This translation is provided for information only. The legally binding version is the German version.
This privacy policy informs you about which personal data we process when you use PLANSWAP, for what purposes and on what legal basis (Art. 13, 14 GDPR).
1. Controller
[Company name], [Address],
Email: –
2. Hosting and provision of the website
The website, the database and the storage for documents are provided via Cloudflare (Cloudflare, Inc., 101 Townsend St., San Francisco, CA 94107, USA; Cloudflare Pages, D1 and R2). When you access the pages, Cloudflare processes technically necessary data such as your IP address, the time of access, the page accessed and browser information in order to deliver the website securely and reliably. The legal basis is our legitimate interest in a secure and functional service (Art. 6(1)(f) GDPR). Cloudflare is certified under the EU-US Data Privacy Framework; standard contractual clauses are also in place.
3. Enquiries, Exit Check and call-back requests
If you contact us via a form (e.g. Exit Check, enquiry about a listing, service request), we process your details (name, email, phone, message and the figures you entered) in order to handle your enquiry. The legal basis is the performance of pre-contractual measures at your request (Art. 6(1)(b) GDPR) and your consent (Art. 6(1)(a) GDPR). The entries in the Exit Calculator are stored only in your browser and are only transmitted when you submit the form.
4. Listings and documents from sellers
If you submit a listing, we store your contact details, the details of the apartment and the payment status, as well as uploaded documents (e.g. purchase agreement/SPA, developer statement of account, Oqood). We use this data to review your listing, prepare a property brochure, market the offer and support the sale (Art. 6(1)(b) GDPR). Uploaded documents are not public and are accessible only to our review team. Only details about the apartment are published, not your name or contact details.
5. Disclosure to partner brokers and partners in the UAE
Brokerage and transaction handling in Dubai are carried out by RERA-licensed partner brokers; services such as financing, holiday letting or handover inspections are provided by partner companies. Where this is necessary for your request and you have given your consent, we pass on your contact details and relevant information to the respective partner. The partners are mainly based in the United Arab Emirates, for which there is no adequacy decision by the EU Commission. The transfer is based on your explicit consent (Art. 49(1)(a) GDPR) or because it is necessary for the implementation of pre-contractual measures taken at your request (Art. 49(1)(b) GDPR). Please note that the level of data protection there may not be comparable to that in the EU. You can withdraw your consent at any time with effect for the future.
6. Customer account and Buyer Club
For an account, we store your email address, password (only as a secure hash), name, optionally your phone number, language, saved searches, watchlist and orders. The legal basis is the performance of the contract (Art. 6(1)(b) GDPR). When suitable new listings become available, we inform you by email about your saved searches; you can delete saved searches in your account at any time.
7. Payments
For online payments, we use Mollie B.V., Keizersgracht 126, 1015 CW Amsterdam, the Netherlands. Mollie processes the data required for the payment under its own responsibility; we only receive the payment status. For bank transfers, we process the details from the incoming payment. The legal basis is the performance of the contract (Art. 6(1)(b) GDPR) and statutory retention obligations (Art. 6(1)(c) GDPR).
8. Sending emails
We send confirmations and notifications via the service Resend (Resend, Inc., USA). In doing so, your email address and the content of the message are processed. The transfer is based on EU standard contractual clauses or – where available – certification under the EU-US Data Privacy Framework (Art. 6(1)(b) and (f) GDPR).
9. Cookies and local storage
We only use technically necessary cookies: a session cookie for logged-in buyers and one for the administration area. In your browser’s local storage, we save your cookie choice, the conversation ID (if you use the chat) and – if you use it – your entries in the Exit Calculator. This storage is strictly necessary for the functions you have requested (§ 25 (2) TDDDG).
10. AI chat and AI-assisted processing
On our website you can chat with an AI assistant. The chat is clearly labelled as AI; answers are generated automatically, may contain errors and are not legal, tax or investment advice. We process your chat messages, the selected language, the page you are on, a hash of your IP address salted with the current date (abuse prevention) and a random conversation ID stored in your browser so that you can continue the conversation.
To generate answers we transmit the messages of the conversation to Anthropic (Anthropic, PBC, San Francisco, USA – Claude API) or to Cloudflare Workers AI (Cloudflare, Inc., San Francisco, USA). Both providers act as processors and, according to their own statements, do not use data submitted via the API to train their models. Transfers to the USA are based on the EU-US Data Privacy Framework or EU Standard Contractual Clauses. The legal basis is Art. 6(1)(b) GDPR (handling your request) and Art. 6(1)(f) GDPR (fast customer service in four languages). Please do not enter ID, bank account or health data in the chat. We delete chat conversations automatically after 180 days; if you leave your contact details via the chat, the retention periods for enquiries apply.
Internally, AI assistants also support us, for example in pre-sorting enquiries, drafting reply emails to your enquiry (these are labelled as AI-assisted), checking listings for completeness and matching new offers with search profiles in the Buyer Club. In doing so, your details from enquiries, accounts and listings may be transmitted to the providers named above (Art. 6(1)(b) and (f) GDPR). No AI makes decisions with legal or similarly significant effects. Publications, the approval of listings and initial business contacts only happen after approval by a human; we do not send marketing emails to private individuals without their consent.
11. Google Ads conversion tracking (only with consent)
Only if you consent to “Marketing” in the cookie banner do we load Google Ads (Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland) to measure the success of our ads. In this process, cookies may be set and data may be transferred to Google LLC in the USA; Google is certified under the EU-US Data Privacy Framework. The legal basis is your consent (Art. 6(1)(a) GDPR, § 25 (1) TDDDG). You can withdraw your consent at any time via “Cookie settings” in the footer.
12. Storage period
We store personal data only for as long as is necessary for the respective purpose. We generally delete enquiries that do not lead to a contract after 24 months. We delete listings and documents no later than 12 months after completion or withdrawal, unless statutory retention obligations apply (e.g. 6 or 10 years for commercial and tax records).
13. Your rights
You have the right of access (Art. 15 GDPR), rectification (Art. 16), erasure (Art. 17), restriction of processing (Art. 18), data portability (Art. 20) and the right to object to processing based on legitimate interests (Art. 21). You can withdraw any consent you have given at any time with effect for the future. You also have the right to lodge a complaint with a data protection supervisory authority. To make a request, simply send an email to the address given above.
14. No automated decision-making
We do not make any decisions based solely on automated processing within the meaning of Art. 22 GDPR. The calculations on the website are non-binding estimates.
Last updated: October 2026