1. Who we are
Luxe Signature Holiday Homes LLC ("we", "us") operates the Luxe PM property-management system, comprising the website at luxepm.online and the Luxe PM mobile application. We are the data controller for the personal data described here.
Golden Mile, Palm Jumeirah, Dubai, United Arab Emirates
Email: director@luxesignatureholidayhomes.ae
Telephone: +971 58 824 5493
2. Who this policy is for
Luxe PM is an internal business tool. The mobile application is a single application carrying four jobs — property management, letting agents, housekeeping and maintenance — and a person sees only the one their account is for. Two different groups of people appear in it, and they are not treated the same way:
- Staff users. Employees of Luxe Signature who sign in to the application. Accounts are created by a director; the application does not offer public registration.
- Tenants, landlords and agents. People whose details our staff record in order to manage a tenancy. They do not have accounts in the application, but their personal data is held in it, and the rights in section 8 belong to them.
3. What we collect
From staff users
| Account | Name, work email address, assigned role, and the units a junior administrator is scoped to. |
| Activity | Records of changes made in the system, so an amendment can be traced to the person who made it. |
| Attendance | Housekeeping team members only. The time a shift is started and ended, the photograph taken at that moment, and the place it was marked from. Held so a shift can be confirmed as worked, and seen only by that person's supervisors. |
About tenants, landlords and agents
| Identity | Full name, gender, nationality, date of birth and occupation. |
| Contact | Telephone number, email address, and an emergency contact's name, relationship, telephone and email. |
| Identity documents | Emirates ID number and expiry date; passport number, issuing country and expiry date; and photographs or scans of those documents. Under UAE law these are sensitive personal data and we treat them accordingly. |
| Tenancy | Lease dates, rent and fees, deposits, invoices, payments, and signed tenancy contracts. |
| Images | Photographs of payment receipts and transfer confirmations, and photographs of maintenance issues and completed work. |
On your device
The mobile application stores your sign-in session in the device's secure keystore (iOS Keychain, Android Keystore), a cached copy of recently viewed figures so the application works without a signal, and a record of which alerts you have read or dismissed. All of it is removed when you sign out or clear the application's saved data in Settings.
4. What we do not do
5. Why we hold it, and on what basis
| To manage tenancies | Performance of the tenancy contract: issuing invoices, recording payments, returning deposits and handling maintenance. |
| To meet legal duties | Compliance with UAE law, including Department of Economy and Tourism holiday-home permit requirements, tenant registration, and tax and accounting obligations. |
| To run the business | Our legitimate interest in operating the portfolio, reporting on it and preventing fraud. |
| Emergency contacts | Our legitimate interest, and the vital interests of the tenant, in being able to reach somebody in an emergency. |
6. Permissions the mobile application asks for
| Camera | To photograph payment receipts, identity documents, maintenance issues and the condition of a unit, and for the photograph a housekeeping team member takes when starting a shift. Used only when you choose to take a photograph. |
| Photo library | To attach an existing photograph to a payment, tenant record or maintenance case. We read only the images you select; we never browse your library. |
| Location | Housekeeping only. Read at the moment a team member starts or ends a shift, to record that attendance was marked at the unit. It is read while the application is open and you are marking attendance, never in the background and never while the application is closed. No other role asks for it. |
| Notifications | To alert you to overdue invoices, expiring leases, deposits due for return, cleaning requests and maintenance assigned to you. Optional, and switchable in Settings at any time. |
| Fingerprint or face unlock | To unlock the application on your own device. The check is performed by the device; we never receive your fingerprint or face data, and it never leaves the handset. |
| Background refresh | To check for those alerts while the application is closed. Optional, and tied to the notification setting. |
The application never records audio, never tracks your location in the background or outside the moment attendance is marked, and never accesses your contacts, calendar or messages.
7. Who else sees it
We disclose personal data only to:
- Supabase, which hosts our database and file storage. Supabase processes data on our instructions under a data-processing agreement, and does not use it for its own purposes.
- Government authorities, where UAE law requires it — including the Department of Economy and Tourism for holiday-home permits.
- The landlord of a unit, who receives statements about their own property and its tenancies.
Our data is held on servers outside the United Arab Emirates. Where personal data is transferred abroad, we rely on the safeguards permitted by the UAE Personal Data Protection Law.
8. Your rights
Under Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data, you may ask us to:
- tell you what personal data we hold about you, and give you a copy;
- correct anything that is wrong or out of date;
- delete your data, where we are not required by law to keep it;
- restrict or object to how we use it; and
- withdraw a consent you previously gave.
Write to director@luxesignatureholidayhomes.ae. We will respond within 30 days. If you are not satisfied, you may complain to the UAE Data Office.
9. How long we keep it
| Tenancy records | Five years after the tenancy ends, to meet UAE accounting and tax retention requirements. |
| Identity documents | Deleted once the tenancy has ended and the deposit has been returned, unless a permit or legal obligation requires otherwise. |
| Maintenance photographs | Two years from the closure of the case. |
| Staff accounts | Deleted when the person leaves, save for the audit record of changes they made. |
10. How we protect it
Data is encrypted in transit. Access is restricted by role, so a member of staff sees only what their role permits, and junior administrators see only the units assigned to them. Identity documents, tenancy contracts and payment records are held in access-controlled storage and are readable only by signed-in staff. Sign-in sessions on mobile devices are kept in the operating system's secure keystore.
One exception, stated plainly: photographs attached to a maintenance request are served from a link-accessible store, so that a tenant can see them in the maintenance portal without needing an account. Anyone given one of those links can open that photograph. We are changing this; in the meantime, please do not photograph documents or anything personal when reporting a maintenance issue.
No system is perfectly secure. If a breach occurs that is likely to harm the people affected, we will notify them and the UAE Data Office as the law requires.
11. Children
Luxe PM is a business tool for our staff and is not directed at children. We do not knowingly collect data from anyone under 18, other than a child's name where they are recorded as an occupant of a tenancy.
12. Changes
We will post any change to this policy on this page and update the date at the top. Material changes will be notified to staff users in the application.
13. Contact
Luxe Signature Holiday Homes LLC
Golden Mile, Palm Jumeirah, Dubai, United Arab Emirates
director@luxesignatureholidayhomes.ae
+971 58 824 5493