LegalPrivacy Policy

Privacy Policy

KLUGSYS UG (haftungsbeschränkt) and KLUGSYS PropTech LLC-FZ respect your privacy and are committed to protecting your personal information.

Effective: 07 January 2026Applies to all Platforms

KLUGSYS UG together with its global affiliates including KLUGSYS PropTech LLC-FZ respects your privacy and is committed to protecting your personal data.

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KLUGSYS UG (haftungsbeschränkt), together with its global affiliates including KLUGSYS PropTech LLC-FZ in Dubai ("KLUGSYS", "we", "us", "our"), respects your privacy and is committed to protecting your personal information.

This Privacy Policy explains how we collect, use, disclose, and safeguard your personal data when you interact with our platforms, websites, mobile applications, products, and services (collectively, the "Platforms").

By using our Platforms, you acknowledge that you have read this Privacy Policy and understand how we process your personal data, to the extent permitted by applicable law.

1. INTRODUCTION

Our Platforms provide information about, and access to, our solutions and related services. For any questions about this Privacy Policy or our data protection practices, you can contact us at info@hayy.ai.

Data Controller / Data Protection Officer

EU/Germany

KLUGSYS UG (haftungsbeschränkt)
Am Ritzerfelder Hof 12
52134 Herzogenrath, Germany
Email: info@hayy.ai
Phone: +49 172 2773241

UAE

KLUGSYS PropTech LLC–FZ
Meydan Free Zone, Dubai, UAE
Email: info@hayy.ai

Depending on your location and the specific Services you use, one or both KLUGSYS entities may act as an independent data controller or as joint controllers. Where we act as joint controllers, we have agreed on our respective responsibilities for compliance with applicable data protection laws, and the essence of that arrangement is reflected in this Privacy Policy.

2. DATA WE COLLECT

i. Identity Data

Full name, username or similar identifier, Country of Residence (if provided), and any profile information (Gender), you choose to provide in the Hayy.AI App.

ii. Contact Data

Email address, phone number, postal address, and other contact details you provide when creating an account, contacting support, or otherwise communicating with us through the Hayy.AI App.

iii. Interest and Preference Data

Property interests, project inquiries, and preferences you share with us.

iv. Communication Content

Any information you share via email, WhatsApp, forms, support tickets, or phone calls when you contact us.

v. Ecosystem Interaction Data

Information you share with agents, partners, or developers through our Platforms in connection with listings, projects, or services.

vi. Transaction & Service Data

Information relating to your use of our services, such as:

Mortgage-related information like Nationality, Residency status, Marital Status, Age, Employment type, Income, Capital, Co-applicant and documents (when applicable), including credit information (UAE only), where required to provide mortgage or related financial services.

vii. Service Preferences

Information about your interests in our products or services and how you configure and use features within the Hayy.AI App (e.g., preferred device settings, automation rules, notification preferences).

viii. Technical Data

IP address, device type, unique device identifiers, operating system, app version, browser type (for web access), language and time zone settings, and other technical information generated when you install, access, or use the Hayy.AI App.

ix. Usage and Behavioural Data

Information about how you use and interact with the Hayy.AI App, including features used, in-app actions (e.g., taps, clicks, screens viewed, time spent, navigation paths), interaction with notifications, log files, and crash or performance data.

x. Communication Data

Content of your communications with us (e.g., support requests, feedback, survey responses, or other inquiries) and related metadata, whether submitted via the Hayy.AI App, email, or other channels.

xi. Children's Data

Hayy.AI is not intended for children under 16 in the EU or under 18 in the UAE. We do not knowingly collect or process personal data from minors. If we discover that a minor has created an account or provided personal information, we will delete the account and associated data immediately. If you believe a minor has used the Platform, please contact us at info@hayy.ai.

3. METHODS OF COLLECTION

We obtain your information:

  • Directly from you when you use our Platforms
  • Automatically through cookies, analytics, and service logs
  • From advertising and analytics providers

We obtain your information as described above with your consent where required or as otherwise permitted by law.

5. HOW WE USE YOUR DATA

i. Providing Services

  • Enabling communication between you and real estate agents/agencies
  • Managing enquiries, bookings, viewings, and interactions
  • Responding to questions, complaints, and support requests

ii. Improving User Experience

  • Personalizing search results, recommendations, alerts
  • Tailoring content, marketing messages, and notifications, where permitted by law and based on your consent or our legitimate interests
  • Enhancing Platform design, performance, and usability

iii. Marketing & Communications

  • Notifications about new listings, projects, and promotions, where you have not opted out of such communications
  • Special offers relevant to your interests, based on your preferences and, where required, your consent
  • Agent/agency-focused communications (product updates, leads, statistics, and service information)

You can opt out of marketing communications at any time by contacting us using the details in Section 13.

iv. Internal Business Purposes

  • Analytics, service optimization, and trend analysis
  • Performance monitoring of agents engaging with users for quality and performance purposes
  • Quality control for calls, emails, and messaging, which may include limited review or recording where permitted by law

v. Fraud detection

  • Fraud detection and prevention, and monitoring for security incidents

vi. Mortgage & Financial Services (Optional)

  • Assessing eligibility for financial services, together with our mortgage or financial partners where applicable
  • Sharing necessary information with banks and other financial institutions to process your mortgage or related financial enquiries, based on your request and, where required, your consent

vii. Legal & Regulatory

  • Compliance with PDPL, GDPR, and other legal requirements
  • Responding to law enforcement or regulatory agencies, courts, and other public authorities, to the extent required or permitted by law

viii. Automated decision-making / profiling

We do not make decisions based solely on automated processing, including profiling, that produce legal effects concerning you or similarly significantly affect you. Any profiling for analytics or marketing is limited and based on your consent or our legitimate interests, and you can object or withdraw consent at any time.

ix. AI Features and Automated Processing

The Hayy.AI Platform includes AI-driven features such as property recommendations, automated insights, and chatbot interactions. These outputs are informational only and should not be considered financial, legal, or investment advice. We do not use automated decision-making that produces legal or significant effects on users. We also do not use your uploaded documents or images to train AI models without explicit consent where required.

6. DATA SHARING

We may share your information with the following categories of recipients, in each case only where necessary for the purposes described in this Privacy Policy and on the legal bases set out in Section 3:

i. Real Estate Ecosystem Partners

  • Registered real estate agents and brokers
  • Real estate agencies
  • Developers
  • Mortgage advisors and banks
  • Property management companies

When you enquire about a property or project through our Platforms, your details (such as your name and contact information and the content of your enquiry) are shared with the assigned agent or relevant ecosystem partner so that they can respond to you, based on your request and the applicable legal basis.

ii. Service Providers

  • Hosting & cloud services
  • CRM systems
  • Customer support tools
  • Marketing & advertising platforms
  • Analytics and anti-fraud systems

These providers act as our processors, may only process your data on our documented instructions, and are contractually prohibited from using your data for their own independent purposes.

iii. Group Companies

Within KLUGSYS Group internationally, for internal administrative purposes, centralised service provision, and to support the purposes described in this Privacy Policy, subject to appropriate safeguards and, where applicable, international data transfer mechanisms.

iv. Business Acquisition / Transfer

In case of a sale, merger, restructuring, or investor transition involving all or part of our business, personal data may be transferred to the relevant third parties as part of the transaction, subject to appropriate confidentiality and data protection obligations and continued protection consistent with this Privacy Policy.

v. Legal Authorities

  • Courts, regulators, law enforcement, or other public authorities when required by law or where we reasonably believe that such disclosure is necessary to comply with legal obligations, protect our rights or the rights of others, or to detect, prevent, or address fraud or security issues.
  • We use third-party processors—such as hosting and cloud providers, IT security and maintenance providers, analytics platforms, customer relationship management (CRM) tools, email and communications providers, customer support tools, and marketing / advertising platforms—who act under our instructions and are contractually obligated to comply with GDPR / PDPL, maintain appropriate security measures, and process personal data only for the purposes specified by us.
  • We may disclose personal data to courts, regulators, law enforcement, or other public authorities where required to do so by law or where such disclosure is necessary to protect our rights, your rights, or the rights of others.

vi. Business Partners and Affiliates

With your consent where required, or as otherwise permitted by law, we may share personal data with selected business partners in connection with joint offerings, integrations, or co branded services involving the Hayy.AI App, and such partners are required to protect your data in accordance with applicable data protection laws.

vii. International Transfers

Some recipients may be located outside the European Economic Area (EEA) or the UAE. Where a recipient is located in a country that has not been recognised as providing an adequate level of data protection, we implement appropriate safeguards in accordance with GDPR and PDPL requirements. Under the GDPR, we rely in particular on:

  • adequacy decisions (Art. 45 GDPR) where available; and
  • EU Standard Contractual Clauses (Art. 46 GDPR), together with transfer impact assessments and supplementary measures as needed. Under the UAE PDPL, we rely on permitted transfer mechanisms, including adequacy decisions, your explicit consent, necessity for contract performance or the establishment, exercise or defence of legal claims, protection of public interest, or other grounds recognised by applicable law. Copies or a description of relevant safeguards (e.g., Standard Contractual Clauses) are available upon request using the contact details in Section 13.
  • We also ensure that all international transfers comply with Google Play’s User Data Policy, including security, minimization, and lawful handling requirements.

7. YOUR RIGHTS

Access

Request a copy of your personal data.

Rectification

Correct inaccurate or incomplete data.

Erasure

Request deletion of your data, subject to applicable legal grounds and retention obligations.

Restriction

Limit the processing of your data in certain cases.

Objection

Object to processing based on our legitimate interests and processing for direct marketing purposes.

Data Portability

Receive your data in a structured, commonly used, and machine-readable format.

Withdraw Consent

Withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal. If you withdraw consent, we may not be able to provide certain services to you.

Device Permissions

You can withdraw consent for Camera, Microphone, Location, Notification, Photos & Videos, Storage, Music & Video from your device settings. If you withdraw consent, we may not be able to provide certain services to you.

To exercise these rights, contact us using the details in Section 13. We may need to verify your identity before responding to your request. We will respond without undue delay and in any event within the timeframes required by applicable data protection laws, taking into account possible extensions for complex or numerous requests as permitted by law.

You also have the right to lodge a complaint with a supervisory authority. Under the GDPR, this may be in the EU Member State of your habitual residence, place of work, or place of the alleged infringement. In Germany, the competent supervisory authority is the Landesbeauftragte für Datenschutz und Informationsfreiheit Nordrhein-Westfalen (LDI NRW). UAE residents may raise complaints with the UAE Data Office in accordance with the PDPL.

8. COOKIES AND TRACKING TECHNOLOGIES

  • Ensure essential functionality of the Hayy.AI App and related websites (Essential Cookies and similar technologies), such as enabling secure login, remembering your session, and providing core features that are necessary for the service you request.
  • Analyze user behavior and app performance for service improvement (Analytics Cookies, SDKs, and similar technologies), including collecting Usage and Behavioural Data to understand how the Hayy.AI App is used and to improve features, usability, and stability. These tools may be operated by us or by third-party analytics providers.
  • Deliver targeted marketing and measure the effectiveness of our campaigns (Marketing Cookies and similar technologies), where permitted by law and subject to your prior consent where required.
  • We use cookies and similar technologies only as permitted by law. Non-essential cookiestrackers are set based on your prior consent under Sec. 25 TTDSG and Art. 6(1)(a) GDPR (and PDPL consent). You can provide, refuse, or withdraw consent at any time via our cookie banner or settings tool, and through your browser or device settings. Your choices do not affect strictly necessary cookies required for the service. For details on categories, purposes, providers, storage periods, and how to change settings, please see our Cookie Policy available on our Website.
  • Third-Party SDKs and Services. To operate the Hayy.AI App and provide mapping functionality, we use the Google Maps SDK, which may collect technical identifiers such as IP address, device information, and interaction data. These are used strictly for displaying maps and location-based content. We do not use SDKs for advertising, data brokering, or profiling. If additional SDKs (e.g., Firebase for analytics or crash reporting) are added in future versions, this Privacy Policy will be updated accordingly.

9. DATA SECURITY

We implement appropriate technical and organizational measures to protect your personal data, including encryption, access controls, secure servers, and regular review of our security practices. However, no online transmission or storage system is completely secure, and we cannot guarantee absolute security. You are also responsible for keeping your account credentials confidential.

10. INTERNATIONAL DATA TRANSFERS

Where transfers of your personal data occur to countries outside the EEA or the UAE that do not benefit from an adequacy decision, we implement appropriate safeguards such as the EU Standard Contractual Clauses, conduct transfer impact assessments, and apply supplementary measures as needed. Under the PDPL, we rely on permitted transfer mechanisms, including adequacy decisions, your explicit consent, necessity for contract performance, the establishment, exercise or defence of legal claims, or other grounds recognised by law. You can request more information about these safeguards using the contact details in Section 13.

11. DATA RETENTION

Account and Data Deletion

You may delete your Hayy.AI account at any time directly within the app:

  1. Open the Hayy.AI App
  2. Go to General Settings
  3. Select "Delete Account"
  4. Confirm your request

Your personal data and account information will be permanently deleted within 90 days, unless a longer retention period is required by law. Data sent to external real-estate agents or service partners as part of your inquiries may continue to be stored by those parties in accordance with their own policies.

You may also request deletion via info@hayy.ai

We retain personal data only for as long as necessary for the purposes outlined in this Privacy Policy or as required by applicable law (including statutory limitation and retention periods).

12. UPDATES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, or legal requirements. Updates will be posted on this page with the effective date. Where required by law, we will notify you of material changes (for example, via email or in-app notification). Continued use of the Platforms after the effective date constitutes acceptance of the revised policy.

This Privacy Policy is effective as of 07 January 2026.

13. CONTACT US

If you have any questions, concerns, or requests regarding this Privacy Policy or our processing of your personal data under applicable law (including the GDPR and the UAE PDPL), contact us at:

EU/Germany

KLUGSYS UG (haftungsbeschränkt)
Am Ritzerfelder Hof 12
52134 Herzogenrath, Germany
Email: info@hayy.ai
Phone: +49 172 2773241

UAE

KLUGSYS PropTech LLC–FZ
Meydan Free Zone, Dubai, UAE
Email: info@hayy.ai

Complaint rights: You may lodge a complaint with a supervisory authority. In Germany, the competent authority for our registered office is the Landesbeauftragte für Datenschutz und Informationsfreiheit Nordrhein-Westfalen (LDI NRW). In the United Arab Emirates, you may also contact the UAE Data Office under the UAE PDPL. This is without prejudice to any other administrative or judicial remedies available to you.