Privacy Policy

Protecting Your Data, Respecting Your Trust

We value the privacy of every visitor and are committed to safeguarding personal information. This Privacy Policy explains how we collect, use, and protect the details provided when visiting our website, using our services, or interacting with our platforms.

Last Updated: July 20, 2025

Who We Are

Novamir ("we", "us", "our") is the controller responsible for personal information collected through this site. We're based at:

Meydan Road, Nad Al Sheba, Dubai, U.A.E.
Contact us at hello@novamir.ai.

Why We Use Your Data

We process personal information for the following purposes:

• Lead Qualification – to assess interest and respond to inquiries.
• Marketing Communications – to share relevant updates about our offerings.
• Website Analytics – to analyze usage trends, improve performance, and detect abuse.

What Data We Collect

Automatically collected details ("Device Information"):

• Includes browser type, IP address, device identifiers, time zone, and usage metrics like pages visited or referral source.

Voluntarily submitted details:

• Includes name, email, phone number, or any other information provided via contact or lead forms.

Legal Basis for Processing

Personal information is processed based on the following legal grounds:

• Consent – when information is provided voluntarily for specific purposes.
• Our Legitimate Interests – such as improving our service, analyzing usage patterns, or protecting our systems, so long as those interests don't override individual rights.

Your Rights

Under both UAE PDPL and EU GDPR, individuals have the right to:

• Access personal records held about them
• Correct inaccuracies
• Request deletion ("right to erasure")
• Object to or restrict processing
• Request portability of personal records

To exercise any of these rights, please email us at hello@novamir.ai. We will respond promptly.

Data Retention & Deletion

We retain personal information only as long as necessary to fulfill the stated purposes or comply with legal obligations. Deletion may also be requested at any time; we will fulfill such requests without undue delay, unless retention is required by law.

International Data Transfers

Personal information may be transferred outside the UAE or EU (e.g., to service providers like CRM platforms or analytics tools). We use appropriate safeguards—such as contractual agreements—to ensure continued protection aligned with UAE PDPL and EU GDPR standards.

Security & Breach Notification

We implement reasonable technical and organizational measures to protect personal information. In the event of a security breach that poses a risk to individual rights or freedom, affected parties and the relevant UAE authority (Data Office) will be notified promptly, as required by law.

Links to Other Websites

Our website may contain links to external sites. We're not responsible for their privacy practices. Please review their privacy policies independently.

Use of WhatsApp Business Platform & Meta Products

As part of our services, we use the WhatsApp Business Platform (powered by Meta) to support automated and human-assisted lead qualification, communication, and customer engagement on behalf of our clients.

When a user contacts us or our clients through WhatsApp, the following types of personal information may be processed:

• WhatsApp phone number, name, profile picture, and language setting
• Messages, including text, media (images, audio, video), documents, and attachments
• Message metadata, including timestamps, message status (sent, delivered, read), and conversation IDs
• Interaction logs used for performance monitoring, follow-ups, analytics, or service improvements

This information is processed to enable two-way messaging, automate common inquiries, assess lead quality, and pass qualified leads to our clients' teams.

We may also interact with other Meta developer tools or APIs (e.g., for templates, analytics, account management) as part of delivering the service.

Data Sharing and Responsibility

Messages and related content may be shared with:

• Meta Platforms Inc., which provides the WhatsApp Business Platform. Meta processes this content under its own Privacy Policy and Terms of Service.
• Our Clients, when we act as a processor or integration provider on their behalf (e.g., real estate agencies, brokers, or sales teams contacted via WhatsApp).
• Our Service Providers, such as CRM, cloud hosting, or analytics tools, solely for the purpose of delivering the service.

We do not sell WhatsApp conversation records or use them for profiling unrelated to the original purpose.

Your Control & Rights (WhatsApp)

Access, correction, or deletion of WhatsApp conversation records can be requested at any time by emailing hello@novamir.ai. To stop receiving WhatsApp messages, reply with "STOP", and we will immediately cease communication.

We will only retain WhatsApp records as long as needed to fulfill service obligations or client instructions, unless longer retention is legally required.

Compliance with WhatsApp Business Solution Terms

No Use for AI Model Training

We confirm that we do not use WhatsApp Business Solution content (including messages, metadata, or derived material) to create, develop, train, or improve any large-language models or general-purpose AI models. In the event that we use AI/ML for internal automation, such models are strictly for our exclusive use and do not incorporate Business Solution material beyond the specific conversation context.

Third-Party Service Provider Safeguards

When we engage service providers (e.g., CRM, hosting, analytics, or AI/ML vendors) that process WhatsApp messages or conversation records on our behalf, we ensure via contract that they:

• Process those records only on our instructions and for our clients' defined purposes,
• Comply with applicable protection terms including WhatsApp Business Solution Terms, and
• Maintain safeguards appropriate to the sensitivity of the information.

No Profiling or Commercial Exploitation

We do not track, build, or augment user profiles using WhatsApp content beyond what is needed to serve and respond to an inquiry. We do not sell, license, or otherwise distribute WhatsApp content for unrelated purposes.

Controller vs Processor Role

Where we act on behalf of a client (e.g., a real estate agency), that client remains the controller and we act as their processor. We handle the information only on their documented instructions, and the client is responsible for ensuring they have a valid legal basis to process personal details.

This policy reflects our alignment with the WhatsApp Business Solution Terms.