17. Jurisdiction-Specific Privacy Provisions

The provisions below supplement this Privacy Policy and apply where HOMI processes personal information of individuals located in, or otherwise protected by the privacy laws of, the relevant jurisdiction.

If a provision below conflicts with another provision of this Privacy Policy, the jurisdiction-specific provision will apply to the extent required by applicable law.

17.1 United Arab Emirates

Where the UAE Federal Personal Data Protection Law and other applicable UAE data-protection requirements apply to HOMI's processing of personal information, HOMI will process personal information in accordance with those requirements.

Legal Basis for Processing

Depending on the circumstances, HOMI may process personal information based on:

• Your consent;

• The need to provide a service or perform a contract with you;

• Steps necessary to respond to your request before entering into a contract;

• Compliance with legal or regulatory obligations;

• Protection of HOMI's or another person's lawful interests where permitted;

• Establishment, exercise or defense of legal claims; or

• Other lawful grounds permitted under applicable UAE law.

Where processing requires consent, HOMI will seek consent in an appropriate manner and allow you to withdraw it where applicable.

Your UAE Privacy Rights

Subject to applicable law and relevant exceptions, individuals may have rights concerning their personal information, including rights to obtain information about processing, request transfer of personal data where applicable, request correction or deletion, restrict or stop certain processing, and object to certain automated processing.

HOMI may request reasonable information to verify your identity before processing a privacy request.

Sensitive Personal Information

Where HOMI processes sensitive information, including health-related information that may be necessary for certain health, wellness or home-care services, HOMI will apply additional protections and obtain consent or rely on another lawful basis where required.

HOMI will seek to ensure that sensitive information is only available to authorized parties where reasonably necessary to provide the requested service.

Cross-Border Transfers

Because HOMI may use Providers, technology partners and cloud infrastructure outside the UAE, personal information may be transferred internationally.

Where UAE data-protection requirements apply, HOMI will use legally appropriate mechanisms and safeguards for such transfers.

UAE Healthcare Data

Some healthcare services available through HOMI may be subject to additional UAE federal or emirate-level healthcare regulations.

Where HOMI merely connects a customer with an independently licensed healthcare Provider, that Provider may independently have legal obligations regarding the medical or health information it collects in connection with providing healthcare services.

HOMI and its Providers will determine their respective responsibilities according to the applicable service and legal requirements.

17.2 Egypt

Where HOMI processes personal information subject to Egypt's Personal Data Protection Law No. 151 of 2020 and its applicable implementing requirements, HOMI will process that information in accordance with applicable Egyptian data-protection requirements.

Collection & Processing

HOMI will seek to collect personal information for specified, legitimate purposes and limit collection to information reasonably necessary for those purposes.

Depending on the circumstances and applicable requirements, processing may be based on consent, performance of a contract, compliance with legal obligations or another legally permitted basis.

Your Privacy Rights in Egypt

Subject to applicable law and exceptions, individuals may have rights regarding their personal information, including rights to:

• Know whether and how their personal information is being processed;

• Access personal information where applicable;

• Request correction, modification or updating of inaccurate information;

• Request deletion where legally available;

• Withdraw consent where processing is based on consent;

• Object to certain processing where applicable; and

• Submit complaints concerning the handling of personal information.

HOMI may verify the identity of a person making a privacy request before fulfilling it.

Marketing

Where consent is required under applicable Egyptian law, HOMI will obtain the appropriate authorization before sending electronic direct-marketing communications.

Users may withdraw applicable marketing consent through HOMI's available communication preferences or unsubscribe mechanisms.

Cross-Border Data Transfers

Where personal information is transferred from Egypt to another jurisdiction, HOMI will comply with applicable requirements governing international transfers, including any required approvals, safeguards or other mechanisms.

Providers in Egypt

Independent Providers operating through HOMI are responsible for complying with privacy and other regulatory requirements applicable to the information they independently collect or process when providing their services.

HOMI will only provide Providers with information reasonably necessary to facilitate the customer's requested booking or service, subject to applicable requirements.

17.3 United States

Privacy regulation in the United States may arise under federal law as well as state-specific privacy laws.

Where a U.S. privacy law applies to HOMI and grants additional rights to residents of a particular state, HOMI will provide those rights as required.

U.S. State Privacy Rights

Depending on your state of residence and whether the relevant law applies to HOMI, you may have rights to:

• Confirm whether HOMI processes your personal information;

• Access personal information;

• Correct inaccurate personal information;

• Request deletion;

• Obtain a portable copy of eligible personal information;

• Opt out of certain sales of personal information;

• Opt out of certain sharing or processing for targeted advertising;

• Opt out of certain profiling or automated decision-making where applicable;

• Limit certain uses of sensitive personal information; and

• Appeal HOMI's decision regarding a privacy request where required by applicable state law.

The exact rights available depend upon your state of residence and the law applicable to HOMI.

HOMI will not unlawfully discriminate against an individual for exercising an applicable privacy right.

17.3.1 California Residents

If HOMI becomes subject to the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), California residents may have additional rights.

The CCPA currently provides qualifying California consumers with rights including knowing what information a covered business collects and how it is used or shared, deletion subject to exceptions, correction, opting out of sale or sharing, limiting certain uses and disclosures of sensitive personal information, and protection from discrimination for exercising CCPA rights. (California DOJ)

Categories of Personal Information

Depending on how a California resident interacts with HOMI, HOMI may collect categories of personal information including:

Identifiers: Name, email address, telephone number, account identifiers and IP address.

Customer Records: Contact information, service addresses and account information.

Commercial Information: Bookings, services requested, Provider interactions, transaction history and purchasing activity.

Internet or Electronic Activity: Platform usage, device information, interactions and technical logs.

Geolocation Information: Approximate or, where authorized, precise location information used for service discovery and fulfillment.

Professional Information: For Providers, business, professional, licensing and service-related information.

Sensitive Personal Information: Where applicable, this may include precise geolocation, account credentials, financial information or health-related information associated with eligible services.

Inferences: HOMI may derive preferences or recommendations from activity on the Platform where applicable.

Sale & Sharing of Personal Information

HOMI does not sell personal information for monetary consideration.

However, certain advertising or analytics technologies can potentially constitute “sharing” under California law even where no money changes hands. Under the CCPA, “sharing” can include disclosure for cross-context behavioral advertising. (California DOJ)

Accordingly, if HOMI deploys technologies that constitute selling or sharing under applicable California law, HOMI will provide the required mechanisms to opt out.

Where applicable, HOMI will also recognize legally required browser-based opt-out preference signals, including Global Privacy Control (GPC). California authorities confirm that covered businesses must honor GPC as an opt-out request where the relevant sale/sharing requirements apply. (California DOJ)

Sensitive Personal Information

HOMI may collect certain information that California law classifies as sensitive personal information, particularly where customers use precise location functionality or certain health-related services.

Where required by the CCPA, California residents may have the right to limit certain uses and disclosures of sensitive personal information. (California DOJ)

California Privacy Requests

Where the CCPA applies to HOMI, California residents may submit eligible requests to know, access, correct or delete personal information and exercise applicable opt-out or limitation rights.

HOMI may verify the identity of the person submitting the request to protect personal information against unauthorized disclosure.

California residents may also use an authorized agent to submit certain requests on their behalf, subject to applicable verification requirements. (California DOJ)

17.3.2 Residents of Other U.S. States

Residents of other U.S. states may have additional rights under their respective state privacy laws.

Rather than limiting this Privacy Policy to a fixed list of states, HOMI intends to honor applicable state privacy rights wherever HOMI is legally required to do so.

This approach allows this Privacy Policy to remain applicable as HOMI expands its U.S. operations and as additional state privacy laws become effective.

17.3.3 U.S. Health & Wellness Information

HOMI may facilitate access to health, wellness, beauty or home-care services provided by independent Providers.

Information provided directly to a healthcare Provider may be governed by different privacy requirements from information processed by HOMI as a marketplace.

HOMI should not represent that all health information on the Platform is protected by HIPAA. HIPAA applies only to particular covered entities and business associates and does not automatically apply to every marketplace, wellness platform or health-related application.

Where additional federal or state consumer-health privacy laws apply to HOMI or a Provider, the relevant party must comply with those requirements.

17.3.4 U.S. Children's Privacy

HOMI's services are intended primarily for adults capable of entering into transactions.

HOMI does not knowingly collect personal information online from children in violation of applicable U.S. children's privacy laws.

Additional restrictions may apply to the sale or sharing of minors' information. For example, California imposes affirmative authorization requirements concerning the sale or sharing of personal information of consumers known to be under 16. (California DOJ)

18. Exercising Your Privacy Rights

Regardless of jurisdiction, users may contact HOMI to submit an applicable privacy request concerning their personal information.

Requests may include access, correction, deletion, withdrawal of consent, marketing opt-out, data portability, restriction, objection, or other rights available under applicable law.

Requests may be submitted through:

HOMI App: Profile → Privacy / Account Settings
Website: Privacy Request / Contact Us
Email: support@get-homi.com

HOMI may request reasonable information to verify your identity before fulfilling a request. Where permitted or required by law, HOMI will respond within the applicable statutory timeframe.

If HOMI cannot fulfill a request, we may explain the reason, subject to applicable legal restrictions.

19. Regulatory & Supervisory Authorities

Where applicable, users may also have the right to raise a concern or complaint with the competent privacy or data-protection authority in their jurisdiction.

HOMI encourages users to contact us first so that we can investigate and attempt to resolve privacy concerns directly. This does not limit any right to approach a competent regulatory authority.

Then renumber your existing sections:

20. Changes to This Privacy Policy
21. Contact Us

One change I strongly recommend before HOMI goes live

Because HOMI will initially operate across UAE, Egypt and the U.S., don't state that HOMI complies with every privacy law simply because a user lives there. Some laws—including California's CCPA—have applicability thresholds. California currently applies the CCPA to qualifying for-profit businesses doing business in California that meet specified thresholds. (California DOJ)

Also, the final production version should identify the actual HOMI legal entity as the data controller/business, its registered address and a real privacy contact. I would also add a dedicated “Do Not Sell or Share My Personal Information” mechanism only if HOMI's advertising/analytics implementation makes that legally necessary.

For the U.S. launch, especially if HOMI starts in Houston/Texas, I would additionally build a Texas-specific subsection rather than relying solely on the generic U.S. language.

Tighten the jurisdiction-specific clauses

• Create a compliance details checklist

• Add a Texas privacy subsection