Legal
Privacy Policy
1. Controller
NEXTLEVEL CORPORATE SERVICE PROVIDER - FZCO, Building A1 / IFZA Business Park, Dubai Digital Park, Dubai Silicon Oasis, Dubai, United Arab Emirates (DIEZ License No. 67837), represented by Tassilo Peter Seitz.
Email for privacy questions and to exercise your rights: [email protected]
Representative in the EU and the UK (Art. 27 GDPR / UK GDPR): We are not established in the EU. If we appoint a representative, we will name them here. You can always contact us directly with any privacy matter.
Data protection officer: No data protection officer is currently appointed. Your contact is the controller at the address above.
2. Overview: what we process, why, and on what legal basis
| Purpose | Data | Legal basis |
|---|---|---|
| Account, sign-in, security | Email address, account ID, sign-in method (email link/password, Apple, Google), session and device details, IP address | Art. 6(1)(b) GDPR (contract/use of the service), (f) (security, preventing misuse) |
| Planner, check-up, favourites, checklists | Details you enter yourself (e.g. life stage, planned moving date, household, work situation, topics, rough budget, task status, saved places) | Art. 6(1)(b) GDPR |
| App data in your account (section 4.6): self-check, deadline dates, trial stay, checklists, decisions | Answers, expiry dates, budget and cost entries, ticks and notes you enter in the app, with the time of the last change and a random device identifier; only when you are signed in | Art. 6(1)(b) GDPR (the same data on all your devices, restoring it) |
| Document vault | Files and document status: stored on your device; only if you turn on cloud backup, also end-to-end encrypted in your account (content not readable by us; we only hold encrypted data, random identifiers, sizes and timestamps, section 4.3) | local storage at your request (section 25(2) no. 2 German TDDDG); cloud backup: Art. 6(1)(b) GDPR |
| Unlock code (B2B) | Code, time of redemption, account ID, unlocked package and term | Art. 6(1)(b) GDPR |
| Purchase, subscription and access | Package, term, purchase/expiry/renewal date, subscription status (active, cancelled, payment failed), payment status, payment provider identifiers, billing data (for businesses, where provided: company name, billing address, VAT ID) | Art. 6(1)(b) GDPR; (c) (statutory retention, tax) |
| Reminder before the end of the first or minimum term (once, 14 or, for 12 months, 30 days before) | Email address, package, renewal date and price, link to cancel | Art. 6(1)(b) GDPR (performance of the contract and information) |
| Data retention on request (data parking, website only) | Email address, account ID, booked duration, end date, payment status, Stripe identifiers | Art. 6(1)(b) GDPR; (c) (statutory retention, tax) |
| Reminder before deletion for inactivity | Email address, language, date of last sign-in or end of access, planned deletion date; log of the deletion without content (pseudonymous identifier, date, reason) | Art. 6(1)(c), (f) GDPR; Art. 5(1)(e) GDPR (storage limitation); log: (f) (evidence) |
| Cancellation ("Cancel contracts here") | Your details in the form (type of cancellation, reason for an extraordinary cancellation, name, email address, optional invoice or customer number, requested date), time of receipt, reference number, technical details used to limit abusive requests (e.g. IP address) | Art. 6(1)(b), (c) GDPR (carrying out the cancellation, duty to keep proof), (f) (abuse protection) |
| Offer after cancellation (existing-customer email) | Email address, package, cancellation status, single-use link | Art. 6(1)(f) GDPR (customer retention; section 7(3) German UWG); you can object at any time |
| Withdrawal | Your withdrawal declaration, contract details, email address, time of receipt | Art. 6(1)(b), (c) GDPR |
| AI assistant | Your messages, the latest messages of the conversation, saved conversation history, package level; in “Personal” mode also profile context and everything you have entered in the app (see section 6), never files from “My documents” | Art. 6(1)(b) GDPR (a feature you use); transfer to Anthropic with your consent (Art. 6(1)(a) GDPR) |
| Transactional emails | Email address, content of the message (sign-in link, password reset, order confirmation, notice before expiry) | Art. 6(1)(b) GDPR |
| Push notifications (app only, only with your consent) | Push token, platform, app language and version, time of registration and update, account ID if signed in | Art. 6(1)(a) GDPR; Section 25(1) TDDDG |
| Content error report ("Something wrong?") | Your note, optionally a source or link and an email address for a reply, the content concerned, language, platform and app version, a salted hash of the IP address (abuse protection); email address and hash are removed after 180 days | Art. 6(1)(f) GDPR (accuracy of content, abuse protection); email address only if you want a reply (Art. 6(1)(a)) |
| Enquiry to IFZA (only with your consent) | Name, email address, phone number, message, language, home country if given | Art. 6(1)(a), Art. 49(1)(a) GDPR |
| Newsletter (only with your consent, double opt-in) | Email address, language, place and time of sign-up and confirmation, consent text and version, hash value of the IP address | Art. 6(1)(a) GDPR, section 7(2) no. 2 UWG; proof and block list: (f) |
| Support | Your message, email address, account and purchase data where relevant | Art. 6(1)(b), (f) GDPR |
| Usage analytics (only with your consent) | Pseudonymous events (e.g. areas viewed, features used, errors), package level, app version, platform | Art. 6(1)(a) GDPR and, where applicable, section 25(1) TDDDG |
| Weather, live data, place photos | IP address and request to our Cloudflare workers | Art. 6(1)(b), (f) GDPR |
| Maps | IP address, map section (when map tiles load) | Art. 6(1)(b), (f) GDPR |
| Legal obligations, legal defence | Booking and contract data | Art. 6(1)(c), (f) GDPR |
| Partner area for businesses (section 7.3): reviewing applications, partnership, publication in the directory, emails, abuse protection | Company details, contact person’s details, contract and review data, IP hash | Art. 6(1)(b) GDPR; licence reminder also (f); abuse protection (f); retention of invoices (c) |
You are not obliged to provide data; without an account and the data needed for a given service we cannot offer certain features (e.g. planner, purchase). We do not make automated individual decisions with legal effect (Art. 22 GDPR). We do not sell your data and do not use it for third-party advertising.
3. Account and sign-in
You can register with an email link or password and, where offered, with "Sign in with Apple" or "Sign in with Google". We process your email address and an account identifier. From Apple/Google we receive only the details needed to sign in (email address or private relay address, identifier). Sign-in, database and session management run on Supabase. To prevent misuse and to limit simultaneous sessions, we store session and device details.
Where the app offers sign-in with Face ID, Touch ID or a comparable device feature and you turn it on, the biometric data stays in your device's secure storage and is not transmitted to us.
4. Planner, check-up and local data
4.1 Planner (roadmap) and profile: on our servers
Your entries in the planner (roadmap: task status, dates) and the profile details used for it (e.g. life stage, household, planned moving date) are linked to your account and stored with Supabase so you can use them on several devices. Other settings may additionally be stored locally on your device. Please do not enter special categories of data (Art. 9 GDPR, e.g. health, religion).
4.2 Deadline reminders: data in your account, reminder on your device
Expiry dates you enter (e.g. visa, Emirates ID, tenancy, health insurance) and your reminder settings are stored on your device and, when you are signed in, also in your account (section 4.6), so they are back on a new device. The reminder itself is a local notification from your device; it does not run through a server, Apple Push or Firebase. On a new device the app schedules the reminders again; you may need to allow notifications there again. We ask for notification permission only when you turn reminders on. In the web version there is a calendar export as a file download instead. We do not analyse this data. In addition: if you use the AI assistant in “Personal” mode, only the type of deadline and the number of days until it expires (not the date) are sent to the assistant with your question (section 6).
4.3 Document vault: on your device, optionally end-to-end encrypted in the cloud
The vault stores the status of your documents (e.g. missing, available, legalised) in local storage and attached photos or PDF files in the local database (IndexedDB) of your device or browser. Without cloud backup, the files are not uploaded and not backed up; we have no access to them, and you are responsible for backups yourself. The app is designed so that vault files on a device are removed when you delete your account in the app or switch to another account. To be sure, you can also delete the files yourself, uninstall the app or clear your browser data.
Cloud backup (optional): If you turn on "Back up vault in the cloud", the app encrypts your files, the file names and the document status on your device before they are transferred (end-to-end encryption with AES-256-GCM). The key is derived from your vault password or your recovery key; the password, the recovery key and the decrypted key never leave your device. So that the backup runs without entering the password again, the app keeps the key in a non-readable form in the app storage of this device; it is deleted there when you sign out, switch accounts or turn off the cloud backup. We only hold encrypted data, linked to your account ID: the encrypted files, an encrypted index, the encrypted (wrapped) keys, technical details of the method (salt, number of iterations) and, for each object, a random identifier, its type (file or index), its size and a timestamp. We cannot read the content and know neither your vault password nor your recovery key. If you lose both, the data in the cloud can no longer be opened; we cannot restore it either.
Where: in the file storage of Supabase in the EU region Frankfurt (sections 11 and 12), at most 50 MB per account, only accessible with your sign-in. The transfer is additionally encrypted via HTTPS. Purpose and legal basis: backing up your vault and restoring it on other devices, at your request (Art. 6(1)(b) GDPR).
Deletion: You can end the cloud backup at any time under "My documents" with "Turn off cloud backup"; we then delete all encrypted data of your vault from the server, and everything on your device is kept. Files you delete in the app are also removed from the cloud with the next backup. When your account is deleted (section 16) or an inactive account is deleted (section 14), the cloud vault is deleted completely; an automatic deletion routine removes the files from storage promptly. If your package ends, the app stops backing up; the encrypted data is kept until you turn off the cloud backup or the account is deleted.
File backup: You can also save the vault as an encrypted file ("Back up vault as a file"). The file is created on your device, encrypted with a password of your choice and not transferred to us. You decide where to keep it (e.g. in a cloud storage service); the terms of that provider apply there.
4.4 Self-check: in your account
Your self-check answers are stored on your device and, when you are signed in, in your account (section 4.6). The result is orientation, not a decision about you. If you use the AI assistant in “Personal” mode, only the traffic-light colour per area (not your individual answers) is sent to the assistant with your question (section 6).
4.5 Unlock codes (B2B)
When you redeem a code on the website, our server (Supabase) checks the code and links the unlocked package to your account. We store the code, time of redemption, your account ID, package and term. We do not pass any details about you to the company or partner that issued the code. Where applicable, we share aggregated figures without personal data with them (e.g. how many of their codes have been redeemed).
4.6 App data in your account (release 1.1)
What: When you are signed in, the app also stores the data you enter in the app in your account. This includes in particular your Dubai profile, your self-check answers, deadline dates and reminder settings, budget and actual costs in the trial-stay studio, saved places and trial-stay details, the “Before you fly” checklist, your visa route, ticks in checklists and roadmap decisions (e.g. your approach to health insurance, without health details) and facts from the fit test and planning. For each entry we store the time of the last change and a random device identifier (not a manufacturer device number).
Why: So that one account gives you the same state on all your devices and you can restore your data after changing phones, reinstalling the app or signing out. If you change the same entry on two devices, the most recent change applies.
Where: with Supabase (section 12), linked to your account and protected by access rules so that only you can access it with your sign-in. Without signing in (guest) we transfer nothing. The transfer is encrypted (HTTPS).
What not: files and status in the document vault (except encrypted via the cloud backup, section 4.3), sign-in data and session tokens, biometric data and drafts of forms with contact details (e.g. the IFZA enquiry) are not stored in your account.
Deletion: If you delete an entry in the app, it is also deleted in your account. Simply signing out keeps the data in your account and removes it from the device. When the account is deleted (section 16) and when inactive accounts are deleted after 12 months (section 14), all app data in the account is deleted completely. Legal basis: Art. 6(1)(b) GDPR.
5. Purchase and payment
Website: payments are processed by Stripe (Stripe Payments Europe, Ltd., Ireland, and other companies of the Stripe group, including Stripe, Inc., USA). Stripe processes payment data (card/payment details, name, email, billing country, address where applicable, for businesses company name and VAT ID) as an independent controller for payment processing, fraud prevention and legal obligations, and partly on our behalf. We do not receive full card details, only purchase confirmation, payment status and identifiers. For contracts with renewal, Stripe stores your payment method for the follow-up payments that fall due and shows you your invoices in the customer portal ("Payment method and invoices"); you do not cancel in the portal but through "Cancel contracts here". See also Stripe's privacy information (stripe.com/legal/privacy-center).
App Store / Google Play: Apple or Google handles purchases as the seller. Via RevenueCat we receive which package your account has, when it starts and ends, and identifiers (your account ID as app user ID, receipt data, store country, product ID). RevenueCat, Inc. (USA) processes this data on our behalf. For subscriptions this includes the renewal and cancellation status and notices about payment problems reported by the store. The store handles cancellation and payment of a store subscription.
Access check: your package status and contract status (source Stripe/App Store/Google Play, package, status, end of the current period, cancellation status) are stored in our database (Supabase) and checked on the server; in the app, "My package" shows only your own data.
Tax: where needed to handle value added tax or comparable taxes and to meet tax evidence requirements, we process details about your country (e.g. billing country, country of the payment card, country derived from the IP address, without storing the IP address itself) and keep them for the period required by law.
6. AI assistant
Consent: Before you send your first message, the app asks whether you agree to your data being sent to our AI provider. Nothing is sent without your consent. You can withdraw your consent at any time in your profile (“AI assistant”) with effect for the future; the app will then ask again before your next message.
When you use the assistant, the following happens:
- What the app sends: your message, the latest messages of the conversation (currently up to 10), the app language and the area of the app you have open. Only if you choose “Personal”: in addition, everything you have entered in the app: profile (goal, timeframe, stage, household, home country), self-check answers (except the questions on medication and personal circumstances, where only the traffic-light colour is sent), mini cost check and cost calculator, net comparison result (only net and disposable-income ranges today and in Dubai, no gross salaries), package tier, all roadmap tasks with status, checklists with status, favourites, type, name and remaining days of deadlines you entered, chosen visa route, trial-stay studio (duration, districts, ratings of everyday tests, budget and actual costs, notes shortened to 200 characters, decision), your preferred currency and, from “My documents”, only document type and status. Files, file names and content from “My documents”, your email address, passwords and payment details are never sent. The scope is limited to about 12 KB per request.
- What the server also retrieves: the request server, a Cloudflare worker (AI proxy) we operate, checks your sign-in, package and usage limits with Supabase. Only in “Personal” mode, and only if your question relates to it, it also reads from your account using your sign-in: saved budget values from the roadmap, the status of your roadmap steps and checklists, your favourites (communities, schools, places) and your trial-living tests with ratings and short notes.
- Transfer to Anthropic: the proxy combines these details with excerpts from the app content into one request and forwards it to Anthropic (Anthropic PBC, USA, provider of the “Claude” language model). The answer is returned to you. The transfer to the USA is covered by Anthropic’s data processing terms with standard contractual clauses (SCCs), where applicable (section 12). Anthropic processes the requests under its terms for commercial API use; according to Anthropic, API data is not used to train its models and is stored only for a limited time, for example to detect misuse.
- On the proxy we do not store conversation content, only technical data needed for operation and troubleshooting (e.g. response times, error codes, number of context details used).
- Conversation history: when you are signed in, we store your conversations (title, questions, answers and suggested app areas) in your account at Supabase so you can open them again later; only you have access. You can delete individual conversations in the app via “Conversations”. When your account is deleted, all conversations are deleted. In addition, the current conversation is kept locally on your device for the session.
- The chat shows a visible notice that you are chatting with an AI. Answers are generated automatically and may be wrong. They are not advice. Please do not enter sensitive data.
- We do not transmit ID, payment or account numbers; the proxy removes values that look like such numbers from the context.
The legal basis is Art. 6(1)(b) GDPR (a feature you use). In addition, data is sent to Anthropic only with your consent (Art. 6(1)(a) GDPR), which you can withdraw at any time (Art. 7(3) GDPR).
7. Emails
We send sign-in links, password resets, order and contract confirmations, acknowledgements of withdrawal and of cancellation (with date, time and end date of the contract), a one-time reminder before the first or minimum term ends (14 days before, 30 days before for 12 months), invoices or receipts after every charge (sent by Stripe), notices about failed payments, notices about the end of access and the reminder before an inactive account is deleted (section 14). For that reminder we use your email address, your language and the date of your last sign-in or the end of your access. Emails are sent via Resend (Resend, Inc., USA; sending region EU-West, Ireland) as our processor; some system sign-in emails may also be sent directly via Supabase. We send marketing newsletters only with your separate consent (section 7.2). The exception is the one-time offer after your cancellation (currently 30% off for 3 months): we send it to you as an existing customer at the email address you gave when you bought, for our own similar services (section 7(3) German UWG, Art. 6(1)(f) GDPR). You receive it only after a cancellation and never before. You can object to your address being used for such offers at any time ([email protected]); we point this out in the email. No further advertising follows from it.
7.1 Enquiry to IFZA (company setup)
In the app or on our website (guides) you can send an enquiry to IFZA (International Free Zone Authority, Dubai) if you want to set up a company in a free zone. We process your first name, last name, email address, phone number, your optional message, the language and, if given, your home country. To prevent misuse we also store a shortened, non-reversible value (hash) of your IP address.
- Purpose: passing your contact details to IFZA so that it contacts you directly, and keeping a record of the referral.
- Legal basis: your consent (Art. 6(1)(a) GDPR), which you give in the form. If the email address you enter is not the confirmed address of your account, we first send an email with a confirmation link (double opt-in). We pass on the data only after you confirm.
- Recipient: IFZA in Dubai (UAE). IFZA then processes your data as an independent controller. There is no EU adequacy decision for the UAE, so the level of data protection may be lower than in the EU. The transfer is based on your explicit consent (Art. 49(1)(a) GDPR); this paragraph informs you of the risks.
- Withdrawing consent: you can withdraw your consent at any time by email to [email protected]. Transfers already made are not affected; we will inform IFZA of your withdrawal.
- Retention: up to 24 months from the enquiry, then deletion. We do not pass on unconfirmed enquiries; the confirmation link expires after 48 hours, and we try to delete such enquiries promptly afterwards, at the latest when the retention period above ends.
We may receive a referral commission from IFZA. This costs you nothing.
7.2 Newsletter (only with your consent)
On the website and in the app you can sign up for our newsletter. It occasionally contains tips on moving to Dubai, news about new guides and offers from Unser Dubai. Signing up is voluntary and is not a condition for a purchase or for using the app.
- Data: email address, language, where you signed up (page of the website or area of the app), time of sign-up and of confirmation, wording and version of the consent text, the link to your account where applicable and, to prevent misuse, a non-reversible hash value of your IP address (not the IP address itself).
- Purpose: sending the newsletter and keeping proof of your consent.
- Legal basis: your consent (Art. 6(1)(a) GDPR; for marketing emails also section 7(2) no. 2 German UWG and, in the UK, regulation 22 PECR). We store the proof of consent on the basis of our legitimate interest in being able to demonstrate consent (Art. 6(1)(f) in conjunction with Art. 7(1) GDPR). We do not send marketing to customers without consent (the existing-customer exception): without your consent you will not receive the newsletter.
- Double opt-in: after you sign up we send you an email with a confirmation link. You are only signed up after you click it. This also applies if you are signed in to the app. The link is valid for 7 days.
- Unsubscribing and withdrawing consent: at any time with effect for the future, using the unsubscribe link in every email (one click, no sign-in), in the app under Profile and Settings, or by email to [email protected]. Processing carried out before you withdraw remains lawful.
- Block list: after you unsubscribe we keep your email address and the time of unsubscribing on a block list so that you do not receive the newsletter any more (Art. 6(1)(f) GDPR). Signing up again requires new consent and a new confirmation. You will still receive emails about a purchase or your account.
- Analysis: we do not track whether you open individual emails or click links in them.
- Recipients: sending via Resend (section 12). For sending the newsletter we may also use rapidmail (rapidmail GmbH, Freiburg im Breisgau, Germany; according to the provider, processing on servers in Germany), in that case as our processor. If so, we transfer only confirmed sign-ups there (email address and time of confirmation) and remove the entry when you unsubscribe.
- Retention: we delete unconfirmed sign-ups after 30 days. We keep confirmed sign-ups until you unsubscribe. After that we keep the proof of consent until the end of the regular limitation period (usually 3 years from the end of the year in which you unsubscribed). We keep the block-list entry for as long as it is needed to respect your unsubscribe request.
7.3 Partner area for service providers (businesses)
Businesses can apply on unser-dubai.com/en/partner for a paid listing in our partner directory. This section concerns the data of applicants and partners; app users are not affected.
- Which data: company details (company name, category, languages, emirates, trade licence details with number, emirate, authority and expiry date, for real estate agents the RERA BRN, for financial and investment advice the regulator and licence number, website, business email and phone, short profile, logo), details of the contact person (first and last name, email, optional phone), contract data (package and billing cycle, time and version of acceptance of the Partner Terms, date of our licence or register check, status of the partnership, subscription status and customer ID at Stripe, internal review notes) and, for abuse protection, a check value (hash) of the IP address formed with a secret value. We do not store the IP address itself.
- Purposes and legal bases: reviewing the application (trade licence, for real estate agents the RERA registration, for financial advice the licence in the regulator’s register), concluding and performing the partnership and publishing the company details in the directory (website, later the app, public data feed for these channels): Art. 6(1)(b) GDPR. Emails to the contact person that belong to the partnership (confirmation of receipt, approval with start link or rejection with reasons, confirmation of the start, notices about failed payments and the end of the contract): Art. 6(1)(b) GDPR. Reminder before the trade licence on file expires and notice of a pause because of an expired licence: Art. 6(1)(b) GDPR and our legitimate interest in only showing partners with a valid licence (Art. 6(1)(f) GDPR). Abuse protection through the IP hash and limiting applications: Art. 6(1)(f) GDPR. Invoices and statutory retention: Art. 6(1)(c) GDPR.
- What is public: only the company details of the listing (company name, category, languages, emirates, profile, logo, website, business email and phone, emirate of the licence, for real estate agents the RERA BRN, for financial advice the regulator and licence number) and whether we have checked the licence or register. The contact person’s name and contact details, the trade licence number, internal notes and payment data are not public. Please do not enter a private address as the business contact.
- Recipients: Supabase (database, file storage for the logo, server functions), Stripe (payment and invoices, separate controller), Resend (sending emails), Pushover (internal message to us about a new application or a status change with company name, category and reference; for sole traders the company name may contain a personal name), Cloudflare (delivery of the website). For registered office, place of processing and safeguards see section 12.
- Retention: see section 14 (“Partner area”).
- Statistics and monthly report: Partners receive a monthly email report with views, clicks per type and the number of enquiries via the form, plus a personal link (no sign-in, valid for 45 days) to the statistics of the current month. The statistics contain no user data. Legal basis: contract (Art. 6(1)(b) GDPR).
7.4 Enquiries to partners in the partner directory
In the partner directory (website, and in the app from version 1.2) you can send a partner a message using the “Send enquiry” form.
- Which data: name, email address, optional phone number, your message, the chosen partner, language, time and wording of your consent, time of confirmation and, for abuse protection, a check value (hash) of the IP address formed with a secret value. We do not store the IP address itself.
- Process (double opt-in): After sending, you receive an email with a confirmation link (valid for 48 hours). Only after you confirm the link do we pass your details on to the partner. Without confirmation, nothing is passed on.
- Disclosure and legal basis: After your confirmation we send your details by email to the partner’s business email address (replies go directly to you). The legal basis is your consent (Art. 6(1)(a) GDPR). Partners are businesses in the United Arab Emirates; there is no EU adequacy decision for the UAE, so a level of data protection comparable to the EU is not ensured. The transfer is based on your explicit consent (Art. 49(1)(a) GDPR). The partner is itself responsible for any further processing of your data.
- Emails to you: confirmation link and notice that your enquiry has been passed on (Art. 6(1)(a) and (b) GDPR). Abuse protection through the IP hash and limiting enquiries: Art. 6(1)(f) GDPR.
- Withdrawal: You can withdraw your consent at any time with effect for the future ([email protected]). We cannot retrieve details already sent to the partner; please contact the partner directly for this.
- Referral code: For each partner, the directory shows a code (e.g. “UD-…”). If you quote it when contacting the partner directly, the partner knows you came via Unser Dubai. We do not learn about this.
- Clicks and views: We count how often a listing was shown and how often a partner’s website, phone, email or WhatsApp was clicked, per day as a plain number. We store neither the IP address nor any identifier, no cookie and no information about your device; whether a listing has already been counted in your session is only remembered by your browser (sessionStorage, deleted when you close the tab). Clicks on a partner’s website go through our redirect, which adds campaign parameters to the partner’s address (utm_source=unserdubai, utm_medium=partner, utm_campaign=partner name), so the partner can see in its own analytics that the visit came from Unser Dubai. Legal basis: legitimate interest in reporting to partners without personal data (Art. 6(1)(f) GDPR); for access to session storage, it is technically necessary to avoid double counting.
8. Usage analytics (only with consent)
The app asks whether you allow pseudonymised usage statistics. Without your consent no analytics events are recorded or sent. With consent we record pseudonymous events (e.g. area viewed, feature used, errors, purchase steps, package level, app version, platform), no content (no search text, no AI messages, no amounts, no entries). The events go to our own backend on Supabase ("first party"). No external analytics provider is used. You can withdraw your consent at any time in the settings with effect for the future. We keep event data for no more than 14 months.
9. Maps
The map view loads map tiles from OpenFreeMap (openfreemap.org), a free map service based on OpenStreetMap data (rendered with MapLibre). Your IP address and the requested map section are sent to its operator; its servers may also be located outside the EU. We pass on no other data for this. The app does not request your location. External links (e.g. to Google Maps or Apple Maps) open those providers only when you click.
10. Notifications
10.1 Reminders on your device
Deadline reminders (section 4.2) are local notifications from your device. They are not sent via our servers, and we do not store a push token for them. You can turn them off at any time in the app or in your device settings.
10.2 Push notifications (only with your consent)
Purpose: In the iOS and Android app you can receive push notifications from us, for example a note shortly before your package ends or occasional news about Unser Dubai and your move. We do not send advertising for other companies. The web app does not send push notifications.
Consent: The app does not ask on first launch, only after you have used it for a while. First, a window of our own explains what this is about. Only if you choose "Yes, please" there does your device's system window appear, in which you allow notifications. The legal basis is your consent (Art. 6(1)(a) GDPR; for Germany also Section 25(1) TDDDG).
Data: Your device receives a push token from Apple (Apple Push Notification service) or Google (Firebase Cloud Messaging), a random identifier used to deliver messages to this device. We store the push token together with the platform (iOS or Android), app language, app version, the time of registration and of the last update and, if you are signed in, your account ID. The account ID lets us send notifications that fit your package. We do not use content from deadline reminders, the document vault or the self-check for this.
Recipients: To deliver a notification we transmit the push token and the text of the notification to Apple Inc. (USA) or Google (Google Ireland Limited, Ireland, and Google LLC, USA), whose services deliver it to your device (section 12).
Withdrawal: You can turn push notifications off at any time in the app's profile under "Push notifications" or in your device's notification settings. This does not affect the lawfulness of processing before the withdrawal. If you turn notifications off in the app or sign out, we deactivate the token and remove the link to your account. If Apple or Google reports a token as invalid (for example after the app has been deleted), we deactivate it as well. We delete deactivated tokens after 90 days at the latest, and immediately when the account is deleted.
11. Hosting, server logs, security
The website and the web app are delivered via Cloudflare (Cloudflare, Inc., USA; global network). This technically requires processing your IP address, time, requested address and device details (server logs). Legal basis: Art. 6(1)(f) GDPR (secure and stable operation). Database and sign-in are hosted by Supabase in the EU region (Frankfurt, AWS eu-central-1). We use technical and organisational measures (encryption in transit, access restrictions, authentication of server calls).
For internal operational notifications to us (e.g. "new registration", "payment received", "new enquiry") we use Pushover (Pushover, LLC, USA). These messages contain no names, email addresses or account identifiers, only general details such as the type of event and, where applicable, country and language.
12. Recipients and third countries
| Service | Purpose | Location / processing | Safeguard for third countries |
|---|---|---|---|
| Supabase | Sign-in, database, server functions, file storage (only for the end-to-end encrypted cloud vault), usage analytics (first party) | Supabase, Inc. (USA); data in the EU region Frankfurt (eu-central-1) | Data processing agreement; standard contractual clauses (SCCs) or EU-US Data Privacy Framework (DPF), where applicable |
| Cloudflare | Hosting, network, AI proxy, weather/live data and place photo workers | Cloudflare, Inc., USA, global | Data processing agreement; SCCs or DPF, where applicable |
| Anthropic | Language model for the AI assistant | Anthropic PBC, USA | Data processing terms; SCCs, where applicable |
| Stripe | Payment and invoices (website), for businesses also company name, billing address, VAT ID | Ireland/USA | Independent controller; SCCs or DPF, where applicable |
| RevenueCat | Managing purchases/access (iOS/Android) | RevenueCat, Inc., USA | Data processing agreement; SCCs or DPF, where applicable |
| Apple / Google | Sign-in (optional), app store purchases | Ireland/USA | Independent controllers |
| Apple / Google (push) | Delivery of push notifications, only with your consent (section 10.2) | Apple Inc., USA; Google Ireland Limited, Ireland, and Google LLC, USA | Under the respective provider's terms; SCCs or DPF where applicable |
| Resend | Sending emails | Resend, Inc., USA; sending region EU-West (Ireland) | Data processing agreement; SCCs or DPF, where applicable |
| rapidmail (where used) | Sending the newsletter, confirmed sign-ups only (section 7.2) | rapidmail GmbH, Freiburg im Breisgau, Germany; servers in Germany (provider's statement) | Data processing agreement; no transfer to a third country |
| Pushover | internal operational notifications; without names, email addresses or account IDs of users; in the partner area with company name, category and reference (section 7.3) | Pushover, LLC, USA | no transfer of contact details; company details in the partner area based on Art. 6(1)(f) GDPR; SCC where applicable |
| Partners in the partner directory | answering your enquiry, only after your consent and confirmation (section 7.4) | businesses based in the UAE | partner’s own responsibility; consent under Art. 49(1)(a) GDPR |
| OpenFreeMap | Map tiles | Free project openfreemap.org; servers may be outside the EU | IP address and map section only; Art. 6(1)(f) GDPR |
| IFZA (International Free Zone Authority) | Handling your company setup enquiry, only with your consent (section 7.1) | Dubai, UAE | IFZA as independent controller; consent under Art. 49(1)(a) GDPR |
Which safeguard applies in each case depends on the contract terms of the respective service. On request we will tell you which safeguard is used and, where possible, provide a copy.
United Arab Emirates: we, the controller, are established in the UAE. There is no EU adequacy decision for the UAE. We process your data on the legal bases set out in this policy, apply the GDPR or UK GDPR where they apply to our service, and take the measures described in section 11. Where data goes to processors in third countries, we use the safeguards listed in the table.
insurance4expats (Verus Vorsorge GmbH): insurance4expats is offered by Verus Vorsorge GmbH, in which a founder of Unser Dubai holds an interest. The app passes no data to Verus Vorsorge GmbH and contains no enquiry form. The link to insurance4expats.com, marked as an advertisement, carries only campaign parameters (source "unserdubai-app", place in the app), no personal data. When you open the link you leave the app; Verus Vorsorge GmbH is responsible for processing on its website. For users who have not yet moved, the app also shows a card marked “Advertisement” with links to book an initial consultation (Calendly), to the website and to the Instagram profile of insurance4expats. These links also carry only campaign parameters and no personal data; the app sends nothing. The respective providers are responsible for processing on those pages (Calendly LLC, USA, and Meta Platforms Ireland Ltd. for Instagram). If you have consented to usage analytics (section 8), we count pseudonymously that a card was shown or a link was opened.
We do not sell personal data.
13. Cookies and local storage
We use no tracking or advertising cookies. The app and the web app store data locally on your device (localStorage, sessionStorage where applicable, IndexedDB for vault files) and, for sign-in, session tokens. This storage is technically necessary (sign-in, language setting, checklist progress, favourites, unsaved planner entries, conversation history, cached package status, consent status). Legal basis: section 25(2) no. 2 TDDDG and Art. 6(1)(b), (f) GDPR. Usage analytics (section 8) only runs with consent. You can delete local data by signing out, deleting your account or using your browser/device settings. When you are signed in, much of this data is also stored in your account (section 4.6).
14. Retention
- Account and profile data: until the account is deleted. If there has been no active access for 12 months (no running package or subscription) and you have not signed in during that time, we delete the account and associated data; for free accounts: 12 months without signing in (storage limitation, Art. 5(1)(e) GDPR). About 30 days beforehand we remind you by email with the deletion date; signing in or buying a new package prevents the deletion. If you book paid data retention on the website (Terms of Sale section 12), the retention period is extended by the booked time (from the purchase or from the deletion date that would otherwise apply, whichever is later); payment is processed via Stripe, and we remind you again about 30 days before it ends. Purchase and billing data are excepted (see below).
- Planner and history data: until you delete it or the account is deleted.
- AI conversation history: until you delete the conversation in the app, at the latest until the account is deleted (section 6).
- Purchase, billing, withdrawal and cancellation data (including the time of receipt and reference number of the cancellation): for the applicable statutory retention periods (depending on the law, up to 10 years), then deletion. This also applies after the contract has ended or the account was deleted, where we need the data as proof.
- Log of deletions of inactive accounts (pseudonymous identifier, date, reason, no content): kept as evidence of lawful deletion for 3 years, then deleted.
- Offer after cancellation: the link can be used once and expires after acceptance or expiry; we keep the proof that the offer was made together with the cancellation data.
- Unlock code redemption: like purchase data where needed for evidence and settlement with the partner, otherwise until the account is deleted.
- Support requests: up to 3 years after the request is closed.
- Server logs: short-term, as a rule no longer than 30 days, unless needed longer to investigate a security incident.
- Analytics events: no more than 14 months (section 8).
- Push tokens: as long as push notifications are on; after you turn them off, sign out or the token is reported invalid, no more than 90 days; immediately when the account is deleted (section 10.2).
- Enquiries to IFZA: up to 24 months (section 7.1).
- Newsletter: unconfirmed sign-ups 30 days; confirmed sign-ups until you unsubscribe; proof of consent after that usually up to 3 years from the end of the year you unsubscribed; block list for as long as needed to respect your unsubscribe request (section 7.2).
- App data in your account (section 4.6): until you delete it in the app or the account is deleted (including deletion for inactivity).
- Local data on your device (e.g. vault files on the device, scheduled reminders, unsaved entries): until you delete it, uninstall the app, clear your browser data or delete the account in the app.
- Cloud vault (end-to-end encrypted, section 4.3): until you turn off the cloud backup or the account is deleted; individual files until you delete them in the app.
- After a package expires the account remains as a free account until you delete it or we delete it for inactivity (see "Account and profile data").
- Partner area (section 7.3): rejected applications including the uploaded logo 180 days after the decision; IP hash 180 days; a partner’s data for the duration of the partnership and 24 months after the contract ends. We then delete the partner record, the subscription status and the logos and anonymise the application: the contact person’s details, email and phone details, profile texts and logo are removed; we keep the company name, category, licence details and the dates of our checks as proof that we checked before accepting the partner. Invoice and payment data at Stripe for the statutory retention periods. Deletion runs automatically every day. During a pause or after removal, the listing is immediately no longer publicly visible.
- Enquiries to partners (section 7.4): unconfirmed enquiries 30 days, confirmed ones up to 24 months after receipt (proof of consent), then automatic deletion. Counts (views, clicks, without personal data) 36 months.
15. Your rights
Under the GDPR (and, where applicable, the UK GDPR) you have the right of access (Art. 15), rectification (Art. 16), erasure (Art. 17), restriction of processing (Art. 18), data portability (Art. 20) and to object to processing based on legitimate interests (Art. 21). You can withdraw consent at any time with effect for the future (Art. 7(3)); this does not affect the lawfulness of processing before the withdrawal. Please contact [email protected]; we usually reply within one month.
You have the right to lodge a complaint with a data protection supervisory authority, in particular in the EU/EEA state of your residence, place of work or the alleged infringement; in the UK with the Information Commissioner's Office (ICO).
16. Deleting your account and data
You can delete your account in the app under "Profile → Delete account" (for security, a recent sign-in or, with Apple, a new confirmation is required) or request deletion by email to [email protected]. We delete account and sign-in data, profile and planner data on the server, the app data in your account (section 4.6) and your link to packages; vault files stored locally on the device used are also meant to be removed (see section 4.3). You delete local data on other devices there by uninstalling or clearing browser data. Data we must retain by law (e.g. purchase and billing data) is blocked and deleted when the period ends. We ourselves delete accounts without active access and without sign-in after 12 months (section 14). You manage App Store or Google Play purchases with the respective store; deleting our account does not refund a purchase (see the Refund Policy). Apple, Google, Stripe and other independent controllers delete your data under their own rules.
17. Minimum age
The service is intended for people aged 18 and over. We do not knowingly collect data from children.
18. Notes for specific regions
United Kingdom: where the UK GDPR applies, processing is based on the grounds set out above; your rights and the right to complain to the ICO are in section 15.
United States: we do not sell or "share" personal data within the meaning of US privacy laws (e.g. the California CCPA/CPRA) and do not use sensitive data for purposes other than operating the app. Where such laws apply to you, you can request access, deletion and correction by email to [email protected]; we will not discriminate against you for doing so.
Other countries: users in other countries (e.g. Russia, Ukraine, Türkiye) may be covered by additional local data protection rules. We apply them where they apply to our service. Please send questions to [email protected].
19. Changes
We update this policy when services or the law change. The current version is available in the app and on the website; we will inform you of material changes.
As of October 2026 (17 Oct 2026), version 1.2