link in the Website footer. Details: Cookie Policy (/en/cookies).

13. Children

The Website and services are intended for persons aged 18 and over. We do not knowingly collect data of persons under 18. If you know that a child has given us data, write to vf@housebook.ae and we will delete it.

14. Applicable law

If you are a citizen of the Russian Federation, your data is processed under 152-FZ (part 1.1 of article 1), see section 15. In other cases processing is governed by UAE law (PDPL) and, where applicable, the GDPR. The Policy does not limit requirements of the law of your country that bind us and cannot be changed by agreement.

15. For citizens of the Russian Federation

If you are a citizen of the Russian Federation, 152-FZ applies to the Company's processing of your personal data (part 1.1 of article 1), because the processing is based on your consent and on a contract to which you are a party. This section supplements the rest of the Policy and prevails over it for citizens of the Russian Federation in case of conflict.

Consent. For a request we obtain a separate consent to personal data processing (/en/consent), drawn up separately from other documents (part 1 of article 9 of 152-FZ). Without consent we cannot accept the request. Consent can be withdrawn at any time by writing to vf@housebook.ae with the subject "Withdrawal of consent"; we stop processing and destroy the data within 30 days of receiving the withdrawal, except where the law allows processing to continue without consent (part 5 of article 21, part 2 of article 9 of 152-FZ).

Transfer abroad. Your data is transferred to the UAE, the USA, Singapore, Germany and the country of the property you are interested in. 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 in those countries may differ from that established in the Russian Federation. We transfer data with your consent. Some recipients are located in Russia (Unisender, MTT, LPT).

Rights (articles 14, 20, 21 of 152-FZ). You have the right to obtain information on the processing of your data, including purposes, methods, recipients and cross-border transfer; to require correction, blocking or destruction of data that is incomplete, outdated, inaccurate, unlawfully obtained or not needed for the stated purpose; to withdraw consent; and to challenge our actions. We respond to a request within 10 (ten) working days of receipt; this period may be extended by no more than 5 (five) working days with notice to you of the reasons.

Complaints. You may apply to the Federal Service for Supervision of Communications, Information Technology and Mass Media (Roskomnadzor) or to a court.

Term and procedure. Requests are kept for 3 years from the last contact; data is destroyed within 30 days after the purpose is achieved or consent is withdrawn. The data processed, recipients and countries are listed in sections 3, 7 and 8.

16. Changes to the Policy

We may update the Policy. The new edition is published on this page with a new version number and date; we will notify you of material changes on the Website by a banner on the Website. If a change requires new consent, we will request it separately. Previous editions are kept in a version archive available on request at vf@housebook.ae.

This Policy is published in several languages and all language versions are equally authoritative. In case of discrepancy, the version in the language in which you viewed the Website applies.

17. Contacts

HOUSEBOOK INVESTMENT L.L.C., Office 2502-01, Marina Plaza Tower, Al Marsa Street, Dubai Marina, Dubai, UAE. E-mail: vf@housebook.ae. Phone: +971 52 298 8804.