Privacy Notice
How we collect, use, share and protect your personal data Text Here
1. Introduction
1.1 This Privacy Notice explains how H&I Technology DMCC (the “Company”, “we”, “us”) collects, uses, shares, transfers, retains and protects personal data when you use the Eazy Life application, the Eazy AI Concierge, our website at www.eazylife.ai and related services (together, the “Platform”).
1.2 We are committed to handling personal data lawfully, fairly and transparently, in accordance with UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (the “PDPL”), its implementing regulations, and – where relevant to our cross-border activities – internationally recognised standards including the principles of the EU General Data Protection Regulation (“GDPR”).
1.3 This Notice should be read together with our Terms & Conditions. Capitalised terms not defined here have the meaning given in the Terms.
2. Who We Are and How to Contact Us
2.1 The data controller responsible for your personal data is H&I Technology with registration number DMCC-782167 and registered address Unit No: BA118, DMCC Business Centre, Level No 1, Jewellery & Gemplex 3, Dubai, United Arab Emirates
2.2 For any privacy question, request or complaint, contact our privacy team at privacy@eazylife.ai. You also have the right to lodge a complaint with the UAE Data Office (or other competent supervisory authority).
3. Scope of this Notice
3.1 This Notice applies to Users of the Platform and to visitors to our website. Separate or supplementary privacy terms may apply to Merchants, partners, advertisers and job applicants.
3.2 The Platform may link to or integrate with third-party services. This Notice does not cover the privacy practices of Merchants, Payment Providers or other third parties, which are governed by their own privacy policies.
4. Personal Data We Collect
We collect the following categories of personal data:
| Category | Examples |
|---|---|
| Identity & contact | Name, email, mobile number, account credentials, profile details, language preference. |
| Transactional | Orders, bookings, reservations, requests, delivery and service addresses, order history, amounts, fees and invoices. |
| Payment | Payment method tokens and limited card details (typically held by our Payment Providers), billing information, transaction status. We do not store full card numbers. |
| AI interaction data | Your conversations, prompts and instructions to the Eazy AI Concierge, generated AI Output, selections, confirmations and related metadata |
| Preferences & profile | Inferred and stated preferences (e.g., dining, shopping, services), patterns, and personalisation signals used to tailor recommendations. |
| Device & technical | Device identifiers, IP address, operating system, app version, language, crash logs, diagnostics. |
| Usage & analytics | Pages and features used, interactions, search queries, session data, and cookie/SDK data (see clause 9). |
| Location | Approximate or precise location (with your permission) to enable delivery, nearby services and relevant suggestions. |
| Communications | Messages with support, feedback, reviews, ratings, and records of consent and preferences. |
| Sensitive / special category | Health-related information may be processed where you use health, pharmacy or wellness services. We process such data only where permitted by law and, where required, with your explicit consent (see clause 13). |
5. How We Collect Personal Data
- Directly from you – when you register, set preferences, chat with the AI Concierge, place orders, contact support, or participate in Eazy Xtra.
- Automatically – through your use of the Platform, via cookies, SDKs, device and analytics technologies.
- From third parties – Merchants, Payment Providers, delivery and integration partners, login providers, fraud-prevention sources and analytics providers, consistent with their obligations and applicable law.
6. Purposes and Lawful Bases for Processing
We process personal data only where we have a lawful basis. The principal lawful bases we rely on under the PDPL (and, where applicable, the GDPR) are: your consent; performance of a contract with you; compliance with a legal obligation; protection of vital interests; and our legitimate interests (balanced against your rights).
| Purpose | Lawful basis |
|---|---|
| Create and manage your account; provide the Platform and the AI Concierge; fulfil your requests, orders and bookings. | Performance of a contract |
| Process payments and prevent payment fraud. | Contract; legal obligation; legitimate interests |
| Personalise content, recommendations and the AI Concierge experience; profiling for relevance. | Consent and/or legitimate interests (see clauses 7 & 8) |
| Operate, secure, debug, audit and improve the Platform and AI systems, including model evaluation and improvement using anonymised or aggregated data. | Legitimate interests; consent where required |
| Send service communications (e.g., order updates, security notices). | Contract; legitimate interests |
| Send marketing communications and offers. | Device identifiers, IP address, operating system, app version, language, crash logs, diagnostics. |
| Comply with KYC/AML, sanctions, tax, consumer-protection and other legal obligations; respond to lawful requests. | Legal obligation |
| Detect, prevent and investigate fraud, abuse, security incidents and misuse (including Eazy Xtra abuse). | Legitimate interests; legal obligation |
| Establish, exercise or defend legal claims; corporate transactions. | Legitimate interests; legal obligation |
7. Consent and Your Choices
7.1 Where we rely on consent (for example, for certain marketing, precise location, non-essential cookies, or certain AI personalisation or sensitive-data processing), you may give or withdraw it at any time through in-app settings, your privacy dashboard, device permissions, or by contacting us. Withdrawing consent does not affect the lawfulness of processing before withdrawal and may limit some features.
7.2 Consistent with our published commitments, you can control what you share. You may, for example, choose to allow the AI Concierge to learn your preferences without sharing precise location, or use the Platform for research without storing payment details, subject to the functionality such choices enable or disable.
8. Legitimate Interests
8.1 Where we rely on legitimate interests, we balance those interests against your rights and freedoms. Our legitimate interests include operating and improving the Platform, securing it, preventing fraud and abuse, understanding usage, and offering relevant features. You may object to processing based on legitimate interests as described in clause 14.
9. Cookies, SDKs, Analytics and Tracking Technologies
9.1 We and our partners use cookies, software development kits (SDKs), pixels, device identifiers and similar technologies to operate the Platform, remember preferences, measure performance, and – with consent where required – personalise content and measure marketing. You may object to processing based on legitimate interests as described in clause 14.
9.2 We use analytics tools to understand how the Platform is used and to improve it. Some analytics and advertising partners may act as independent controllers or processors; details and controls are provided in our [Cookie Settings] and, on the website, our cookie banner.
9.3 You can manage non-essential cookies and tracking through our consent tools and your device settings. Disabling certain technologies may affect functionality.
10. AI Processing, Profiling and Automated Decision-Making
10.1 AI Concierge interactions
10.1.1 When you interact with the Eazy AI Concierge, we process your prompts, instructions, generated AI Output and related metadata to interpret and fulfil your requests, coordinate with Merchants and Third-Party Providers, and operate, secure and improve the feature.
10.1.2 The AI capabilities may be powered in whole or in part by third-party model providers acting as our processors under contractual safeguards. We take steps intended to ensure such providers process data only as instructed and protect it appropriately.
10.2 Profiling and personalisation
10.2.1 We use profiling and recommendation systems to infer preferences and personalise content, suggestions, offers and the behaviour of the AI Concierge. You can review and adjust personalisation through your privacy dashboard and settings, and object to or limit certain profiling as described in clause 14.
10.3 Automated decision-making
10.3.1 Some processing is automated (for example, recommendation ranking and fraud scoring). We do not make decisions producing legal or similarly significant effects about you based solely on automated processing without a lawful basis and appropriate safeguards. Where such decisions are made, you may, where applicable, request human review, express your view and contest the decision.
10.4 Model improvement
10.4.1 Where we use data to train, evaluate or improve machine-learning models beyond fulfilling your immediate request, we use anonymised or aggregated data from which you cannot reasonably be identified, or rely on another lawful basis with appropriate safeguards. You may contact us for more information about these practices.
11. How We Share Personal Data
We share personal data only as necessary and as described below:
11.1 Merchants and service providers. We share the data necessary to fulfil your requests (e.g., name, contact, delivery address, order details) with the relevant Merchant, delivery or service provider. They act as independent controllers for their own processing.
11.2 Payment Providers. Payment data is processed by licensed Payment Providers to complete transactions and prevent fraud, subject to their terms and security standards.
11.3 Processors and vendors. We use service providers (e.g., cloud hosting, communications, analytics, customer support, AI model providers) who process data on our behalf under written contracts requiring appropriate security and confidentiality.
11.4 Cloud hosting and data residency. The Platform is hosted on cloud infrastructure. Consistent with our commitments, we host personal data on infrastructure located in the UAE where reasonably practicable, and apply encryption in transit and at rest. [Identify hosting provider(s) and region(s).]
11.5 Legal, regulatory and safety. We may disclose data where required by law, regulation, court order or a competent authority, or to protect our rights, users, the public, or to prevent or investigate fraud, abuse or security incidents.
11.6 Corporate transactions. We may disclose or transfer data in connection with a merger, acquisition, financing, reorganisation or sale of assets, subject to appropriate safeguards.
11.7 No sale of personal data. Consistent with our public commitment, we do not sell your personal data to advertisers, whether identified, aggregated or de-identified.
12. International Data Transfers
12.1 Some recipients (including certain cloud, AI model, analytics or support providers, or Merchants for cross-border services) may be located outside the UAE. Where we transfer personal data abroad, we do so only in accordance with the PDPL – for example, to jurisdictions providing an adequate level of protection, or subject to appropriate safeguards (such as contractual clauses), or on another lawful basis (such as your explicit consent or the necessity of the transfer to perform a contract).
12.2 You may contact us for more information about the safeguards applied to international transfers.
13. Sensitive and Health-Related Data
13.1 If you use health, pharmacy, wellness or mental-health services through the Platform, we may process health-related data to facilitate your request. We process such sensitive data only where permitted by the PDPL and, where required, on the basis of your explicit consent or another lawful basis, and with enhanced safeguards. Much of this data may pass directly to the relevant licensed healthcare Merchant, who acts as a controller.
14. Your Rights
Subject to the PDPL and applicable law, you have the right to:
(a) Access – obtain confirmation of, and a copy of, your personal data;
(b) Rectification – correct inaccurate or incomplete data;
(c) Erasure – request deletion in certain circumstances;
(d) Restriction – request that we limit processing in certain circumstances;
(e) Objection – object to processing based on legitimate interests and to direct marketing;
(f) Portability – receive certain data in a structured, commonly used, machine-readable format, and have it transferred where technically feasible;
(g) Withdraw consent – where processing is based on consent;
(h) Object to automated decisions – and request human intervention where applicable; and
(i) Complain – to us and to the UAE Data Office or other competent authority.
14.1 You can exercise many of these rights directly through your in-app privacy dashboard – including viewing, editing, exporting and deleting data – or by contacting [privacy@eazylife.ai]. We will respond within the timeframe required by law and may need to verify your identity. Some rights are subject to conditions and exceptions.
15. Marketing Communications
15.1 With your consent where required, we may send you marketing about the Platform, offers and Eazy Xtra benefits by email, push notification, SMS or in-app message. You can opt out at any time using the unsubscribe link, your notification settings, or by contacting us. You will continue to receive essential service communications.
16. Children and Minors
16.1 The Platform is intended for adults aged 18 and over and is not directed at children. We do not knowingly collect personal data from children. If we learn that we have collected data from a child without an appropriate lawful basis or required guardian consent, we will take steps to delete it. If you believe a child has provided us data, contact [privacy@eazylife.ai].
17. Data Security
17.1 We implement technical and organisational measures designed to protect personal data, including encryption in transit and at rest, access controls, network security, logging and monitoring, and staff confidentiality obligations. No system is completely secure, and we cannot guarantee absolute security.
17.2 You are responsible for keeping your credentials confidential and for using the Platform on secure devices and networks.
18. Personal Data Breaches
18.1 We maintain procedures to detect, assess, contain and respond to personal-data breaches. Where a breach is likely to result in a risk to your rights, we will notify the competent authority and, where required, affected individuals, within the timeframes and in the manner required by the PDPL and its regulations.
19. Data Retention
19.1 We retain personal data only for as long as necessary for the purposes described, including to provide the Platform, comply with legal, tax, accounting, KYC/AML and regulatory obligations, resolve disputes, prevent fraud, and enforce our agreements.
19.2 Retention periods vary by data type and purpose. When data is no longer required, we delete, anonymise or securely dispose of it. Anonymised and aggregated data may be retained for analytics and model improvement.
20. Third-Party Links and Services
20.1 The Platform may contain links to or integrations with third-party sites, apps and services that we do not control. Their privacy practices are governed by their own policies, and we are not responsible for them. Review their notices before providing personal data.
21. Changes to this Notice
21.1 We may update this Notice from time to time. We will post the updated version on the Platform and update the “Last updated” date, and, for material changes, take reasonable steps to notify you. Your continued use after the effective date indicates awareness of the updated Notice; where the law requires consent, we will obtain it.
22. How to Contact Us and Complaints
Data controller: H&I Technology with registration number DMCC-782167 and registered address Unit No: BA118, DMCC Business Centre, Level No 1, Jewellery & Gemplex 3, Dubai, United Arab Emirates.
Privacy team: privacy@eazylife.ai | Web: www.eazylife.ai
You may also contact the UAE Data Office (or other competent supervisory authority) if you have concerns about our handling of your personal data.