PRIVACY POLICY

1. Who Controls Your Personal Data

Al Ayman generally acts as controller for personal data processed to operate the Platform. A Provider may separately act as controller for Client personal data that the Provider processes independently to provide an underlying service.

2. Personal Data We Collect

Depending on how you use the Platform, we may collect the following categories of personal data:

• Account and identity data, such as name, account identifiers, date of birth or age confirmation where required, profile information and login or authentication information;
• Contact data, such as email address, telephone number and communication preferences;
• Provider data, such as business information, trade licence or professional licence information, qualifications, authorised representative details, service categories and verification records;
• Order and service data, such as service requests, locations or service areas, Responses, proposed prices, timing, Order status and information exchanged in connection with an Order;
• Communications, including Platform chat messages, support requests, complaints and related correspondence;
• Payment and Wallet data for Providers, such as Wallet transactions, Platform Fee records, payment confirmations, refunds, withdrawals and limited payment-related identifiers received from payment service providers;
• Ratings, reviews, portfolio materials and other content submitted to the Platform;
• Technical and security data, such as IP address, device and browser information, app identifiers, login records, security events and diagnostic information;
• Location data where relevant to Platform functionality. Depending on the feature, this may be an approximate location or location information provided or permitted by the User; and
• Marketing and cookie preference data, including consents, opt-outs and preferences.

We do not seek to collect sensitive personal data unless it is necessary for a specific lawful Platform function or compliance purpose. If such data is required, we will apply the safeguards and legal basis required by applicable law.

3. How We Obtain Personal Data

We collect personal data directly from Users when they register, create profiles, post Orders, submit Responses, communicate, make Platform payments, contact support or otherwise use the Platform.

We may also receive limited personal data from service providers that support payments, authentication and communications, hosting and infrastructure, maps or location functionality, analytics, security, error monitoring, customer support and Provider verification.

Where a Client and Provider interact through the Platform, each may provide information about the other in connection with an Order, complaint, review or Service Agreement.

4. Why We Process Personal Data

Depending on the activity, processing may be based on consent or may be carried out without consent where a specific exception or other legal basis under applicable UAE law applies, including where processing is necessary to perform a contract or take requested pre-contractual steps, comply with legal obligations, protect relevant interests, establish or defend legal claims, or in another case permitted by law. Withdrawing consent does not prevent processing that is lawful on another applicable basis.

5. Provider Payments and Client Payments

5.1 Under the current Platform model, Clients do not pay Platform Fees to Al Ayman and do not require a Platform Wallet.

5.2 Providers may use a Wallet or equivalent balance feature to pay Platform Fees, including the Response Fee and Provider Selection Fee described in the Provider Agreement. We process payment and Wallet data as necessary to operate these functions, handle refunds or withdrawals, prevent payment abuse and maintain required records.

5.3 Payment card processing may be performed by an external payment service provider. Al Ayman does not intend to store full payment card numbers where card processing is handled directly by that provider.

5.4 Payment for the underlying service is arranged directly between Client and Provider outside the Platform under the current model. Al Ayman does not process that Service Price merely because the parties met through the Platform.

6. When We Share Personal Data

We may disclose personal data only where reasonably necessary for the purposes described in this Policy, including to:

• other Platform Users where necessary for an Order, Response, Provider profile, review or Service Agreement;
• service providers supporting payment processing, authentication and communications, cloud hosting and infrastructure, maps or location functionality, analytics, security and error monitoring, customer support and verification;
• professional advisers, auditors or insurers where reasonably necessary;
• competent courts, regulators, law-enforcement bodies or other authorities where disclosure is required or permitted by applicable law; and
• a purchaser, successor or relevant adviser in connection with a lawful merger, restructuring, financing, acquisition or transfer of the Platform business, subject to appropriate confidentiality and legal safeguards.

We do not sell personal data as a standalone commercial product. Service providers are expected to process personal data only for authorised purposes and subject to appropriate contractual and security requirements.

7. International Transfers

Some service providers or technical systems used to operate the Platform may process or store personal data outside the UAE. Where personal data is transferred internationally, Al Ayman will use a transfer mechanism and safeguards permitted by applicable UAE data protection law, taking into account the destination, recipient and nature of the processing.

Where required, this may include transfers to jurisdictions recognised as providing an adequate level of protection or other contractual, organisational or legal safeguards permitted under the UAE PDPL. We do not represent that a foreign contractual mechanism automatically satisfies UAE transfer requirements merely because it is used under another country's privacy law.

8. Data Retention

We retain personal data only for as long as reasonably necessary for the purpose for which it was collected and for applicable legal, accounting, security, dispute-resolution and record-keeping requirements.

When personal data is no longer required, we will delete it, anonymise it, or securely isolate it where deletion must be delayed for a lawful reason.

9. Security

Al Ayman uses reasonable technical and organisational measures appropriate to the nature of the personal data and the risks involved. These may include access controls, authentication measures, encryption where appropriate, logging, backups, security monitoring and restrictions on personnel access.

No online service can guarantee absolute security. Users are responsible for keeping Account credentials confidential and should notify Al Ayman promptly if they suspect unauthorised Account access.

Where a personal data breach occurs, Al Ayman will assess and address it and make any notifications required by applicable UAE law.

10. Platform Chat and Moderation

10.1 Platform chat is intended to facilitate communication relating to Orders and Service Agreements. Chat content may be processed to deliver messages, provide support, investigate complaints, enforce Platform rules, protect Users and prevent fraud or fee circumvention.

10.2 Al Ayman may use proportionate automated tools to identify indicators of spam, fraud, prohibited contact sharing, abuse or other rule violations. Authorised personnel may review relevant communications where a message is flagged, a User makes a complaint, a security or compliance issue arises, or review is otherwise reasonably necessary and lawful.

10.3 We do not state that every message is read by a person. Access to chat content is limited according to operational need and applicable access controls.

10.4 Chat records may be retained where reasonably necessary for complaint handling, safety, fraud prevention, dispute evidence and legal obligations.

11. Automated Processing

Al Ayman may use automated processing to support functions such as matching or ranking relevant Providers, security monitoring, fraud detection and technical moderation. A Client remains responsible for choosing a Provider.

Where applicable UAE law gives an individual rights in relation to a decision based solely on automated processing that produces significant effects, Al Ayman will provide the rights and safeguards required by that law. Users may contact support@alayman.ae about materially significant automated decisions.

12. Your Data Protection Rights

Subject to the conditions and exceptions in applicable UAE law, individuals may have rights relating to their personal data, including rights to obtain information about processing and access personal data, request correction, request deletion where applicable, restrict or object to certain processing, request transfer of data where applicable, withdraw consent where processing is based on consent, and raise a complaint concerning the handling of personal data.

Requests may be submitted to support@alayman.ae. We may request reasonable information to verify identity before acting on a request. We will respond within the period required by applicable law and will explain where a request cannot lawfully be fulfilled.

Withdrawal of consent does not affect processing lawfully carried out before withdrawal and does not prevent processing based on another lawful basis.

13. Children

The Platform's registered transactional services are intended for persons aged 18 or over. We do not knowingly permit a person under 18 to register as a Client or Provider. If we learn that personal data has been collected from a child contrary to applicable requirements, we will take appropriate steps, which may include deletion or restriction of the relevant Account and data.

14. Cookies and Similar Technologies

The Platform may use cookies, local storage, mobile SDKs and similar technologies for essential functionality, security, preferences, analytics and, where enabled, marketing. Non-essential technologies will be handled in accordance with applicable consent requirements. More information is provided in the Cookies Policy and relevant preference controls.

15. Changes to this Privacy Policy

We may update this Policy to reflect changes in law, Platform functionality, service providers or our processing practices. The current version and effective date will be made available through the Platform.

Where a change materially affects Users, we will provide an appropriate notice. Where a new processing activity requires consent, we will obtain the required consent before relying on it.

16. General

This Policy is prepared in English and may be translated into other languages for convenience and accessibility. To the extent permitted by applicable law, the English version will be used to interpret differences between translations. This does not override any mandatory Arabic-language requirement or the requirements of a competent UAE court or authority.

17. Contact and Complaints

Privacy questions, requests and complaints may be sent to:

Al Ayman Services Gateway L.L.C-FZ

Meydan Grandstand, 6th Floor, Meydan Road, Nad Al Sheba, Dubai, U.A.E.

Support: support@alayman.ae

Individuals may also have the right to submit a complaint to the competent UAE data protection authority in accordance with applicable law. We encourage Users to contact Al Ayman first so that we have an opportunity to address the concern.