1. Introduction

Welcome to Property Inventory Enterprise (hereinafter referred to as "PIE"). The Website located at www.pie.properties (“Website,” “Site,” or “Platform”) is owned and operated by Kingfisher Consultancy, a Company formed and operating in accordance with the Laws of Egypt (“Company,” “We,” “Us” or ,“Our”). We respect your privacy and are committed to protecting the information you provide us. We strive to adhere to the principles of lawfulness, fairness, and transparency in how we collect and use your data as well as how we secure it. Please read this Privacy Policy as well as our applicable Terms and Conditions before you proceed to use the Website. This Privacy Policy informs you about what information we collect from you, how we use it and with whom we share your personal information. By using our Website, you expressly consent to the collection and use of your data as outlined hereunder. Any reference to “You”, “Your” or “User” in this Privacy Policy refers to you, the Website Visitor, PIE Account Holder and their Authorised Users.

2. Changes to this Policy

The Company reserves the right to change this Privacy Policy at any time without prior notice to you. Where we make any material changes to this Privacy Policy, we will inform you of such changes by amending the last updated date at the top of this page. Your continued use of the Website following the introduction of the changes to the Privacy Policy will constitute an acceptance of such changes.

3. When does this Privacy Policy apply

This Privacy Policy applies when you access www.pie.properties

4. Data Controller and Data Processor

The Company is the data controller for your personally identifiable information collected through our Website and Amazon Web Services (AWS) is our data processor.

5. Terminology

Whenever you use our Website, we process all your data in compliance with local Privacy Laws as well the General Data Protection Regulation (“GDPR”). We will not process your data unless it is essential for delivering our Platform Service or improving your User Experience on the Website. For this Privacy Policy, any reference to the following terms shall hold the meaning as defined in Article 4 of the General Data Protection Regulation (“GDPR”):

• ‘Personal Data’ -

  “Any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an 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’ -

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

6. Personal Data We Collect and Process

Personal data you provide to us voluntarily

• Personal data provided by Brokers

  When you register an account on the Platform as a Broker, you may choose to register an account as an individual or as a Broker Company. Where you create an account as an individual, you will be asked to provide personal information including your full name, gender, email address, phone number, your short bio, your city/country of current residence as well as information about your services and experience in the industry. When you register an account on the Platform as a Broker Company, you will be asked to provide some information about your Broker Company such as your organisation name, organisation address, website, facebook page, email address, number of employees in the organisation, organisation description, contact person in the organisation and contact person’s email address as well as phone number.



• Purpose of Processing and Legal Bases

  We process this personal information to create your User Account, to enable Brokers to securely login to the online account, to enable Suppliers to view the Broker profiles when the Broker send the sharing rights requests. We also use this information to contact you as and when required and to deliver our services to you under the Broker Terms and Conditions as well as Subscription quotation. The legal basis for our processing of this personal data is your consent in accordance with Article 6(1)(a) of the GDPR and performance of our contract with you in accordance with Article 6(1)(b).



• Data Retention Duration

  We retain Broker’s personal information on our record as long as the Broken subscription is active on our Platform. We will not retain any Broker related personal data on our records for more than two years after the Broker account is terminated, unless such information is required to defend a legal action or assert Company’s claim in a legal action.



• Personal Information Provided by Suppliers

  When you register an account on the Platform as a Supplier, you may choose to register an account as a Real Estate Developer or as a Reseller and you will be asked to provide us your organisation name, website, email address, speciality, authorised organisation representative, relevant department and the department’s phone number.



• Purpose of Processing and Legal Bases

  We process the information that you provide us to create your User Account, to enable you to securely login to the online account, to enable Brokers to view your inventory after you approve their sharing rights requests. We also use this information to contact you as and when required and to deliver our services to you under the Supplier Terms and Conditions as well as Subscription quotation. If you wish for alternative contact information to be used than that provided during account creation, you may request by sending an email to the Company. You understand that alternative contact information provided by you will be governed by this Privacy Policy. The legal basis for our processing of this personal data is your consent in accordance with Article 6(1)(a) of the GDPR and performance of our contract with you in accordance with Article 6(1)(b).



• Data Retention Duration

  We retain Supplier information on our record as long as the Supplier subscription is active on our Platform. We will not retain any Supplier related personal data on our records for more than two years after the Supplier account is terminated, unless such supplier information is required to defend a legal action or assert Company’s claim in a legal action.

7. Information we collect when you use our Service

There is certain information that we collect about our Users through the use of log data such as our User’s IP address, the date and time of their visits, the pages they view on our Website. We use this information to learn how Users interact with our Website, to improve our User experience, as well as to develop new features and functionality that we believe enhance our service offering.

8. Use of Cookies

We and the third-party service providers that we use make use of cookies and other tracking technologies to identify you when you visit our Website or third-party services, to analyze how our advertising campaigns are performing to learn how you use our Website and to serve retargeted ads to you. Cookies are also used to improve your user experience. Cookies are small pieces of data that are placed on your browser when you visit a website provided your browser is set to accept cookies. These cookies remain on your browser until they expire or you take active steps to delete them yourself. You can easily change your browser settings to decline cookies. To learn more, please visitwww.allaboutcookies.org .
Which Cookies and Pixels we use on our Website:

• Google Analytics

  We use Google analytics services to better understand how users interact with our Website. Google Analytics is owned and operated by Google LLC. Google Analytics uses cookies that are stored on your device for the purpose of evaluating your use of our website. We use Google Analytics with IP anonymization enabled. We do not use the analytics tools in a way that will identify you. All information collected from you is stored on Google servers located in the U.S. in accordance with EU-US Privacy Shield. You can learn more about how Google processes your personal information at this link. You can stop these cookies from being stored on your computer by installing the browser plug-in available here.



• Facebook Pixel

  We use Facebook Pixel which enables us to track user behaviour when they visit our website after clicking on our Facebook ad and to retarget ads to such users after they leave our website. We also use Facebook Pixel to analyze how our Facebook ads are performing. All data is anonymous and we do not receive any personally identifiable User data from Facebook Inc. Although Facebook Inc does not disclose your personal data to us, this information is still stored and processed by Facebook Inc and may be used by them, in accordance with their own Privacy Policy. If you do not wish for Facebook Pixel to use your data for the Facebook ads display, please contact Facebook the link provided here. Facebook is currently taking steps to ensure compliance with GDPR and is also certified under the Privacy Shield Agreement.

You can decline cookies from our website by clicking decline in the cookie banner on our website or by changing your browser settings to decline all third-party cookies.

9. Sharing your Information

We do not sell or rent your personal information to any third-party.
We may disclose your personal information in the following circumstance:

• If required to do so for the performance of our service.
• To other Platform users with your consent and in accordance with your agreement with the Company.
• If we are required to do so by law.
• If such disclosure is made to protect the vital interest of a data subject or another natural person.
• To perform our contract with you.
• Upon reasonable requests from the law enforcement and regulatory authorities.

In addition to Facebook pixel and Google Analytics we may also share your personal data with:

• Our developers and other subcontractors that we use to deliver our services to you.
• Any governmental body and regulatory authority where we are required to provide such personal information by law.

10. Transfer of data to third countries

Our data processors are based in several jurisdictions around the world where the data protection laws may be different from those of your country of current residence. By accessing or in any way interacting with our Website, you give us your express consent to transferring and processing your data in and outside the country of your current residence for the purposes outlined in this Privacy Policy and those that are compatible with the specified purposes. Whenever we transfer your personal information to another jurisdiction we take all necessary steps to ensure that your data is adequately protected in such recipient location.

11. Right to lodge a complaint

If you believe that we have infringed your privacy rights, you have the right to lodge a complaint with Data Protection Supervisory Authorities. If you are living in the EEA, you can find your Data Protection Authority here.

12. Security

We care about the safety of your personal information and strive to keep all your personal information secure. Although we use industry best practices and commercially viable methods to protect your personal information, our Website uses third-party software tools and services which may have vulnerabilities that we are not yet aware of; therefore, we are unable to offer any guarantees as to the security of your personal information.

13. Third-party websites

Our website may contain links to third-party websites. If you choose to click on these third-party links, you will be redirected to such third-party’s Website. Please note that their own legal policies and agreements govern these websites, and we encourage you to review their Terms and Privacy Policy before you make use of their services. We cannot be held liable for your use and access of such third-party websites or for any information or content made available by such third-party sites. Any presence of third party links on our website does not indicate an endorsement or recommendation of such third-party by the Company, and your access/use of these sites is solely at your own risk.

14. Children’s Privacy Policy

We do not knowingly collect any personal information from Users under the age of eighteen (18) years. If you are aware that a person under the age of eighteen has provided any personal information to the Company through the Website, please contact us immediately at support@pie.properties . We will take steps to investigate the matter and remove any and all personal information for such User on our records.

15. Your Rights

The General Data Protection Regulation grants data subjects more control over their personal data and here are some of the rights that you can exercise regarding your data that we collect and process:

• Your right to access your personal information
• Your right to rectify your personal information
• Your right to be forgotten
• Your right to object to the processing of your data
• Your right to withdraw your consent

To exercise any of the rights listed above please contact us at support@pie.properties with your request.

16. Contact us

Company: Kingfisher Consultancy S.A.E.
Address: Office 4-6-D, Polygon Building 4, Sodic West Compound
Km 38 Cairo-Alex Desert Road, Sheikh Zayed, Giza, EG
Telephone: +2 02 3865 3757
E-mail: support@pie.properties