1. General

1.1. This Privacy Policy (the “Policy”) explains how SHELLGROW HOLIDAY HOMES L.L.C (the “Company”, “we”, “our”, “us”) collects, uses, stores and protects personal data of users of the website https://shellgrow.com (the “Website”) and our clients and partners (the “User”, “you”, “your”).

1.2. By using the Website, submitting any personal data through the Website or through other communication channels (including WhatsApp, email, contact forms, social media, phone calls), you confirm that you have read and understood this Policy and agree to its terms.

1.3. The Company processes personal data in accordance with applicable data protection laws of the United Arab Emirates, including, where applicable, Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (UAE PDPL), and other relevant regulations.

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2. Personal Data We Collect

2.1. We may collect the following categories of personal data:

• Identification data: first name, last name, middle name (if provided);

• Contact details: mobile phone number, WhatsApp number, email address, social media or messenger usernames;

• Booking and service data: property of interest, dates of stay, number of guests, preferences for accommodation and services, comments you provide;

• Payment and billing information: necessary details for processing payments and refunds (we do not store full card details if payments are processed by third-party payment providers);

• Communication data: messages and correspondence with us (including via WhatsApp, email, forms on the Website and other channels);

• Technical data automatically collected when you visit the Website:

  • IP address;

  • browser type and version;

  • device information;

  • operating system;

  • cookies and similar technologies;

  • date, time and pages of visits, referring URLs and clickstream data.

2.2. We do not intentionally collect special categories of personal data (such as information on health, religion, political opinions, etc.), unless required by law and only with your explicit consent.

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3. Purposes of Processing Personal Data

3.1. We process personal data for the following purposes:

• To respond to your enquiries and requests, provide customer support and communicate with you;

• To prepare, conclude and perform contracts for our services, including property bookings, holiday homes management and related services;

• To manage bookings, payments, check-in/check-out, and other operational matters;

• To provide you with information regarding your bookings, payments, changes to reservations and other service notifications;

• To operate, maintain and improve the Website and our services, including analytics and performance monitoring;

• To comply with applicable laws and regulations, including accounting, tax and regulatory requirements;

• To send you marketing and informational communications about new products and services, special offers, promotions, events and updates, including via WhatsApp Business, email, SMS and other channels, where permitted by law.

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4. Legal Basis for Processing

4.1. We process your personal data based on:

• Your consent (for example, when you submit a form, tick a box, or agree to receive marketing communications);

• The necessity to perform a contract or to take steps at your request prior to entering into a contract (for example, to manage your property booking);

• Compliance with legal obligations under applicable UAE laws;

• Our legitimate interests, such as improving our services, ensuring the security of our systems and preventing fraud, provided that such interests do not override your rights and freedoms.

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5. Marketing Communications and WhatsApp Broadcasts

5.1. The Company has the right to send the User notifications about new products and services, special offers, promotions and various events of the Company, including via WhatsApp Business, email, SMS and other communication channels, where permitted by applicable law.

5.2. Such communications may include, for example:

• Offers and promotions for short-term or long-term rentals;

• Updates on new properties managed by the Company;

• Information about additional services (concierge services, cleaning, transportation, etc.);

• News, events and other marketing content related to the Company’s activities.

5.3. You can opt out of receiving marketing and promotional messages at any time. To do so, you may:

• Send us an email to support@shellgrow.com with the subject line “Unsubscribe from notifications” or similar wording; and/or

• Follow the instructions provided in each message (for example, sending a reply in WhatsApp with the text “STOP” or using another opt-out method described in the message).

5.4. Opting out of marketing messages will not affect our ability to send you service and transactional notifications, which are necessary for the performance of our contract with you (for example, booking confirmations, payment receipts, check-in instructions, important updates about your stay).

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6. Sharing of Personal Data with Third Parties

6.1. We may share your personal data with third parties in the following cases:

• Service providers and partners involved in the provision of services to you, including:

  • Property owners and management partners;

  • Cleaning, maintenance, technical and concierge service providers;

  • Transport or transfer companies;

  • Other third parties involved in fulfilling your booking and service requests.

• Communication and marketing platforms, including official providers of WhatsApp Business API, CRM systems, email and SMS services, and other tools used to send notifications and manage customer interactions.

• Payment institutions and banks, for processing payments, refunds and related financial transactions.

• Hosting, IT and analytics providers, who support our Website, databases, cloud infrastructure and analytics tools.

• Advertising and analytics partners, who help us measure and improve our marketing campaigns and Website performance.

• Government authorities, regulators and law enforcement, when required by applicable law, court orders or official requests.

6.2. When we share personal data with third parties, we take reasonable steps to ensure that such parties protect your personal data and use it only for the purposes for which it was disclosed.

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7. International Transfers

7.1. Some of the third parties listed above may be located outside the United Arab Emirates. This means your personal data may be transferred to and processed in countries that may have different data protection laws than those in the UAE.

7.2. In such cases, we take appropriate measures to ensure an adequate level of protection for your personal data, in accordance with applicable UAE data protection laws.

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8. Cookies and Similar Technologies

8.1. The Website uses cookies and similar technologies to:

• Ensure the proper functioning and security of the Website;

• Remember your preferences and settings;

• Analyse how you use the Website and improve user experience;

• Tailor our marketing and advertising campaigns.

8.2. You can manage cookies through your browser settings. Please note that disabling certain types of cookies may affect the functionality of the Website or prevent some features from working properly.

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9. Data Retention

9.1. We store personal data in an identifiable form for as long as necessary to fulfil the purposes described in this Policy, and in line with:

• The duration of our contractual relationship with you;

• Statutory retention periods under applicable laws of the UAE;

• The limitation periods for legal claims where retention of data is necessary for the establishment, exercise or defence of legal claims.

9.2. Once personal data is no longer required for the purposes described above, we will delete or anonymise it, unless we are legally required to retain it for a longer period.

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10. Your Rights

10.1. Subject to applicable UAE data protection laws, you may have the following rights with respect to your personal data:

• The right to be informed about how your personal data is processed;

• The right to access your personal data held by us;

• The right to request correction or updating of inaccurate or incomplete personal data;

• The right to request deletion of your personal data in certain circumstances;

• The right to request restriction of processing in certain circumstances;

• The right to withdraw your consent, where processing is based on consent;

• The right to object to certain types of processing, including direct marketing;

• The right to lodge a complaint with the competent data protection authority, where applicable.

10.2. To exercise any of your rights, you can contact us using the contact details provided in Section 11 below. We may request additional information to verify your identity before responding to your request.

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11. Contact Details of the Company

Data controller / operator of personal data:
SHELLGROW HOLIDAY HOMES L.L.C,
Commercial License No. 1199032, Register No. 2172608,
issued by the Department of Economy and Tourism, Dubai.

Registered (legal) address:
Office 3108, Al Salam Tecom Tower, Internet City, Dubai

Phone numbers:
+971 50 346 3933
+971 50 106 1650

Email for general enquiries:
info@shellgrow.com

Email for privacy and data protection enquiries / unsubscribe:
support@shellgrow.com

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12. Changes to This Policy

12.1. We may update this Policy from time to time. The updated version will be published on the Website at:
https://shellgrow.com/privacy-policy/ and will be effective from the date of publication, unless otherwise stated.

12.2. We encourage you to review this Policy periodically to stay informed about how we process your personal data.