Privacy Policy

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.

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.

Interest and Preference Data: Property interests, project inquiries, and preferences you share with us.

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

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

Transaction & Service Data: Information relating to your use of our services, including 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.

Service Preferences: Information about your interests in our products or services and how you configure and use features within the Hayy.AI App.

Technical Data: IP address, device type, unique device identifiers, operating system, app version, browser type, language and time zone settings, and other technical information.

Usage and Behavioural Data: Information about how you use and interact with the Hayy.AI App, including features used, in-app actions, time spent, navigation paths, and performance data.

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 data from minors.

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 with your consent where required or as otherwise permitted by law.

Consent: For marketing communications, non-essential cookies and similar tracking technologies, behavioural analytics, and, where required by law, the use of user-uploaded content (such as pictures) for improving and training our AI models and Services.

Legitimate Interests: For app and service analytics, security and fraud prevention, improving and developing the Hayy.AI App and our AI models (including limited use of user-uploaded content where permitted by law), and ensuring the effective operation of our business, provided that such interests are not overridden by your fundamental rights and freedoms.

To comply with applicable laws and regulations, regulatory requirements, and lawful requests from competent authorities, and to establish, exercise, or defend legal claims, including related record-keeping obligations.

Contract Performance: Operating the Platforms, responding to contact forms, and account-related interactions under Art. 6(1)(b) GDPR and/or Art. 6(1)(f) GDPR.

Providing Services: Enabling communication between you and real estate agents/agencies, managing enquiries, bookings, viewings, interactions and Responding to questions, complaints, and support requests

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

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,

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

Fraud detection : Fraud detection and prevention, and monitoring for security incidents.

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.

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.

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. Where we ever rely on automated decision-making that produces legal or similarly significant effects, we will inform you separately and provide you with the rights required under applicable law, including the right to obtain human intervention.

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.

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:

Real Estate Ecosystem Partners: Registered real estate agents and brokers, Real estate agencies, Developers, Mortgage advisors and banks, and 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.

Service Providers: Hosting & cloud services, CRM systems, Customer support tools, Marketing & advertising platforms, and 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.

Group Companies: Within KLUGSYS Group internationally for internal administrative purposes and centralized service provision.

Business Acquisition/Transfer: Personal data may be transferred in case of sale, merger, restructuring, or investor transition.

Legal Authorities: Courts, regulators, law enforcement, or other public authorities when required by law.

International Transfers: Where recipients are located outside the EEA or UAE, we implement appropriate safeguards including EU Standard Contractual Clauses and transfer impact assessments.

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 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 prior processing.

To exercise these rights, contact us using the details in the Contact Us section. We will respond within the timeframes required by applicable data protection laws.

Essential Cookies: Ensure essential functionality of the Hayy.AI App, such as secure login and core features.

Analytics Cookies: Analyze user behavior and app performance for service improvement using Usage and Behavioural Data.

Marketing Cookies: Deliver targeted marketing and measure campaign effectiveness where permitted by law and subject to your prior consent.

Non-essential cookies and trackers are set based on your prior consent. You can provide, refuse, or withdraw consent via our cookie banner or settings tool.

Third-Party SDKs: We use Google Maps SDK for displaying maps and location-based content. We do not use SDKs for advertising, data brokering, or profiling.

We implement appropriate technical and organizational measures to protect your personal data, including encryption, access controls, secure servers, and regular review of 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.

Where transfers occur to countries outside the EEA or UAE without adequacy decisions, we implement appropriate safeguards such as EU Standard Contractual Clauses and conduct transfer impact assessments.

Under the PDPL, we rely on permitted transfer mechanisms including adequacy decisions, your explicit consent, necessity for contract performance, or other grounds recognized by law.

You can request more information about these safeguards using the contact details in the Contact Us section.

You may delete your Hayy.AI account at any time directly within the app by going to General Settings and selecting 'Delete Account'.

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 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 outlined purposes or as required by applicable law.

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 make decisions based solely on automated processing that produce legal effects concerning you or similarly significantly affect you.

We do not use your uploaded documents or images to train AI models without explicit consent where required.

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 via email or in-app notification.

Continued use of the Platforms after the effective date constitutes acceptance of the revised policy.

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.