1. VR INVEST LLC, with number 45001026 (referred to as “DreamFlat” or “we”) takes measures for the protection and the processing of your personal data on the website (referred to as the “Website”) and the Platform (as defined in our Terms of Use).
    2. In this Privacy Policy we explain how we, as the controller, collect, if necessary share, and use personal data, and how you can exercise your rights as a data subject. This Privacy Policy should be read alongside, and in addition to, our Platform terms and conditions (Terms of Use) and our Cookie Policy.
    3. We urge you (also referred to as the "User") to read this Privacy Policy as well as our Terms of Use and Cookie Policy carefully before using this Platform. When you use the Platform, you are aware that you accept this Privacy Policy. If you don’t agree with this Privacy Policy and with the Terms of Use, you mustn’t use the Platform.
    4. Providing access to the Platform, we proceed from the assumption that you:
      1. acting on your own behalf represent the legitimate interests of a company (Business User), or are acting on your own behalf and in your own interest (Individual User) and have all the necessary authority to register on and use this Platform;
      2. provide true information about yourself to the extent necessary for use of the Platform services;
      3. are responsible for the actions you take on the Platform;
      4. are aware of and accept this Privacy Policy;
      5. are aware of and accept the Terms of Use.
    5. We do not check the user information received from you, except where such check is necessary in order for us to fulfill our obligations to you or to the Company.
    6. Capitalized terms not defined here have the same meaning as those defined in the Terms of Use.
    1. In order to implement the agreement between you and us (please refer to Terms of Use and License Agreement), and provide you with access to the use of the Platform functionality, in compliance with applicable laws, we will collect, store, aggregate, organise, extract, compare, use, and supplement your data (hereinafter “processing”).
    2. The information that we receive in connection with and within the scope of your use of the Platform (e.g. in connection with a product or service request, contact form, registration, communication with you personally online, or your use of Platform’s services), comprise the following categories:
    3. Unless your subscription has expired or this License Agreement is terminated pursuant to the terms set forth in this License Agreement, you may use the Software as follows:
    4. We use this information in order to manage and administer the Platform including providing our services to you, to fulfill our obligations under our agreement with you, as well as for the purpose of sending you automatic newsletters (exclusively with your consent).
    5. Certain information that we may also automatically collect from your device when you visit the Platform: IP address, name of the file accessed, date and time of access, amount of data transmitted, notification of successful access, web browser, device type and unique device identification numbers.
    6. We may also collect information about how your device interacted with the Platform, such as which pages were accessed and which links were clicked.
    7. By collecting this information, we can better understand who visits the Platform, where visitors come from and what content on the Platform they are interested in. We use this information for our internal analysis and to improve the quality of the Platform services and to better tailor it to the interests of our visitors. Furthermore, the data can be used to guarantee network and data security.
    8. Information that is created by you while placing requests to our technical support.
    9. We use this information in order to verify your identity and to fullfil your support request. We may also use this data in order to investigate any complaints on your behalf and to provide you with a more efficient service.
    10. Information that is received as the result of your behavioral actions on the Platform including the content you upload and create on the Platform.
    11. We use this information to improve our Services and Software, as well as the User experience (where your consent is not required).
    12. Information we received from other group companies (as further specified herein) or third-party companies that have obtained your consent or otherwise have the legal right to share such information with us (including publishing partners, platforms, advertising platforms and partners and a data aggregator). This data may include information about you and your interests, as well as other services you use, demographic information, and information about the location of your device.
    13. We use this information for marketing and analytical purposes. We process this information in accordance with this Privacy Policy, and subject to the limitations set forth in the privacy policy of the company that collected this information from you.
    14. We do not use cookies or similar technologies on our website to collect personal data.
    1. The legal basis for the collection and processing of personal data depends on the specific context in which we collect it:
      1. Contractual obligations (Art 6 para 1 lit b GDPR): Your personal data will be processed in order to manage and fulfill the contract with you.
      2. Legal obligations (Art 6 para 1 lit c GDPR): In part, we are required by statutory or regulatory obligations to process your personal data.
      3. Consent (Art 6 para 1 lit a GDPR): If we have received your consent, DreamFlat will process your data only to the extent of the consent given. You can withdraw your consent at any time with effect for the future.
      4. Legitimate interests (Art 6 para 1 lit f GDPR): Furthermore, we may process your data on the basis of legitimate interests of DreamFlat or a third party. These legitimate interests include:
        1. Effective business administration and development;
        2. Improving our processes and practices;
        3. Ensure compliance with internal guidelines and policies as well as applicable laws and business standards;
        4. to avoid or mitigate damages for you, us and third parties.
    1. Please note, that we do not collect on the Platform and do not process special categories of personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data, data concerning health or data concerning a natural person's sex life or sexual orientation.
    1. Please note, that we do not process your payments for use the Platform and have no access to your credit card information. The payment providers around the world process and store your credit card details. Although we work with payment providers, they are completely independent of DreamFlat. Please review their respective privacy policies before providing them with your data.
    2. When you make a payment, you enter your credit card details into a form provided by the payment provider that will process the payment, and this information goes directly to the payment provider's server. Your credit card information never reaches the DreamFlat servers. When you save your credit card information, it is stored on the servers of the relevant payment provider, and the payment provider provides us with a token that you can reuse for future payments. Your credit card information cannot be recovered from the token.
    3. Due to the fact that we do not process credit card data or transaction information, we are not authorized to handle complaints about these matters. Any disputed payments are the responsibility of the payment providers and banks involved in the exchange.
    1. We may share the personal data with the following recipients:
    2. with our employees who need it to fulfill contractual and legal obligations and legitimate interests, group companies (as further specified herein), external service providers (e.g. IT service providers) and partners who provide data processing services for us or who otherwise process personal data for the purposes described in this Privacy Policy (such as banks and financial service providers, insurers, financial advisors, professional consultants and external legal advisors) or who are disclosed to you when we collect your personal data. A list of group companies, service providers and partners to whom personal data is currently disclosed or who currently are processing personal information on our behalf, is available on request. All recipients are obliged to treat your data confidentially and to process it only within the framework of the provision of services;
    3. with any competent authority, such as tax, supervisory or safety authorities, or public authorities, a court or other third parties, when disclosure is necessary (i) by law or regulation, (ii) to exercise, protect or defend our statutory rights, or (iii) to protect your important interests or the important interests of another person; data is currently disclosed or who currently are processing personal information on our behalf, is available on request. All recipients are obliged to treat your data confidentially and to process it only within the framework of the provision of services;
    4. If we merge with or are acquired by another company, sell the Site, app, or business unit, or if all or a substantial portion of our assets are acquired by another company, your information will likely be disclosed to our advisers and any other prospective purchaser's advisers and will be one of the assets that is transferred to the new owner.
    5. If you publish your content on the Platform, you understand and accept that your account name will be available to other Users of the Platform.
    1. We need the abovementioned data for the performance of the obligations to you and/or in order to comply with legal obligations we are subject to. If you refuse to provide personal data which is required for the performance of the agreement or which we are obliged to process due to legal obligation it may not be possible for us to provide the Platform’s services, more specifically, the purposes listed above and/or it would significantly slow down the relevant purpose.
    1. We may share your personal data with our parent group company, DreamFlat FZ-LLC, located in Russia, to help to provide, improve and support our Services. We take appropriate security measures to ensure that your personal data remains protected in accordance with this Privacy Policy. This includes the application of the European Commission's standard contractual clauses for the transfer of personal data. In addition, such information is transmitted exclusively through secure communication channels. Further details on the appropriate safety precautions taken are available on request.
    1. Your personal data and files are stored on DreamFlat's servers and those of the companies we hire to provide services to us.
    1. We keep your personal data during the business relationship as long as this is necessary for the fulfilment of the purpose or as long as contractual or legal obligations or legitimate interests exist (e.g. to fulfil our obligations or legal storage obligations, or to assert legal claims). As soon as there are no legitimate purposes for the further storage of personal data, these will either be deleted or made anonymous. If this is not possible (for example because your personal data was stored in backup archives), we will store your personal data securely and make it inaccessible to further processing until deletion is possible.
    1. Automated decisions within the meaning of Art 22 GDPR mean that a decision that has legal effect on you or significantly affects you in a similar way is automatically made - including profiling - without verification by a natural person. We do not use automated decisions.
    1. In accordance with applicable law, you have the right to access, correct, request deletion of your personal data, to object to the processing of your personal data, and portability of your personal data, to request restriction of the processing of your personal data, and to file a complaint with the data protection authority, when you believe your data protection rights have been violated.
    2. Many of our Services allow you to edit your personal information by accessing the “my profile”, or a similar feature of the service you are using. Likewise, you can delete files or photos you have stored in our Services and Software by logging in and using the deletion functions that are available.
    3. To exercise these rights send an email to We will aim to respond to you within one month of receipt of the request. That period may be extended by two further months where necessary, considering the complexity and number of the requests.
    4. If you have unresolved concerns, you have the right to report them to your local privacy regulator or data protection authority.
    5. Upon your consent we may use your information to provide you with information and offers related to the Platform. Where we rely on your consent, you will always be able to withdraw that consent, although we may have other legal grounds for processing your information for other purposes, such as those set out above. In some cases, we are able to send you direct marketing without your consent, where we rely on our legitimate interests. You have an absolute right to opt-out of direct marketing, or profiling we carry out for direct marketing, at any time by:
      1. updating your preferences in your profile;
      2. updating your preferences in your specific website or app accounts;
      3. clicking the unsubscribe link at the bottom of our marketing emails; or
      4. contacting us using the details provided at the end of this privacy policy.
      1. We may update this Privacy Policy to reflect legal, technical or business changes. When we update this Privacy Policy, we will take reasonable steps to inform you of the importance of the changes made. You will be prompted to review any material changes to the Privacy Policy we make if and to the extent required by applicable data protection laws. You will find the date of the "last update" at the end of this Privacy Policy.