Haq HR

HAQ HR

PRIVACY POLICY

DRAFT --- for review. Version 0.1. Last updated: [DATE]

This Privacy Policy explains how Amplified Mind ("Haq HR", "we", "us", or "our") collects, uses, discloses, and protects personal data in connection with the Haq HR website and progressive web application (the "Service"). This Policy is drafted with reference to UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data ("PDPL") and its implementing regulations, as the primary applicable data protection framework for the Service.

1. Scope and Applicability

1.1 This Policy applies to personal data processed through the Service, regardless of where you access it from.

1.2 [OPEN ITEM] If the operating entity for Haq HR is ultimately registered or hosted within a UAE free zone (such as the DIFC), the applicable data protection framework may instead be, or additionally include, the free zone's own data protection law (e.g., DIFC Data Protection Law No. 5 of 2020). This Policy should be revisited once the operating entity and hosting arrangement are finalised.

2. Data Controller

2.1 The data controller responsible for personal data processed through the Service is: Amplified Mind. A registered business address is maintained but not published; a contact channel is provided below to satisfy PDPL requirements that a data controller be identifiable and reachable for data-subject requests.

2.2 Data protection / privacy contact: [support/contact email --- TO BE CONFIRMED]

3. Personal Data We Collect

Depending on how you use the Service, we may process the following categories of data:

Session identifier: a randomly generated identifier stored on your device, used to associate your Ask questions, rate-limit usage, and Saved Answers with your session. This identifier is not, by itself, directly linked to your name or other identifying information unless you separately provide it.
Ask questions and answers: the text of questions you submit to the Ask feature, and the corresponding AI-generated answers, are processed to generate a response and, where you choose to save an answer, are stored in association with your session identifier.
Calculator inputs: figures you enter into calculators (e.g. wage, tenure) are processed locally to generate a result. [OPEN ITEM: confirm whether calculator inputs are transmitted to or stored on our servers, or processed entirely client-side, and update this clause accordingly.]
Technical and usage data: device type, browser type, general usage patterns, and log data collected automatically for security, rate-limiting, and Service-improvement purposes.
Any information you voluntarily provide, for example if you contact us directly.

4. What We Do Not Currently Collect

4.1 As of the date of this Policy, the Service does not require account registration, does not collect your name, email address, Emirates ID, or other direct identifiers as a condition of use, and does not process payment information.

4.2 If this changes (for example, if account functionality is introduced), this Policy will be updated accordingly before such collection begins.

5. Legal Basis for Processing

Under the PDPL, we process personal data on the following bases:

Consent: where you take an affirmative action, such as choosing to save an Ask answer;
Legitimate interest: to maintain, secure, and improve the Service, including rate-limiting to prevent abuse, provided this does not override your fundamental rights and interests;
Legal obligation: where processing is necessary to comply with applicable law.

6. How We Use Personal Data

To provide and operate the Ask, Calculators, Library, and related features of the Service;
To maintain Saved Answers you choose to store, and allow you to view or delete them;
To enforce reasonable rate limits and protect the Service from abuse;
To monitor, diagnose, and improve Service performance and content accuracy;
To comply with applicable legal obligations.

We do not use personal data collected through the Service for advertising, and we do not sell personal data to third parties.

7. Disclosure to Third Parties

7.1 We engage third-party service providers to operate the Service, including:

Hosting and infrastructure providers (including database and application hosting);
The underlying AI model provider used to generate Ask responses, to whom question text is transmitted for the purpose of generating an answer;

7.2 These providers process personal data on our behalf and are contractually (or, where a formal contract is not yet in place, will be required to be) restricted from using it for any purpose other than providing services to us.

7.3 [OPEN ITEM: confirm the identity, location, and data-handling terms of the hosting provider and AI model provider, and whether either results in a transfer of personal data outside the UAE --- see Clause 8.]

7.4 We may disclose personal data if required to do so by law, regulation, or valid legal process.

8. International Data Transfers

8.1 Where personal data is processed by service providers located outside the UAE (which may include the AI model provider referenced in Clause 7), such transfers will be made in accordance with the PDPL's requirements for cross-border data transfer, which generally require an adequate level of protection, appropriate safeguards, or another lawful basis for transfer.

8.2 [OPEN ITEM: this clause should be finalised once the specific providers and their data-processing locations are confirmed.]

9. Data Retention

9.1 Session identifiers and associated rate-limit data are retained for a limited period consistent with their operational purpose and are not retained indefinitely.

9.2 Saved Answers are retained until you delete them, or until [OPEN ITEM: define maximum retention period, if any].

9.3 We retain data only for as long as necessary for the purposes described in this Policy, or as required by applicable law.

10. Your Rights Under the PDPL

Subject to applicable conditions and exceptions under the PDPL, you have the right to:

Request access to personal data we hold about you;
Request correction of inaccurate personal data;
Request erasure of your personal data;
Object to or restrict certain processing;
Request data portability, where applicable;
Withdraw consent at any time, where processing is based on consent (this will not affect the lawfulness of processing carried out before withdrawal).

To exercise these rights, contact us using the details in Clause 13. Because the Service does not require account registration, we may need you to provide your session identifier (visible within the Service) to help us locate relevant data.

11. Data Security

11.1 We implement reasonable technical and organisational measures designed to protect personal data against unauthorised access, loss, misuse, or alteration, consistent with the requirements of the PDPL.

11.2 No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

12. Children's Privacy

12.1 The Service is not directed at, and is not intended for use by, children. We do not knowingly collect personal data from children. If you believe a child has provided us with personal data, please contact us so we can take appropriate action.

13. Cookies and Local Storage

13.1 The Service uses browser local storage (not third-party advertising cookies) to store your session identifier and support Progressive Web App installation and offline functionality.

13.2 You can clear this data at any time by clearing your browser's site data, though this will reset your session and any unsaved preferences.

14. Changes to This Policy

14.1 We may update this Policy from time to time. Material changes will be indicated by updating the "Last updated" date above.

15. Complaints

15.1 If you have concerns about how we handle your personal data, please contact us first using the details below.

15.2 You also have the right to lodge a complaint with the UAE Data Office (or the relevant free zone data protection authority, if applicable), the competent supervisory authority for personal data protection matters in the UAE.

16. Contact

For any questions about this Privacy Policy or to exercise your rights, contact: [support/contact email --- TO BE CONFIRMED]