A Privacy Policy You Can Trust

This Privacy Policy (“Privacy Policy”) describes how Holo (“Holo ”, “us”, “we” and “our”) collects, uses and shares Personal Data (as described below) of you (“you”), as the User of our Hub by Holo and the Services, and your Client. Terms used in this Privacy Policy not defined herein shall have the same meanings ascribed to them in our Terms and Conditions. By using our Services and/or accessing Hub by Holo , you accept the terms of this Privacy Policy and consent to our collection, use, disclosure, retention and protection of your and your Clients’ Personal Data, as described herein. You acknowledge that you are solely responsible for obtaining the consent of each of your Clients prior to submitting any Personal Data. We reserve the right to amend this Privacy Policy at any time without prior notice. It is your responsibility to review it periodically. Continued use of Hub by Holo constitutes acceptance of any updates.

We may collect Personal Data about you, your Client, and any devices used to access Hub by Holo . “Personal Data” includes: • Name, address, phone number, email address • Date of birth, nationality • Username and account information • Financial data (e.g. salary, bank details) • Occupation information Examples of collected data: • Identification data (name, address, email, phone) • Emirates ID / passport information (including RFID-linked data) • RERA broker license • Financial details (credit card, bank accounts) • Billing and transaction data • Web form submissions and correspondence • Any voluntarily provided information • Legal verification data required by applicable laws We only collect data that is relevant and necessary. We may also collect technical data such as: • IP address • Browser and device data • Page views and traffic data • Referral URLs and browsing activity

We use cookies, web beacons, and similar technologies to track activity on Hub by Holo . You may disable cookies via your browser settings, though this may affect functionality.

We use Personal Data to: • Provide and maintain Services • Personalise user experience • Communicate updates, invoices, and alerts • Send marketing communications (where permitted) • Detect and prevent fraud or illegal activity Specifically, we may use data to: • Provide access to Services • Improve Platform functionality • Send confirmations and administrative messages • Deliver promotions and updates • Customise and enhance services • Provide location-based services

Personal Data may be shared with: • Group companies • Service providers and agents • Government authorities (if required by law) We ensure third parties: • Maintain confidentiality • Use data only for intended purposes Data may be transferred outside your country, including outside the UAE.

We implement security measures to protect Personal Data from: • Unauthorized access • Misuse or disclosure • Loss or destruction Data is retained only as long as necessary and then securely deleted or anonymised.

If you provide Personal Data of others (e.g. Clients), you must: • Obtain their prior consent • Inform them of this Privacy Policy

Hub by Holo may contain links to third-party websites. We are not responsible for their privacy practices—please review their policies before submitting data.

We may disclose Personal Data: • To provide Services • To comply with legal obligations • To enforce Terms and Conditions • To prevent fraud or illegal activity Examples include: • Payment processors and service providers • Fraud prevention and security partners • Legal authorities and regulators • Credit agencies (where applicable) We do not share Personal Data for marketing without consent.

Personal Data may be transferred during: • Mergers • Acquisitions • Financing or bankruptcy proceedings

We use: • Google APIs (in compliance with Google policies) • AI tools for administrative efficiency AI tools are used only to: • Process data faster • Assist with applications and inquiries They are not used for decision-making.

You may: • Access your data • Correct or update information • Request deletion or restriction We may refuse requests where legally permitted, but will provide reasons.

You may: • Opt out of marketing emails • Update communication preferences • Request changes to your Personal Data Note: Opting out may limit access to certain Services.

Your data may be: • Stored outside the UAE • Processed by international staff We take reasonable steps to ensure secure handling, but internet transmission is not completely secure.

If you have questions or requests, contact us at: Address: 2606 Marina Plaza, Dubai Email: [email protected]