Privacy Policy
Privacy Policy
At Free Room, your privacy is our top priority. We are dedicated to safeguarding your Personal Data (defined below) and want to ensure transparency about how we collect and use this data as you access our website (“Platform”). This policy also informs you about your privacy rights and the protections available under the law.
This Privacy Policy outlines how Free Room collects and processes your Personal Data when you use our Platform.
By using the Platform, you consent to the collection, use, and transfer of your Personal Data as described in this Privacy Policy.
This Privacy Policy covers:
- About Us: Information on who we are and how to reach us.
- Data Collection: The types of Personal Data we collect from you.
- Use of Personal Data: How and why we use your Personal Data.
- Data Sharing: The entities with whom we share your Personal Data.
- Data Security: The measures we take to keep your Personal Data safe.
- Data Retention: How long we retain your Personal Data.
- Your Rights: The rights you have regarding your Personal Data.
- Marketing Communications: Information about how we communicate with you regarding marketing.
- Minors: Our policy concerning the collection of data from minors.
- Policy Changes: Information on how this Privacy Policy may be updated.
We may update this Privacy Policy periodically, with or without notice. Any changes will be reflected on this page.
This Privacy Policy may be available in multiple languages. In case of discrepancies between versions, the English version will take precedence.
What is This Policy?
This Acceptable Use Policy (the “Policy”) outlines the rules that apply when you use or upload content to the platform available at www.freeroom.ae. It also covers your interactions with other users of the Platform, linking to the Platform, or engaging with the Platform in any other manner.
This Policy should be read in conjunction with our Platform Terms of Use, as it forms an integral part of those terms.
Restricted Uses
You may not use the Platform:
- If you are under the age of eighteen (18).
- In any manner that violates applicable local, national, or international law.
- In any unlawful or fraudulent way, or for any unlawful or fraudulent purpose or effect.
- To bully, insult, intimidate, or humiliate any individual.
- To harm any person.
- To send, knowingly receive, upload, download, use, or reuse any material that does not adhere to our Content Standards.
- To transmit any unsolicited or unauthorized advertising or promotional material, or any other form of similar solicitation (“spam”).
Content Standards
These content standards apply to all material you contribute to the Platform (your “User Content”). Compliance with these standards is required both in spirit and in letter. Free Room will determine, at its sole discretion, whether any User Content breaches these standards.
Any User Content must:
- Be accurate (where it states facts).
- Contain opinions that are genuinely held (where relevant).
- Comply with the law applicable in any country from which it is posted and to which the Platform is targeted.
Any User Content must not:
- Be likely to deceive any person.
- Contain illegal content or promote any illegal activity.
- Be defamatory of any person.
- Be obscene, offensive, hateful, or inflammatory.
- Bully, insult, intimidate, or humiliate any individual.
- Encourage, promote, or provide instructions for deliberate self-harm.
- Promote or encourage terrorism.
- Promote sexually explicit material.
- Include child sexual abuse material.
- Incite violence or hatred against specific groups.
- Promote discrimination based on race, sex, religion, nationality, disability, sexual orientation, or age.
- Infringe any copyright, database right, or trademark of any other party.
- Include video content not legally permitted in any country from which it is posted and to which the Platform is targeted.
- Breach any legal duty owed to a third party, such as a contractual duty or duty of confidence.
- Be in contempt of court.
- Invade another person’s privacy.
- Impersonate any person or misrepresent your identity or affiliation with any individual.
- Give the impression that the User Content originates from, or is associated with or endorsed by, Free Room when it is not the case.
- Contain any external advertising or promote services or web links to other sites.
Restricted Items
The Platform allows you to advertise items and services to other users. You must not advertise any item or service on the Platform that is included in our List of Prohibited Items.
Breach of This Policy
If we determine that you are in breach of this Policy, we may take appropriate action at our sole discretion. Failure to comply with this Policy constitutes a breach of our Platform Terms of Use, which detail how you are permitted to use the Platform. This may result in us taking any or all of the following actions:
- Issuing a warning to you.
- Immediate, temporary, or permanent withdrawal of your right to use the Platform (including the closure of your account, if applicable).
- Immediate, temporary, or permanent removal of any User Content found to be in breach.
- Legal proceedings against you for reimbursement of all costs resulting from your breach, or any further legal action against you.
- Disclosure of such information to law enforcement authorities as we reasonably believe is necessary or as required by law.
Who We Are and How to Contact Us
Who We Are
Free Room operates the Platform and is the controller of your Personal Data (referred to as “Free Room,” “we,” “us,” or “our” in this Privacy Policy). Our address is Office C5, Floor 31, Prime Tower, Marasi Street, Business Bay, Dubai, UAE.
How to Contact Us
You can reach us by emailing: info@freeroom.ae or by calling us at +971-04-3230052.
Personal Data We Collect from You
The Personal Data we collect directly from you is detailed in the table below.
“Personal Data” refers to information that can identify an individual directly or indirectly. It does not include ‘anonymized data’ (information where an individual’s identity has been permanently removed). However, it does include ‘pseudonymized data’ (information that does not identify an individual by itself but could do so when combined with additional information).
Aggregated Data
We also collect, use, and share ‘aggregated data,’ such as statistical or demographic data for various purposes. This aggregated data may be derived from your Personal Data but does not reveal your identity. For instance, we may aggregate your Behavioural Data to determine the percentage of users accessing a specific feature. However, if we combine aggregated data with your Personal Data to enable identification, we treat the combined data as Personal Data, which will be handled according to this Privacy Policy.
Special Categories of Personal Data
We do not knowingly collect any ‘special categories of personal data’ about you, including details about race, ethnicity, religious beliefs, political opinions, health information, genetic data, or criminal records. We advise against sharing any such data with us or other users through the Platform. However, if you do choose to share this data, you consent to our processing of it in line with this Privacy Policy.
Below is a table summarizing the legal bases we rely on when processing your Personal Data:
What Happens if You Refuse to Provide Necessary Personal Data?
You are not obligated to provide us with any Personal Data. However, if we require your Personal Data to grant you access to the Platform or comply with applicable laws and you do not provide the requested information, we may be unable to grant you access. For instance, we need your email address to register your account on the Platform.
How We Use Your Personal Data and Why?
We will only use your Personal Data for the purposes for which it was collected, as outlined below unless we reasonably determine that we need to use it for another compatible reason. If we need to use your Personal Data for an unrelated purpose, we will update this Privacy Policy and explain the legal basis that allows us to do so (please see the ‘Changes to this Privacy Policy’ section below).
What is Our ‘Legal Basis’ for Processing Your Personal Data?
Applicable privacy laws require us to have a “legal basis” for processing your Personal Data for each purpose. Most commonly, we rely on one of the following legal bases:
- Contractual Necessity: When we need to process your Personal Data to fulfill our contractual obligations to you (e.g., providing you access to the Platform).
- Compliance with Law: When we need to process your Personal Data to adhere to legal or regulatory requirements.
- Consent: When we have your consent to process your Personal Data for a specific purpose.
Below is a table summarizing the legal bases we rely on when processing your Personal Data:
Who We Share Your Personal Data With
The table below outlines who we may share your Personal Data with and the reasons for sharing it.
We require all recipients of your Personal Data to implement appropriate security measures to protect it adequately, in line with our policies and any applicable data security obligations. We do not allow our third-party service providers to use your Personal Data for their own purposes; they can only process your Personal Data for specified purposes in accordance with our instructions.
Data Transfers
We may transfer your Personal Data to jurisdictions outside your home country that may not offer the same level of data protection. We will ensure that any such cross-border transfers comply with applicable requirements.
How We Keep Your Personal Data Secure
We have implemented appropriate security measures to protect your Personal Data from accidental loss, alteration, unauthorized access, or misuse.
Access to your Personal Data is limited to employees and staff members who need it for business purposes. All individuals with access are bound by a contractual duty of confidentiality.
We have established procedures to address any actual or suspected Personal Data breaches. In the event of such a breach, we have systems in place to minimize any impact on your privacy and to collaborate with relevant regulatory authorities.
How Long We Store Your Personal Data
We will retain your Personal Data only for as long as is necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required by applicable law (e.g., for regulatory reasons).
In some cases, we may anonymize your Personal Data so that it can no longer be linked to you. We may retain this anonymized data indefinitely.
Our data retention policies are reviewed regularly and comply with all applicable requirements.
Your Rights in Relation to Your Personal Data
Under certain circumstances, you may have specific rights regarding your Personal Data. These rights may include:
- Request Access to Your Personal Data: You can request a copy of the Personal Data we hold about you and verify that we are processing it lawfully.
- Request Correction of Your Personal Data: You have the right to ask us to correct any incomplete or inaccurate information we hold about you.
- Request Erasure of Your Personal Data: You may request the deletion or removal of your Personal Data from our systems when there is no valid reason for us to continue processing it.
- Object to the Processing of Your Personal Data: You can object to our processing of your Personal Data for specific purposes (e.g., for marketing).
- Request Transfer of Your Personal Data: You can request that your Personal Data be transferred in a structured, commonly used, machine-readable format, either to you or to a designated third party.
- Withdraw Your Consent: If we rely on your consent to process your Personal Data, you have the right to withdraw it. Please note that withdrawing your consent may limit your access to certain features of our Platform.
Not all of these rights may be available to you, and some may only apply in specific situations.
How to Exercise Your Rights
To exercise any of the rights mentioned above, please contact us.
We may need to request specific information to verify your identity and confirm your right to access your Personal Data or to exercise any other rights. This is a security measure to ensure that your Personal Data is not disclosed to unauthorized individuals. We may also reach out for additional information to expedite our response.
We strive to respond to all legitimate requests within one month of receipt. However, if your request is particularly complex or if you have made multiple requests, it may take longer. In such cases, we will notify you and keep you informed.
While we typically do not charge a fee for exercising your rights, we reserve the right to impose a reasonable fee in certain circumstances (for example, if your request is deemed unreasonable or if you submit an excessive number of requests).
Complaints
If you wish to file a complaint regarding this Privacy Policy or our handling of your Personal Data, please contact us. We will address your complaint as promptly as possible.
If you are not satisfied with our response to your concerns, you may have the right to submit a complaint to the data protection authority in your jurisdiction.
Marketing Communications
You can opt-out of receiving marketing messages at any time by logging into the Platform and adjusting your marketing preferences or by following the “Unsubscribe” link included in any marketing email you receive from us.
Our Policy on Minors
This Platform is not intended for use by minors, and we do not actively monitor the ages of our users.
If you become aware that a minor has used the Platform in violation of this policy, please contact us so we can take appropriate action to remove their Personal Data from our systems.
Changes to This Privacy Policy
Free Room reserves the right to modify this Privacy Policy at any time, with or without prior notice to you.
When updates are made, we will revise this page to reflect the updated Privacy Policy. In certain circumstances, we may also notify you of significant changes (for example, via email).
All changes to this Privacy Policy will take effect immediately upon posting on this page.