Privacy Policy

Here is the translated version in English, preserving all formatting, structure, and context without altering the content:

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title: "Privacy Policy" description: "Privacy Policy of Ghanem Al-Oula for Information Technology and the Ghanem Real Estate Platform" lastUpdated: "2025-07-03"

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Privacy Policy

Ghanem Al-Oula for Information Technology

1. Introduction to the Company:

Ghanem Al-Oula for Information Technology ("the Company") is a Saudi closed joint stock company established under the laws of the Kingdom of Saudi Arabia, holding Unified National Number 7049166916, dated 26/02/2025.

The Ghanem Platform ("the Platform") is a website and mobile application managed by the Company.

The Company specializes in providing innovative real estate opportunities that allow Platform users to participate in such opportunities and generate returns. The Platform targets individuals and legal entities interested in participating in real estate opportunities across various categories within the Kingdom of Saudi Arabia.

2. Contact Information

You can contact the Company via:

Department/Team: Customer Service Team
Address: King Abdulaziz, 2728, P.O. Box: 13216, Riyadh
Phone: 920031882
Email: hala@ghanem.sa

Data Protection Officer: Customer Service Team Representatives, contact number (920031882), and email (privacy@ghanem.sa).

Last Updated Date:

The privacy policy was last updated on 2025/07/03. You can view the update history via the following link (here).

3. Personal Data to Be Collected

The Company collects and processes several types of data directly from you as follows:

Data Type	Collected Data	Mandatory or Optional	Purpose of Collection	Collection Method
Account Data (Account Creation)	Name, National ID/Iqama number, Address, Email, Mobile number.	Mandatory	To create a personalized account, verify your identity, and communicate with you to provide the service or respond to your request.	Directly from you via the Platform registration form.
Personal Identification Data	Education level, Occupation/Job type, Approximate annual income, Potential subscription amount.	Optional	To help us offer real estate opportunities aligned with your financial capabilities and interests, and to assess your suitability for available opportunities.	Directly from you via the registration form or by completing your profile.
Subscription Preferences	Target subscription size, Previous real estate experience, Preferred regions, Target return, Preferred opportunity duration.	Optional	To offer opportunities tailored to your preferences and improve your experience on the Platform.	Directly from you via the registration form or real estate preferences survey.
Bank Account Information	IBAN, Bank name, Account holder name.	Mandatory	To transfer financial entitlements such as returns or liquidation funds to your bank account.	Directly from you via the bank account registration form.
Payment Data	Card number, Cardholder name, Expiry date, CVV.	Optional	To facilitate payment when subscribing. Enables you to store payment data for faster future purchases.	Directly from you via the payment form.
Contract Authentication Data	E-signature, ID info, Property deed and document images (in some cases).	Mandatory	To authenticate contracts for subscription, ownership, or usufruct and ensure legal rights.	Directly from you via the contract authentication form.
Communication Data	Text communications via the site’s contact form or email, Technical support inquiries.	Mandatory	For service improvement, verifying service representative info accuracy, and for research and development purposes.	Directly from you via contact forms or email.

The Company also collects and processes certain data indirectly as follows:

Data Type	Data Collected	Mandatory	Purpose	Collection Method
Platform Interaction & Technical Issues	Digital interactions with the Platform.	Mandatory	To improve Platform performance and resolve technical/customer issues.	Through automated digital systems.
Subscription Operations	Subscription amount, Transaction date, Reference number, Opportunity details.	Mandatory	To track your subscriptions, provide periodic reports, ensure return distribution, and offer post-subscription services.	Indirectly through internal operational systems.
Financial Transaction Data	Deposit and withdrawal history and amounts, Wallet balance, Return records.	Mandatory	To monitor your real estate wallet’s financial transactions and comply with regulatory requirements.	Indirectly through payment/accounting systems.
Communication Records	Voice calls with customer service, Live chat conversations.	Mandatory	To enhance service quality, verify rep information accuracy, and assist with troubleshooting.	Indirectly through recording systems.
Identity Verification	ID number, Expiry date, Validity of provided data.	Mandatory	To verify applicant identity, protect investor rights, and comply with AML/CFT regulations.	Indirectly via services like "Absher", "Nafath", "Yaqeen", or by requesting ID uploads.
Technical Data	IP address, System name, Browser name, Browser version, Approximate geolocation.	Optional	To provide better user experience, optimize services, and localize opportunities without revealing user identity.	Indirectly via cookies or third-party analytics providers.
Visit Data	Full clickstream (URLs), Pages viewed/searched, Response times, Errors, Visit durations, Interaction data, Viewed opportunities.	Optional	To improve UX and tailor content and opportunities to your interests.	Indirectly via cookies and user behavior analytics systems.

4. How We Disclose Your Personal Data

We may disclose your personal data to the following parties:

Entity	Data Disclosed	Purpose
Regulatory Authorities (e.g. Ministry of Municipal Affairs & Housing, General Real Estate Authority, CMA, SAMA)	Name, ID number, Subscription info, Subscription amount.	For regulatory compliance including AML/CFT.
Real Estate Title Registry	Name, ID number, Property data, Deed info, Ownership/Usufruct rights.	To register partial ownership or usufruct rights per real estate laws.
Ejar and Other Government Platforms	Name, ID number, Property data, Deed info, Ownership or usufruct details.	To document lease or usufruct contracts.
Banks & Payment Providers	Name, Payment info, Paid amount, Email, Mobile.	To process payments, collect fees, and distribute returns securely.
Law Firms/Legal Consultants	Name, ID, Contact data, Contract info, Subscription details.	For legal disputes, contract drafting, and notarization support.
Notary Offices	Name, ID, Deed info, Property data, Ownership or usufruct contract details.	To notarize partial ownership or usufruct contracts.
Cloud/Infrastructure Providers	Technical data, Account info, Browsing data.	To host/run the Platform, provide support, and store data securely.
Real Estate Valuation Firms	Property data, Location, Area, Subscription type.	To conduct property evaluations and share reports without disclosing investor identities.
Company’s Professional Service Providers	Transaction-specific data as needed.	For auditing, tax, marketing, software development, and customer service—disclosed as necessary under data protection agreements.
Specialized Government Platforms	Identity verification data, Contract info, Transaction data.	To comply with legal obligations and document transactions on official platforms.

5. Legal Basis for Collecting and Processing Your Data

Under the Personal Data Protection Law, we process your data based on:

• Your explicit consent, which can be withdrawn anytime without affecting previously lawful processing. Contact the Company’s Data Office to withdraw consent.

• Contractual necessity, especially to fulfill real estate investment contracts (e.g., partial ownership/usufruct), ensuring your rights and returns.

• Legal obligation, as per Saudi laws and regulations (e.g., AML/CFT, Companies Law, Capital Market Law, Housing Ministry).

• Legitimate interests, such as platform security, service development, fraud prevention, and UX enhancement—balanced with your rights.

6. How We Store Your Personal Data

Your data is securely stored at the Company’s premises and approved cloud providers located within Saudi Arabia, using modern encryption and security standards.

Retention periods based on data type are:

Data Type	Retention Period (Months)
Registration & ID Data	While the account is active + 24 months after closure
Payment Data	24 months after the last transaction
Subscription & Contract Data	Duration of subscription + 60 months (for auditing/regulatory compliance)
Financial Records	120 months (as per ZATCA and SAMA)
Communications/Inquiries	12 months from the last contact date
Browsing & Technical Data	6 months

After expiration, data is securely deleted using secure deletion techniques (e.g., overwriting), and paper records (if any) are shredded.

7. Your Rights Regarding Your Personal Data

Under the law, you have the right to:

• Be informed: Understand how your data is collected, used, stored, and disclosed. Refer to this policy or contact us.

• Access your data: View your stored data through your account's “Personal Data” or “Settings” sections, or request it via a “Personal Data Access Request” form.

• Obtain your data: Request a readable/exported copy in JSON/CSV/PDF via the “Export Data” option in “Settings”. Delivered within 7 business days.

• Correct your data: Update inaccurate/incomplete data via “Update Personal Data” in your account or through customer service. Processed within 5 business days.

• Request data deletion: If data is no longer needed, you’ve withdrawn consent, or object to processing without valid justification. Use the “Data Deletion Request” form. Some legal exceptions apply.

• Withdraw consent: At any time, unless other legal bases exist. Use the “Manage Consent” section or contact the Data Protection Officer.

You won’t be charged for exercising these rights unless otherwise legally stated. We’ll respond within 15 business days of receiving a complete request.

For more on exercising your rights, contact the Data Protection Officer:

Data Protection Officer	Customer Service Team
Phone	920031882
Email	privacy@ghanem.sa
Address	King Abdulaziz, 2728, Riyadh

8. How to File a Complaint or Objection

If you believe we’ve violated the data protection law, you can file a complaint via:

• Email: privacy@ghanem.sa
• Phone: 920031882
• Platform: Contact form in “Contact Us” section

If unsatisfied or no response within 15 business days, escalate to the official authority:

Competent Authority	Saudi Data & AI Authority (SDAIA)
Address	Riyadh, Kingdom of Saudi Arabia
Website	Official site: sdaia.gov.sa – Data Governance Portal: Dgp.sdaia.gov.sa