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Privacy Policy

PRIVACY NOTICE 

(IWAA TECH PLATFORM) 

Effective date: 01/01/2026 

This Privacy Notice (the “Notice”) describes how Integrated Workstream Technologies Solutions FZ-LLC (“IWAA TECH”, “we”, “us” or “our”) controls Personal Data in connection with the IWAA TECH platform (the “Platform”). The Platform is built with Integrated Applications that provides access to FM solutions, including applications but not limited to Predictive maintenance, Asset management and other Workplace related services. The Platform hosts both third-party software products offered by independent software vendors (“ISVs”) and certain in-house products developed and operated under the aegis of IWAA TECH. 

  1. SCOPE 

This Notice applies where you access or use the Platform as: (i) an authorised user of a customer organisation (“Customer”), including a customer administrator; and/or (ii) an individual who communicates with us in relation to Platform access, administration, security or support. 

The Platform provides access to ISV Products and  in certain cases, in-house products developed by IWAA TECH. Personal Data shared with or processed within an ISV Product is governed by the relevant ISV’s privacy notice and the applicable agreement(s) between the ISV and the Customer and/or end user. IWAA TECH is not responsible for the privacy practices of ISVs. 

  1. DEFINITIONS 

“Personal Data” means information relating to an identified or identifiable natural person. 

“Processing” means any operation performed on Personal Data (including collection, use, disclosure, storage, or deletion). 

  1. ROLES 

For Personal Data controlled in connection with operating, securing and administering the Platform, such as access management, authentication, audit logging and support (together, “Platform Data”) IWAA TECH acts as a controller. IWAA TECH does not act as a data processor in respect of Platform Data in regard to ISV applications. IWAA TECH does not store Personal Data on behalf of Customers; it controls and shares Platform Data as described in this Notice. Personal Data processed within ISV Products or in-house products is subject to the terms applicable to those products. 

  1. PLATFORM DATA WE CONTROL 

        Depending on how the Platform is used, Platform Data may include: 

  • Account and administrative information (such as name, business email address, phone number where provided, organisation, job title and user role/permissions). 
  • Authentication and identity information (such as login and authentication events and SSO/identity attributes processed via a third-party identity provider). 
  • Technical, security and audit information (such as IP address, device and browser information, audit trails, activity logs and security telemetry used for monitoring, fraud prevention and incident response). 
  • Support and communications (such as support tickets, service requests and correspondence with related metadata). 
  • ISV and in-house product enablement information (limited) (such as entitlements, workspace identifiers, integration identifiers and related technical metadata required to enable access to ISV Products or in-house products selected or operated by a Customer). 

IWAA TECH does not host or store Customer datasets processed within ISV Products, except to the limited extent technically necessary for Platform enablement, security or support or as otherwise agreed. IWAA TECH’s role is to control and direct the sharing of Platform Data with the relevant parties; data storage is the responsibility of ISVs (or, for in-house products, the applicable product terms). Processing within ISV Products is primarily governed by the relevant ISV and its arrangements with the Customer. 

The Platform is not intended to require sensitive Personal Data as a standard feature. If sensitive Personal Data is processed, IWAA TECH will apply enhanced safeguards and provide any additional notices required by applicable law. 

  1. SOURCES OF PERSONAL DATA 

We obtain Personal Data: (i) directly from you or from your organisation, including via Customer administrators; (ii) automatically through use of the Platform (including logs and technical data); and (iii) from third parties such as identity/SSO providers where applicable. 

  1. PURPOSES OF CONTROLLING PERSONAL DATA 

        We control Platform Data for the following purposes: 

  • Provisioning and account management, including user onboarding and access/role administration. 
  • Authentication and access security, including SSO/identity verification, audit logging, monitoring, fraud prevention and incident response. 
  • Platform operation and service delivery, including maintaining functionality, reliability, troubleshooting and service continuity. 
  • Support and communications, including responding to enquiries and tickets, and issuing service and security notifications. 
  • Enablement of ISV Products and in-house products selected by Customers, including routing, entitlements and integrations as configured or required. 
  • Compliance and protection, including meeting legal obligations, enforcing terms, defending claims and responding to lawful requests. 
  • Improvement and analytics relating to Platform performance, reliability and security, subject to appropriate controls. 

Service communications may be sent where necessary to provide or protect the Platform and are not marketing in nature. Marketing communications, if introduced, will be carried out in accordance with applicable law and, where required, on an opt-in basis with an unsubscribe mechanism. 

  1. DISCLOSURES 

       We may share Platform Data with: 

  • ISVs and integration partners (Customer-selected), where necessary to enable access to and/or operation of an ISV Product selected by a Customer, consistent with Customer configuration and Platform requirements. 
  • Group affiliates, which store certain Platform audit and security logs for operational, monitoring and security purposes and act as affiliate service providers supporting Platform operations. 
  • Identity provider is a third-party identity/SSO provider used for authentication and access control. This identity provider forms part of the same corporate group as IWAA TECH but is a separate legal entity from IWAA TECH and operates its own services under its own terms. 
  • Service providers, including cloud hosting/infrastructure, cybersecurity, monitoring and support tooling providers engaged to operate and secure the Platform. 
  • Legal and regulatory recipients, including professional advisers (such as legal and audit) and competent authorities where disclosure is required by law or reasonably necessary to protect rights, safety and security. 

IWAA TECH does not sell Personal Data. 

  1. INTERNATIONAL TRANSFERS 

The Platform infrastructure is hosted outside the UAE. Accordingly, Platform Data may be transferred to and processed in jurisdictions outside the UAE in case if customer opts for SaaS model. 

In addition, ISVs accessible through the Platform may host or process Personal Data in other jurisdictions according to their own arrangements with Customers. Customers and end users should review the relevant ISV privacy notice and contractual terms for ISV-specific transfer details. 

Where IWAA TECH shares Personal Data internationally, IWAA TECH implements safeguards consistent with applicable law and relevant contractual requirements. 

  1. RETENTION 

IWAA TECH retains Platform Data only for as long as necessary for the purposes described in this Notice, taking into account legal, regulatory, security and operational requirements. Retention periods may vary by data type. As noted in Section 4, IWAA TECH does not store Personal Data processed within ISV Products; such retention is determined by the relevant ISV and/or the ISV–Customer agreement. 

  1. SECURITY 

We maintain technical and organisational measures designed to protect Platform Data against unauthorised access, loss, misuse, alteration or disclosure. No system is entirely secure; however, we apply safeguards proportionate to the risks associated with the Platform. 

  1. AUTOMATED PROCESSING AND PREDICTIVE ANALYTICS 

The Platform and/or certain ISV Products or in-house products may include analytics or predictive functionality (including automated processing) intended to generate insights, recommendations or forecasts. Where IWAA TECH performs such processing as part of Platform or in-house product operations, it will be limited to what is necessary for the stated purposes and subject to appropriate safeguards. Processing performed within ISV Products is governed by the relevant ISV privacy notice and terms. 

  1. YOUR RIGHTS 

Subject to applicable law, you may have rights to request access, correction, deletion, restriction or objection to certain controlling activities, and to withdraw consent where controlling is based on consent. 

Requests may be submitted to. Where you are provisioned through a customer, we may need to verify the request and/or coordinate with the relevant Customer administrator where appropriate. 

You may also have the right to lodge a complaint with the competent data protection authority. 

  1. CHILDREN 

The Platform is not directed to children, and we do not knowingly collect Personal Data from children. 

  1. CHANGES TO THIS NOTICE 

We may update this Notice from time to time. The “Last updated” date indicates when this Notice was last revised. Material changes will be communicated through the Platform or other appropriate channels. 

  1. CONTACT 

Integrated Workstream Technologies Solutions FZ-LLC 

Dubai Internet City, Makateb Building 1, Floor 01, Premises 109, Dubai, United Arab Emirates 

Email: customer.Support@iwaa.com 

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