Privacy and Cookies Policy
Effective date: 17 November 2019
Your data protection and privacy are our highest priority.
Land Sterling | KSA cares about and respects your privacy and the data you share with us, and want you to understand how we are using and protecting the data we collect about you. We adopt the best practises in compliance with the applicable privacy law and regulations, including the international standards of General Data Protection Regulation (“GDPR”).
The policy set forth below is provided in English to avoid any misinterpretations caused by a language translation.
If necessary, please seek the proper advice or do not use this website.
Land Sterling | KSA (“us”, “we” or “our”) operates the website at landsterling.sa (“Site”). We respect the privacy of each user of this Site (“you”, “your” or “user”), whether you are just beginning your real estate investment and consultancy search or have previously visited this Site.
By using this Site, you accept this Policy and agree to the collection and use of your Personal Data in accordance with this Policy. If you do not agree to this Policy, you cannot use this Site.
Land Sterling | KSA reserves the right to modify this Policy at any time by posting a notice on this Site’s homepage (if we consider it appropriate, then we may also provide additional notice of significant changes).
Your use of this Site after the date of the last modification mentioned at the beginning of this Policy indicates to us that you agree to the changes.
Please be aware that we are not responsible for the privacy practises of those other websites and we expressly disclaim liability for their actions, including actions related to the use and disclosure of Personal Data by those third parties.
LOCATION OF SERVERS
This Site is hosted on servers in Asia. With reference to the country or general location, the Kingdom of Saudi Arabia (“KSA”), wherein this Site is mostly expected to be accessed, then this Site is governed by the KSA law. If you are located outside of the KSA, you adhere to use this Site in accordance with this Policy and the KSA law.
SCOPE OF THIS POLICY
This Policy applies to your use of this Site only.
Accordingly, this Policy does not apply to the Land Sterling | UAE and Land Sterling | UK websites or to their collection, use, storage, and disclosure of your Personal Data (if required or provided).
WHAT DATA DO WE COLLECT?
Land Sterling | KSA may collect information about you from a variety of sources. This includes information we collect directly from you; information we collect when you visit this Site; view our online content or use our mobile applications (if any) or other services; and information we collect about you from other sources.
• Data we collect directly from you
Land Sterling | KSA collects information directly from you when you choose to participate in our offers, enquire about our services and products, register on our online forms, call or email us, or otherwise provide information directly to us. The following are examples of information we may collect directly from you:
- First name
- Last name
- Email address
- Postal address
- Landline or mobile number
- Date of birth
- Demographic information
- Future communication preferences
- Telephone number and recordings when you call our call centre
- Job title or designation
- Employer or company name
- Employer of company address
- Employer or company website
- Work email address
- Work landline or mobile number
• Data we collect when you visit this Site, view our online ads or promotions, or other services
- Internet Protocol (“IP”) address
- The region or general location of a computer or device accessing the internet
- Browser type
- Operating system
- Page view history
- Browsing search history
- Links you click
- Land Sterling | KSA emails you open
- Other usage information
However, to the extent that any cookie can uniquely identify a computer, mobile device, or tablet (“Device”), or the person using that Device, under the GDPR, this is Personal Data. Therefore, this Policy shall apply to such Personal Data collected by us.
In some cases, we may ask you to provide additional professional information such as the size of the company you work for and the industry type.
To enhance and/or update the information that you have provided to us, we may combine it with professional or personal data that we collect from third-party sources.
The Personal Data that we refer to in this Policy is the personal and professional information you provide, as well as the information that we obtain from third-party sources, both of which we typically combine as one user record.
HOW DO WE COLLECT YOUR PERSONAL DATA?
Land Sterling | KSA may collect your Personal Data when you register to receive any of the services, products and/or content offered by us, our Third-Party Sponsors (“Sponsors”) and/or our Strategic Partners (“Partners”), such as reports, publications, subscriptions, contests, offers, newsletters, memberships, premium content, webcasts, video, white papers, online seminars, conferences, and events.
WHAT HAPPENS IF YOU DO NOT PROVIDE YOUR PERSONAL DATA?
In order for Land Sterling | KSA to provide the services, products and/or content you requested, we need your Personal Data. Therefore, if you do not provide such Personal Data, we cannot deliver the services, products and/or content.
HOW DO WE PROTECT YOUR PERSONAL DATA?
Security of your Personal Data
Land Sterling | KSA maintains safeguards, which include technical and organizational security measures to protect your Personal Data from loss, misuse, unauthorized use, access, inadvertent disclosure, alteration, and destruction, and we require the third parties we contract with to support our business operations to employ reasonable security measures as well (please refer to WHEN AND HOW WE SHARE YOUR PERSONAL DATA WITH OTHERS? below).
We update and test safeguards on an ongoing basis and restrict access to your Personal Data to only those who need to know in order to provide our services, products and/or content to you.
Storage of your Personal Data
Land Sterling | KSA may store your Personal Data using our own secure onsite servers or other internally-hosted technology. Your Personal Data may also be stored by third parties via cloud-based services or other technologies.
These third parties do not use or have access to your Personal Data other than for cloud-based storage and retrieval, and we require such parties to employ at least the same level of security that we use to protect your Personal Data (please refer to the aforementioned Security of your Personal Data).
HOW WILL WE USE YOUR PERSONAL DATA?
Land Sterling | KSA uses the Personal Data that we collect to:
• Communicate with you
Land Sterling | KSA may use your Personal Data to send you important notices, such as communications about your registration, transactions and changes to our terms, conditions, policies, and /or other internal purposes.
• Deliver your request
Land Sterling | KSA may use your Personal Data to provide the services, products and/or content that you requested. If you enter a promotion or contest, we may use your Personal Data to administer such activity.
• Improve our service
Land Sterling | KSA may use your Personal Data for auditing, data analysis and research to improve our services, products and/or content.
• Present offers that may be of interest to you
Land Sterling | KSA may contact you to offer you additional or third-party services, products and/or content that may be of interest to you.
THE LEGAL BASIS WE HAVE FOR PROCESSING YOUR PERSONAL DATA
The GDPR requires data collectors to have a legal basis to use the Personal Data of the residents. Therefore, this section shall apply to any such Personal Information collected by us.
Land Sterling | KSA uses the Personal Data that you provide to supply you with high-quality services, products and/or content as you requested, to send important notices, and for internal purposes, such as auditing, data analysis and research to provide you with the information you need to make the most informed technology purchasing decisions.
Land Sterling | KSA may also use your Personal Data to offer you services, products and/or content that may be of interest to you, based upon your interests or the preferences you shared with us, and may share your Personal Data with Sponsors or Partners of services, products, content, reports, publications, subscriptions, contests, offers, newsletters, memberships, premium content, webcasts, video, white papers, online seminars, conferences, and/or events.
The legal basis for processing your Personal Data is your consent. In certain circumstances, we may otherwise process your Personal Data if we have a legitimate interest in doing so and we are not infringing any of your rights and freedoms.
Our legitimate business interests do not override your interests. We will not use your Personal Data in circumstances where your rights and freedoms override our legitimate interests, unless we have your consent or are otherwise required or permitted to by law.
WHEN AND HOW WE SHARE YOUR PERSONAL DATA WITH OTHERS?
services, products and/or content that might interest you, including sponsored content and events, for business operations and to comply with valid legal processes.
• For services, products and/or content that may interest you or that you requested
As aforementioned, your Personal Data may be shared within the network of communications of Land Sterling | KSA to provide you with information about services, products and/or content that might interest you and for internal analytical and business development purposes.
We may also share your Personal Data with third parties to deliver third-party-sponsored services, products and/or content that you requested (please refer to Third-party-sponsored services, products, and/or content below).
• For business operations
Land Sterling | KSA may also share your Personal Data with third parties we have contracted with to support our business operations, including delivery, fulfillment, payment processing, email deployment, suppression list management, and data processing.
• For third-party-sponsored services, products and/or content
Land Sterling | KSA collaborates with Sponsors and Partners to make available a large library of content to our users, such as white papers, professional events (live or online) as well as other services, products and/or offers. In return for access to such content, we may ask you to provide us with your Personal Data as part of the registration.
We reserve the right to share your Personal Data with our Regional Offices, affiliated company/ies, Sponsors, and Partners as permitted by law in order to fulfill our commitment to providing you with a full-service real estate investment and consultancy firm.
We do share your Personal Data under the following circumstances:• Third-party vendors we engage to provide services on our behalf have access to Personal Data, but they have agreed not to disclose the Personal Data or to use it for any purpose other than providing the requested services, products and/or content
• There may arise special circumstances where it is necessary for us to disclose and use Personal Data and Non-Personal Data, such as:
- To protect our property or rights
- To protect the safety of anyone
- To investigate, prevent or take action regarding illegal or improper activities
- To carry out a merger or consolidation with another entity, a sale or transfer of some or all of our assets, or any similar transaction/s
For other reasons we determine in good faith are necessary, appropriate or required by law, such as when we respond to subpoenas, court orders or other legal or administrative process
We may use your Personal Data to send you the services, products and/or content you requested. In addition, your Personal Data may be shared with the sponsor/s or partner/s of the services, products and/or content to communicate with you regarding the services, products, content and other information or offers that may be of interest to you.
Please be aware that we are not responsible for the privacy practices of those other websites and we expressly disclaim any liability for their actions, including actions relating to the use and disclosure of Personal Data by those third parties.
Our hosting service maintains its systems in accordance with reasonable industry standards to reasonably secure the information of its clients against unauthorized access, accidental orientational manipulation, and loss.
However, no data transmission over the internet can be guaranteed to be 100% secure and you use this Site at your own risk.
AS REQUIRED BY LAW
Your Personal Data may be shared when authorized by law or necessary to comply with a valid legal process.
IN THE EVENT OF NEW OWNERSHIP
Land Sterling | KSA may share your Personal Data if the composition of the firm changes in the future:
• We may choose to sell, transfer or merge parts of our business or our assets, or we seek to acquire other businesses or merge with them.
• During such process, we may share your Personal Data with other parties. We will only do this if they agree to keep your Personal Data safe and private. • If the change to our firm happens, then other parties may use your Personal Data in the same way as set out in this Policy.
HOW LONG DO WE KEEP YOUR PERSONAL DATA?
Land Sterling | KSA retains your Personal Data for the duration of your business relationship with us, and we hold your Personal Data only as long as necessary for each purpose we use it, unless we have obtained your consent to use for another or similar purpose.
YOUR RIGHTS AND PREFERENCES
If you inform us that you want your Personal Data deleted or that you no longer wish for us to communicate with you for business or marketing purposes, or to otherwise restrict our processing of your Personal Data, we may retain some basic information in order to avoid sending you unwanted materials in the future and to keep a record of your request and our response.
CONTACTING LAND STERLING | KSA
If you contact us, then we collect Personal Data – including, without limitation, name, address, contact number/s, and email address – which is retained or referred to our Regional Offices and/or “Network of Professionals” (Land Sterling | KSA Network of Professionals, Land Sterling | UAE Network of Professionals and Land Sterling | UK Network of Professionals – our business insignia for all our team members, locally and globally, comprising of the management, employees, surveyors, consultants, valuers, business partners, affiliates, and sales associates), depending on the nature of your enquiry.
If you are looking for a real estate consultant or sales associate, then your Personal Data is referred to our Regional Offices and/or our Network of Professionals. If your enquiry or complaint requires a response from us, then it is referred to the appropriate department for research and a response.
The information we collect is not used in any other way.
Even if you do not send us any Personal Data, we collect information about how you use this Site (“Non-Personal Data”). This information cannot be used to identify you personally and is explained in more detail below.
Like many sites, we obtain Non-Personal Data such as IP addresses, browser types, the name of your ISP (internet service provider), information about where a user comes from before arriving at this Site, what pages a user visits, the order of those pages, and the amount of time spent on each. A vendor may perform this service for us by sending a cookie to gather this information, compile it and report to us.
Use of Non-Personal Data
Land Sterling | KSA uses Non-Personal Data to:
• Customize the marketing content you see
• Improve our services
• Conduct research
• Provide anonymous aggregated reporting for internal audits and third parties
Land Sterling | KSA would like to send you information about our services and products that we think you might be interested in, as well as those of our Regional Offices, Sponsors, Partners, and affiliate company/ies.
If you have agreed to receive marketing, you may always opt out at a later date.
You have the right at any time to stop Land Sterling | KSA from contacting you for marketing purposes or giving your data to our Regional Offices, Network of Professionals, Sponsors, Partners, and affiliate company/ies.
If you no longer wish to be contacted for marketing purposes, please contact us by sending an email to email@example.com.
SOCIAL NETWORKS AND THIRD-PARTY PLUG-INS
CO-BRANDING/COLLABORATIONS WITH CAREFULLY SELECTED PARTNERS
Land Sterling | KSA, from time to time, may collect personal and other information for a co-branding, co-promotion or joint program with a Partner and share your Personal Data with that Partner. For these programs, we will make clear at the point of collection that the Personal Data will be shared with Land Sterling | KSA and the participating Partner and ask for your
WHAT ARE YOUR DATA PROTECTION RIGHTS?
Land Sterling | KSA would like to make sure that you are fully aware of all your data protection rights. Every user is entitled to the following:
• The right to access
You have the right to request Land Sterling | KSA for copies of your Personal Data. We may charge you a small fee for this service.
• The right to rectification
You have the right to request that Land Sterling | KSA corrects any information you believe is inaccurate. You also have the right to request Land Sterling | KSA to complete the information you believe is incomplete.
• The right to erasure
You have the right to request that Land Sterling | KSA erases your Personal Data, under certain conditions.
• The right to restrict processing
You have the right to request that Land Sterling | KSA restricts the processing of your Personal Data, under certain conditions.
• The right to object to processing
You have the right to object to our firm’s processing of your Personal Data, under certain conditions.
• The right to data portability
You have the right to request that Land Sterling | KSA transfers the data that we have collected to another organization, or directly to you, under certain conditions.
If you make a request, we have one (1) month to respond to you. If you would like to exercise any of these rights, please contact us by sending an email to firstname.lastname@example.org.
A website can send its own cookie to your browser if your browser’s preferences allow it, but – to protect your privacy – your browser permits a website to access only the cookies it has already sent to you, not the cookies sent to you by other sites. You can configure your browser to:
– Accept all cookies
– Reject all cookies
– Notify you when a cookie sent (each browser is different, so check the “Help” menu of your browser to learn how to change your cookie preferences)
This Site is not directed to any individual under the age of 13 (“Children”), and we do not knowingly collect any information, including Personal Data, from Children.
If you are a parent or guardian and you are aware that your Children has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from Children without verification of parental consent, we take steps to remove that information from our servers.
THE DATA PROTECTION AND ANTI-CYBER CRIME LAWS IN THE KSA
In general, there is no specific data protection law in KSA. Therefore, in the absence of specific provisions on data protection, the Saudi Arabian courts and adjudicatory bodies will interpret data privacy violations under general Sharīʿah Principles, which are often expressed in general terms and afford courts and adjudicatory bodies considerable discretion. We understand, however, that a new personal data protection law is under review by the Consultative Assembly of Saudi Arabia (“Shura Council”).
Data protection under Sharīʿah Principles
Sharīʿah Principles protect each individual’s right to privacy and prohibit any invasions thereon. Under Shaiah Principles, disclosure of secrets is prohibited except inter alia where the owner of the relevant secret agrees to such disclosure or if the public interest requires so.
The Holy Qu’ran and the Sunnah do not stipulate a penalty for disclosure of secrets. However, as explained above, such disclosure may be punishable by a penalty that a judge, in his discretion, deems appropriate and equitable. Such penalty may include a fine, imprisonment or deprivation of certain rights such as suspension of a practicing license.
Secular regulations passed by the government
There are certain secular regulations passed by the government, which, although not dedicated as a whole to data privacy or protection, contain specific provisions governing the right to privacy and data protection in certain contexts. Specific regulations applicable to the real estate industry in the KSA may be available from the Shura Council.
PRIVACY POLICIES OF OTHER WEBSITES
Land Sterling | KSA keeps this Policy under regular review and shall update this Policy at its sole discretion from time to time.
We will post changes to this Policy and indicate the effective date when this Policy is updated. If we make any material changes to this Policy, we may notify you by email, and by posting notice of the changes on this Site. Changes to this Policy are effective once published on this Site.
You are encouraged to check this Site for changes in the Policy and to stay informed about how your Personal Data is protected by us, and you acknowledge and agree that it is your responsibility to review this Policy periodically and become aware of any modifications.
By using this Site, you signify your acceptance of this Policy as may be modified from time to time. Your continued use of this Site after we make changes is deemed to be acceptance of those changes, as they are binding on you. You are advised not to access this Site if you do not agree with our Policy and practices.
HOW TO CONTACT LAND STERLING | KSA?
If you have any questions about this Policy, the Personal Data we hold on you, or you would like to exercise one of your data protection rights, please do not hesitate to contact us by sending an email to email@example.com.