Privacy Policy
How we collect, use, and protect your personal data
Effective Date: December 25, 2025
At Huptal, operated by Humai FZCO ("we," "us," or "our"), we respect your privacy and are committed to protecting your personal data. This Privacy Policy explains how we collect, use, disclose, and protect your personal data when you use our Platform and services.
1.Who We Are
Legal Entity: Humai FZCO, trading as "Huptal," is a company registered in the Dubai Multi Commodities Centre (DMCC) Free Zone, United Arab Emirates, with License No. DMCC-959435.
Data Controller: We are the controller of personal data collected through the Platform. For questions about this Privacy Policy or our data practices, please contact us at [email protected].
Registered Address: 30E, Silver Tower, JLT, Dubai, UAE
2.Scope of This Policy
This Privacy Policy applies to all users of our Platform (huptal.com and its subdomains), mobile applications, and related services, including both Talent (job seekers and candidates) and Clients (employers and organizations). This Policy describes how we collect, use, and protect your personal data when you use our Platform and when we communicate with you.
3.Information We Collect
3.1Information You Provide
Account Information: Name, email address, phone number, password, and other registration details.
Profile Information (Talent): Professional experience, skills, education, certifications, work history, salary expectations, location preferences, career goals, CVs, portfolios, and other professional details.
Company Information (Clients): Company name, industry, size, hiring requirements, job descriptions, and contact details for authorized users.
Communications: Messages, feedback, and other communications you send to us or through the Platform.
3.2Information from AI Interactions
Voice & Video Recordings: Audio and video recordings of your interactions with our AI systems, including interviews and assessments.
Transcripts: Transcriptions of your conversations with our AI systems.
Assessment Data: Scores, evaluations, and analytics from AI-powered assessments.
3.3Automatically Collected Information
Device Information: Device type, operating system, browser type, unique device identifiers.
Usage Data: Pages visited, features used, time spent on the Platform, click patterns, and other usage analytics.
Log Data: IP addresses, access times, referring URLs, and error logs.
Location Data: Approximate location based on IP address or, with your consent, more precise location data.
4.How We Use Your Information
We use your personal data for the following purposes:
Service Delivery: To provide our talent matching and recruitment services, including creating and maintaining your profile, matching you with opportunities or candidates, and facilitating Introductions.
AI Processing: To analyze your information using AI and machine learning to improve matching quality, provide recommendations, and generate insights.
Communications: To send you service-related communications, job alerts, updates, and, with your consent, marketing and promotional messages via email, SMS, WhatsApp, or other channels.
Platform Improvement: To analyze usage patterns, improve the Platform, develop new features, and enhance user experience.
AI Model Training: To train, improve, and refine our AI models and algorithms using anonymized or aggregated data. We may also use data to improve third-party AI models we use, subject to appropriate data protection safeguards.
Security & Fraud Prevention: To protect the Platform, detect and prevent fraud, unauthorized access, and other illegal activities.
Legal Compliance: To comply with applicable laws, regulations, legal processes, and governmental requests.
Aggregated Analytics: To compile and use aggregated or anonymized data for analytics, marketing, and research purposes. Such data will not identify you personally.
5.Legal Basis for Processing
We process your personal data based on the following legal grounds:
Contract Performance: Processing necessary to perform our contract with you and provide our services.
Legitimate Interests: Processing necessary for our legitimate business interests, such as improving our services, marketing, security, and fraud prevention, provided these interests are not overridden by your rights.
Consent: Where we rely on your consent for specific processing activities (e.g., marketing communications, special category data), you may withdraw your consent at any time.
Legal Obligations: Processing necessary to comply with applicable laws and regulations.
6.Data Sharing & Disclosure
6.1Sharing with Employers/Clients (for Talent)
By default, we may automatically share your profile, professional details, and contact information with potential employers and clients we believe align with your experience and interests. You can control this automatic sharing in your account settings.
6.2Service Providers
We share personal data with third-party service providers who help us operate the Platform, including cloud hosting providers, AI model providers (such as OpenAI, Anthropic, and Google), analytics providers, communication service providers, and payment processors.
6.3Business Transfers
In connection with any merger, acquisition, corporate reorganization, sale of assets, or similar transaction, your personal data may be transferred to the acquiring entity.
6.4Legal Requirements
We may disclose your personal data if required by law, court order, legal process, or government request, or to protect our rights, property, safety, or the rights, property, and safety of others.
6.5No Selling of Data
7.International Data Transfers
Our services are operated from the United Arab Emirates. If you access our Platform from outside the UAE, your data may be transferred to and processed in the UAE and other jurisdictions where we or our service providers operate.
We implement appropriate safeguards for international data transfers, including Standard Contractual Clauses, adequacy decisions, or other legally recognized transfer mechanisms, to ensure your data receives adequate protection.
8.Data Retention
Active Accounts: We retain your personal data for as long as your account is active and as necessary to provide our services.
After Account Closure: We may retain your personal data (including voice recordings and transcripts) for up to forty-eight (48) months after account closure or last activity to comply with legal obligations, resolve disputes, enforce our agreements, and for legitimate business purposes.
Inactive Profiles: If you create an account but do not complete registration or become inactive, we may delete your data after twenty-four (24) months of inactivity.
AI Training Data: Anonymized data used for AI training may be retained indefinitely as it cannot be linked back to you.
Deletion Requests: You may request deletion of your data at any time by contacting [email protected]. We will comply within thirty (30) days, subject to legal retention requirements.
9.Your Rights
Depending on your location and applicable law, you may have the following rights regarding your personal data:
- Access: Request a copy of the personal data we hold about you.
- Rectification: Request correction of inaccurate or incomplete data.
- Erasure: Request deletion of your personal data ("right to be forgotten").
- Restriction: Request restriction of processing in certain circumstances.
- Portability: Request your data in a structured, commonly used, machine-readable format.
- Objection: Object to processing based on legitimate interests or for direct marketing.
- Withdraw Consent: Withdraw consent at any time where processing is based on consent.
To exercise these rights, contact us at [email protected]. We will respond within the timeframes required by applicable law.
10.AI & Automated Decision-Making
10.1AI Processing
We use AI and automated systems to analyze your profile, conduct assessments, generate recommendations, and match you with opportunities. This means some decisions may be made or supported by automated processing.
10.2Human Oversight
We maintain human oversight over significant decisions. AI outputs are reviewed by qualified personnel, and final hiring decisions always remain under human control.
10.3Your Rights
You have the right to:
- Request human review of automated decisions
- Challenge AI-driven assessments
- Request information about how AI decisions were made
- Opt out of certain AI processing where legally required
10.4AI Limitations
AI technology has limitations and may occasionally produce inaccurate results. If you believe your information was inaccurately processed, please contact us at [email protected].
11.Use of AI Recordings & Transcripts
We reserve the right to access and review user recordings and transcripts internally for:
Product Improvement: Enhancing AI accuracy and user experience.
Compliance & Security: Monitoring for inappropriate activity, ensuring compliance with our terms, and detecting fraud.
Technical Support: Troubleshooting and resolving issues.
Access is limited to authorized personnel with a legitimate business need, and we maintain confidentiality obligations internally.
13.Security
We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, loss, alteration, or disclosure. These measures include encryption, access controls, secure data centers, and regular security assessments.
However, no method of transmission over the internet is 100% secure. While we strive to protect your data, we cannot guarantee absolute security. You are responsible for keeping your login credentials confidential.
14.Children's Privacy
Our Platform is not intended for individuals under the age of 18. We do not knowingly collect personal data from children. If we become aware that we have collected data from a child under 18, we will take steps to delete such data promptly. If you believe we have collected data from a child, please contact us at [email protected].
15.Third-Party Links
Our Platform may contain links to third-party websites or services. We are not responsible for the privacy practices or content of such third parties. We encourage you to read the privacy policies of any third-party services you access.
16.Marketing Communications
With your consent, we may send you marketing communications about our services, new features, and relevant opportunities. You can opt out at any time by:
- Clicking the unsubscribe link in our emails
- Replying STOP to SMS messages
- Updating your communication preferences in account settings
- Contacting us at [email protected]
Opting out of marketing will not affect transactional or service-related communications.
17.Region-Specific Rights
17.1European Economic Area, UK, and Switzerland
If you are located in the EEA, UK, or Switzerland, you have additional rights under the GDPR/UK GDPR, including the rights described in Section 9. You also have the right to lodge a complaint with your local data protection authority.
17.2United States (California and Other States)
If you are a California resident or resident of another US state with privacy legislation, you may have additional rights, including the right to know what personal information we collect, the right to delete, and the right to opt out of the sale or sharing of personal information. We do not sell your personal information. To exercise your rights, contact us at [email protected].
17.3United Arab Emirates
If you are a UAE resident, we process your data in accordance with UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data. You have rights to access, correct, and delete your personal data.
18.Changes to This Policy
We may update this Privacy Policy from time to time. We will notify you of material changes by posting the updated policy on our Platform, updating the "Effective Date," and, where appropriate, sending you an email notification. Your continued use of the Platform after any changes constitutes acceptance of the updated Policy.
19.Contact Us
If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:
Data Protection Contact: [email protected]
General Support: [email protected]
20.Complaints
If you believe we have not handled your data appropriately, you have the right to lodge a complaint with your local data protection authority. However, we encourage you to contact us first so we can try to resolve your concerns directly.