PRIVACY POLICY

Augustus Vacation Homes LLC

Last updated: 11 October 2026

1. Introduction

Augustus Vacation Homes LLC (“Augustus”, “we”, “us”, “our”) respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, store, and share your personal information when you visit our Website augustus-homes.ae, book or stay at one of our managed properties, or engage us for property management services.

This Policy is issued in accordance with:

UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (PDPL),

the EU General Data Protection Regulation (GDPR) where applicable to individuals in the European Economic Area,

the UK GDPR for individuals in the United Kingdom,

the California Consumer Privacy Act (CCPA) for California residents,

the Russian Federal Law No. 152-FZ on Personal Data where applicable.

2. Data Controller

The data controller is:

Augustus Vacation Homes LLC

Office S05-131, Trade Center First, Dubai, UAE

Trade License: 1362939

For any privacy-related questions or requests, contact:

privacy@augustus-homes.ae

3. Information We Collect

3.1 Contact and Identification Data

Full name, email address, phone number, nationality, date of birth

Passport or Emirates ID copy (collected for check-in in compliance with DET and Dubai Tourism regulations)

3.2 Booking and Transaction Data

Booking dates, property, number of guests, special requests

Payment card information (processed and stored by Stripe, not by Augustus)

Booking channel (direct, Booking.com, Airbnb, Expedia, etc.)

3.3 Property Owner Data

Name, contact details, bank account details for payouts, property details, ownership documents, Ejari records

3.4 Communications

Messages sent to us via email, website forms, or messaging apps

Reviews and comments

3.5 Technical Data

IP address, browser type and version, operating system, time zone, device identifiers, referral source

Pages visited, time spent on pages, click behavior

Cookies and similar tracking technologies

4. How We Collect Your Data

Directly from you when you fill out forms on our Website, make a booking, sign a management agreement, or contact us.

Automatically through cookies and analytics tools when you browse the Website.

From third-party platforms (Booking.com, Airbnb, Expedia, Hostaway, Stripe) when you book or transact through them.

From public sources (e.g. Dubai Land Department) when required to verify property ownership.

5. How We Use Your Data

We use your personal data to:

Process and manage bookings and payments.

Comply with DET, DTCM, and UAE legal requirements, including guest registration and tourism fee reporting.

Provide property management services to Owners, including financial reporting and revenue payouts.

Communicate with you about your booking, stay, or management agreement.

Issue VAT invoices and comply with UAE tax law (TRN: 104580031300003).

Improve our Website and Services, analyze user behavior, and prevent fraud.

Send marketing communications where you have consented.

6. Legal Basis for Processing (GDPR)

Where GDPR applies, we rely on the following legal bases:

Contract performance — to fulfil bookings and management agreements.

Legal obligation — to comply with UAE regulatory, tax, and tourism law.

Legitimate interests — to operate, improve, and protect our business.

Consent — for marketing communications and non-essential cookies, which you may withdraw at any time.

7. Sharing Your Data

We share your data only where necessary with:

Hostaway — property management system (EU-based).

Stripe — payment processing.

Chekin — online check-in and ID verification.

PriceLabs — dynamic pricing (anonymized data only).

DET / Dubai Tourism / Dubai Police — where legally required for guest registration.

OTA platforms (Booking.com, Airbnb, Expedia) — only data related to your booking on their platform.

Our accountants and auditors — for VAT and bookkeeping compliance.

Legal and governmental authorities — where required by law or court order.

We do not sell your personal data to any third party.

8. Accounting Data (QuickBooks Online)

Augustus Vacation Homes LLC operates an internal application that connects to the company’s QuickBooks Online account to support bookkeeping, reconciliation, and tax reporting.

8.1 What data is processed

From QuickBooks Online: invoices, payment records, customer records (including guest names appearing on invoices), chart of accounts, tax codes, products and services, class tracking, vendor and expense records.

From Hostaway and our booking channels: reservation data required to match bookings to invoices and payments (dates, amounts, booking channel, guest reference).

8.2 Purpose

This data is processed solely for internal bookkeeping, management reporting, reconciliation of guest payments against bookings, VAT reporting and other UAE tax compliance, and audit and financial control. The data is not used for advertising, marketing, profiling, or any purpose beyond the company’s own accounting.

8.3 Where the data is stored

Accounting data remains on infrastructure under the control of Augustus Vacation Homes LLC:

Company-managed devices with encrypted storage.

Internal spreadsheets within the company’s Google Workspace account.

The company’s own QuickBooks Online account hosted by Intuit.

Company-controlled servers used to run internal operations software.

8.4 Security

Access is restricted to authorized staff of Augustus Vacation Homes LLC.

All connections use encrypted (HTTPS) transport.

API access tokens and credentials are stored separately from the data they protect and are not shared with third parties.

8.5 Third-party processors

Data is not sold or shared, except with:

Intuit (QuickBooks Online) — hosting provider of our accounting records.

Google (Google Workspace) — where reconciliation files are stored.

Our accountants and auditors — strictly in the course of their engagement.

Governmental and regulatory authorities — where required by UAE law (including the Federal Tax Authority).

8.6 Retention

Accounting data is retained for the period required by UAE tax and commercial law — a minimum of 5 years from the end of the relevant tax period.

8.7 Disconnection and deletion

Access to QuickBooks Online can be revoked at any time by the QuickBooks administrator (Settings → Apps → Connected apps). Once revoked, the application no longer requests new data. Previously stored data is deleted on request, except where retention is required by UAE law.

9. AI-Assisted Data Processing

Augustus Vacation Homes LLC uses AI-assisted agents and internal automations to process operational and financial data — including bookings, payouts, invoices, and emailed documents — in order to prepare profit-and-loss reports, reconcile payments across channels, and support day-to-day accounting.

9.1 Data processed by AI agents

Booking data from Hostaway (guest names, dates, amounts, channel)

Payout statements from Stripe, Booking.com, Airbnb (including guest references and amounts)

Supplier and vendor invoices received by email

Internal spreadsheets and documents stored in the company’s Google Workspace

9.2 AI service provider

AI processing is performed using the Anthropic Claude API. Data is transmitted to Anthropic strictly for the purpose of generating the requested output (reports, reconciliations, document parsing). Under Anthropic’s API terms, data submitted via the API is not used to train Anthropic’s models and is retained only as long as necessary to deliver the service.

9.3 Purpose

AI-assisted processing is used solely for internal accounting, operational reporting, document handling, and tax preparation. It is not used for advertising, profiling, or any purpose beyond the company’s own operations.

9.4 Human oversight

Automated agents produce reports and drafts. All financial entries, outgoing communications, and binding decisions are reviewed and confirmed by authorized staff before being acted upon.

10. International Data Transfers

Some of our service providers are located outside the UAE (including the EU and the United States). Where we transfer your data abroad, we rely on standard contractual safeguards and ensure the recipient provides adequate protection consistent with UAE PDPL and GDPR requirements.

11. Data Retention

Guest booking records: retained for 5 years from the booking date, as required by UAE tax and tourism regulations.

Owner management records: retained for 7 years from the end of the management agreement.

Marketing data: retained until you withdraw consent.

Cookies: session or persistent, up to 24 months.

12. Your Rights

Depending on your jurisdiction, you have the following rights:

Under UAE PDPL: right to access, correct, delete, restrict, object, data portability, and withdraw consent.

Under GDPR / UK GDPR:

The right to access — request copies of your personal data.

The right to rectification — request correction of inaccurate data.

The right to erasure — request deletion under certain conditions.

The right to restrict processing — request restriction under certain conditions.

The right to object — object to processing under certain conditions.

The right to data portability — request transfer of your data to another organization.

The right to withdraw consent at any time.

Under CCPA (California residents):

Right to know what personal data we collect.

Right to request deletion of personal data.

Right to opt out of the sale of personal data (we do not sell data).

Right to non-discrimination for exercising your rights.

Under Russian Federal Law 152-FZ: right to access, correct, delete, and restrict processing of personal data concerning you.

To exercise any of these rights, email privacy@augustus-homes.ae. We will respond within 30 days.

13. Cookies

Our Website uses cookies to:

Keep the Website functioning correctly (essential cookies).

Analyze user behavior and improve performance (analytics cookies, e.g. Google Analytics).

Measure the performance of our marketing campaigns (marketing cookies, e.g. Meta Pixel).

You can control cookies through your browser settings and through our cookie banner. Blocking essential cookies may impair Website functionality.

14. Log Files

Like most websites, we automatically log visitor data including IP address, browser type, Internet Service Provider, timestamps, and referral pages. This data is used for analytics, administration, and fraud prevention.

15. Children’s Privacy

Our Website and Services are not directed at children under the age of 18. We do not knowingly collect personal data from minors. If you believe a minor has provided personal data to us, contact privacy@augustus-homes.ae and we will delete the information promptly.

Where a minor is included in a booking as a guest, their details are collected only through the booking adult responsible for them and used solely for DET-mandated guest registration.

16. Data Security

We implement reasonable technical and organizational measures to protect personal data, including encrypted storage on company devices, HTTPS for all data in transit, two-factor authentication on administrative accounts, access controls, and vendor due diligence.

In the event of a personal data breach, we will notify affected individuals and relevant authorities as required by UAE PDPL and GDPR within the mandated timeframes.

17. Third-Party Links

The Website may contain links to third-party websites, including OTA platforms. We are not responsible for the privacy practices of those sites. Review their privacy policies before providing personal data.

18. Changes to This Policy

We may update this Privacy Policy from time to time. The updated version will be posted on this page with a new “Last updated” date. Material changes will be communicated via email where appropriate.

19. Contact Us

For any questions or to exercise your data rights:

Augustus Vacation Homes LLC

Attn: Privacy Officer

Office S05-131, Trade Center First, Dubai, UAE

Email: privacy@augustus-homes.ae

Governing law: United Arab Emirates / Dubai.

Jurisdiction: Dubai Courts.