LEGAL
Privacy Policy
This Privacy Policy explains how XAINA Services L.L.C. (“XAINA”, “we”, “us” or “our”) collects, uses, stores, shares and protects personal data when you use the XAINA website, applications and services.
We process personal data in accordance with applicable data protection laws and requirements in the United Arab Emirates.
SECTION 1
Who is responsible for your personal data
For XAINA customer services, the relevant data controller is:
SECTION 2
Personal data we collect
Depending on how you use XAINA, we may collect the following categories of personal data.
Account and identity information
This may include:
- name
- mobile number
- email address
- account identifier
- authentication and security information
Property and location information
This may include:
- community or area
- building or villa
- unit or address information
- saved properties
- property type
- property size
- entry and access instructions
- booking-related location information
Booking information
This may include:
- selected service
- booking date and time
- property details
- selected Cleaning Expert or Preferred Lead where applicable
- assigned team
- add-ons
- bundles
- service notes
- recurring subscription settings
- booking status
Service records
Where required for service delivery, quality control, security or dispute handling, XAINA may process operational records such as:
- check-in and check-out information
- service timestamps
- before/after service documentation where applicable
- service completion information
- service-related communications
- issue and dispute information
Payment information
Payment processing may involve:
- payment method type
- payment transaction references
- payment status
- authorization status
- capture status
- refund status
- reusable recurring payment mandate or token references where applicable
Where payment processing is handled through an authorized payment provider, XAINA does not need to store your full raw payment-card number.
Communications
We may process communications including:
- customer-support requests
- booking-related communications
- complaints
- feedback
- other communications with XAINA
Technical and usage information
Depending on your device and use of the platform, this may include:
- IP address
- device information
- browser or application information
- technical logs
- security information
- application interactions
- diagnostic and performance information
SECTION 3
How and why we use personal data
We may process personal data as permitted under applicable law for purposes including:
- creating and securing customer accounts
- providing quotations
- checking serviceability
- creating and managing bookings
- assigning Cleaning Experts
- scheduling and dispatch
- processing and reconciling payments
- operating Cleaning Subscriptions
- providing booking status and ETA information
- communicating booking updates
- providing customer support
- maintaining service quality
- handling service issues and disputes
- preventing fraud and misuse
- maintaining platform and account security
- improving XAINA services and operations
- understanding service demand
- complying with legal, accounting and regulatory requirements
Where applicable law requires consent for a particular processing activity, XAINA will request the relevant consent.
SECTION 4
Property and customer location information
Customer location information may be used to:
- determine whether a property is serviceable
- schedule the booking
- assign operational resources
- coordinate Cleaning Experts and Drivers
- plan transportation
- calculate estimated arrival times
- deliver the booked service
Address and access information may be shared with assigned personnel only where reasonably necessary to perform the booking or related transportation.
SECTION 5
Driver location and ETA information
XAINA Drivers may transmit operational GPS location data while on shift or carrying out active XAINA transportation runs.
XAINA may use this information to:
- monitor active Driver positions
- coordinate Cleaning Expert transportation
- manage active operations
- calculate travel times
- detect or respond to delays
- provide estimated arrival information to customers
Customer-facing tracking may show information such as:
The customer does not need to receive the Driver's raw GPS coordinates for this purpose.
Operational Driver tracking is intended to operate during relevant working and operational periods rather than as permanent 24/7 tracking.
SECTION 6
Out-of-area requests
If you select:
XAINA may process the location and booking information you provide to:
- assess whether your location can be served
- evaluate operational capacity
- assess the requested booking date and time
- decide whether the booking can be accepted
- contact you regarding the request
XAINA may also use out-of-area request information to understand geographic customer demand and support future service-area planning.
This demand information may be analyzed in aggregated form.
SECTION 7
Payments
XAINA uses payment service providers to facilitate payments.
Payment-related information may be processed for purposes including:
- payment authorization
- payment capture
- payment authentication
- refunds
- reconciliation
- fraud prevention
- payment support
For out-of-area requests, XAINA may authorize a payment before final operational approval.
If the request is declined before capture, the authorization is released or cancelled rather than processed as a normal refund.
SECTION 8
Cleaning Subscriptions and recurring payments
Cleaning Subscriptions require a payment method capable of supporting recurring payments.
For this purpose, XAINA and its payment provider may process a reusable payment mandate or token associated with the subscription.
A payment card or payment method previously used for a one-time transaction is not automatically treated as authorization for future recurring charges unless the necessary recurring-payment authorization has been established.
XAINA may also process:
- subscription frequency
- recurring booking schedule
- subscription status
- saved property
- recurring eligible extras selected by the customer
- pause, skip, rescheduling and cancellation information
SECTION 10
International data transfers
Some technology, infrastructure or service providers used by XAINA may process personal data outside the United Arab Emirates.
Where international transfers occur, XAINA will handle those transfers in accordance with applicable UAE data protection requirements.
SECTION 11
Data retention
XAINA retains personal data only for as long as reasonably necessary for the purposes for which it was collected and for applicable:
- contractual requirements
- service and operational requirements
- accounting requirements
- fraud-prevention and security requirements
- dispute-resolution requirements
- regulatory requirements
- legal obligations
Different categories of personal data may have different retention periods.
Where personal data is no longer required, XAINA will delete, anonymize or otherwise handle it in accordance with applicable requirements.
SECTION 12
Data security
XAINA uses appropriate technical and organizational measures intended to protect personal data against:
- unauthorized access
- accidental loss
- misuse
- unauthorized alteration
- destruction
- unauthorized disclosure
Access to personal data should be restricted according to role and operational need.
No digital service can guarantee absolute security.
SECTION 13
Your data protection rights
Subject to applicable UAE law, applicable conditions and permitted exceptions, you may have rights including the right to:
- receive information about how your personal data is processed
- request access to eligible personal data
- request correction of inaccurate or incomplete personal data
- request erasure where applicable
- request restriction of processing in applicable circumstances
- request transfer of eligible personal data where applicable and technically feasible
- object to certain automated processing decisions where applicable
- withdraw consent where processing is based on consent
Some requests may be subject to legal exceptions or record-retention obligations.
To submit a privacy request, contact:
SECTION 14
Marketing communications
Where required, XAINA will obtain appropriate permission before sending optional promotional marketing communications.
You may opt out of marketing communications through available unsubscribe or preference mechanisms.
Operational communications necessary to provide or manage a booking, account or subscription are distinct from optional promotional communications and may still be sent where necessary to provide the service.
SECTION 16
Children
XAINA's customer booking services are intended for adults aged 18 or older who are capable of entering into a service contract.
The platform is not intended for children to independently create customer accounts or enter into service contracts.
SECTION 17
Automated systems
XAINA may use automated systems and technology to support functions such as:
- service matching
- scheduling
- capacity management
- fraud prevention
- operational recommendations
- serviceability and booking workflows
Where applicable law provides rights regarding decisions based solely on automated processing that produce legal or similarly significant effects, those rights will be respected.
SECTION 18
Changes to this Privacy Policy
XAINA may update this Privacy Policy to reflect changes in:
- applicable law
- technology
- operations
- XAINA services
The latest version and its Effective Date will be made available through the XAINA platform.
SECTION 19
Contact and privacy requests
For privacy questions or requests: