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Privacy Policy
Version: 1.0
Last updated: September 2026
1. Who is the data controller?
Your privacy is our top priority. Fully aware of our responsibility in this regard, our Company, acting as the data controller, processes and protects personal data in accordance with the Federal Decree Law No. 45 of 2021 on the Protection of Personal Data Law (“PDPL”) and other relevant legislation. The purpose of this Privacy Policy is to provide you with information about the personal data processed in accordance with the PDPL in connection with your use of the products and services we offer to our visitors, thereby ensuring the necessary transparency.
This Privacy Policy describes how Huspy Properties L.L.C (“Huspy”, “us”, “we” and “our”) collects, uses, stores and protects your personal data (as outlined below) when you access and use the website [huspysignature.com] and the services provided therein as described in the Terms and Conditions of Use (hereinafter, the “Portal”).
As a data subject, you may submit requests regarding your rights detailed in this policy in accordance with Articles 13 to 18 of the PDPL through our contact information provided below. Your requests will be reviewed and resolved within 30 (thirty) days.
| Trade Name | Huspy Properties L.L.C |
|---|---|
| Registered office | 7th Floor, the Bay Gate, Al Khaleej Al Tejari, Business Bay, United Arab Emirates (“UAE”) |
| Contact email | contact@huspy.io |
2. Sources and Categories of Data
What Personal Data Will We Process?
The categories of personal data (“Personal Data”) we may process are as follows.
Customers
- Identifying data: first name and surname, date of birth, gender, nationality, national identity number, passport number and photograph.
- Contact details: email address, telephone number, and current and/or permanent postal address.
- Financial details relating to your debit or credit card and bank account information.
- Data relating to your marital status and family circumstances, including members of your immediate family and/or dependants.
- Browsing data: web traffic patterns, referring URLs, browsing history, IP address, operating system, language used, and time zone.
Agents
- Identifying data: first name and surname, date of birth, gender, nationality, national identity number, passport number and photograph.
- Contact details: email address, telephone number and current and/or permanent address.
- Professional data, such as your CV, previous employment history, education, qualifications and skills identified during recruitment.
- Financial data: bank account number for payment of agreed remuneration.
Candidates
- Identifying details: first name and surname.
- Contact details: email address, telephone number, LinkedIn username.
- Professional details, such as your CV, previous employment history, education, qualifications and key skills identified during recruitment.
In addition to the Personal Data collected through the forms published on the Website, and any other data you provide during our contractual relationship, we may process Personal Data generated while you browse the Website, if you accept cookies. This may include offers and sections viewed, time and length of visit, and location of connection. This data helps us tailor the content and design of the Website and our services to your preferences.
Fields marked with an asterisk (*) on the forms must be completed. If the relevant data is not provided, or is provided incorrectly, we may be unable to provide the services or information requested, although you will still be able to view the Website’s content.
You must provide certain Personal Data for us to properly deliver the services offered through the Website. By providing your Personal Data, you confirm it is true and accurate. You are responsible for keeping the information you provide current, and you are solely responsible for any false or inaccurate statements made by the data subject, as well as any damage caused as a result thereof to the data controller.
3. Purpose and Legal Basis of The Processing
We will process the Personal Data we collect via our Portal for the following purposes:
3.1 For what purposes on what legal grounds will Huspy process Personal Data
| Purpose | Legal Basis |
|---|---|
| Booking management Processing and managing bookings for in-person viewings of the property. | The performance of the contractual relationship with you, or the taking of pre-contractual measures if you are not yet a customer. |
| Continuity of the property services via our platform, specifically: sending you information, including invoices, communications regarding property transactions carried out, technical notices, updates, security alerts, support and similar administrative messages, and the publication and management of your listings on the website. | To fulfil our contractual relationship with you, or to take pre-contractual steps if you are not yet a customer |
| Responding to requests for information: addressing and resolving any issues, queries, questions, requests or enquiries you raise via our website. | Your consent or our legitimate interest in processing your enquiries, requests or applications. |
| Property valuations: To process your request for us to provide a valuation report for your property via our Website. | The performance of the contractual relationship with you, or the taking of pre-contractual steps if you are not yet a customer. |
| e-Marketing for Clients: Sending commercial communications, including by electronic means, regarding our products and/or services, and including the sending of our newsletter with updates on our services, activities and/or events. | Legitimate interest in informing our customers about our products and services. Where you are not a customer, we will seek your express consent for this. |
| Putting you in touch with intermediaries to obtain bank financing. At your request, we will put you in touch with financial intermediaries so that they can provide services or act as intermediaries for the conclusion of loan or credit agreements | Your consent, the performance of the contractual relationship with you, or the taking of pre-contractual steps if you are not yet a customer. |
| Transaction Notification: updates will be sent regarding the status of the various transactions carried out by each user. | The performance of the contractual relationship with you, or the taking of pre-contractual steps if you are not yet a customer. |
3.2 For what purpose and on what legal grounds will Huspy process agents’ personal data?
| Purpose | Legal Basis |
|---|---|
| Job opportunities for Agents. Processing and managing job applications submitted by Agents in order to assess applicants through the Huspy Talent Management team, including making decisions regarding their recruitment, assignment of duties, and the determination and updating of employment terms and salary conditions. | The performance of the contractual relationship with you, or the taking of pre-contractual steps if you are not yet an Agent. |
| Responding to requests for information. Addressing and resolving any queries or requests you submit via our website. | The performance of the contractual relationship with you, or the taking of pre-contractual measures if you are not yet an Agent, or our legitimate interest in responding to any other inquiry. |
3.3. For what purpose and on what legal grounds will Huspy process Personal Data?
| Purpose | Legal Basis |
|---|---|
| Job opportunities for candidates. Processing and managing candidates’ job applications in order to assess and evaluate applicants, including making decisions regarding their recruitment, assignment of duties, and the determination and updating of employment terms and salary. Furthermore, provided you give your consent, we may retain your application for future recruitment processes that match your professional profile and interests. | The implementation of pre-contractual measures and your consent. |
| Responding to requests for information. To address and resolve any queries or requests you submit via our website regarding your application | The performance of the contractual relationship with you, or the taking of pre-contractual measures, or our legitimate interest in responding to any other request |
3.4 Automated Decision-Making and Profiling
| Purpose | Legal Basis |
|---|---|
| Creation of a commercial profile based on the information you have provided, with the aim of carrying out commercial activities tailored to you, via any channel, using your Personal Data derived from the management of the products you have contracted, as well as data obtained through web forms or browsing, access habits, traffic, etc. | Your consent. |
4. How long will we retain your Personal Data?
We will retain your Personal Data for as long as our pre-contractual or contractual relationship with you remains in force, to ensure its proper management, and even after it has ended, to send you information – including commercial information – that may be of interest to you, provided that this is appropriate, relevant and limited to what is necessary for the purposes for which we process your Personal Data. The above shall apply unless you exercise your right to erasure or your right to object to receiving commercial communications by electronic means.
Where the processing of your Personal Data is no longer appropriate, relevant or limited to what is necessary for the purposes for which it is processed, we will retain your Personal Data for the periods required by law and will subsequently keep your data blocked to meet potential liabilities, as required by the applicable data protection regulations.
5. Who will have access to your Personal Data?
5.1 Financial Intermediation Service Providers
When you ask us to put you in touch with organisations providing financial intermediation services for the purpose of entering into loan or credit agreements, we will transfer your Personal Data (full name, national identity document number, postal address, email address and telephone number) to our licensed affiliates. These organisations are duly registered in their local jurisdiction, and will process your Personal Data for the purpose of carrying out preparatory work for the conclusion of the aforementioned loan or credit agreements between you and the relevant financial institution, including, where applicable, making such agreements available for your signature.
5.2 Suppliers who will process Personal Data on behalf of the Data Controller?
The following may have access to your Personal Data:
(i) other companies within the Huspy Group that require such access to provide internal services to the Data Controller (i.e. data analysis services for the design and implementation of marketing and product development strategies and policies, etc.).
(ii) entities external to the Data Controller that require such access in order to provide their services to us, such as IT or hosting providers. Where such service providers are located in, or process your Personal Data in, countries whose data protection regulations may not be equivalent to those in Europe (e.g. the United Arab Emirates), the Data Controller will implement the necessary measures to ensure that your Personal Data is processed in those countries with a level of protection equivalent to that provided in the European Union.
5.3 Third parties or organisations to comply with our legal obligations, defend ourselves against potential claims and/or safeguard our legal or commercial interests
Third parties or bodies to comply with our legal obligations, defend ourselves against potential claims and/or safeguard our legal or commercial interests. On occasion, we may be obliged to respond to requests or enquiries for information from third parties, primarily administrative and/or judicial bodies, or to use your Personal Data to defend ourselves against potential claims or safeguard our legal or commercial interests. In all cases, the Data Controller will provide such third parties with, or use, only the Personal Data that is strictly necessary to process in order to respond to such requests, defend ourselves against potential claims or safeguard our legal or commercial interests.
6. International Transfers of Personal Data
In order to provide our services, we may need to carry out international data transfers to third countries. In such cases, we will use the appropriate safeguards in accordance with:
the Regulation (EU) 2016/679 of the European Parliament and of the Council, of 27 April 2016, on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (“General Data Protection Regulation” or “GDPR”); and/or (ii) the United Arab Emirates’ Federal Decree by Law No. (45) of 2021 concerning the Protection of Personal Data (“UAE PDPL”); and/or (iii) the British Virgin Islands’ Data Protection Act of 2021 (“BVI DPA”); and/or (iv) the Spanish Organic Law 3/2018 of 5 December on the Protection of Personal Data and the Guarantee of Digital Rights (“LOPDGDD”); and/or (v) the Italian Personal Data Protection Code (Legislative Decree No. 196/2003), as amended by Legislative Decree No. 101/2018 (“Italy PDPC”); and/or (vi) any equivalent legislation in any other jurisdiction in which a Party is established, each as applicable to the relevant Party in respect of the relevant Processing, and as amended, consolidated, restated, or re-enacted from time to time.
7. What rights do you have in relation to the processing of your Personal Data?
- Know whether your personal data is being processed;
- Request information about how your personal data has been processed;
- Know the purpose of processing your personal data and whether such data has been used appropriately for its purpose;
- Know the third parties to whom your personal data has been transferred domestically or abroad;
- Request rectification in case your personal data has been processed incompletely or inaccurately, and request notification of such correction to any third parties to whom the personal data has been transferred;
- Request the deletion or erasure of personal data where the purpose requiring processing has ended, and request notification of such deletion to any third parties to whom the personal data has been transferred;
- Request restriction of the processing of your personal data in certain circumstances;
- Object to decisions made about you based solely on the automated processing of your personal data, including profiling, where such decisions produce legal effects or otherwise significantly affect you;
- Withdraw your consent at any time, where processing is based on consent.
8. How can you exercise your rights?
You may exercise your rights at any time by contacting us via the following email addresses:
privacdidad@huspy.com, dpo@huspy.io, legal@huspy.io. Requests regarding your rights as a data subject will be reviewed and resolved within 30 (thirty) days.
9. Security measures
Huspy has implemented all necessary technical and administrative measures to establish the appropriate level of security for your personal data. These protection protocols are designed to prevent unlawful data processing, block unauthorized access, and ensure safe data preservation, including:
- Data Encryption: encryption securing data both in transit
- Access Management: role-based authorization parameters and an internal authorization matrix ensuring only designated personnel access.
- Identity Authentication: Deployment of multi-factor authentication (MFA) protocols
- System Tracking & Log Management: Continuous monitoring of system activities and data movements
- Security Audits: Regular infrastructure evaluations and risk analyses
- Penetration Testing: Regular penetration testing on a quarterly basis
10. Minors
Huspy’s services are intended exclusively for persons aged 18 and over. Huspy does not knowingly collect data from minors. If it is discovered that a minor has provided data, this will be deleted immediately.
11. Changes to the Privacy Policy
We reserve the right to amend this policy to bring it into line with new legislation, case law, business developments, and changes to our data processing procedures.
Last updated: September 2026