This Privacy Policy explains how Property Shop Investment LLC ("PSI", "we", "us") collects, uses, shares and protects personal data when you use PSI ERP at https://stg.psi-hcm.com and the PSI mobile app for Android and iOS (together, the "System"). The System is PSI's internal business platform for human resources, attendance, payroll, recruitment, broker licensing, approvals, internal communication and related back-office work. It is used by PSI group employees and by people who deal with us, such as job applicants, new joiners, brokers, vendors and clients.
For the public website psinv.net, please see its own privacy policy.
1. Who is responsible for your data
Property Shop Investment LLC is responsible for the personal data processed in the System (the "controller"). Where you work for, or deal with, another company of the PSI group, that company is also responsible for the data that relates to its own relationship with you.
Property Shop Investment LLC
Office No. 4410 & 4411, Addax Tower, Level 44, Al Reem Island, City of Lights, Abu Dhabi, United Arab Emirates
Phone: 600 548 200 · +971 2205 2888
Licence No. CN-1100434 · Brokerage No. 202100982107
We process personal data in line with the UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data and the other laws that apply to us, including UAE labour and anti-money-laundering laws.
2. Personal data we process
Depending on your relationship with us and the features you use, we may process:
- Identity and contact details: name, staff number, photo, date of birth, nationality, gender, work and personal email, phone numbers, address and emergency contacts.
- Official documents: passport, visa, Emirates ID, work permit, labour card, driving licence, broker licence, certificates and their numbers, issue and expiry dates.
- Employment records: company, department, job, manager, contract, joining and leaving dates, time off, letters, disciplinary records, performance, training and assets assigned to you.
- Attendance: check-in and check-out times, the place you checked in from (location, city, IP address) and punches from office biometric devices.
- Payroll and finance: salary, allowances, deductions, commissions, expenses, bank account details (IBAN) and final settlement.
- Recruitment and onboarding: CV, application details, interview notes, referrals and the documents a new joiner provides.
- Business records: deals, clients, vendors, invoices and the records you create or approve as part of your work.
- Communication: chat messages, comments, calls, emails and notifications sent through the System, and the files you upload.
- Account and security data: username, sign-in times, IP address, browser and device details, the devices you sign in from and the access rights given to you.
- Single sign-on: when you sign in with UAE PASS, Microsoft or Google, we receive the identity details that provider shares with us (such as your name, email and, for UAE PASS, your Emirates ID number) to match you to your account. We never receive your password for those services.
Most of this data comes from you, from your manager or HR, or from the System itself as you use it. Some comes from government portals, banks, insurers or previous employers where the law or your contract requires it.
3. The mobile app
The PSI mobile app opens the same System on your phone. On top of the data above, it uses:
- Location: only when you check in or out, to record where you did so. The app does not track your location in the background.
- Camera and photos: only when you choose to take a photo or attach a file, for example a document or a receipt.
- Microphone: only during voice or video calls you start or answer.
- Face ID, fingerprint or other biometrics: checked by your phone's own operating system. Your biometric data never leaves your phone and is never sent to us. The app keeps only a device sign-in key, which changes at every sign-in and which we store in encrypted (hashed) form.
- Notifications: a push token from Google Firebase or Huawei Push Kit, so we can send you notifications about your messages, approvals and requests.
- Device information: device model, operating system, app version and an app installation identifier, to keep your device registered and secure.
You can refuse or withdraw any of these phone permissions in your phone settings; the related feature will then stop working. You can sign out at any time, and HR or IT can remove a lost device from your account.
4. Why we use your data
- To manage your employment: contracts, attendance, time off, payroll, benefits, visas, documents, letters, training and leaving (performance of your contract).
- To meet our legal duties, such as labour, immigration, Wage Protection System, tax, anti-money-laundering and real estate brokerage rules (legal obligation).
- To recruit and onboard new colleagues (steps before a contract and legitimate interest).
- To run our business: approvals, deals, commissions, finance, purchasing, assets and internal communication (legitimate interest).
- To keep the System and your account safe: sign-in checks, new-device alerts, access control and audit logs (legitimate interest and legal obligation).
- To send you notifications you need for your work, and optional features you turn on (legitimate interest or consent).
Where we rely on your consent, you may withdraw it at any time without affecting what we did before. We do not use the System to sell your data or to show you advertising.
5. Who we share your data with
We share personal data only when needed for the purposes above, and only what is needed:
- Within the PSI group: colleagues and group companies who need it for their role, according to the access rights they have been given.
- Government authorities: such as the Ministry of Human Resources and Emiratisation, the Federal Authority for Identity, Citizenship, Customs and Port Security, real estate regulators, courts and law enforcement, where the law requires it.
- Banks, insurers and payroll partners: for salary payments (WPS), medical insurance and other benefits.
- Service providers: companies that host and support the System, send email, SMS, WhatsApp messages and push notifications, provide single sign-on, and read documents or answer questions for our AI assistant. They act on our instructions and must protect your data.
- Professional advisers and buyers: auditors, lawyers and, if we reorganise or sell part of our business, the buyer and its advisers, under confidentiality.
6. AI assistant
The System includes an AI assistant that helps users find information and prepare records. When you use it, your question and the System data needed to answer it are sent to an AI service provider for processing. The assistant sees only what you are allowed to see, does not make decisions about you on its own, and its answers are suggestions that a person reviews before acting on them.
7. Transfers outside the UAE
Some of our service providers process data outside the United Arab Emirates. When this happens, we make sure the destination offers an adequate level of protection or that appropriate safeguards, such as contractual clauses, are in place, as the UAE data protection law requires. You may ask us for details of these safeguards.
8. How long we keep your data
We keep personal data for as long as we need it for the purposes above and for as long as the law requires, for example to keep employment, payroll and accounting records or to deal with legal claims. After that we delete or anonymise it. Former employees' records are kept in an archive with restricted access.
9. How we protect your data
- Encrypted connections (HTTPS) between your browser or app and the System.
- Role-based access: each user sees only the records their role allows.
- Sign-in protection: session time limits, alerts when you sign in from a new device, and locking of a device after repeated failed sign-ins.
- Logs of sign-ins and of changes to important records, and regular backups.
No system is completely secure. If you think your account has been misused, please tell HR or IT straight away.
10. Cookies
The System uses only the cookies it needs to work: a session cookie that keeps you signed in, and small cookies that remember your language, your selected company and whether you are using the mobile app. We do not use advertising or tracking cookies in the System.
11. Your rights
Subject to the law, you have the right to:
- know what personal data we hold about you and receive a copy of it;
- have inaccurate data corrected, and incomplete data completed;
- ask us to delete your data, or to restrict how we use it, where we no longer need it;
- object to processing based on our legitimate interest, and withdraw your consent;
- receive your data in a structured, commonly used format; and
- complain to the UAE Data Office.
Some data must be kept even if you ask us to delete it, because the law requires it or because we need it for a legal claim. Many details, such as your contact details and bank account, can be updated yourself in the System, or by asking HR.
12. Changes and contact
We may update this Privacy Policy from time to time. The date at the top shows when it last changed, and we will tell users about important changes in the System.
For any question about this policy or to use your rights, contact your HR team or write to us at the address in section 1.