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© 2026 NextBayt Analytics FZCO • Dubai, VAE

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Nicht mit einem Makler verbunden • Daten stammen von Digital Dubai

Legal

Privacy Policy

How NextBayt collects, uses, and protects your data.

On this page

  • 1. INTRODUCTION / SCOPE / WHO WE ARE
  • 2. DEFINITIONS
  • 3. GEOGRAPHIC SCOPE
  • 4. CATEGORIES OF PERSONAL DATA WE COLLECT
  • 5. SOURCES OF DATA
  • 6. PURPOSES OF PROCESSING
  • 7. LEGAL BASES UNDER PDPL
  • 8. IMPORTANT DISCLAIMER — AUTOMATED/STATISTICAL OUTPUTS ONLY
  • 9. AI CHAT ASSISTANT ("ZANE") DATA USE
  • 10. PROACTIVE CONTACT / DEAL-MATCHING
  • 11. FUTURE LEAD SHARING WITH REAL ESTATE BROKER PARTNERS (NOT CURRENTLY ACTIVE)
  • 12. SUB-PROCESSORS / THIRD PARTIES
  • 13. INTERNATIONAL DATA TRANSFERS
  • 14. COOKIES AND TRACKING TECHNOLOGIES
  • 15. DATA RETENTION
  • 16. DATA SUBJECT RIGHTS UNDER PDPL
  • 17. CHILDREN'S DATA
  • 18. DATA SECURITY MEASURES
  • 19. DATA BREACH NOTIFICATION
  • 20. PAYMENT DATA HANDLING (STRIPE)
  • 21. REFERRAL PROGRAM DATA USE
  • 22. FUTURE MULTI-SEAT / TEAM / ENTERPRISE ACCOUNTS
  • 23. CHANGES TO THIS POLICY
  • 24. CONTACT INFORMATION / PRIVACY CONTACT POINT
  • 25. RELATIONSHIP TO OTHER LEGAL DOCUMENTS

PRIVACY POLICY

Effective Date: 21 August 2026 Last Updated: 21 August 2026

1. INTRODUCTION / SCOPE / WHO WE ARE

This Privacy Policy explains how NextBayt Analytics FZCO ("NextBayt," "we," "us," or "our"), a company incorporated in the International Free Zone Authority (IFZA), Dubai Silicon Oasis, Dubai, United Arab Emirates, under Trade License No. 89752, collects, uses, discloses, and protects personal data in connection with the NextBayt platform, which includes our website (www.nextbayt.com), our iOS application, our Android application, our Chrome browser extension, and any related tools, features, or services we make available (collectively, the "Service").

NextBayt is the data controller responsible for the personal data described in this Policy, except where we identify a broker partner or other third party as an independent controller (see Section 11).

The Service helps users research, analyze, and track UAE real estate opportunities, including automated property analytics (such as our Deal Score, Fair Price Estimate, and Risk Analysis features), an AI chat assistant, saved searches, watchlists, portfolio tracking, and a referral program. This Policy applies to all personal data we process through any of these channels, whether you access the Service via web browser, mobile app, or browser extension.

This Policy should be read together with our Terms of Service, Cookie Policy, and, where applicable, our Data Processing Agreement ("DPA"), each of which is referenced at the relevant points below and described further in Section 25.

By creating an account or otherwise using the Service, you acknowledge that your personal data will be processed as described in this Policy. If you do not agree with this Policy, please do not use the Service.

2. DEFINITIONS

For purposes of this Policy, and aligned with the terminology used in the UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data ("PDPL"), the following terms have the meanings below:

a) "Personal Data" means any data relating to an identified or identifiable natural person, whether directly or indirectly, by reference to an identifier such as a name, email address, device identifier, IP address, or similar.

b) "Processing" means any operation performed on personal data, whether or not by automated means, including collection, recording, organization, storage, adaptation, retrieval, use, disclosure, transmission, or deletion.

c) "Controller" means the entity that determines the purposes and means of processing personal data. NextBayt acts as controller for the personal data described in this Policy, except as noted in Section 11.

d) "Processor" means an entity that processes personal data on behalf of, and under the instructions of, a controller.

e) "Sub-Processor" means a third-party processor engaged by NextBayt (as controller) or by a NextBayt customer's processor to assist in processing personal data, such as our cloud hosting, database, analytics, and AI service providers listed in Section 12.

f) "Cross-Border Transfer" means the transfer of personal data from the United Arab Emirates to a recipient located in another country, including transfers to service providers whose servers or operations are located outside the UAE.

g) "Data Subject" means the individual to whom personal data relates, i.e., you, our user.

h) "Consent" means a freely given, specific, informed, and unambiguous indication of a data subject's agreement to the processing of their personal data.

3. GEOGRAPHIC SCOPE

The Service is designed for, and operated in connection with, the United Arab Emirates real estate market and, as of the Effective Date, the European Union and European Economic Area ("EU/EEA"). If you are located in the EU/EEA, our International Data Protection Addendum (Part A - EU/EEA) applies to you in addition to this Policy and describes additional rights and safeguards specific to EU/EEA users, including as to legal bases under GDPR, international data transfers, automated-processing transparency, and supervisory authority complaint rights.

NextBayt does not currently direct marketing toward, or knowingly target, residents of the United Kingdom, Switzerland, or other jurisdictions with data protection regimes materially different from the PDPL and GDPR. If NextBayt in the future offers the Service to individuals located in the UK or Switzerland on a routine basis, we will publish a further supplementary addendum and update this Section accordingly.

If you access the Service from outside the UAE and the EU/EEA despite it not being directed to your jurisdiction, you do so on your own initiative and are responsible for compliance with any local laws that may apply to you.

Technical restriction measures (such as geoblocking, applicable to the Excluded Territories described in the Terms of Service) are applied on a reasonable-efforts basis and may be more effective on some platforms than others; browser extensions such as the NextBayt Chrome extension are inherently more difficult to reliably geo-restrict than app-store-distributed mobile applications, consistent with our Terms of Service.

4. CATEGORIES OF PERSONAL DATA WE COLLECT

We collect the following categories of personal data, depending on how you use the Service:

a) Account and Profile Data: name, email address, phone number, password (stored in hashed form), profile photo, account preferences, and language settings.

b) Usage Data: pages and features viewed, searches performed, buttons clicked, session duration, in-app navigation paths, and interaction with AI chat features.

c) Device and Technical Data: IP address, browser type and version, operating system, device identifiers, mobile advertising identifiers, screen resolution, and app version.

d) Property Search, Watchlist, and Portfolio Data: saved searches, search filters and criteria, properties viewed or bookmarked, watchlisted listings, portfolio entries you create (including any property details, notes, or valuations you input), and generated outputs such as Deal Score, Fair Price Estimate, Risk Analysis results, and PDF Dossiers associated with your account.

e) Payment Metadata: billing name, billing address, subscription plan, transaction history, and invoice records. We do not collect or store full payment card numbers; card data is collected and held directly by our payment processor, Stripe (see Section 20).

f) AI Chat Inputs and Uploaded Files: messages you type into our AI chat assistant, and any documents, images, PDFs, or other files you upload to the chat feature (see Section 9 for how this data is used).

g) Location and IP Data: approximate location derived from your IP address, and, where you grant permission, more precise device location data (for example, to support location-based property search).

h) Referral Data: identifiers and contact information (such as name and email or phone number) for individuals you refer to NextBayt through our referral program (see Section 21).

i) Communications: records of correspondence between you and NextBayt, including support tickets, emails, in-app messages, and feedback you submit.

j) Inferred Preferences: preferences or priorities you express when chatting with the AI Assistant (for example, that proximity to a university, school, or transit link is important to you), which we may extract and store as part of your profile to personalize your Deal Score and Fair Price Estimate (see Section 9(g)).

5. SOURCES OF DATA

We collect personal data from the following sources:

a) Directly From You: information you provide when you register an account, complete your profile, use the AI chat assistant, upload files, create saved searches or watchlists, make a purchase, submit a referral, or contact our support team.

b) Automatically: through cookies, analytics tools, software development kits (SDKs), and similar technologies embedded in the Service, which collect usage, device, and technical data as described in Section 4(b)-(c). See our Cookie Policy for full detail.

c) Public Government Sources: property-related data sourced from the Dubai Land Department (DLD) and Digital Dubai public data APIs and open data portals, which we use to power our analytics features. This data generally relates to properties and transactions rather than to identifiable individuals, but where it does contain personal data (for example, transaction party names in public records), we process it as permitted under applicable law for the purposes described in Section 6.

NextBayt does not currently receive personal data about you from any third-party real estate broker or brokerage firm. See Section 11 regarding our future Lead Sharing feature, which is not currently active.

6. PURPOSES OF PROCESSING

We process personal data for the following purposes:

a) Account creation, authentication, and account management; b) Delivering core analytics features, including Deal Score, Fair Price Estimate, Risk Analysis, and PDF Dossier generation, personalized where applicable based on preferences you share with the AI Assistant (see Section 9(g)); c) Operating the AI chat assistant and responding to your queries (see Section 9); d) Enabling saved searches, watchlists, and portfolio tracking; e) Administering the referral program (see Section 21); f) Processing payments and managing subscriptions via Stripe (see Section 20); g) Product analytics, service improvement, and research and development; h) Security, fraud prevention, and abuse detection; i) Complying with legal, regulatory, and tax obligations; j) Marketing communications and proactive deal-matching, where permitted (see Section 10).

NextBayt does not currently share your data with third-party real estate broker partners for lead-generation purposes; see Section 11 regarding this potential future feature.

7. LEGAL BASES UNDER PDPL

We rely on the following legal bases, as recognized under the PDPL, to process your personal data:

a) Consent: for processing that requires your affirmative agreement, including: use of your chat content to train, fine-tune, or improve AI systems as described in Section 9(f); marketing and proactive deal-matching contact as described in Section 10; cross-border transfer of your data tied to optional features — the AI chat assistant and non-essential marketing/analytics tools — as described in Section 13; and the use of non-essential cookies and tracking technologies as described in our Cookie Policy. Where processing is based on consent, you may withdraw that consent at any time as described in Section 16, without affecting the lawfulness of processing carried out before withdrawal.

By contrast, cross-border transfer of your data that occurs as part of core Service infrastructure (for example, cloud hosting via Google Cloud Platform in the United States), and the use of the underlying AI model to generate a response to a chat query, are processed on the basis of contractual necessity described in paragraph (b) below, because they are integral to delivering the Service you have requested and cannot be separately opted out of while continuing to use the Service.

b) Contractual Necessity: processing needed to deliver the Service you have requested, including account provisioning, core analytics features, generating responses to AI chat queries, personalizing your Deal Score and Fair Price Estimate based on preferences you share with the AI Assistant (Section 9(g)), billing through Stripe, and the underlying cross-border hosting infrastructure (Section 13) necessary to operate the Service at all.

c) Legitimate Interest: processing necessary for our legitimate business interests, including maintaining the security and integrity of the Service, preventing fraud and abuse, and conducting product analytics to improve the Service, provided such interests are not overridden by your fundamental rights and interests.

d) Legal Obligation: processing necessary to comply with applicable law, including tax record-keeping, financial reporting, and responding to lawful requests from UAE regulators or courts.

NextBayt does not currently process any personal data for the purpose of Lead Sharing with Broker Partners, as this feature is not currently active (see Section 11). If we activate this feature in the future, we will identify and document the applicable legal basis and update this Policy accordingly before the feature applies to your Account.

8. IMPORTANT DISCLAIMER — AUTOMATED/STATISTICAL OUTPUTS ONLY

Our Deal Score, Fair Price Estimate, and Risk Analysis features are generated using deterministic, rules-based statistical models applied to available property and market data. These outputs are not generated by artificial intelligence or machine learning, and they are not predictions, guarantees, or professional appraisals of any kind. They are provided for general informational purposes only, to help you organize and interpret publicly available property data.

NextBayt is not a licensed real estate broker, financial advisor, investment advisor, or valuation professional, and nothing in the Service constitutes brokerage services, financial advice, investment advice, or a formal property valuation. You should not rely on any output of the Service as a substitute for independent professional advice, and you should conduct your own due diligence, including consulting licensed professionals, before making any real estate or financial decision.

This disclaimer is a summary. The full and controlling disclaimer, including limitations of liability, appears in our Terms of Service, which you should review in conjunction with this Policy.

9. AI CHAT ASSISTANT ("ZANE") DATA USE

Our AI chat assistant, referred to in the Service as "Zane" (also known in some contexts as "Zain"), allows you to ask questions and receive information about properties, the market, and your account. This section explains specifically how we handle the data you share through this feature.

a) What We Collect: when you use the AI chat assistant, we collect the text of your messages and any files you upload to the chat (such as documents, images, spreadsheets, or PDFs), together with associated metadata (timestamps, conversation identifiers, and account association).

b) How We Use It: your chat messages and uploaded files may be used to (i) generate responses to your queries, (ii) monitor the performance, safety, and reliability of the AI chat feature, (iii) improve NextBayt's own systems, and, where a third-party AI provider's terms permit it, help improve the underlying models we use, and (iv) investigate misuse, abuse, or violations of our Terms of Service.

c) Human Review: we can't promise a particular conversation will or won't be seen by a human. We don't review conversations as a routine practice, but staff or contracted reviewers may look at specific conversations when needed — for example, to investigate flagged content, handle a support request, check quality and safety, or meet a legal requirement.

d) Third-Party AI Sub-Processors: to power the chat assistant, we transmit your chat inputs and uploaded files to one or more third-party artificial intelligence providers acting as our sub-processors, depending on which underlying model is used to process a given request. These providers currently include:

- Anthropic (Claude API), based in the United States; - OpenAI (ChatGPT), based in the United States; - Moonshot AI (Kimi), based in China; and - DeepSeek, based in China.

These providers process chat content under their own respective data processing terms and may temporarily retain data as needed to provide the service to us, subject to the safeguards described in Section 13 regarding cross-border transfers. We select and route requests among these providers based on factors including performance, cost, and feature availability, and the specific provider used for a given conversation may vary and may change over time. Several of our AI providers commit not to use API inputs for their own model training by default, and we do not represent that any given provider trains on your data unless its own terms permit it.

e) Sensitive Information: please do not share personal data of third parties, financial account credentials, government identification numbers, or other highly sensitive information in the AI chat unless necessary and appropriate, as such content is subject to the same processing described above.

f) Legal Basis: sending your message to the underlying model to generate a response is necessary to deliver the chat feature and is based on contractual necessity. Using your chat content to train, fine-tune, or improve our AI systems or third-party models is based on your consent, which you may withdraw via your account privacy settings without needing to stop using the chat feature for query-response.

g) Profile Personalization: where you express a preference or priority in your conversation with the AI Assistant (for example, that proximity to a university, school, or transit link is important to you), we may extract that preference and store it as part of your account profile, and may use it to personalize the weighting applied within your Deal Score and Fair Price Estimate. This personalization changes which inputs are weighted more heavily for your account; it does not change the deterministic, rule-based nature of the underlying methodology, as described in our Terms of Service. Because extracting a preference from natural-language chat uses non-deterministic AI models, the specific preference recorded may vary depending on how a statement is phrased or interpreted, so your resulting Deal Score or Fair Price Estimate may change over time even where the scoring rules themselves have not. This processing is necessary to deliver the personalized experience you request through the AI Assistant and is based on contractual necessity, not consent, and is not subject to withdrawal in the same way as the training-related consent described in paragraph (f) above; however, you may review, correct, or delete stored profile preferences at any time through your account settings, which will stop them from being used in future personalization.

10. PROACTIVE CONTACT / DEAL-MATCHING

To help you find relevant opportunities without having to search manually, NextBayt may proactively analyze your account activity, saved searches, watchlist entries, portfolio data, and profile information to identify properties, listings, or market developments ("Matches") that may be relevant to your stated interests.

a) What We Analyze: this may include the criteria in your saved searches, the properties you have watchlisted, the characteristics of properties in your portfolio, your stated preferences, and your general usage patterns on the Service.

b) How We Contact You: where we identify a potential Match, or otherwise wish to send you marketing or promotional content about the Service, we may contact you through one or more of the following channels: email, WhatsApp, phone call, and in-app notification.

c) Your Opt-Out Rights: you have the right to opt out of proactive contact and deal-matching communications on a per-channel basis. This means you can, for example, disable WhatsApp contact while continuing to receive email notifications, or vice versa. You can manage these preferences at any time through your account settings, through the unsubscribe link included in marketing emails, by replying "STOP" to WhatsApp messages, or by contacting us using the details in Section 24. Opting out of marketing and deal-matching communications does not affect transactional or service-related communications necessary for the operation of your account (such as billing notices, security alerts, or responses to your support requests), which are not marketing in nature.

d) Consent: proactive contact and deal-matching communications are conducted on the basis of your consent, which you provide at signup or through your continued use of the relevant features, and which you may withdraw at any time through the mechanisms described above.

11. FUTURE LEAD SHARING WITH REAL ESTATE BROKER PARTNERS (NOT CURRENTLY ACTIVE)

NextBayt does not currently share your contact details, property interests, or other personal data with any third-party real estate broker, brokerage firm, or similar business ("Broker Partner(s)").

We may introduce a lead-sharing feature in the future, under which limited contact and property-interest information could be shared with independent Broker Partners so they can contact you directly about relevant opportunities ("Lead Sharing"). If we do, Broker Partners would act as independent controllers of the data shared with them, not as our processors: they would determine their own purposes and means for using that information, and NextBayt would not control or be responsible for their independent handling of it. Before activating Lead Sharing, we will update this Policy to describe the feature and the data involved, present it to you clearly and prominently at account registration (separately from your general acceptance of this Policy), and provide a genuine, easy, always-available opt-out, consistent with Section 23.

12. SUB-PROCESSORS / THIRD PARTIES

We engage the following categories of third-party service providers ("sub-processors") to help us operate the Service. Each processes personal data only to the extent necessary to perform its function on our behalf (except where noted as an independent controller).

Sub-Processor

Role

Location

Google Cloud Platform (GCP)

Cloud hosting and infrastructure

United States

Supabase

Database and backend services

United States (primary region; NextBayt will update this table if the hosting region changes)

Cloudflare

Content delivery network (CDN) and security services

Global network (edge); United States (corporate)

Anthropic (Claude API)

AI chat assistant processing

United States

OpenAI (ChatGPT)

AI chat assistant processing

United States

Moonshot AI (Kimi)

AI chat assistant processing

China

DeepSeek

AI chat assistant processing

China

Google Analytics

Product and website analytics

United States

Microsoft Clarity

Product and website analytics (session/behavior analytics)

United States

Meta (Facebook Pixel)

Advertising and marketing analytics

United States

Prighter GmbH (EU Representative, Art. 27 GDPR)

Channeling and forwarding data subject requests and, where applicable, data breach notifications received via NextBayt's EU Representative

Austria (Prighter); Germany (underlying infrastructure via Hetzner Online GmbH)

Stripe

Payment processing

United States / global

We may update the list of sub-processors from time to time as our operational needs evolve, including replacing or adding vendors that perform similar functions. Where such a change involves a new category of processing or a materially different transfer risk, we will update this Policy and, where required, seek renewed consent.

13. INTERNATIONAL DATA TRANSFERS

Cross-border transfer of your data occurs as part of core Service infrastructure (for example, cloud hosting via Google Cloud Platform in the United States) that is necessary to provide the Service you have requested, and is carried out on the basis of contractual necessity — it cannot be individually withdrawn while you continue to use the Service.

Separately, cross-border transfer tied to optional features — the AI chat assistant (Section 9) and non-essential marketing/analytics tools (Section 14) — is carried out on the basis of your consent, given at signup and through continued use of those specific features, and may be withdrawn at any time by discontinuing use of the relevant feature, without affecting your ability to use the rest of the Service.

Where your data is transferred to AI sub-processors located in China (Moonshot AI, DeepSeek), be aware those providers are subject to Chinese law, which may permit government access to data held by companies operating there. We recommend not entering highly sensitive personal information into the AI chat (see Section 9(e)).

Where required, we also seek to ensure that recipients are subject to contractual or organizational commitments regarding the protection of personal data consistent with applicable UAE requirements.

14. COOKIES AND TRACKING TECHNOLOGIES

We and our third-party partners use cookies, pixels, SDKs, and similar tracking technologies on the Service to enable core functionality, remember your preferences, understand how the Service is used, and support marketing and analytics (including through Google Analytics, Microsoft Clarity, and the Meta Facebook Pixel referenced in Section 12).

For full details on the specific cookies and tracking technologies we use, their purposes, their duration, and how to manage your preferences (including how to decline non-essential cookies), please see our standalone Cookie Policy, which forms part of, and should be read together with, this Privacy Policy.

15. DATA RETENTION

We retain personal data only for as long as reasonably necessary to fulfil the purposes for which it was collected, as described below:

a) Account Data: retained for as long as your account remains active, and for a reasonable period thereafter (generally up to 12 months following account closure) to allow for account recovery, dispute resolution, and legal compliance, after which it is deleted or anonymized. This includes any preferences inferred from your conversations with the AI Assistant and stored as part of your profile (see Section 9(g)).

b) AI Chat Logs: retained for up to 24 months from the date of the conversation, then deleted or anonymized, except that specific flagged conversations may be retained longer where needed to investigate misuse, respond to a legal request, or resolve an active dispute.

c) Transaction and Payment Records: retained for the period required by applicable UAE tax, accounting, and commercial record-keeping laws (generally at least five years from the date of the relevant transaction).

d) Analytics Data: usage and device data collected through analytics tools is generally retained in identifiable or pseudonymized form for up to 26 months, consistent with standard analytics platform retention settings, after which it is deleted or aggregated.

e) Marketing and Contact Records: retained for as long as you have not opted out of marketing communications, and for a reasonable period thereafter to record and honor your opt-out preference.

f) Post-Deletion: following account deletion or the expiry of the applicable retention period, we delete or irreversibly anonymize personal data, except where retention is required by law, necessary to resolve disputes, or necessary to enforce our agreements. Backup copies may persist for a limited additional period consistent with our standard backup rotation cycles before being permanently purged.

16. DATA SUBJECT RIGHTS UNDER PDPL

Subject to applicable law, you have the following rights regarding your personal data:

a) Right of Access: to request confirmation of whether we process your personal data, and to obtain a copy of it.

b) Right of Correction: to request that we correct inaccurate or incomplete personal data.

c) Right of Deletion: to request that we delete your personal data, subject to applicable legal retention requirements described in Section 15.

d) Right to Object/Restrict: to object to, or request restriction of, certain processing of your personal data, including processing based on legitimate interest.

e) Right to Withdraw Consent: to withdraw any consent you have previously given, including your consent to: (i) use of your chat content to train or improve AI systems (Section 9(f)); (ii) marketing and proactive deal-matching contact (Section 10); and (iii) cross-border data transfer tied to optional features such as AI chat and marketing/analytics tools (Section 13). Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal and may limit your ability to use certain features.

How to Exercise Your Rights: you may exercise any of these rights by contacting us using the details in Section 24, or, where available, through the relevant in-app account settings. We aim to acknowledge requests within a reasonable time and to respond substantively within thirty (30) days, or such other period as required under applicable law. We may need to verify your identity before processing certain requests.

17. CHILDREN'S DATA

The Service is not directed to, and is not intended for use by, individuals under the age of 18. We do not knowingly collect personal data from children under 18. If we become aware that we have inadvertently collected personal data from a child under 18, we will take reasonable steps to promptly delete that data from our records. If you believe a child has provided us with personal data, please contact us using the details in Section 24 so we can investigate and take appropriate action.

18. DATA SECURITY MEASURES

We implement technical and organizational measures designed to protect personal data against unauthorized access, loss, misuse, or alteration, appropriate to the nature and sensitivity of the data. These measures include, among others:

a) encryption of data in transit (e.g., via TLS/HTTPS) and, where appropriate, at rest; b) access controls limiting internal access to personal data on a need-to-know basis, including role-based permissions; c) reliance on reputable infrastructure providers (Google Cloud Platform, Supabase, and Cloudflare) that maintain their own industry-standard security certifications and safeguards; d) monitoring and logging designed to detect and respond to suspicious activity; and e) periodic review of our security practices as the Service evolves.

No method of transmission or storage is completely secure, and we cannot guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials and for notifying us promptly of any suspected unauthorized access to your account.

19. DATA BREACH NOTIFICATION

In the event of a personal data breach that is likely to result in a risk to the rights and freedoms of affected individuals, we will assess the incident promptly and, consistent with the expectations of the PDPL, notify the UAE Data Office (or successor competent authority) and affected users without undue delay, taking into account the nature of the breach and the need to investigate and remediate before notification where appropriate. Notification to affected users will include, to the extent reasonably available, a description of the nature of the breach, the likely consequences, and the measures taken or proposed to address it.

20. PAYMENT DATA HANDLING (STRIPE)

Payments for the Service (currently supported in AED and USD, via the web platform only) are processed by Stripe, Inc., a third-party payment processor. When you make a payment, your card details are collected and stored directly by Stripe in accordance with Stripe's own security standards (including PCI-DSS compliance); NextBayt does not collect, transmit, or store your full card number, expiry date, or CVV. We receive and retain only payment metadata from Stripe, such as transaction confirmations, invoice records, subscription status, and the last four digits of your card for your reference, as necessary to manage your subscription and comply with our accounting obligations. Your use of Stripe's payment services is also subject to Stripe's own privacy policy and terms.

21. REFERRAL PROGRAM DATA USE

If you participate in our referral program, we collect and process: (a) your own referrer identifier and referral activity (such as the number of referrals made and rewards earned), and (b) contact information you provide about the person you wish to refer (the "referee"), such as their name and email address or phone number, solely for the purpose of sending them an invitation to join NextBayt on your behalf. We do not use referee contact information for any purpose other than delivering the referral invitation and administering the referral program, and we will honor any request from a referee to not be contacted again. If you submit a referral, you confirm that you have a lawful basis to share the referee's contact information with us for this purpose (for example, their consent or an existing relationship with you).

22. FUTURE MULTI-SEAT / TEAM / ENTERPRISE ACCOUNTS

NextBayt may in the future introduce multi-seat, team, or enterprise account offerings that allow organizations to manage multiple individual users under a single account structure. Should such offerings become available, additional or updated privacy terms may apply to describe how personal data is processed within such accounts, including the respective roles and responsibilities of NextBayt and the enterprise customer (which, for such offerings, are generally expected to be governed by our Data Processing Agreement, as referenced in Section 25). We will update this Policy, or provide a supplementary notice, before such features are made generally available.

23. CHANGES TO THIS POLICY

We may update this Policy from time to time to reflect changes in our practices, the Service, or applicable law. When we make material changes, we will update the "Last Updated" date at the top of this Policy and, where the changes are significant (for example, changes affecting the legal basis for processing, new categories of data collected, or new purposes of processing), we will provide additional notice, such as an in-app notification or email, and, where required by law, seek renewed consent before the change takes effect. We encourage you to review this Policy periodically. Continued use of the Service after a change takes effect constitutes your acceptance of the revised Policy, except where your affirmative consent is separately required by law.

24. CONTACT INFORMATION / PRIVACY CONTACT POINT

If you have questions, concerns, or requests regarding this Policy or our handling of your personal data, including requests to exercise your rights under Section 16 or to opt out of the practices described in Section 10, please contact us at:

NextBayt Analytics FZCO IFZA, Dubai Silicon Oasis, Dubai, United Arab Emirates Email: [email protected]

We aim to acknowledge all privacy-related inquiries promptly and to resolve them within a reasonable timeframe, consistent with the response periods described in Section 16.

25. RELATIONSHIP TO OTHER LEGAL DOCUMENTS

This Privacy Policy operates alongside, and should be read together with:

a) Terms of Service — governs overall use of the Service and contains disclaimers and limitations of liability, including the disclaimer at Section 8 (Important Disclaimer) of this Policy;

b) Cookie Policy — provides full detail on cookies per Section 14;

c) DPA — for enterprise/business customers, governs the specifics of data processing, sub-processor arrangements, and data protection commitments applicable to that customer's account, and takes precedence over this Policy solely with respect to data-processing matters arising under the applicable enterprise agreement between NextBayt and that customer.

Where this Policy and the DPA conflict regarding processing under an applicable enterprise agreement, the DPA governs; otherwise, this Policy governs.