Privacy Policy

Last updated: December 2, 2025

CLUE ("we," "our," or "us") operates the CLUE Property Honesty Platform, a mobile application and website that enables tenants to share their rental experiences and property seekers to access this information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information.

1. Information We Collect

1.1 Account Registration Data

When you create an account, we collect:

• Contact Information: Email address and phone number for authentication and communication
• Profile Information: First name, last name, and optional profile image
• Account Identifiers: Unique user ID generated by our authentication system
• User Preferences: App settings and notification preferences

1.2 Identity Verification Data

To ensure authenticity and prevent fraud, we collect verification documents:

• UAE Pass Authentication: If you verify via UAE Pass, we receive your UAE Pass UUID and verification level (SOP1, SOP2, or SOP3)
• Emirates ID: Document image for OCR extraction of name and ID number
• Ejari (Rental Contract): Document image to verify your tenancy status, including tenant name, property address, and lease dates
• Title Deed: For property owners, to verify ownership

We use Optical Character Recognition (OCR) technology to extract relevant information from these documents. Original document images are processed and not permanently stored after verification.

1.3 CLUE Submission Data

When you submit a CLUE (property review), we collect:

• Property Information: Building name, address, area, emirate, and Makani number
• Review Content: Title, detailed description, issue category (property defect or people problem), and subcategory
• Evidence Files: Photos, videos, audio recordings, and documents you upload as evidence
• Location Data: GPS coordinates captured when you take photos/videos in-app (with your permission)
• Device Metadata: Device model, camera type, capture timestamp, and file specifications for authenticity verification

1.4 Email Evidence

We provide temporary email addresses for you to forward relevant correspondence as evidence. When you use this feature, we collect:

• Email sender and recipient addresses
• Subject line and email content
• Attachments forwarded with the email
• Email headers and timestamps

1.5 Automatically Collected Data

• Device Information: Device type, operating system version, unique device identifiers
• Usage Analytics: Features used, submission events, and interaction patterns
• Push Notification Tokens: FCM tokens for delivering notifications to your devices
• Location Data: With your permission, GPS coordinates when capturing evidence

1.6 Purchase Data

For Seeker Pass purchases, we collect:

• Product purchased and purchase timestamp
• Purchase verification tokens from Apple App Store or Google Play
• Pass expiry dates and renewal status

Payment processing is handled entirely by Apple or Google. We do not collect or store credit card numbers or payment credentials.

2. How We Use Your Information

2.1 Providing the Service

• Process and display your CLUE submissions to help other users
• Verify your identity and tenancy status to prevent fraudulent submissions
• Match CLUEs to specific properties using Makani numbers and addresses
• Process Seeker Pass purchases and manage subscriptions
• Send push notifications about your submissions and account activity

2.2 Content Moderation & Quality Assurance

• Analyze submitted content using AI to ensure compliance with our policies
• Detect and flag privacy concerns (visible faces, personal information in images)
• Assess evidence quality and relevance
• Identify potentially false or misleading submissions
• Verify authenticity of uploaded media using metadata analysis

2.3 Safety & Security

• Prevent fraud, abuse, and unauthorized access
• Verify document authenticity during registration
• Detect duplicate or spam submissions
• Protect users from harmful content

2.4 Improvement & Analytics

• Understand how users interact with the app
• Improve our AI moderation systems
• Develop new features based on usage patterns
• Monitor system performance and reliability

3. AI Processing & Third-Party Services

To provide our service, we use the following third-party services that process your data:

3.1 Google Cloud Platform Services

• Google Cloud Vision API: Analyzes images for face detection, text extraction, content safety, and object recognition
• Google Cloud Speech-to-Text: Transcribes audio from videos and voice recordings
• Google Cloud Video Intelligence: Analyzes video content for faces, objects, and explicit material
• Google Gemini AI: Performs comprehensive content moderation, policy compliance checking, and quality assessment of submissions

3.2 Firebase Services (Google)

• Firebase Authentication: Manages user accounts and login sessions
• Firebase Firestore: Stores user profiles, submissions, and analytics data
• Firebase Storage: Stores uploaded media files (images, videos, documents)
• Firebase Cloud Messaging: Delivers push notifications
• Firebase Cloud Functions: Processes submissions and runs backend logic

3.3 Government & Payment Services

• UAE Pass: Government identity verification service
• Makani API: UAE government address verification service
• Apple App Store / Google Play: In-app purchase processing

4. Information Sharing

4.1 Public Information

When you submit a CLUE, the following information becomes visible to other users who search for that property:

• Your review content (title, description, category)
• Evidence files (photos, videos) you upload
• Property information (building, area, but not your unit number)
• Submission date

Your personal identity (name, contact information) is NOT displayed with your CLUEs. You remain anonymous to other users viewing your submissions.

4.2 Service Providers

We share data with third-party service providers who help us operate the platform, as described in Section 3. These providers are contractually bound to protect your data and use it only for the services they provide to us.

4.3 Legal Requirements

We may disclose your information if required by law, court order, or government request, or if we believe disclosure is necessary to:

• Comply with legal obligations
• Protect our rights, property, or safety
• Protect users from fraud or security threats
• Respond to claims that content violates others' rights

4.4 Business Transfers

In the event of a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction. We will notify you of any such change.

5. Data Storage & Security

5.1 Storage Location

Your data is primarily stored on Google Cloud servers. Data may be processed in multiple regions, including the United States and Europe, where our service providers operate.

5.2 Security Measures

• Encryption of data in transit (TLS/SSL) and at rest
• Secure authentication via Firebase and UAE Pass
• Access controls limiting employee access to personal data
• Regular security assessments and monitoring
• Secure Cloud Functions with authentication requirements

5.3 Data Retention

• Account Data: Retained while your account is active
• CLUE Submissions: Retained indefinitely to help future renters, unless you request deletion
• Verification Documents: Processed for extraction and not permanently stored in original form
• Analytics Data: Retained for service improvement
• Cache Data: Automatically deleted after 24 hours
• Purchase Records: Retained as required for tax and legal compliance

6. Your Rights & Choices

6.1 Access & Portability

You can request a copy of your personal data in a portable format.

6.2 Correction

You can update your profile information directly in the app, or contact us to correct other data.

6.3 Deletion

You can:

• Delete individual CLUE submissions through the app
• Request complete account deletion by contacting us

Note: Some data may be retained for legal compliance or legitimate business purposes even after deletion requests.

6.4 Notification Preferences

You can manage push notification preferences in the app settings or through your device settings.

6.5 Location Permissions

You can grant or revoke location permissions through your device settings. The app can function without location access, though some features may be limited.

6.6 Exercise Your Rights

To exercise any of these rights, contact us at privacy@clue.ae.

7. Children's Privacy

CLUE is not intended for users under 18 years of age. We do not knowingly collect personal information from children. If you believe we have inadvertently collected information from a child, please contact us immediately at privacy@clue.ae.

8. International Data Transfers

Your information may be transferred to and processed in countries other than the UAE, including the United States where Google Cloud services operate. We ensure appropriate safeguards are in place for such transfers, including standard contractual clauses and compliance with applicable data protection laws.

9. UAE Data Protection Compliance

This Privacy Policy is designed to comply with UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data. We:

• Process personal data lawfully, fairly, and transparently
• Collect only data necessary for specified purposes
• Keep data accurate and up to date
• Store data only as long as necessary
• Implement appropriate security measures
• Respect your rights as a data subject

10. Changes to This Policy

We may update this Privacy Policy periodically. We will notify you of material changes by:

• Posting the updated policy in the app
• Updating the "Last updated" date
• Sending a notification for significant changes

Your continued use of the Service after changes constitutes acceptance of the updated policy.

11. Contact Us

If you have questions about this Privacy Policy or our privacy practices:

• Email: privacy@clue.ae
• Support: clue.ae/support

By using CLUE, you acknowledge that you have read and understood this Privacy Policy. For our Terms of Service and End User License Agreement, please visit our Terms page.