Privacy Policy for KLUGSYS PropTech LLC-FZ

1. Data Collection
We may collect the following categories of personal data:
- Identity Data: Full name, date of birth, nationality.
- Contact Data: Email address, phone number, postal address.
- Property Preferences: Budget, location, property type, number of bedrooms, amenities.
- Technical Data: IP address, device type, browser type, operating system.
- Usage Data: Your activity on our platform (pages visited, time spent, searches).
- Communication Data: Interactions with our support and inquiry forms.
We collect this data:
- Directly from you when you sign up, search for properties, or communicate with us.
- Automatically via cookies and tracking technologies.
- From third-party sources (e.g., real estate partners with your consent).
Guests may access limited parts of the platform without logging in. Full features require user registration.

2. Data Usage
We use your data to:
- Provide and personalize AI-powered property search and recommendations.
- Improve and enhance our platform's functionality and user experience.
- Communicate with you about listings, updates, and promotional offers (with consent).
- Process transactions or inquiries made through our platform.
- Analyze trends and gather insights to optimize our services.
- Comply with legal obligations and enforce our terms.

3. Data Sharing
We may share your data with:
- Real estate brokers and developers to connect you with relevant property listings.
- Technology service providers (e.g., hosting, analytics, CRM) operate our platform.
- Legal and regulatory authorities where required by UAE law.
- Corporate affiliates and partners, subject to data protection agreements.
We use Google services such as Google Analytics and Google Ads for analytics and marketing.
We do not sell your personal data to third parties.
All third-party data processors are contractually bound to protect your data.

4. Data Security
We implement appropriate technical and organizational security measures including:
- End-to-end encryption of user data in transit and at rest.
- Role-based access control and multi-factor authentication.
- Regular penetration testing and code audits.
- Employee training on data privacy and security protocols.
However, no system is 100% secure, and we cannot guarantee absolute data protection.

5. Data Retention
We retain your personal data:
- Only as long as necessary to fulfill the purposes it was collected for.
- For as long as your account remains active.
- As required by legal, accounting, or reporting obligations.
Once no longer needed, your data is securely deleted or anonymized.

6. User Rights
You have the right to:
- Access your personal data and receive a copy.
- Correct inaccuracies in your data.
- Request deletion of your data (right to be forgotten), under certain conditions.
- Restrict or object to specific processing.
- Data portability: request your data in a machine-readable format.
- Withdraw consent at any time where processing is based on consent.
To exercise any of these rights, contact us at: info@hayy.ai

7. Cookies and Tracking
We use cookies and similar technologies to:
- Remember user preferences.
- Understand user behavior to improve services.
- Retarget and market via Google Ads (only with user consent).
You can manage your cookie preferences through your browser or our cookie consent tool.
Essential cookies cannot be disabled.
We use Google Analytics to track site performance and user interactions. Google may collect IP addresses and usage data, subject to their own privacy policy.

8. Contact Information
For any privacy-related inquiries, data access, or complaints, please contact:
KLUGSYS PropTech LLC-FZ Contact Person
Sufian Ashraf Mazhari
Email: info@hayy.ai
Business Address: Meydan FZ
Phone: +971524780353

9. Governing Law
This Privacy Policy and all related data processing activities are governed by the United Arab Emirates Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (PDPL), and other applicable UAE regulations.
Any disputes shall be subject to the jurisdiction of the UAE courts.

10. Artificial Intelligence and Automated Decisions
Our platform uses AI algorithms to recommend properties based on your preferences and behavior.
- You will be informed when an AI system is involved in significant decisions.
- You can request human intervention or challenge decisions made by automated processes.
- Our AI systems are regularly audited for fairness, transparency, and bias mitigation.

11. International Data Transfers
Where your data is transferred outside the UAE:
- We ensure the destination country offers adequate data protection.
- Alternatively, we use legally binding agreements (e.g., Standard Contractual Clauses).
- You will be informed and asked for consent where required.

12. Data Breach Notification
In case of a data breach:
- We will notify the UAE Data Office as required by law.
- Affected users will be informed without undue delay if the breach is likely to result in high risk to their rights and freedoms.

13. Policy Updates
We may update this policy to reflect changes in our practices or legal requirements.
- Significant changes will be notified to you via email or platform notice.
- We encourage you to review this policy periodically.

Last revision: July 26, 2025