Privacy Notice
Last Updated: March 3, 2026 · Effective Date: March 3, 2026
Privacy Notice Highlights
Virtue ("Company," "we," "us") understands and respects that you care about your personal data and how it is used. We respect your privacy, as further described in our Full Privacy Notice. These highlights summarize key points about how we collect, use, and share personal data. Please review the Full Privacy Notice below for complete details about our privacy practices.
Privacy Notice Scope
Virtue owns and operates websites and other online services, including websites, mobile-optimized websites, applications, and electronic communications (such as emails we send) (collectively, the "Services").
This Privacy Notice applies to personal data we collect when you use the Services and explains:
- what personal data we collect,
- how and why we use it,
- with whom we share it, and
- how to contact us about our privacy practices.
Collection of Information
We collect personal data from a variety of sources, including:
- Information you provide directly to us (such as contact details, professional information, and communications);
- Information from business partners (such as developers, brokers, or introducers involved in referrals);
- Information from public or commercially available sources; and
- Information collected automatically through cookies and similar technologies, including device data, IP address, browsing activity, and usage data.
We do not intentionally collect sensitive personal data unless strictly necessary and permitted by law.
Use of Information
How we use personal data depends on how you interact with the Services. We may use personal data to:
- Provide and operate our Services and facilitate real estate introductions and referrals;
- Administer accounts and provide customer support;
- Communicate with you, including responding to inquiries and sending service-related messages;
- Send marketing communications, where permitted by law and subject to your preferences;
- Conduct analytics, research, and improve our Services;
- Detect and prevent fraud and misuse; and
- Comply with legal and regulatory obligations.
Your Choices and Rights
As described in our Full Privacy Notice, you may have certain choices and rights regarding your personal data, including:
- The right to access, correct, delete, or receive a copy of your personal data, subject to applicable law;
- The ability to unsubscribe from marketing emails at any time;
- Choices regarding cookies, targeted advertising, and certain data disclosures, as described in our Cookie and Advertising section.
We verify requests before processing them to protect your data.
Sharing of Information
We may share personal data in certain circumstances, including:
- With service providers that help operate our Services;
- With business partners (such as developers, brokers, or introducers) to facilitate introductions and referrals;
- With subsidiaries or affiliates, where applicable;
- In connection with a business transaction, such as a merger or sale;
- To comply with legal obligations or protect the rights, safety, and security of Virtue, our users, or others; or
- With your direction or consent.
We may also share de-identified or aggregated data.
Additional Information
We maintain administrative, technical, and physical safeguards designed to protect personal data. However, no system or transmission over the internet can be guaranteed to be 100% secure.
Virtue is based in the United Arab Emirates, and personal data may be processed in the UAE or other countries where we or our service providers operate, subject to applicable safeguards.
For complete details, please review the Full Privacy Notice below.
Contact Us
If you have questions, comments, or requests regarding our privacy practices or this Privacy Notice, please contact us at: [Privacy Contact Email]
California Privacy Rights
California residents have specific rights under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA). For additional information, please review Additional Information for California Residents in the Full Privacy Notice below.
Other U.S. State Privacy Rights
Residents of certain U.S. states may have additional privacy rights under applicable state laws. For more information, please review Additional Information for Other U.S. State Residents in the Full Privacy Notice below.
Full Privacy Notice for Virtue
Last Updated: March 3, 2026 · Effective Date: March 3, 2026
Virtue ("Company," "we," "us") is a Dubai-based real estate services and introducer platform that respects your privacy and understands that you care about how your personal data is used. We value your trust in sharing your personal data with us and are committed to protecting your privacy, as described in this Privacy Notice.
1. Scope
This Privacy Notice ("Notice") applies to personal data of clients, introducers, business partners, and other users collected by Virtue through our websites, mobile applications, mobile-optimized websites, and other applications and electronic media (such as emails we send) (collectively, the "Services").
Virtue operates as a real estate services and introducer platform, partnering with international real estate agents, business owners, and other introducers who refer clients interested in Dubai off-plan property purchases. All real estate transactions, contracts, and client funds are handled exclusively by our Dubai-based entity or by licensed third-party developers or brokers, as applicable.
Except as otherwise indicated, introducers, clients, and other persons using the Services are individually and collectively referred to as "you." This Privacy Notice describes the types of personal data we collect about you, how we use it, with whom we share it, the choices and rights you have regarding your data, how we protect it, and how you can contact us about our privacy practices.
Our Services are intended for a general audience and are not directed to individuals under the age of 18.
Virtue acts as a data controller with respect to personal data collected through its own websites, marketing activities, and business operations. In certain circumstances, Virtue may act as a data processor or service provider on behalf of independent real estate agents, developers, or introducers who are separate data controllers. In such cases, the privacy practices of those third parties are governed by their own privacy notices.
2. Data We Collect and Obtain
We obtain personal data about you from a variety of sources, including data you provide directly to us, data obtained from third parties, and data collected automatically through your use of the Services.
Data You Provide to Us
When you register as an introducer, become a client, participate in our services, or directly correspond with us, we collect certain types of data from you, including:
- contact information (such as name, postal address, email address, and telephone and/or mobile number);
- account credentials (such as username and password);
- professional or business information relevant to introducer, referral, or brokerage activities;
- transaction-related information necessary to facilitate referrals or introductions;
- communications and correspondence submitted through our contact or inquiry features; and
- any other personal data you voluntarily provide to us.
Where applicable, payment-related information may be collected to facilitate membership fees, commissions, or other agreed charges. Payment transactions are processed through third-party payment processors, and Virtue does not store full credit card numbers or bank account details. We may retain limited records of payment-related information such as payment status, timestamps, amounts, and invoice references for accounting, audit, and compliance purposes.
Data Obtained from Other Sources
We may obtain personal data about you from publicly available or commercially available sources and from our business partners, including:
- demographic data;
- professional or occupational information (such as profession, title, industry, or business address);
- information relating to advertisements you have viewed or interacted with; and
- referral or introducer-related data.
If you choose to log in or interact with our Services through a third-party account (such as Google, Facebook, or Apple), we may receive certain personal data from that service in accordance with your privacy settings on that platform.
Data Collected by Automated Means
We may collect data automatically through cookies, web beacons, web server logs, JavaScript, and similar technologies, including:
- Internet Protocol (IP) address;
- device identifiers and connection data;
- device type, operating system, browser type, and settings;
- referring URLs and pages visited before and after using the Services;
- pages viewed, links clicked, and interactions with content or advertisements;
- usage patterns, including dates, times, and duration of visits; and
- approximate location data derived from IP addresses (such as city or region).
We do not intentionally collect sensitive personal data (such as precise geolocation, health data, biometric identifiers, or government identification numbers) unless it is strictly necessary for a specific transaction or legal requirement and, where required, with your explicit consent. Please do not provide sensitive personal data through general webforms or email unless requested.
3. How We Use the Data We Obtain
We, or service providers acting on our behalf, use personal data collected from and about you for the following purposes:
- to provide, operate, and manage our Services, including facilitating real estate introductions and referrals;
- to create and administer user accounts;
- to process membership fees, commissions, and payments;
- to communicate with you regarding your use of the Services;
- to send promotional materials, market updates, alerts, and information about opportunities, subject to your preferences;
- to conduct surveys, market research, and analytics;
- to respond to inquiries and provide technical or customer support;
- to generate recommendations or content suggestions;
- to supplement personal data with information from publicly or commercially available sources;
- to improve and develop our Services and business operations;
- to protect against, detect, and prevent fraud, misuse, and unlawful activity;
- to protect the rights, safety, and property of Virtue, our partners, and users; and
- to comply with applicable laws, regulations, industry standards, contractual obligations, and our terms of service.
Where required by applicable law, we will obtain your consent before using personal data for specific purposes.
We process personal data where it is permitted under applicable law and necessary to: (i) provide and administer the Services and take steps you request prior to entering into a contract; (ii) perform our contractual obligations; (iii) comply with legal and regulatory obligations; (iv) protect the security and integrity of the Services and prevent fraud and misuse; and (v) where applicable, based on your consent (including for certain marketing communications and cookie preferences), which you may withdraw at any time.
We do not use personal data to make decisions based solely on automated processing (including profiling) that produce legal or similarly significant effects on you. If this changes, we will update this Notice and, where required, provide you with additional information and choices.
5. Your Choices and Rights
Your Choices
You can choose to use Virtue's Services without providing any data about yourself to us directly, but some data may be collected automatically or be requested by us so that you can take advantage of certain features on our Services. To ask us to remove your data from our marketing mailing lists, please contact us as outlined in the "How to Contact Us" section below. You also can unsubscribe from our marketing mailing lists by following the "Unsubscribe" link in our emails. Even if you unsubscribe from our marketing communications, we may still need to send you communications relating to your use of our Services, such as service announcements.
Your Rights
Subject to applicable law, you have certain rights to access, review, update, correct inaccuracies in, and/or port your personal data in our custody and control by submitting a request through our contact channels or by emailing or writing to us at the address provided in the "How to Contact Us" section. For security purposes, we will verify your identity when you request to exercise your data privacy rights.
The Right to Access and Correction
You have the right to access, correct, and update your personal data at any time.
The Right to Deletion
Under certain circumstances, you have the right to request that we delete your data. If you wish to delete the personal data we hold about you, please let us know and we will take reasonable steps to respond to your request in accordance with applicable legal requirements. Certain data may be exempt from such requests under applicable law.
The Right to Data Portability
Under applicable laws, in addition to the general right of access described above, you have, subject to certain exceptions, the right to receive a copy of your personal data in a structured, commonly used, and machine-readable format, transmit the data to another business or data controller, and depending on the circumstances, have us perform that transmission.
In addition to the rights described above, and subject to applicable UAE law (including Federal Decree-Law No. 45 of 2021 and its implementing regulations) and other applicable laws, you may have the right to (i) object to or restrict certain processing (including processing for direct marketing), (ii) withdraw consent where processing is based on consent (without affecting processing carried out before withdrawal), and (iii) request information about the legal basis and categories of recipients of your personal data. Where we receive an objection or restriction request, we will assess and respond in accordance with applicable law.
6. How We Protect Personal Data
We maintain administrative, technical, and physical safeguards designed to protect the personal data we have about you against accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use. However, no data transmission or storage, or use of the Internet, can be guaranteed to be 100% secure.
7. Data Retention
We retain personal data for as long as reasonably necessary to: (i) provide the Services; (ii) maintain our relationship with you; (iii) comply with legal, regulatory, accounting, and audit obligations; (iv) resolve disputes; (v) enforce our agreements; and (vi) protect our rights and the security of the Services. Retention periods vary depending on the type of personal data, the purposes of processing, and applicable legal requirements. Where we no longer need personal data, we will delete it, anonymize it, or securely store it and isolate it from further processing except as required by law. We may retain limited data in backups for a restricted period in accordance with our backup and security policies.
8. Transfers of Personal Data
The Services are hosted in and managed from the United Arab Emirates. Your personal data may be processed in the UAE and/or other countries in which we or our service providers operate. Some of these countries may not be deemed to have the same data protection laws as your state of residence. Applicable laws in the UAE and/or other countries may allow courts, law enforcement, and national security authorities to access personal data in certain circumstances, as permitted by law.
Where required by applicable law, we implement appropriate safeguards for cross-border transfers, which may include contractual protections and security measures designed to protect your personal data.
9. Links to Third-Party Sites, Apps, and Services
For your convenience and information, our Services may provide links to third-party sites, apps, and services that may be operated by companies not affiliated with Virtue. These companies may have their own privacy notices or policies, which we strongly suggest you review. We are not responsible for the privacy practices of any non-Virtue sites, apps, or services.
10. Changes to Our Privacy Notice
From time to time, we may change our Privacy Notice to reflect changes to our privacy practices and Services. If we modify the Privacy Notice, we will update the "Last Modified Date" and the changes will be effective as of the date we post such Notice. For material changes, we will notify you by posting a prominent notice on our Services indicating at the top of the Privacy Notice when it was most recently updated, or by other appropriate means, such as email through the email address you most recently provided to us, or if required by law, will also seek your consent to any such material changes.
12. Additional Information for California Residents
This section provides additional information for residents of California, as required by the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2023 (collectively, "CCPA").
Categories of Personal Information Collected
In the preceding 12 months, we have collected the following categories of personal information:
- Identifiers, such as name, email address, postal address, phone number, and online identifiers;
- Personal information categories listed in Cal. Civ. Code § 1798.80(e), such as name, address, telephone number, and financial information;
- Protected classification characteristics under California or federal law, such as age and gender;
- Commercial information, such as records of services purchased or considered, or other purchasing or consuming histories or tendencies;
- Internet or other electronic network activity information, such as browsing history, search history, and information regarding your interaction with our Services;
- Geolocation data;
- Professional or employment-related information; and
- Inferences drawn from any of the above categories.
Categories of Personal Information Disclosed for a Business Purpose
In the preceding 12 months, we have disclosed the following categories of personal information for a business purpose: Identifiers; Personal information categories listed in Cal. Civ. Code § 1798.80(e); Protected classification characteristics; Commercial information; Internet or other electronic network activity information; Geolocation data; Professional or employment-related information; and Inferences.
Categories of Personal Information Sold or Shared
In the preceding 12 months, we may have "sold" or "shared" (as those terms are defined under the CCPA) the following categories of personal information to third parties for targeted advertising or other commercial purposes: Identifiers; Commercial information; Internet or other electronic network activity information; Geolocation data; and Inferences.
Your California Privacy Rights
As a California resident, you have the following rights under the CCPA:
- Right to Know. You have the right to request that we disclose to you the categories of personal information we have collected about you, the categories of sources from which we collected the personal information, the business or commercial purposes for collecting, selling, or sharing the personal information, the categories of third parties to whom we have disclosed personal information, and the specific pieces of personal information we have collected about you.
- Right to Delete. You have the right to request that we delete the personal information we have collected from you, subject to certain exceptions.
- Right to Correct. You have the right to request that we correct inaccurate personal information that we maintain about you.
- Right to Opt-Out of Sale/Sharing. To exercise this right, please use the "Do Not Sell or Share My Personal Information" link (and/or "Cookie Preferences" tool) on the Services where available, or contact us using the information in Section 15.
- Right to Limit Use of Sensitive Personal Information. If we collect sensitive personal information (such as Social Security numbers, financial account information, or precise geolocation data) for purposes beyond those specified under the CCPA, you have the right to limit such use.
- Right to Non-Discrimination. You have the right not to receive discriminatory treatment for exercising your CCPA rights.
Submitting Requests
To submit a request to exercise your California privacy rights, please contact us using the information provided in the "How to Contact Us" section below. You may also designate an authorized agent to make a request on your behalf. We will verify your identity before processing your request, which may require you to provide certain personal information.
California "Shine the Light" Law
California Civil Code Section 1798.83 permits California residents to request information regarding the disclosure of their personal information to third parties for those third parties' direct marketing purposes. To make such a request, please contact us using the information in the "How to Contact Us" section.
Financial Incentive Programs
We may offer programs that provide certain benefits, such as discounts on membership fees or enhanced services, to members who provide personal information (e.g., email addresses) or participate in loyalty programs. The value of the personal information provided is reasonably related to the value of the discount or benefit offered, taking into account the expenses related to offering those discounts and benefits. Participation is voluntary, and you may withdraw from these programs at any time by contacting us.
Sensitive Personal Information
We do not use or disclose sensitive personal information for the purpose of inferring characteristics about you. If we collect sensitive personal information (as defined by the CCPA/CPRA), we will use it only as permitted by applicable law and, where required, we will provide a right to limit its use and disclosure.
13. Additional Information for Other U.S. State Residents
Residents of certain U.S. states, including Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, Delaware, Iowa, Nebraska, New Hampshire, New Jersey, and other states with comprehensive privacy laws, may have additional rights regarding their personal information. Subject to applicable state law, you may have the following rights:
- Right to Access. You have the right to confirm whether we are processing your personal data and to access such personal data.
- Right to Correction. You have the right to correct inaccuracies in your personal data.
- Right to Deletion. You have the right to delete personal data you have provided to us or that we have obtained about you.
- Right to Data Portability. You have the right to obtain a copy of your personal data in a portable and, to the extent technically feasible, readily usable format.
- Right to Opt-Out. Depending on your state of residence, you may have the right to opt out of: (1) the sale of your personal data; (2) targeted advertising; and/or (3) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
Submitting Requests
To exercise any of these rights, please contact us using the information provided in the "How to Contact Us" section. We will verify your identity before processing your request. If we are unable to honor your request, we will inform you of the reasons why.
Appeals
If we deny your request to exercise any of these rights, you may appeal that decision by contacting us using the information in the "How to Contact Us" section. We will respond to your appeal in accordance with applicable law.
Nevada Residents
Nevada residents may opt out of the "sale" of covered information (as defined under Nevada law) by contacting us using the information in the "How to Contact Us" section. We do not currently sell covered information as defined by Nevada law, but you may still submit an opt-out request, which we will honor if our practices change in the future.
14. Governing Law and Jurisdiction
This Privacy Notice and any disputes arising in connection herewith shall be governed by the laws of the United Arab Emirates and referred to the Dubai Courts. However, where you are a resident of a U.S. state that provides you with privacy rights that cannot be waived by contract, those statutory rights (and any mandatory enforcement provisions) will apply notwithstanding the foregoing.
15. How to Contact Us
If you have any questions or comments about this Privacy Notice or the manner in which we or our service providers treat your personal data, would like to exercise your choices, or would like us to update information we have about you or your preferences, please contact us as follows:
Privacy Administrator
Virtue
[Address in Dubai, UAE]
Email: [Privacy Contact Email]
If you submit a request to exercise your privacy rights, we will respond within the timeframe required by applicable law and may request additional information to verify your identity and the scope of your request. If you submit a request on behalf of another person, we may require proof of authorization.
U.S. State Privacy Requests. Depending on your state of residence, you may also be able to opt out of targeted advertising and certain data disclosures through device- or browser-based signals (such as the Global Privacy Control) where we can reasonably authenticate the signal and it is technically feasible. You may submit requests yourself or, where permitted by law, through an authorized agent; we may require proof of authorization and verification of your identity.