Privacy

Effective date: 1 November 2026

Your privacy matters to us. This Privacy Policy explains how Emigeo Homes Real Estate LLC, trading as homes.me, collects, uses, shares and protects your personal data when you use the platform at https://homes.me, any Property Invest application we operate, our WhatsApp, email and phone channels and our advertising (together, the "Platform"), and it tells you about your rights and how to exercise them. By using the Platform you acknowledge this policy; where the law requires your consent (for example for cookies or marketing) we ask for it separately.

1. Who we are and how to contact us

homes.me (https://homes.me, the "Platform") is owned and operated by Emigeo Homes Real Estate LLC, a company registered in Dubai, United Arab Emirates, with its registered office at Dubai, United Arab Emirates. In these pages "we", "us" and "our" mean Emigeo Homes Real Estate LLC. We are the controller of the personal data described in this policy.

For privacy questions, requests and complaints: supports@homes.me · WhatsApp +971 58 592 3565 · post: Emigeo Homes Real Estate LLC, Dubai, United Arab Emirates.

We process personal data under the UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (PDPL) and its regulations and, for visitors in the European Economic Area, the United Kingdom and Switzerland, under the GDPR, the UK GDPR and the Swiss FADP. Where the Dubai Land Department, the Abu Dhabi Real Estate Centre or a free-zone authority issues rules on advertising and record-keeping, we follow them.

2. What this policy covers

This policy covers personal data: information about an individual from which that person is identified or identifiable. It does not cover anonymised data, from which no one can be identified. Information about projects, prices, payment plans and developers is not personal data and is governed by our Terms of Use. This policy may be published in other languages; if versions differ, the English version prevails.

3. Personal data we collect from you

Identity data: first and last name, and, if you give them, title, nationality and country of residence.
Contact data: phone or WhatsApp number, email address, preferred language and the best time to call.
Request data: the project, price list, brochure, floor plan, availability, call, viewing or consultation you asked for, and the message you wrote.
Preference and search data: budget, city, area, property type, bedrooms, purpose (to live in or to invest), timeline, where you are based, saved and compared projects, recently viewed projects, your last search, currency, language and Plain English setting, and your AI Matchmaker answers (your "Property DNA").
Conversation data: what you type or say to Emir AI, the questions you put to a project, and messages exchanged with us on WhatsApp, email or SMS. Calls with our advisors may be recorded for training and quality; you are told at the start of a recorded call.
Upload data: documents or pictures you give a tool, for example a reservation form or sale and purchase agreement for the Contract Reader or a photo for the photo search, processed only to provide that tool.
Waiting-list data: your email when you ask to be told about a tool that is not live yet.
Feedback data: ratings, survey answers and reviews you choose to give us.

We do not ask for passport, Emirates ID, bank or card details through the Platform and we do not take payments on it; Emir AI is instructed to refuse such details. We do not knowingly collect special categories of data (health, religion, political opinion, biometrics and the like). Please do not send them to us; if you do, we delete them.

If you choose not to give us personal data we cannot answer a request that needs it, for example sending a price list to an email address.

4. Personal data we collect automatically

Technical data: IP address, device and browser type and version, operating system, language, screen size, time zone, and the page you came from.
Usage data: the pages and projects you view, searches and filters, the tools you use, map use, time on a page, scroll depth, clicks on WhatsApp or call buttons, and errors.
Campaign data: UTM parameters, Google and Meta click identifiers, the landing page you arrived on and the advert you clicked.
A visitor identifier stored in a cookie so that your searches, Emir AI conversation and request belong together. Details are in the Cookie Policy.
Approximate location derived from your IP address (country and city level) and, only if you type it, a place you name for a drive-time calculation. We never read your device's location without asking.
Behavioural data: inferences about your interests drawn from your activity on the Platform, for example that you mostly look at beachfront villas in Abu Dhabi, used to order what you see.

5. Personal data we receive from others

Developers, brokers and partners, when you registered with them and they refer you to us, or when they confirm the status of a request we passed to them.
Advertising and analytics providers (Google, Meta, Microsoft Clarity), who tell us which campaign brought you and how the Platform is used, in aggregated or pseudonymous form.
Messaging providers (WhatsApp, our email provider), who deliver your messages to us together with your number or address.
Public sources, for example a company register, when we check a business that contacts us.

6. Aggregated data

We also create aggregated statistics, for example how many visitors used a tool or which areas were searched most in a month ("Demand Pulse"). Aggregated data does not identify you. If we ever combine it with your personal data so that it identifies you again, we treat it as personal data under this policy.

7. Why we use personal data and on what legal basis

Answering your request: sending prices, brochures or floor plans, arranging a call or viewing, handing your request to an advisor or, where you asked, to the developer or broker. Legal basis: performance of a contract or steps taken at your request.
Running the Platform: showing results, remembering preferences, keeping the Platform secure, preventing abuse and fraud, fixing errors and measuring load. Legal basis: our legitimate interest in operating a safe, working service, and legal obligation for security and record-keeping.
Personalising what you see: reordering projects to your Property DNA, "because you viewed", recently viewed, saved and compared projects. Legal basis: consent given through the cookie banner for personalisation that uses tracking, and legitimate interests for settings stored only on your device.
Operating Emir AI and the AI tools: producing answers, checks, comparisons, summaries and extractions from our files and your input. Legal basis: performance of a contract (you asked) and our legitimate interest in improving the files; transcripts are attached to a request with your consent.
Analytics: understanding how the Platform is used and improving it. Legal basis: consent (cookie banner); without consent only cookieless, aggregated counts are collected.
Advertising: showing you our adverts on Google and Meta, measuring them and excluding you from adverts for things you already asked about. Legal basis: consent (cookie banner).
Marketing messages: new launches, alerts, digests and offers by email or WhatsApp. Legal basis: consent, which you can withdraw at any time.
Lead and conversation records: keeping a record of requests, conversations and documents sent for our advisors, for complaints and disputes, and to meet record-keeping duties. Legal basis: legitimate interests and legal obligations.
Quality and training: reviewing conversations and recorded calls to train advisors and improve answers. Legal basis: legitimate interests.
Compliance: responding to lawful requests from authorities, meeting advertising and anti-fraud rules, enforcing our Terms. Legal basis: legal obligation and legitimate interests.

We use personal data only for the purposes we collected it for, or for a compatible purpose. If we need it for something unrelated we update this policy and, where required, ask for your consent.

8. Emir AI and automated tools

When you use the chat, the voice search or a tool, the text you type or say, the page you are on, your recent searches and, for a tool, the document or picture you provide are sent to our AI providers so that an answer can be produced. Our providers are Google (Gemini API) and Anthropic (Claude API). Under the terms we have with them, your data is not used to train their models and is not kept by them beyond what is needed to produce the answer and meet their abuse-monitoring duties.

Emir AI answers from our project files, documents and approved guides only; it is labelled as AI; it gives information, not advice; and it hands over to a human on request or for anything about price, availability, negotiation or a viewing. We log the questions it could not answer, without your identity, so that our team can complete the files.

We do not make decisions about you with legal or similarly significant effects by automated means alone. Match scores, "Emir's pick" and lead scores seen by our advisors are suggestions that a person reviews; you can ignore them and ask for a human at any time.

9. Who receives personal data and why

Our advisors, who reply to you personally, including on WhatsApp, and who see your request, preferences and the conversation that led to it.
Developers and licensed brokers, only when you ask us to register your interest in a specific project or to arrange a viewing, and only the details needed for that. They handle your data under their own policies.
Service providers acting on our instructions: our hosting provider (servers in Frankfurt, Germany); Google (Tag Manager, Analytics, Ads, Sheets for lead records, Gemini API); Meta (Pixel, Conversions API and WhatsApp Business); Microsoft (Clarity session analytics); Mapbox (maps, geocoding and drive times); Web3Forms (email delivery of request notifications); Anthropic (Claude API); our email and SMS providers; and the CRM our advisors use. They may use your data only for the purposes we instruct and must protect it.
Professional advisers: lawyers, accountants, auditors and insurers, when they need limited access to advise us.
Public authorities: where the law requires it, for example the Dubai Land Department, the Abu Dhabi Real Estate Centre, a free-zone authority, the UAE Data Office, a court or the police, on a lawful request.
A buyer or successor of our business, in a merger, sale or reorganisation, who would be bound by this policy.

We do not sell personal data and we do not give it to other advertisers for their own use.

10. International transfers

We are in the United Arab Emirates and our servers are in Germany. Some providers above process data in the United States, the European Union or elsewhere. Whenever personal data leaves the UAE or the EEA we rely on the provider's standard contractual clauses, on an adequacy decision where one exists, and on the safeguards the PDPL allows, and we require the recipient to protect the data to the standard described here.

11. How long we keep personal data

Requests, leads and the conversations attached to them: while we are in contact with you and for up to five years after the last contact, so that we can answer later questions and meet record-keeping duties.
Emir AI transcripts not attached to a request: twelve months.
Uploaded documents and pictures: until the tool has produced its result and for no more than thirty days, or sooner on request.
Waiting-list emails: until the tool launches and you have been told, or until you ask us to remove you.
Recorded calls: ninety days, unless needed for a complaint or dispute.
Analytics and advertising data: according to each provider's retention settings, at most twenty-six months for Google Analytics.
Preferences stored in your browser: until you clear them.
Marketing consent records: for as long as you are subscribed and for three years after you unsubscribe, as proof of your choice.

When data is no longer needed we delete it or anonymise it. Our retention periods are reviewed regularly.

12. Your rights

Depending on where you live, you have the right to:

access your personal data and receive a copy;
correct data that is inaccurate or incomplete;
delete your data where we no longer have a good reason to keep it;
restrict processing in certain circumstances;
object to processing based on legitimate interests, and to direct marketing at any time;
export your data in a structured, machine-readable form;
withdraw consent at any time where we rely on it, without affecting what was done before;
complain to a supervisory authority: the UAE Data Office, or your data-protection authority if you are in the EEA or the UK.

To exercise a right, email supports@homes.me. We may ask you to confirm your identity so that data is not disclosed to the wrong person. We answer within thirty days, and we tell you if a complex request needs longer. We do not charge for these requests unless they are clearly excessive.

13. Marketing communications

We send launches, alerts, digests and offers only if you asked for them. Every email has an unsubscribe link and every WhatsApp message can be stopped by replying STOP. Stopping marketing does not stop replies to a request you made. We do not send marketing to anyone under eighteen.

14. Security

Data travels over HTTPS and is stored on access-controlled servers with daily encrypted backups and a tested restore. Access is limited to staff who need it, under confidentiality duties, and admin access uses strong authentication. Secrets and API keys are never placed in the website code. Uploaded files are scanned and size-limited. We have procedures for suspected data breaches; if a breach is likely to affect you we will tell you and the authority as the law requires.

15. Children

The Platform is for adults and we do not knowingly collect data from anyone under eighteen. If you believe a minor has given us data, tell us at supports@homes.me and we will delete it.

16. Third-party links

The Platform links to developers' sites, WhatsApp, maps, social networks and other services. Clicking those links takes you off the Platform, where their privacy practices apply. We do not control them; read their policies.

17. Changes to this policy

We may update this policy at any time. The effective date at the top shows the current version; material changes are announced on the Platform and, where required by law, by email to the address you gave us. Changes take effect when published.

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