This policy explains what personal data KlientFlo (“we”, “the Service”) processes on behalf of the real estate agent or brokerage operating it (“the Agent”), and how. It is written with the UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (“PDPL”) in mind. Where the Agent determines the purposes of processing, the Agent is the data controller and KlientFlo acts as a processor.
Data we process
- Contacts & leads: name, phone number, email, nationality, and stated property requirements (budget, area, bedrooms, timeline).
- WhatsApp conversations: message content, voice notes and their transcriptions, media, timestamps, and delivery status, ingested via the WhatsApp Business Platform.
- Owners database: owner names, contact details, and property/building/unit references uploaded by the Agent.
- Transactional records: deals, viewings, calendar events, uploaded documents, and generated brochures.
- Account data: agent/user login email and a password stored only as a salted hash.
How we use it
To operate the Service for the Agent: organising WhatsApp communications, matching clients to properties, scheduling, document handling, reporting, and sending agent-initiated messages. We do not sell personal data or use it for third-party advertising.
AI processing
Conversation text may be sent to Anthropic’s Claude API to classify, summarise, extract requirements, and draft replies. This processing is to provide the Service’s features. Where no AI key is configured, a local heuristic is used instead and no message content leaves the Service for AI processing.
WhatsApp consent
Messaging via the WhatsApp Business Platform is subject to Meta’s policies, including opt-in requirements and the 24-hour customer-service window. The Agent is responsible for obtaining and recording each contact’s consent to be messaged and for honouring opt-out requests.
Sub-processors
We rely on infrastructure and service providers that may process data on our behalf, including: Anthropic (AI), Meta Platforms (WhatsApp Business), Amazon Web Services (file storage), the speech-to-text provider configured by the Agent, and the application hosting provider. Each is engaged to deliver the Service only.
Retention & security
Personal data is retained while the Agent’s account is active or as required to provide the Service, then deleted or anonymised on request. We apply access controls, encrypted transport (HTTPS), hashed credentials, and signed sessions. Uploaded files are stored in private object storage and served through authenticated application routes.
Your rights (PDPL)
Data subjects may request access, correction, deletion, restriction of processing, or portability of their personal data, and may withdraw consent. Requests should be directed to the Agent operating this instance, who will action them in line with the PDPL.
Contact
For privacy questions or data-subject requests, contact the Agent / brokerage operating this KlientFlo instance. (Insert your data protection contact details here.)