PRIVACY POLICY
This Privacy Policy (“Privacy Policy”) describes how Huspy (“Huspy”, “us”, “we” and “our”) collects, uses and shares Personal Data (as described below) of you (“you”), as the User of our Platform and the Services, and your Client. Terms used in this Privacy Policy not defined herein, shall have the same meanings ascribed to them in our Terms and Conditions.
By using our Services and/or accessing our Platform, you are accepting the terms of this Privacy Policy and are consenting to our collection, use, disclosure, retention and protection of your and your Clients’ Personal Data, as described in more detail herein. You acknowledge and agree that you are solely responsible for obtaining the consent of each of your Clients prior to submitting any Personal Data to us and/or onto the Platform.
We reserve the right to amend this Privacy Policy at any time without prior notice to you or your Clients. It shall be your sole responsibility to review this Privacy Policy periodically and update yourself and your Clients of any changes that might be made. By continuing to access our Platform and/or use the Services, you are accepting the terms of this Privacy Policy in full. Should you not agree to any of the terms in this Privacy Policy, you should stop accessing our Platform and/or using the Services immediately.
PERSONAL DATA THAT WE COLLECT
We may collect Personal Data about you, your Client and any devices you use when you access our Platform and use the Services, when you correspond with us regarding the Platform or the services provided through it, and when you generally access our Platform for any reason whatsoever.
"Personal Data" includes any data which may be used to identify or contact an individual, including but not limited to, name, address, telephone number, email address, date of birth, nationality, username and/or other data which may be necessary to create an account on the Platform or use the Services and complete a transaction. Personal Data of your Client may also include, without limitation, financial data, such as salary and bank details, and occupation information. Personal Data shall not include aggregated data or data that, by itself, does not permit the identification of individual persons.
Personal Data that is transmitted to us may include, but is not limited to:
Information which can identify an individual such as name, address, telephone number, username and email address;
RFID-linked personal information contained in Emirates ID, Passport and any other document that you share with us;
Financial data (such as credit card or bank account numbers when you pay for the third party Services via our Platform and/or data relating to your Clients financial status when applying for a mortgage);
Postage, billing and other Personal Data used to purchase and/or process Services through the Platform;
Data through a web form or when you correspond with us regarding the Services;
Profile information of any third-party platform that you may choose to use to log in or sign up to our Platform;
Other information voluntarily provided by you and/or your Client;
Any other information we need to enable us to deliver any services to you and/or your Client; and
Additional data required by applicable laws to collect and process an order to authenticate or identify you and/or your Client or to verify the data that we have collected is correct.
We will only gather Personal Data that is relevant for the purposes for which it will be used and will not gather excessive or unnecessary Personal Data about you or your Client.
We may also collect Personal Data about and/or from your interactions with our Platform; your advertising preferences; your communications with us; and computer and connection data such as statistics on your page views, traffic to and from the sites, referral URL, ad data, your IP address, your browsing history and your web log data. This is Personal Data we receive from the devices you use when you access our Platform, register to receive Services, provide us data on a web form, or when you otherwise correspond with us regarding the Services.
COOKIES
We may use cookies, web beacons, unique identifiers and similar technologies to collect data about the pages that you view, the links that you click and other actions you may take on our Platform, within our advertising or e-mail content.
You can typically remove and reject cookies from our Platform with your browser settings. Many browsers are set to accept cookies until you change your settings. If you remove or reject our cookies, it could affect how our Platform works for you.
OUR USE OF PERSONAL DATA
We may use the Personal Data we collect about you and your Clients to provide you and your Clients with continuity in services, customer service, a personalized experience when you visit our Platform, a personalized advertising and marketing experience; to contact you about our Platform or the services we provide through it; and to detect, prevent, mitigate and investigate fraudulent or illegal activities.
We may therefore use and retain your and/or your Clients’ Personal Data as follows:
to give access to the Services provided through our Platform;
to operate, maintain, and improve our Platform and the services provided through it;
to send data including confirmations, invoices, technical notices, updates, security alerts, support and administrative messages;
to communicate about promotions, upcoming events, and other news about products and services offered by us and our selected partners;
to link or combine User data with other Personal Data;
to customize, measure and improve our services; and
to provide you with location-based services (such as advertising, search results and other personalized content using your GPS).
Personal Data may be transferred to our group companies, Service Providers that are performing services on our/your/your Clients’ behalf, or persons acting as our agents (which may be located in a country outside of your country of origin). We will require that any such parties agree to keep Personal Data secure and confidential, use it only for the purposes for which the Personal Data is transferred and use it only in accordance with our directions and subject always to the provisions of this Privacy Policy. Personal Data may be transferred to any government authority, agency and institution if and as required or permitted by applicable laws and regulations.
We take precautions to protect your and your Clients’ Personal Data. We have or may implement policies that forbid our employees or anyone having access to Personal Data from using or disclosing Personal Data in an inappropriate or unlawful manner, and maintain security measures to safeguard the Personal Data from unauthorized access, misuse, alteration, loss or destruction. We shall not collect, use, disclose or transfer the Personal Data except as described in this Privacy Policy, unless you and/or your Client give us your permission to collect, use, disclose or transfer it for other purposes.
Personal Data is retained only for as long as necessary to fulfill the purposes described within this Privacy Policy and in accordance with our internal data retention policies. Once it is no longer needed, it will be securely deleted or anonymized.
THIRD PARTY PERSONAL DATA
If you give us Personal Data about someone else, such as your Clients, you must do so only with their explicit and prior consent. You must inform them how we collect, use, disclose and retain their Personal Data according to this Privacy Policy.
LINKS TO OTHER WEBSITES
Our Platform may from time to time contain links to and from other websites. This may include websites owned or controlled by independent parties not controlled or authorized by us. If you follow a link to any of these websites please note that these websites have their own privacy policy, data collection practices and security measures and we do not accept any responsibility or liability for these policies. Please ensure you check these policies before submitting any personal data.
SHARING OF PERSONAL DATA
We may disclose your and/or your Clients’ Personal Data to third parties. This disclosure may be required for us to provide you access to our Platform and the Services, to comply with our legal obligations, to enforce our Terms and Conditions, to facilitate our marketing and advertising activities, or to prevent, detect, mitigate and investigate fraudulent or illegal activities related to our Platform and/or Services. We minimize the amount of Personal Data we disclose to what is directly relevant and necessary to accomplish the specified purpose. We do not disclose Personal Data to third parties for their marketing and advertising purposes without your explicit consent.
We may disclose the collected Personal Data for the following purposes:
To help detect and prevent potentially fraudulent and illegal acts, violations of our Terms and Conditions, and data security breaches.
To third party service providers who help us to provide and/or achieve: the Services through our Platform; payment processing for the usage of Services; bill collection; customized advertising; the prevention, detection, mitigation and investigation of potentially illegal acts, violations of our Terms and Conditions, fraud and/or security breaches; affiliate and rewards programs; co-branded credit cards; and/or other business operations.
We may share Personal Data when we do a business deal, or negotiate a business deal, involving the sale or transfer of all or a part of our business or assets. These deals can include any merger, financing, acquisition, or bankruptcy transaction or proceeding.
We may share Personal Data for legal, protection, and safety/safeguarding purposes.
To comply with our legal requirements, enforce our Terms and Conditions, respond to claims that any content violates the rights of others, or to protect anyone's rights, property or safety.
With law enforcement or governmental agencies, or authorized third-parties, in response to a verified request relating to a criminal investigation or alleged or suspected illegal activity or any other activity that may expose us, you, your Client or any other of our Users to legal liability. We will only disclose data we deem relevant to the investigation or inquiry
With credit agencies or bureaus as authorized by applicable national laws (e.g. data on late or missed payments or other defaults that may be reflected in your/your Clients’ credit report or file).
We may share data to respond to lawful requests and legal processes.
We may share data to protect the rights and property of Huspy’s group companies, our agents, customers, and others. This includes enforcing our agreements, policies, and Terms and Conditions.
We may share data in an emergency. This includes protecting the safety of our employees and agents, our customers, or any person.
We may share data with those who need it to complete work for us related to the Services.
We may share data to our external service providers such as digital service providers and IT service providers. Some of these may be located overseas.
Disclosure of information by Huspy to third parties is not considered to be a violation of the Privacy Policy if it is performed based on any additional agreements related to distribution of our Services to you and/or your Clients. For example, we may hire third party companies to process payments, store data, host sites and access APIs. We will share the Personal Data with third parties only in the ways and amounts necessary for provision of our Services. Huspy appointed third parties have no right to use such Personal Data other than as directed by us.
We utilize Google Application Programming Interfaces (APIs) and Artificial Intelligence (AI) tools throughout the provision of our Services to you (and/or your Client) in order to improve user experience, enhance and personalize our Services, and drive business insights. Our use of information received from Google APIs and transfer of such information to any other third party service provider will adhere to the Google API Services User Data Policy, including its Limited Use requirements. AI tools are used for administrative purposes to (i) process Personal Data in a manner that reduces the turnaround time of the Services provided, by allowing us to efficiently complete forms and applications that require Personal Data input and (ii) to help answer questions you may have on lender policies/procedures when preparing Client applications. AI tools and/or models are not used for any decision-making exercises. Personal Data processed using AI tools helps us train and refine our AI tools to provide better Services to you and is subject to the same guidelines and procedures set out in this Privacy Policy.
UPDATED DATA
We take steps to ensure that the Personal Data we collect from you is accurate and up to date, and that you have the ability to access and make corrections to it, which includes reviewing and updating your and your Clients’ Personal Data upon request and honoring any statutory right you and/or your Clients might have to access, rectify, restrict, modify or erase the Personal Data we hold. You have a responsibility to keep the data that you provide to us updated and we will take reasonable steps to facilitate this. Where you have and/or your Client has a statutory right to request access, rectification, restriction, objection of use, modification or erasure of Personal Data, we can still withhold that access or decline the request in some cases in accordance with applicable laws, but will give you reasons if we do so.
DATA CHOICES
Our marketing emails tell you how to “opt-out” of receiving such emails. If you opt out, we may still send you non-marketing emails. Non-marketing emails include emails about the Services we are providing you and/or your Clients and our business dealings with you and your Clients.
You may sign-up to receive emails or newsletters from us. If you would like to discontinue receiving this data, you may update your email preferences by replying to the email or clicking the "unsubscribe" link found in emails we send to you.
You may send requests about Personal Data to our Contact Data below. You can request to change contact choices, opt-out of our sharing of Personal Data with others, and update your Personal Data.
Note that if you choose to 'opt-out' of certain options, withhold, block or request that we delete your Personal Data, you may not be able to receive the benefit of our Platform or Services.
WHERE WE STORE YOUR DATA
The data that we collect from you may be transferred to and stored at a destination outside UAE. It may also be processed by staff operating outside the UAE working for us. Such staff may be engaged in, among other things, the fulfilment of your transaction, the processing of your payment details and the provision of support services. By submitting Personal Data, you agree to this transfer, storing and processing on behalf of yourself and your Clients. We will take all steps reasonably necessary to ensure that your data is treated securely, in accordance with your rights and in accordance with this Privacy Policy. All information you provide to us is stored on our secure servers. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your data transmitted to our Platform and any transmission is at your own risk.
CONTACT DATA.
We welcome your comments or questions about this Privacy Policy. You may also contact us at our address: 7th Floor, The Bay Gate, Business Bay, Dubai, United Arab Emirates and by email at dpo@huspy.com.