Privacy Policy

Background

This Privacy Policy applies to all data subjects whose personal data is collected, used, disclosed, and otherwise processed in accordance with the provisions of the UK Data Protection Act 2018 and the General Data Protection Regulations (GDPR UK).

Personal data is defined as any information relating to an identified or identifiable living individual. All such data is handled and processed in accordance with the principles of data protection outlined in the GDPR UK.

1. Information About Us

Hooblu is operated by Ayima AI Ltd, a limited company registered in England and Wales (company number [TBC]). Our registered office is at [TBC].

2. Scope

This Privacy Policy applies to your use of Hooblu. It does not extend to any websites that are linked from the Service. We have no control over how your data is collected, stored, or used by third-party websites and advise you to check their privacy policies before providing any data to them.

3. What Data Do We Collect?

When you use Hooblu, we may collect the following data:

• Account information — name, email address, and encrypted password (when you register)
• Conversation data — messages you send and AI responses, stored to provide conversation history
• User preferences — property profile (buying/renting/both), theme preference, and other settings
• Location data — if you choose to share your location via the browser, we use it to contextualise property and area searches. Location data is not stored permanently.
• Anonymous identifier — a UUID stored in an HTTP-only cookie to track anonymous usage before registration
• Automatically collected data — IP address, browser type, operating system, and referral URLs

4. How Do We Use Your Data?

All personal data is stored securely in accordance with UK Data Protection Legislation. We use your data to:

• Provide and manage your access to Hooblu
• Process your conversations through AI language models to provide property search and area information
• Maintain conversation history so you can resume previous sessions
• Personalise your experience based on your property profile and preferences
• Optionally search your past conversations for relevant context (Conversation Memory, when enabled by you)
• Analyse usage patterns to improve the Service
• Respond to support requests

We will not send you unsolicited marketing or spam.

5. Your Rights as a Data Subject

Under data protection law, you have the following rights:

• Right of access — you have the right to ask for copies of your personal information.
• Right to rectification — you have the right to ask us to correct inaccurate personal information or complete incomplete information.
• Right to erasure — you have the right to ask us to erase your personal information. You can delete your account and all associated data from Settings > Profile > Delete Account.
• Right to restriction of processing — you have the right to ask us to restrict the processing of your personal information in certain circumstances.
• Right to object to processing — you have the right to object to the processing of your personal information in certain circumstances.
• Right to data portability — you have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond. Please contact us at hello@hooblu.com.

6. How and Where Do We Store Your Data?

We only keep your data for as long as we need to in order to provide the Service.

Your data is stored on Cloudflare's global network, which may include locations outside of the UK and European Economic Area. Cloudflare maintains appropriate safeguards including Standard Contractual Clauses for international data transfers.

Data security is of great importance to us. We use encrypted connections (HTTPS), encrypted password storage (bcrypt hashing), server-side-only token storage, and Cloudflare's infrastructure security.

The transmission of data via the internet may not be completely secure. You are advised to take suitable precautions when transmitting data to us via the internet.

7. Do We Share Your Data?

We may share your data with:

• AI language model providers (Anthropic, OpenAI, Google) — your conversation messages are sent to the selected AI provider for processing. These providers have their own data processing agreements and privacy policies.
• Google Maps Platform — location queries and addresses may be sent to Google for geocoding, mapping, and distance calculations. Subject to Google's privacy policy.
• Cloudflare — infrastructure provider. Data is processed on Cloudflare's network (D1 database, KV storage, Vectorize, Workers AI, R2 storage).

We may be legally required to share data in certain circumstances, such as compliance with court orders or governmental requirements.

8. Legal Basis for Processing

Our legal basis for processing personal data includes:

• Consent — you have given clear consent for us to process your personal data, for example by creating an account.
• Contract — the processing is necessary to provide the Service you have requested.
• Legitimate interests — the processing is necessary for our legitimate interests, such as improving the Service and preventing abuse.
• Legal obligation — the processing is necessary for us to comply with the law.

9. Third-Party Processors

Our service providers that may process personal information on our behalf include:

• Cloudflare, Inc. — infrastructure and data storage
• Anthropic, PBC — AI language model provider
• OpenAI, Inc. — AI language model provider
• Google LLC — AI language model provider and Google Maps Platform

10. Automated Decision Making

No automated decision-making that has legal or similarly significant effects is made by Hooblu. The AI-generated property and area information provided by the Service is informational and advisory only.

11. Withdrawing Consent

You have the right to withdraw consent at any time. You can:

• Delete your account and all associated data from Settings > Profile
• Disable Conversation Memory from Settings > Preferences
• Contact us at hello@hooblu.com for any other requests

12. Retention Period

We retain your personal information only for as long as necessary to provide the Service. Conversation data is retained until you delete it or delete your account. Anonymous usage data may be retained in aggregate form for analytical purposes.

13. Controlling Your Data

You can control your data through the Settings pages within Hooblu:

• Edit your profile information (name, email, password)
• Delete individual conversations
• Toggle Conversation Memory on/off
• Delete your entire account and all associated data

14. Accessing Your Data

You have the legal right to ask for a copy of any personal data held by us. Please contact us at hello@hooblu.com.

15. Complaints

If you wish to make a complaint about how your personal data is being processed, please contact us at hello@hooblu.com. All complaints will be treated confidentially.

If you feel unsatisfied with our handling of your data, you are entitled to escalate your complaint to the ICO (Information Commissioner's Office) at ico.org.uk/make-a-complaint or telephone 0303 123 1113.

16. Contacting Us

If you have any questions about the Service or this Privacy Policy, please contact us:

• Email: hello@hooblu.com
• Post: Ayima AI Ltd, [TBC]

17. Changes to This Policy

This policy may be updated from time to time. Changes will be posted on this page with an updated date. We encourage you to check this policy regularly.

Legal Information

Ayima AI Ltd is a limited company registered in England and Wales (company number [TBC]).

Registered office: [TBC]