Whitewill · Oman

Policy on Processing Personal Data and Cookies

quiz-oman.om.estate

Terms and their definitions

Policy — this personal data and cookie processing policy, published online at: quiz-oman.om.estate/cookie.

We, Us, Our, and the Operator — Whitewill Real Estate SPC, License No. 1582266, address: Beach Commercial Complex, 2nd floor, Office 212, Way 3003 Shatti Al Qurum, Muscat, Oman, e-mail: oman@whitewill.ae.

Your and the Personal Data Subject — our counterparty under the User Agreement, which may be an individual who uses the Website in accordance with the procedure and on the terms set forth in the Agreement.

User Agreement — the offer regulating the procedure for the use of the Website by Users, published at: quiz-oman.om.estate/user-agreement.

Personal Data — any information relating to an identified or identifiable natural person. An identifiable person is one who can be identified directly or indirectly, in particular by reference to identifiers such as a name, identification number, location data, online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

Processing of Personal Data — any operation or set of operations performed with or without the use of automation tools on personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data. Personal data processing is carried out through mixed (including automated) processing.

Automated Processing of Personal Data — processing of personal data using computer technology.

Confidentiality of Personal Data — a mandatory requirement for Us or for another person who has obtained access to Personal Data not to disclose such data without the consent of the Personal Data Subject or without other legal grounds.

Anonymization of Personal Data — actions that result in it being impossible, without additional information, to determine whether personal data belongs to a specific personal data subject.

Website — Our website quiz-oman.om.estate.

Cookies — a small text file placed by the Website on your computer or device when you visit certain sections of the Website and/or when you use certain features of the Website.

GDPR or Regulation — the General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, repealing Directive 95/46/EC, as amended and incorporated into the national legislation of the Member States.

California Online Privacy Protection Act or CalOPPA — the California Online Privacy Protection Act.

California Consumer Privacy Act or CCPA — the first comprehensive privacy law in the United States, adopted in late June 2018, which provides various privacy rights to California consumers.

US Privacy Act 1974 or UPA — the law regulating the processing of personal information of U.S. citizens or persons with permanent residence in the U.S.

PECR — the Privacy and Electronic Communications (EC Directive) Regulations 2003.

Oman Data Protection and Privacy Laws — all and any laws and regulations governing the Processing of Personal Data in the Sultanate of Oman, including but not limited to the Personal Data Protection Law promulgated by Royal Decree No. 6/2022, and the regulations and policies adopted by the competent authorities of Oman regarding the protection of personal data and telecommunications consumer data.

Subject and Legal Basis of Processing of Personal Data

Subject of the Policy. The provisions of this Policy apply to the relationship between Us and You related to the Processing of personal data within the framework of the relationship arising between Us on the use of the Site, formed as a result of Your acceptance of the terms of the User Agreement.

Legal Basis for Processing. The legal basis for Processing Your Personal Data is always Your consent. Without Your consent to the terms of this Policy, We will not be able to fully perform our obligations under the agreements concluded with You (including, but not limited to, the User Agreement).

Acceptance of the Policy Terms

In this section, You can learn about the actions that indicate Your consent to the Processing of Your Personal Data (hereinafter — "Consent to Data Processing").

Content of Consent to Data Processing. By providing Consent to Data Processing, You confirm that You have fully read and agree with the User Agreement, Personal Data and Cookie Processing Policy, and that You provide specific, informed, conscious, and unambiguous consent to the Processing of Your Personal Data. Please note that Consent to Data Processing means, among other things, that You also agree to both Automated and non-automated Processing of Your Personal Data, under the terms set forth in this Policy as well as in the Consent to Data Processing.

Requesting a callback. If You request a callback using the relevant functionality of the Website, You are considered to have provided Consent to Data Processing at the moment of clicking the "Request a Call" button (or an equivalent).

Making an outgoing call. By calling the Operator and continuing the conversation with an Operator's employee, You provide Consent to Data Processing.

Messenger messaging. If You send Us a message via a messenger, including by using the relevant functionality of the Website, Your Consent to Data Processing is considered provided at the moment You send the first message to Us.

Familiarizing yourself with the content of the Site. If You are simply browsing the Site, You are deemed to have given Us Consent to the processing of Personal Data to the extent set out in this Policy (technical data, Cookies), unless a different consent procedure in relation to the processing of Cookies is implemented on the Site.

Storage of consent information. Please note that We may store information about Your actions (by means of logging systems or equivalent) confirming Your Consent to Data Processing, as specified in this section of the Policy, for three (3) years after You express such consent, unless a different period is provided by law.

Term of the Policy and Processing of Personal Data

Term of the Policy. Once You accept the terms of this Policy, it remains valid indefinitely. However, this does not affect the term of Processing Your Personal Data — it is determined by this Policy.

Term of Processing of Personal Data. As a general rule, We process Your Personal Data until the moment We respond to Your inquiry, and for three (3) years thereafter, unless another retention period is established by applicable law, the User Agreement, or any other contract related to the use of the Website or the Processing of Your Personal Data, to which You are a party. In other cases, We will cease Processing Your Personal Data if You object to such Processing or if You withdraw Your previously given consent to Processing, in accordance with the terms of this Policy and applicable law. However, in such cases, We may be unable to fulfil our obligations under contracts with You.

Amendments. We may amend this Policy at any time. Such changes may be related to modifications of Our business processes, external factors, or other reasons. After making amendments, We immediately publish the updated Policy on the Website so that You can review it in its new version. If You continue using the Website after the Policy has been amended, We will consider this as Your unconditional acceptance of the Policy in its updated version.

Grounds, Purposes, and Principles of the Policy

Grounds. This Policy has been developed in compliance with the requirements of: (a) GDPR; (b) CalOPPA; (c) CCPA; (d) PECR; (e) Federal Law No. 152-FZ; (f) Oman Data Protection and Privacy Laws; and (g) other laws and regulations that determine the cases and specifics of processing Personal Data of the Data Subject.

Purposes. The Policy pursues the following purposes: (1) ensuring the protection of human and civil rights and freedoms in the Processing of Personal Data, including the right to privacy, personal and family confidentiality; (2) preventing unauthorized actions (unlawful or accidental access) by third parties to Your Personal Data, as well as its destruction, alteration, blocking, copying, or distribution; (3) ensuring a legal and regulatory regime of confidentiality and control over Your Personal Data; (4) protecting the rights of Personal Data Subjects to privacy and preventing possible threats to Your security.

The main purpose of this Policy is to provide You with a complete and transparent understanding of: the legal basis for the collection and Processing of Your Personal Data; the categories of Personal Data that We may collect about You; what happens with the Personal Data We collect; where We process Your Personal Data; how long We store Your Personal Data; to whom We may transfer Your Personal Data; and to explain Your rights as a Personal Data Subject.

Principles. We adhere to the following principles when Processing Personal Data: (1) processing of Personal Data must be lawful and fair; (2) processing of Personal Data must be limited to achieving specific, pre-defined, and legitimate purposes; Processing that is incompatible with the purposes of data collection is not allowed; (3) the content and scope of the processed Personal Data must correspond to the stated purposes of Processing; Personal Data must not be stored longer than necessary for the purposes of Processing, unless another retention period is established by this Policy.

Composition of Collected Personal Data

Requesting a callback. You may request a callback from Us. To do this, You need to provide the following data by entering it into a special form on our Website: a mobile phone number and a Name. Please note that by providing third-party data, You undertake to comply with the guarantees specified in this Policy. Also keep in mind that You may enter any Name, including one that does not correspond to Your real Name. However, such a Name must comply with ethical and moral standards.

Messenger data. Our Website allows You to contact Us via WhatsApp, Telegram, or other messengers (if available). The Website contains special URLs, and when following such a link, You will be able to send Us a message in the selected messenger. By sending such a message, We will receive data about the address of Your account in the relevant messenger, as well as other data specified in that account and made publicly available.

Technical data. When using the Website, We automatically collect certain Personal Data. Such data may include, for example, the Internet Protocol (IP) address used to connect Your computer to the Internet, login data, browser type and version, time zone settings, types and versions of browser plug-ins, operating system and platform, and information about Your visits to websites.

Other data. In exceptional cases, We may request that You provide additional Personal Data. We will always notify You in advance and request Your additional consent for Processing.

Personal Data of third parties. Please note that if You provide Us with Personal Data of third parties, You guarantee that You have obtained all necessary consents from such persons, including consent to the transfer of Personal Data, and other documents required to ensure full compliance with this Policy, executed in accordance with their applicable law (Third-Party Consent). If You act as an operator of such Personal Data, You also guarantee that You ensure the transfer and protection of their Personal Data at a level no less than that provided by this Policy. Third-Party Consent must be executed in writing, and the original must be provided by You within seven (7) calendar days from the date of the Operator's request. Providing third-party Personal Data without such guarantees is not permitted, and You assume full responsibility for any breach of this guarantee.

Rights of the Personal Data Subject

Obtaining information. You have the right to receive information about Us, about Our location, and about whether We hold Your Personal Data, as well as to review such Personal Data.

Clarification. You have the right to request that We clarify, block, or delete Your Personal Data if it is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of Processing, and to take measures provided by law to protect Your rights.

Form of provision. Information about the presence of Your Personal Data will be provided to You in an accessible form, and will not contain Personal Data relating to other Personal Data Subjects.

Procedure for access. You (or Your legal representative) may obtain access to Your Personal Data in person or by submitting a written request. The request must contain the number of the main identity document of You or Your representative, the date of issue of the document, the issuing authority, and a handwritten signature. The request may also be submitted electronically. We are obliged to respond to Your request within thirty (30) days of receipt, which may be extended to sixty (60) days depending on the complexity and number of requests.

Content of Response. In a request for access to Personal Data, You have the right to demand from Us information related to the Processing of Your Personal Data, including: (1) confirmation of the fact of Processing of Personal Data and the purpose of such Processing; (2) methods of Processing; (3) the name and location of the Operator; information about persons who have access to Personal Data or to whom such access may be provided; (4) the list of processed Personal Data and the source of its receipt; (5) the duration of Processing, including the period of storage; (6) information about the legal consequences for the Personal Data Subject that may result from the Processing of their Personal Data.

Withdrawal of consent. You have the right to withdraw Your consent to the Processing of Personal Data, to limit the methods and forms of Processing, and to prohibit the distribution of Personal Data without Your consent.

Right to appeal. You have the right to appeal Our actions or inaction to the authorized body for the protection of the rights of Personal Data Subjects or in court.

Right to protection. You have the right to the protection of Your rights and lawful interests, including compensation for damages and moral harm, through the courts.

Rights of the Data Subject (GDPR)

If You are a citizen of a Member State of the European Economic Area or the United Kingdom (or lawfully provide Us with the Personal Data of such a person), You are also granted the rights listed below. You may exercise them by sending an email to Our contact details.

Right to be informed (Articles 12–14 of the Regulation). You have the right to receive information about the collection and use of Your Personal Data, in particular about the purposes of Processing, retention periods, and to whom the data will be transferred.

Right of access (Article 15 of the Regulation). You have the right to obtain confirmation from the Operator as to whether Your Personal Data is being processed, and if so, access to the Personal Data and related information, including a copy of the Personal Data undergoing Processing.

Right to rectification (Article 16 of the Regulation). You have the right to have inaccurate or incorrect Personal Data corrected upon request, made either orally or in writing. The Operator has one calendar month to respond to such a request.

Right to erasure ("right to be forgotten") (Article 17 of the Regulation). You may request deletion by contacting Our Data Protection Officer, who has one month to respond to Your request. Please note that this right is not absolute and applies only in specific circumstances provided for in Article 17 of the Regulation.

Right to restrict Processing (Article 18 of the Regulation). You have the right to request the restriction or suspension of the Processing of Your Personal Data. Please note that this right is not absolute and applies only in specific circumstances provided for in Article 18 of the Regulation.

Right to data portability (Article 20 of the Regulation). This right allows You to receive and reuse Your Personal Data for Your own purposes across different services, including requesting the direct transmission of Personal Data from one Operator to another, where technically feasible.

Right to object (Article 21 of the Regulation). You have the right to object at any time to the Processing of Your Personal Data on grounds relating to Your particular situation, including where Your Personal Data is processed for direct marketing purposes.

Rights related to automated decision-making, including profiling (Article 22 of the Regulation). You have the right not to be subject to a decision based solely on automated processing, including profiling, that produces legal consequences in relation to You or significantly affects You. You may withdraw Your consent to the Processing of Personal Data at any time; withdrawal extends only to the future.

Transmission of Personal Data

Transfer of Personal Data. In order to achieve the purposes of the Personal Data Processing, We may need to share Your Personal Data with Our counterparties, including but not limited to AmoCRM, TIN: 7709477879, OGRN: 5157746087681. Your Personal Data may also be shared with public authorities, in particular executive authorities, based on their request.

Mandatory and optional transfers. The transfer of information may be mandatory, e.g. in terms of information about user equipment: IP address, OS, geographical data, ID/type of equipment, channel used: browser/application, payment authorization, identification/verification, or optional, e.g. in terms of information about address match indicators, account information, etc.

Storage of Personal Data

Localization of Personal Data. If You are a citizen of the Russian Federation, We store Your data on servers located in the Russian Federation. If You are a citizen of a member state of the European Economic Area, the United Kingdom, or another country whose personal data laws require Personal Data to be Processed in such country, Your Personal Data is collected and Processed in the European Economic Area or such country, respectively.

Personal Data Protection Principles and Measures

Defense Principles. We employ legal, organizational, administrative, technical, and physical measures to ensure the protection of Your Personal Data.

Security Measures. Measures to ensure the security of Personal Data during its processing are planned and implemented to ensure compliance with the requirements of Personal Data legislation. We ensure the security of Your Personal Data by, among other things: (1) limiting and specifying the number of the Operator's employees who have access to Personal Data, (2) appointing a person responsible for organizing the processing of Personal Data, (3) developing and implementing local regulations on the processing of Personal Data, (4) identifying threats to the security of Personal Data during their processing in the Operator's information systems, (5) applying organizational and technical measures to ensure the security of Personal Data.

Cookies

Use of Cookies. The Site uses cookies. When You visit the Site, Your Internet browser transmits certain information to Our server: (1) date and time of visit, (2) browser type, (3) language settings, (4) operating system. This information is stored in connection logs for a limited period of time (from a session to a year) to ensure the security and proper operation of the Site and to gather statistical information.

Functions of Cookies. There are different groups of Cookies used on the Site. The first group is functional and technical Cookies — they allow the server of the Site to obtain information about Your session, language used, browser, etc., and to ensure the full operation of the Site. These files are necessary to recognize You when You access the Site again, allowing Us to personalize the content of the Site to Your needs and remember Your preferences. The second group is analytical Cookies — they allow Us to evaluate and count the number of visitors and understand how they move around the Site as they interact with it, helping Us to improve the Site. You have the right to refuse the use of analytics cookies by making the appropriate settings in Your web browser.

Cookies storage time. Cookies are categorized into Persistent Cookies and Session Cookies based on how long they are stored on Your device: "Session Cookies" are stored on Your device until You close Your browser. "Persistent Cookies" are stored on Your device until they expire or until You delete them.

Disabling Cookies. You have the option to accept or reject all cookies on all sites You visit by changing the settings in Your web browser. Please note that certain functionality of the Site may not be available if You disable Cookies. To learn more about how to adjust or change Your browser settings, please refer to Your browser's instructions or at www.aboutcookies.org or www.allaboutcookies.org. If You use different devices to access the Site (e.g. smartphone, tablet, computer, etc.), You should ensure that each browser on each device is configured according to Your cookie preferences.

Addresses for exchanging legally relevant messages

Details of the Parties. In the course of performing obligations under this Policy and/or other obligations as a Personal Data Operator, there may be an exchange of legally significant communications between Us. Such exchange shall take place through official contacts of the Parties, either in writing or electronically. Our details are provided in the Official Notice below, and Your details are provided by You at the time of leaving a callback request, by messenger message or other communication channels. Please be aware that You bear all risks that Your data for legally relevant messaging is no longer relevant.

Correspondence exchange. Correspondence may only be exchanged using the Parties' data as defined in accordance with the rules of this Policy.

Final Provisions

Divisibility clause. In case one or more of the provisions of the Policy are held to be invalid or irreconcilable, such provisions shall be deemed to be replaced by valid provisions as near as possible. However, the Policy shall not be held invalid in its entirety under any circumstances.

Whitewill Real Estate SPC

License No. 1582266

Address: Beach Commercial Complex, 2nd floor, Office 212, Way 3003 Shatti Al Qurum, Muscat, Oman

E-mail: oman@whitewill.ae

Email (Personal Data questions): privacy@whitewill.ae

THE CONTACTS LISTED ARE THE ONLY OFFICIAL SOURCES OF CONTACT WITH US. PLEASE PAY ATTENTION!

Document reference: quiz-oman.om.estate/cookie

The Policy is published in free access on the Operator's Website.

All information provided on the website is not a public offer
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Personal data processing policy
Privacy Policy
By sending a message via messengers, I confirm that I give specific, informed, conscious, and unambiguous consent to the processing of my personal data and that I have fully read and agree to the User Agreement, the User Agreement, the Personal Data Processing Policy, and the Cookie Policy.
Whitewill Real Estate SPC is a company registered in Oman, licensed to operate in real estate brokerage. License Nr. 1582266
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