Privacy Policy

Last Updated: January 2025

1. Introduction

Welcome to 360PropertyVA (“we,” “our,” or “us”). We are committed to protecting your personal data and respecting your privacy rights. This Privacy Policy explains how we collect, use, store, and protect your personal information when you use our website and services.

360PropertyVA is part of the 360 Group and operates globally with operations in the United Kingdom and United Arab Emirates. We comply with applicable data protection laws in all jurisdictions where we operate, including:

UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018
UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data
Dubai International Finance Centre (DIFC) Data Protection Law (as applicable)
Abu Dhabi Global Market (ADGM) Data Protection Regulations (as applicable)

2. Information We Collect

2.1 Information You Provide to Us

We collect personal data that you voluntarily provide when you:

Fill out contact forms or request a discovery call
Subscribe to our newsletter or communications
Apply for VA services or employment
Communicate with us via email, phone, or chat
Use our services or engage with our VAs
Enter into service agreements

This information may include:

Full name
Email address
Phone number
Business name and size
Type of property business
Service requirements
Billing and payment information
Employment history (for VA applicants)
Identity verification documents (as required by local law)
Any other information you choose to provide

2.2 Information We Collect Automatically

When you visit our website, we automatically collect:

IP address
Browser type and version
Device information
Operating system
Pages visited and time spent on pages
Referring website addresses
Geographic location data
Date and time of access
Cookies and similar tracking technologies (see Section 8)

2.3 Third-Party Information

We may receive information about you from:

Analytics providers (e.g., Google Analytics)
Advertising networks (e.g., Google Ads, Meta Ads)
Social media platforms
Payment processors
Background check providers (for VA recruitment)
Property management platforms and partners
Credit reference agencies (where applicable)

3. How We Use Your Information

We use your personal data for the following purposes:

3.1 Service Delivery

To provide virtual assistant services
To match you with suitable VAs
To facilitate onboarding and training
To manage service delivery and reporting
To process payments and invoicing
To maintain service quality and performance

3.2 Communication

To respond to your inquiries and requests
To send service updates and confirmations
To provide customer support
To send marketing communications (with your consent)
To conduct satisfaction surveys
To send important account notifications

3.3 Business Operations

To improve our website and services
To conduct business analysis and reporting
To comply with legal and regulatory obligations
To protect against fraud, security threats, and abuse
To enforce our terms and conditions
To manage corporate transactions (mergers, acquisitions)
To maintain business records and archives

3.4 Marketing

To send promotional materials about our services
To display targeted advertising
To measure advertising effectiveness
To personalise your experience
To conduct market research

3.5 Legal and Compliance

To verify identity and prevent fraud
To comply with anti-money laundering requirements
To respond to legal processes and government requests
To establish, exercise, or defend legal claims
To comply with tax and accounting obligations

Legal Basis (UK GDPR):

Consent: When you opt-in to marketing communications
Contract: When necessary to provide our services
Legitimate Interests: For business operations, improvements, and fraud prevention
Legal Obligation: To comply with UK and international laws

Legal Basis (UAE): We process personal data in accordance with UAE Federal Law No. 45 of 2021, which permits processing for:

Fulfilling contractual obligations
Protecting vital interests
Legitimate business purposes
Legal compliance
Consent (where required)

4. How We Share Your Information

We may share your personal data with:

4.1 Service Providers

Virtual assistants assigned to your account
Cloud hosting and storage providers (AWS, Microsoft Azure, Google Cloud)
Email and communication platforms
Payment processors (Stripe, PayPal, local payment gateways)
CRM and analytics tools
IT support and security providers
Accounting and professional service firms

4.2 Business Partners

Companies within the 360 Group ecosystem
Property management software providers
Platform partners (with your consent)
Channel partners and resellers

4.3 Legal Requirements

Law enforcement or regulatory authorities when legally required (UK, UAE, or other jurisdictions)
Courts and legal advisors in connection with legal proceedings
Tax authorities and government agencies
Third parties in connection with business transfers or restructuring
Professional advisors (lawyers, auditors, insurers)

4.4 Marketing Partners

Google Ads and advertising networks
Social media platforms (LinkedIn, Facebook, Instagram)
Analytics providers
Email marketing platforms

4.5 Geographic Sharing

Data may be shared between our UK and UAE operations for:

Service delivery and coordination
Customer support
Business reporting and analytics
System administration

We ensure all third parties are contractually bound to protect your data and use it only for specified purposes in compliance with applicable data protection laws.

5. International Data Transfers

Your personal data may be transferred to and processed in countries outside the UK and UAE, including:

United Kingdom
United Arab Emirates
European Economic Area (EEA)
United States
Other countries where our service providers operate

5.1 Safeguards for UK Transfers

When transferring data from the UK, we ensure appropriate safeguards:

Standard Contractual Clauses approved by the UK ICO
Adequacy decisions recognising equivalent data protection
Binding Corporate Rules for intra-group transfers
International Data Transfer Agreements (IDTAs)

5.2 Safeguards for UAE Transfers

When transferring data from the UAE, we comply with:

UAE Federal Law No. 45 of 2021 requirements for cross-border transfers
Approved mechanisms for international data transfers
Contractual safeguards ensuring equivalent data protection
Regulatory approvals where required

5.3 UK-UAE Data Flows

Data transferred between our UK and UAE operations is protected by:

Intra-group data transfer agreements
Equivalent privacy and security standards
Regular compliance audits

6. Data Retention

We retain your personal data only for as long as necessary:

UK Retention Periods:

Active clients: Duration of service plus 7 years for financial records (UK tax law)
Prospective clients: 2 years from last contact (unless you request deletion)
Marketing data: Until you withdraw consent or request deletion
Employment records: 7 years after employment ends
Legal obligations: As required by UK law

UAE Retention Periods:

Active clients: Duration of service plus 5 years for commercial records (UAE Commercial Companies Law)
Financial records: As required by UAE Federal Tax Authority
Prospective clients: 2 years from last contact (unless you request deletion)
Marketing data: Until you withdraw consent or request deletion
Legal obligations: As required by UAE law

After retention periods expire, we securely delete or anonymise your data in accordance with industry standards and legal requirements.

7. Your Data Protection Rights

7.1 Rights Under UK GDPR

If you are based in the UK or your data is processed under UK law, you have the following rights:

Right of Access: Request a copy of the personal data we hold about you

Right to Rectification: Request correction of inaccurate or incomplete data

Right to Erasure: Request deletion of your personal data (subject to legal obligations)

Right to Restriction: Request limitation on how we process your data

Right to Data Portability: Receive your data in a structured, machine-readable format

Right to Object: Object to processing based on legitimate interests or for marketing purposes

Right to Withdraw Consent: Withdraw consent at any time (without affecting prior processing)

Right to Complain: Lodge a complaint with the Information Commissioner’s Office (ICO):

Website: ico.org.uk
Helpline: 0303 123 1113
Address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

7.2 Rights Under UAE Law

If you are based in the UAE or your data is processed under UAE law, you have the following rights under Federal Law No. 45 of 2021:

Right of Access: Request information about your personal data being processed

Right to Rectification: Request correction of inaccurate personal data

Right to Erasure: Request deletion of your data (subject to legal exceptions)

Right to Restrict Processing: Request limitation on data processing

Right to Data Portability: Receive your data in a transferable format (where technically feasible)

Right to Object: Object to processing for direct marketing or legitimate interests

Right to Withdraw Consent: Withdraw consent at any time

Right to Complain: File a complaint with the UAE Data Office or relevant regulatory authority:

UAE Data Office: dataoffice.gov.ae

7.3 Exercising Your Rights

We will respond to your request within:

UK: 30 days (extendable by 2 months for complex requests)
UAE: 30 days as required by law

8. Cookies and Tracking Technologies

Our website uses cookies and similar technologies to:

Enable website functionality
Analyse website traffic and user behaviour
Deliver personalised advertising
Remember your preferences
Ensure security and prevent fraud

8.1 Types of Cookies We Use

Essential Cookies: Required for website functionality (always active)

Analytics Cookies: Help us understand how visitors use our site (Google Analytics, Hotjar)

Marketing Cookies: Used to deliver relevant ads and track campaign performance (Google Ads, Facebook Pixel, LinkedIn Insight Tag)

Functional Cookies: Remember your preferences and settings

Performance Cookies: Collect information about how you use our website

8.2 Cookie Duration

Session Cookies: Deleted when you close your browser
Persistent Cookies: Remain on your device for a set period or until deleted

8.3 Managing Cookies

You can control cookies through:

Our cookie consent banner (displayed on first visit)
Your browser settings (see browser help for instructions)
Third-party opt-out tools:
- Google Ads Settings: adssettings.google.com
- Network Advertising Initiative: networkadvertising.org/choices
- Your Online Choices (EU): youronlinechoices.eu
- Digital Advertising Alliance: optout.aboutads.info

Note: Disabling cookies may affect website functionality and your user experience.

For more details, see our Cookie Policy.

9. Google Ads and Advertising

We use Google Ads and other advertising platforms to promote our services across UK, UAE, and international markets.

9.1 Data Collection for Advertising

Conversion tracking via cookies and pixels
Remarketing to previous website visitors
Audience targeting based on demographics, interests, and behaviour
Performance measurement and campaign optimisation
Cross-device tracking
Custom audience creation

9.2 Advertising Platforms We Use

Google Ads (Search, Display, YouTube)
Meta Ads (Facebook, Instagram)
LinkedIn Ads
Twitter/X Ads
Regional advertising networks

9.3 Your Advertising Choices

Opt-out of Personalised Advertising:

Google: Visit adssettings.google.com
Facebook: Visit facebook.com/ads/preferences
LinkedIn: Visit linkedin.com/psettings/advertising
General opt-out: Visit youronlinechoices.eu or networkadvertising.org

Mobile Device Settings:

iOS: Settings > Privacy > Advertising > Limit Ad Tracking
Android: Settings > Google > Ads > Opt out of Ads Personalization

9.4 Advertising Compliance

Our advertising practices comply with:

UK GDPR and Data Protection Act 2018
UK ePrivacy Directive (Cookie Law)
PECR (Privacy and Electronic Communications Regulations)
UAE Federal Law No. 45 of 2021
Google Ads Policies
Meta Advertising Policies
Industry self-regulatory codes (ASA, CAP)

10. Data Security

We implement comprehensive technical and organisational measures to protect your data:

10.1 Technical Measures

SSL/TLS encryption (256-bit) for all data transmission
AES-256 encryption for data at rest
Secure authentication and access controls
Multi-factor authentication (MFA) for sensitive systems
Regular security audits and penetration testing
Intrusion detection and prevention systems
Secure backup and disaster recovery procedures
Regular software updates and patch management

10.2 Organisational Measures

Staff training on data protection and security
Confidentiality agreements with all employees and contractors
Role-based access controls (principle of least privilege)
Regular privacy impact assessments
Incident response and breach notification procedures
Vendor security assessments
Physical security at office locations
Data protection by design and by default

10.3 Security Certifications

We maintain industry-standard security certifications including:

ISO 27001 (Information Security Management) [if applicable]
SOC 2 Type II compliance [if applicable]
Cyber Essentials [if applicable]

Important Notice: While we implement robust security measures, no internet transmission or electronic storage is 100% secure. We cannot guarantee absolute security but commit to taking all reasonable and legally required steps to protect your personal data.

11. Children’s Privacy

Our services are not intended for individuals under 18 years of age. We do not knowingly collect personal data from children.

If you believe we have inadvertently collected data from a minor, please contact us immediately:

UK: [Insert UK Email]
UAE: [Insert UAE Email]

We will promptly investigate and delete such information in compliance with applicable child protection laws.

12. Third-Party Websites and Services

Our website may contain links to third-party websites, plugins, and applications. We are not responsible for the privacy practices of external sites or services.

Third-party services we integrate with may include:

Social media platforms (LinkedIn, Facebook, Instagram, Twitter)
Payment processors
Property management systems
Video conferencing tools (Zoom, Microsoft Teams)
Cloud storage services

Please review the privacy policies of third-party services before providing personal information.

13. Automated Decision-Making and Profiling

We may use automated processing for:

Initial VA-client matching (subject to human review)
Basic customer service inquiries (chatbots)
Fraud detection and prevention
Website personalisation

Important: No significant decisions affecting you are made solely by automated means without human oversight. You have the right to request human review of automated decisions.

14. Data Breach Notification

In the event of a personal data breach that poses a risk to your rights and freedoms:

UK Obligations:

We will notify the ICO within 72 hours
We will notify affected individuals without undue delay if high risk

UAE Obligations:

We will notify the UAE Data Office within required timeframes
We will notify affected individuals as required by law

What we will tell you:

Nature of the breach
Likely consequences
Measures taken to address the breach
Contact point for further information
Recommended steps you should take

15. Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect:

Changes in our practices
Legal or regulatory requirements
Technology developments
Business operational changes

15.1 Notification of Changes

We will notify you of significant changes via:

Prominent website banner notification
Email notification (for registered users and clients)
Updated “Last Updated” date at the top of this policy
Social media announcements (for material changes)

15.2 Review and Acceptance

We encourage you to review this Privacy Policy regularly. Your continued use of our services after changes constitutes acceptance of the updated policy.

For material changes affecting your rights, we may require explicit consent before the changes take effect.

16. Contact Us

For questions, concerns, or to exercise your data protection rights:

16.1 UK Data Protection Contact

360PropertyVA (UK) – Data Protection Team

Email: support@360propertyva.com

Phone: +971 585 660 360

Address: Office 207, A5, Dubai South Business Park, Dubai, 282228, UAE

16.2 UAE Data Protection Contact

360PropertyVA (UAE) – Data Protection Team Email: [Insert UAE Email] Phone: [Insert UAE Phone Number] Address: [Insert Full UAE Address]

16.3 Response Time

We aim to respond to all inquiries within:

UK: 30 days (may extend to 90 days for complex requests)
UAE: 30 days as required by law

17. Supervisory Authorities

17.1 UK Supervisory Authority

Information Commissioner’s Office (ICO)

Website: ico.org.uk
Helpline: 0303 123 1113
Email: casework@ico.org.uk
Address: Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, United Kingdom

17.2 UAE Supervisory Authority

UAE Data Office

Website: dataoffice.gov.ae

17.3 DIFC Supervisory Authority (if applicable)

DIFC Commissioner of Data Protection

Website: difc.ae
Email: dataprotection@difc.ae

17.4 ADGM Supervisory Authority (if applicable)

ADGM Registration Authority

Website: adgm.com
Email: registration@adgm.com

18. Additional Information for California Residents

While primarily UK and UAE-based, if you are a California resident, you may have additional rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA).

CCPA Rights include:

Right to know what personal information is collected
Right to delete personal information
Right to opt-out of sale of personal information
Right to non-discrimination

Note: We do not sell personal information.

19. Additional Information for EEA Residents

If you are located in the European Economic Area, you benefit from GDPR protections. Our UK GDPR compliance measures apply equally to EEA residents.

20. Consent Statement

By using our website and services, you acknowledge that you have:

Read and understood this Privacy Policy
Understood how your personal data will be collected, used, and shared
Consented to the processing described herein (where consent is the legal basis)

For marketing communications:

You can opt-in via checkboxes on forms
You can unsubscribe at any time via:
- Unsubscribe links in our emails
- Account settings (for registered users)
- Contacting us directly
- Preference centre

For cookies:

You can manage preferences via our cookie banner
You can change settings at any time

21. Language and Interpretation

This Privacy Policy is provided in English. In case of any translation, the English version shall prevail.

22. Governing Law and Jurisdiction

UK Operations: This Privacy Policy and any disputes relating to it shall be governed by the laws of England and Wales. Disputes shall be subject to the exclusive jurisdiction of the courts of England and Wales.

UAE Operations: This Privacy Policy and any disputes relating to it shall be governed by the laws of the United Arab Emirates. For entities in DIFC or ADGM, their respective laws and courts shall apply.

Effective Date:15.01.26

Version: 1.0

Part of the 360 Group ecosystem | UK & UAE Operations