Data Sharing Agreement
This Data Sharing Agreement forms part of the Client Platform Terms
Effective Date: December 25, 2025
This Data Sharing Agreement ("DSA") forms part of the Client Platform Terms ("Platform Terms") and is between:
- Humai FZCO, a company registered in the Dubai Multi Commodities Centre (DMCC) Free Zone, United Arab Emirates, with License No. DMCC-959435, and registered address at 30E, Silver Tower, JLT, Dubai, UAE ("Huptal," "we," "us," or "our"); and
- The organization that is a counterparty to the Platform Terms ("Client," "you," or "your").
This DSA prevails if there is any conflict or inconsistency between this DSA and the Platform Terms. We may update this DSA from time to time by notice to you if such update is reasonably necessary to address the requirements of applicable Data Protection Laws.
1.Definitions
In this DSA, the following definitions apply:
"Controller," "Data Subject," "Personal Data," "Personal Data Breach," and "Processing" have the meanings given to them in applicable Data Protection Laws, including the GDPR, UK GDPR, and UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data ("UAE Data Protection Law").
"Data Protection Laws" means all applicable data protection, privacy, and security laws and regulations applicable to the Processing of Shared Personal Data under the Platform Terms, including:
- The UAE Data Protection Law
- The EU General Data Protection Regulation 2016/679 ("GDPR")
- The UK General Data Protection Regulation and Data Protection Act 2018 ("UK GDPR")
- The California Consumer Privacy Act and California Privacy Rights Act
- Any other applicable data protection laws in the jurisdictions where Talent or Client are located
"Shared Personal Data" means any Personal Data provided or communicated by us or on our behalf to you in connection with the Platform Terms, as more fully described in Section 6.
"Talent Terms" means the terms that apply to the use of the Platform by Talent.
2.Purpose of Data Sharing
2.1 Purpose
The sharing of Shared Personal Data by Huptal with you is necessary to facilitate Introductions in accordance with the Platform Terms.
2.2 Legal Basis
The Processing of Shared Personal Data as contemplated by this DSA and the Platform Terms is:
- Necessary for Huptal to perform its contractual obligations to Talent under the Talent Terms
- In the legitimate interests of Huptal, you, and Talent
- Based on the consent of Talent where required by applicable law
3.Data Processing Roles
3.1 Independent Controllers
In relation to the Processing of Shared Personal Data under the Platform Terms, you and we are each separate and independent Controllers. Neither party acts as a Processor for the other party.
3.2 Compliance
Each party agrees to comply with its obligations under applicable Data Protection Laws in connection with its Processing of Shared Personal Data.
3.3 Assistance
Each party agrees to provide reasonable assistance to the other, at the requesting party's cost, as reasonably required to enable the other to comply with Data Protection Laws in connection with this DSA and the Platform Terms.
4.Your Obligations
4.1 Lawful Processing
You must only Process Shared Personal Data:
- For the purposes of evaluating, interviewing, and potentially Engaging Talent
- In accordance with applicable Data Protection Laws
4.2 Data Subject Requests
You must provide reasonable assistance to us if we receive a request from a Data Subject to exercise their rights in relation to the Shared Personal Data, and such request relates to your Processing. You must respond to our requests for assistance within ten (10) business days.
4.3 Personal Data Breaches
You must notify us without undue delay, and in any event within forty-eight (48) hours, if you become aware of a Personal Data Breach affecting the Shared Personal Data. You must provide us with sufficient information to allow us to meet any obligations under Data Protection Laws to inform affected Data Subjects and/or regulators of such breach.
4.4 Security Measures
You must implement and maintain appropriate technical and organizational security measures to protect the Shared Personal Data against unauthorized or unlawful Processing and against accidental loss, destruction, damage, theft, alteration, or disclosure.
4.5 Data Retention
You must not retain Shared Personal Data for longer than is necessary for the purposes for which it was shared. If you do not Engage the Talent, you must delete or anonymize the Shared Personal Data within twelve (12) months of the Introduction, unless required to retain it by applicable law.
4.6 No Further Sharing
You must not share Shared Personal Data with any third party without the prior written consent of Huptal or the relevant Talent, except as required by applicable law or to your employees, contractors, or advisors who have a need to know and are bound by appropriate confidentiality obligations.
5.International Data Transfers
5.1 Transfer Mechanisms
If the sharing of Shared Personal Data constitutes a restricted transfer under applicable Data Protection Laws (for example, a transfer from the EU/EEA or UK to a country without an adequacy decision), you and we agree to enter into appropriate data transfer mechanisms, such as the EU Standard Contractual Clauses or UK International Data Transfer Addendum, as applicable.
5.2 Additional Safeguards
Each party shall implement appropriate supplementary measures as may be required to ensure an adequate level of protection for Shared Personal Data transferred internationally.
6.Data Sharing Details
Our Details
| Field | Information |
|---|---|
| Name | Humai FZCO |
| Address | 30E, Silver Tower, JLT, DMCC Free Zone, Dubai, UAE |
| Contact for Data Protection | [email protected] |
| Activities | AI-driven talent matching and recruitment assistance, identifying suitable Talent and making Introductions to prospective employers. |
| Role | Controller |
Your Details
| Field | Information |
|---|---|
| Name | The organization you represent when registering for the Platform |
| Address | The address you provide when registering for the Platform |
| Contact for Data Protection | The contact details you provide when registering for the Platform |
| Activities | A company using our Platform to find and Engage Talent |
| Role | Controller |
Details of Processing
| Category | Details |
|---|---|
| Categories of Data Subjects | Talent (job seekers and candidates) |
| Categories of Personal Data | Personal data about Talent including: Name, title, contact details (address, email, phone), photograph; National identification and/or passport details (where applicable); Education history, professional history, qualifications, certifications; Skills, language proficiencies, and competencies; References and referees' contact details; Information from CVs, portfolios, and professional profiles |
| Special Categories of Data | None expected or intended. Note: We use measures to screen and prevent sharing of sensitive data. You are responsible for compliance with Data Protection Laws if you receive such data. |
| Frequency of Transfer | Ongoing / continuous as Introductions are made |
| Nature and Purpose | Sharing Talent information to facilitate Introductions and potential Engagements under the Platform Terms |
| Retention Period | As necessary for the purposes of Engagement, subject to Data Protection Laws. If Talent is not Engaged, data must be deleted within 12 months of Introduction. |
7.Liability
Each party's liability under this DSA shall be subject to the limitation of liability provisions in the Platform Terms.
You shall indemnify and hold harmless Huptal against any fines, penalties, claims, losses, or expenses arising from or in connection with your breach of this DSA or your non-compliance with applicable Data Protection Laws, except to the extent caused by Huptal's own breach or negligence.
8.Term
This DSA shall remain in effect for the duration of the Platform Terms and shall survive termination to the extent necessary to fulfill the obligations set forth herein and to comply with applicable Data Protection Laws.
9.Governing Law
This DSA shall be governed by the same law as the Platform Terms (laws of the United Arab Emirates as applicable in the Emirate of Dubai), except where Data Protection Laws require otherwise.
10.Contact
For questions about this DSA or data protection matters, please contact us at:
Email: [email protected]
Address: 30E, Silver Tower, JLT, DMCC Free Zone, Dubai, UAE