Privacy Policy

Effective date: 28 August 2026

This Privacy Policy explains how TOP HOUSE REAL ESTATE L.L.C (“we”, “us”, “our”) collects, uses, and protects information when you use brokki.ai (the “App”) and any related services (together, the “Service”).

By using the Service you confirm that you have read, understood, and accepted this Privacy Policy. If you disagree, please do not use the Service.

1. Who we are

The Service is provided by TOP HOUSE REAL ESTATE L.L.C, with a registered address at Shop P41, Bahar 6, Jumeirah Beach Residence, Dubai 500551, United Arab Emirates. For privacy-related questions you can reach us at klim@tophouse.one.

2. Information we collect

We only collect information that is necessary to operate the Service:

• Account information — your phone number, used to sign you in via a one-time code, and an optional display name you provide.

• Billing information — if you take a paid subscription: your plan, its status and dates, the number of seats, and the identifiers our payment provider uses for your account and invoices. Card details are not part of this: they are entered on the provider’s pages and never reach us.

• Property information you provide — details you enter into the App about a property you wish to value, such as type, size, number of rooms, condition, and similar characteristics, as well as any photographs you choose to upload.

• Service usage data — basic technical information automatically generated when you use the App: device type and operating system, app version, language, IP address, and timestamps of your activity.

• Reports we produce for you — once you complete a valuation, we store the resulting market estimate report and associate it with your account so you can access it later from your history.

We do not knowingly collect any sensitive personal data (such as health, racial, religious, or biometric information). Please do not submit such data to us.

3. How we use your information

We use the information for the following purposes:

• To provide the Service — to authenticate you, generate the market estimate reports you request, save them to your account, and let you view, share, or download them later.

• To maintain and improve the Service — to monitor performance, fix bugs, prevent abuse, and improve usability. Where we analyse usage, we use aggregated or de-identified information wherever possible.

• To communicate with you — to send service messages related to your account, such as the one-time login code or important changes to the Service.

• To comply with legal obligations — to keep records required by applicable laws, respond to lawful requests, and protect our legal interests.

We do not use your personal information for advertising. We do not sell your personal information.

4. Service providers

To operate the Service we rely on a small number of trusted service providers acting on our instructions. They process information only to perform services for us and are bound by confidentiality obligations. The categories include:

• Cloud infrastructure provider — hosts the App’s backend, database, file storage, and authentication.

• Messaging provider — delivers the one-time login codes to your phone.

• Payment provider — takes payment for subscriptions and keeps the record of them. Card details are entered directly on the provider’s own pages: we never see, receive, or store your card number, its expiry date, or its security code. The provider receives the details needed to take the payment, together with your email address, and processes them under its own privacy policy, including for fraud prevention.

• Advertising measurement (Meta Platforms) — our website uses the Meta Pixel and Conversions API to measure the effectiveness of our advertising. When you visit the website, Meta may receive technical data (pages viewed, IP address, browser information, and Meta’s own cookie identifiers). When you create an account on the website, we additionally share your phone number in hashed (irreversible) form, so Meta can attribute the sign-up to an ad. We never share your name, your properties, your clients, or any content you create. Meta processes this data as an independent controller under its own privacy policy.

• Mobile app distribution platforms — Apple App Store and Google Play, governed by their own privacy policies.

We do not authorise these providers to use your information for their own purposes.

5. Where we store your information

Your information is stored on servers operated by our cloud infrastructure provider. Depending on the provider’s region, your data may be processed outside the United Arab Emirates, including in countries that may not offer the same level of data protection as your home jurisdiction. Where this happens, we rely on appropriate safeguards required by applicable law, such as standard contractual clauses.

6. How long we keep your information

• Account data and reports — we keep these for as long as your account remains active. If you ask us to delete your account, we will delete or anonymise this information within a reasonable period unless retention is required by law.

• One-time login attempts — we keep short-lived records of recent code requests to prevent abuse; these records are deleted automatically within a short time.

• Service usage data — we retain technical logs for a limited period for security, debugging, and audit purposes.

7. Security

We use technical and organisational measures intended to protect your information from unauthorised access, alteration, disclosure, or destruction. These include encryption in transit, access controls, and regular review of our practices. No method of transmission or storage is completely secure; we cannot guarantee absolute security.

8. Your rights

Subject to applicable law, you have the right to:

• Access the personal information we hold about you;

• Correct information that is inaccurate or incomplete;

• Delete your personal information when there is no overriding reason for us to keep it;

• Restrict or object to certain uses of your information;

• Withdraw consent where we rely on consent as the basis for processing;

• Receive a portable copy of information you provided to us, in a structured machine-readable format;

• Lodge a complaint with the competent supervisory authority.

To exercise these rights, contact us at klim@tophouse.one. We may need to verify your identity before responding. We aim to respond within a reasonable timeframe and as required by applicable law.

9. Children

The Service is intended for users 18 years of age or older. We do not knowingly collect personal information from minors. If you believe a minor has provided us information, please contact us so that we can delete it.

10. Users in the European Economic Area and the United Kingdom

If you access the Service from the EEA or the UK, the following additional points apply:

• The legal basis on which we process your information is (i) the performance of our agreement with you (to operate the Service); (ii) our legitimate interests in running, securing, and improving the Service; (iii) compliance with legal obligations; and (iv) your consent where required.

• You may contact your local data protection authority if you believe your rights have been infringed.

• Where we transfer your information outside the EEA or the UK, we rely on the safeguards described in section 5.

11. Property selections shared with you

A licensed real-estate broker may prepare a personal selection of properties for you and share it with you through a private link (a “collection”). If you open such a link, the points below apply to you, even though you do not have an account with us.

• What we record — which properties in the selection you open, how long you spend viewing each property and its photos, and any properties you mark as liked or not interested. We also store a randomly generated identifier in your browser, a one-way hashed form of your IP address (never your raw IP), and basic technical data such as device type and timestamps.

• Why — so the broker who prepared the selection can see which properties interest you and follow up more helpfully. This activity is visible to that broker.

• Automated summaries — we may use an automated service to generate a short summary of this activity for the broker. The summary is based on your actions on the page; we do not send your name to that service.

• Retention — this activity is kept for up to 12 months and then deleted automatically.

If you would prefer this not to happen, you can choose not to open the link, ask the broker who shared it with you to stop, or contact us at klim@tophouse.one to stop and delete this information.

12. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. If we make material changes we will notify you within the App or by other reasonable means. The “Effective Date” at the top reflects when the latest version took effect. Continued use of the Service after that date constitutes acceptance of the updated Policy.

13. Contact

If you have any questions about this Privacy Policy or about how we handle your personal information, please contact us at klim@tophouse.one.