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Business Account Terms & DPA

Effective 5 Sep 2026 Last updated 5 Sep 2026 Version 1.0

These Terms apply to corporate and organisational accounts. Where they conflict with the consumer Terms of Service, these prevail for business accounts. Where a signed enterprise agreement conflicts with these Terms, the signed agreement prevails.

Part A — Business Account Terms

Who this is for

Organisations using Let's Horaro for employee recognition, corporate gifting, internal announcements, scheduled communications and digital signage.

"Customer" means the organisation. "Authorised Users" means employees and others the Customer permits to use the account.

The Customer is responsible for its users

The Customer is responsible for:

  • all activity under its account, including by Authorised Users
  • ensuring Authorised Users comply with these Terms and the Acceptable Use & Community Guidelines
  • promptly removing access when someone leaves
  • the accuracy of employee and recipient data it uploads
  • having a lawful basis to process the personal data it puts into the PlatformAuthorised Users are individuals with their own rights. An employee using a corporate account is still a person whose data is protected. The Customer cannot instruct us to act against an individual's data protection rights.

Employee groups

When the Customer creates its first Tribute, we automatically create a chat group containing its employees. Employees join when they register through their invitation link.

Before you switch this on, please consider:

  • Employees can see each other's phone numbers in the group.
  • Employees may not expect their personal mobile number to be visible to colleagues.
  • In some jurisdictions, requiring employees to use a personal device or personal number for work communication raises employment law issues.We recommend telling employees clearly, before they join, what the group is, who can see what, and that participation is voluntary or a condition of the role — the Customer must specify which.

What Customers cannot do

  • No unified customer groups. Corporate admins cannot create a single chat group containing their customers. Customer communications must be individual. This is a deliberate design restriction that prevents corporate accounts being used for bulk unsolicited messaging.
  • No covert monitoring. The Customer must not use the Platform to monitor employees' private communications, and must not represent to employees that content is monitored when it is encrypted and cannot be.
  • No use of employee personal data beyond the stated purpose.

Digital signage

The Customer can push scheduled messages to signage, office screens and event displays.

This publishes content to a physical space where anyone may see it. The Customer is solely responsible for:

  • ensuring displayed content is appropriate for a public or semi-public space
  • obtaining consent before displaying an identifiable individual's name, photograph or personal message
  • compliance with workplace and public display laws
  • a human confirmation step before anything reaches a public screenWe strongly recommend that no content reaches a public display without a person approving it first, particularly where the content is AI-generated. See the AI Features Terms.

Gift catalogue

Corporate accounts see a curated catalogue of up to 10 gift options configured by the Customer or by us. Corporate pricing, volume terms and invoicing arrangements are as separately agreed.

Account administration

  • The Customer nominates administrators who can add and remove Authorised Users, configure settings, view billing, and manage the catalogue.
  • Administrators cannot read employees' end-to-end encrypted private chats. No configuration enables this. If an administrator needs to be told this, please tell them.
  • The Customer must keep at least two administrators, so account access is not lost.

Payment terms

Unless otherwise agreed: invoices are payable within 30 days; late payment may incur interest at the rate set out in the order form; and we may suspend the account for non-payment after 14 days' notice.

We will not delete already-scheduled, already-paid Tributes for non-payment of unrelated invoices.

Term and termination

  • Term as set out in the order form, or month-to-month.
  • Either party may terminate for material breach not cured within 30 days of written notice.
  • On termination, the Customer may export data for 30 days, after which we delete it under the DPA.
  • Scheduled Tributes already paid for will be delivered unless the Customer instructs otherwise before termination.

Confidentiality

Each party will keep the other's confidential information confidential, use it only for the purposes of this agreement, and protect it with at least reasonable care. This survives termination by 3 years, and indefinitely for trade secrets.

Liability

Section 17 of the Terms of Service applies, except that the cap in Section 17.3 is the greater of the fees paid by the Customer in the 12 months preceding the claim, or AED 5,000.

Part B — Data Processing Addendum

This DPA applies where we process personal data on the Customer's behalf. It forms part of the agreement between us.

Roles

DataRole
Employee and recipient data the Customer uploadsCustomer = controller; Let's Horaro = processor
Account, billing and usage dataLet's Horaro = controller
Security, fraud prevention and service improvementLet's Horaro = controller
Data
Employee and recipient data the Customer uploads
Role
Customer = controller; Let's Horaro = processor
Data
Account, billing and usage data
Role
Let's Horaro = controller
Data
Security, fraud prevention and service improvement
Role
Let's Horaro = controller

Where we are processor, we act only on the Customer's documented instructions. Where we are controller, our Privacy Policy applies.

Scope of processing

Subject matterProvision of the Let's Horaro platform
DurationThe term of the agreement, plus the deletion period in Section 18
Nature and purposeStorage, scheduled delivery, transmission, manufacture and fulfilment of gifts, notification
Types of personal dataNames, mobile numbers, email addresses, photographs, delivery addresses, employment relationship, message content, order and delivery records
Categories of data subjectThe Customer's employees, contractors, gift recipients, and their nominated recipients
Special categoriesNot intended. The Customer must not upload special category or sensitive personal data without our prior written agreement.
Subject matter
Duration
Provision of the Let's Horaro platform
The term of the agreement, plus the deletion period in Section 18
Subject matter
Nature and purpose
Provision of the Let's Horaro platform
Storage, scheduled delivery, transmission, manufacture and fulfilment of gifts, notification
Subject matter
Types of personal data
Provision of the Let's Horaro platform
Names, mobile numbers, email addresses, photographs, delivery addresses, employment relationship, message content, order and delivery records
Subject matter
Categories of data subject
Provision of the Let's Horaro platform
The Customer's employees, contractors, gift recipients, and their nominated recipients
Subject matter
Special categories
Provision of the Let's Horaro platform
Not intended. The Customer must not upload special category or sensitive personal data without our prior written agreement.

Our obligations as processor

We will:

  • process personal data only on the Customer's documented instructions, unless required otherwise by law — in which case we will tell the Customer first, unless the law prohibits it;
  • ensure personnel with access are bound by confidentiality;
  • implement the security measures in Section 16;
  • respect the conditions on sub-processors in Section 15;
  • assist the Customer, as far as reasonably possible, in responding to data subject requests;
  • assist the Customer with data protection impact assessments and regulator consultations;
  • notify the Customer without undue delay, and in any event within 48 hours, of becoming aware of a personal data breach affecting the Customer's data;
  • delete or return personal data at the end of the agreement, per Section 18;
  • make available information reasonably necessary to demonstrate compliance, and allow audits under Section 17;
  • immediately inform the Customer if we consider an instruction infringes applicable data protection law.

Customer obligations

The Customer warrants that it:

  • has a lawful basis for the personal data it uploads;
  • has given required privacy notices to its employees and to recipients;
  • has obtained any consents required — particularly for gift recipients who are not employees;
  • will not instruct us to do anything unlawful;
  • is responsible for the accuracy of data it uploads.

Sub-processors

The Customer gives general authorisation for us to engage sub-processors. Our current list is at letshoraro.com/legal/sub-processors and includes cloud hosting, couriers, payment processors, messaging gateways and AI providers.

We will:

  • give 30 days' notice before adding or replacing a sub-processor;
  • impose data protection obligations on each sub-processor equivalent to those in this DPA;
  • remain fully liable to the Customer for a sub-processor's performance.

If the Customer reasonably objects to a new sub-processor on data protection grounds within the notice period, we will work in good faith to find an alternative. If we cannot, the Customer may terminate the affected service and receive a pro-rata refund.

Security measures

AreaMeasure
Encryption in transitTLS 1.2 or higher
Encryption at restAES-256
End-to-end encryptionIndustry-standard end-to-end encryption with forward secrecy for one-to-one and group chats; keys generated and held on user devices only, never on our servers
Access controlRole-based, least privilege, MFA for administrative access
LoggingAccess and administrative actions logged and retained 12 months
Data residencyUnited Arab Emirates — named on our sub-processor page
BackupsAutomated, encrypted, with restore testing
PersonnelBackground checks where lawful, confidentiality undertakings, security training
Vulnerability managementRegular scanning and patching; annual penetration testing
Incident responseDocumented plan with defined escalation
Business continuityDocumented plan, tested annually
Area
Encryption in transit
Measure
TLS 1.2 or higher
Area
Encryption at rest
Measure
AES-256
Area
End-to-end encryption
Measure
Industry-standard end-to-end encryption with forward secrecy for one-to-one and group chats; keys generated and held on user devices only, never on our servers
Area
Access control
Measure
Role-based, least privilege, MFA for administrative access
Area
Logging
Measure
Access and administrative actions logged and retained 12 months
Area
Data residency
Measure
United Arab Emirates — named on our sub-processor page
Area
Backups
Measure
Automated, encrypted, with restore testing
Area
Personnel
Measure
Background checks where lawful, confidentiality undertakings, security training
Area
Vulnerability management
Measure
Regular scanning and patching; annual penetration testing
Area
Incident response
Measure
Documented plan with defined escalation
Area
Business continuity
Measure
Documented plan, tested annually

We may update these measures provided the level of protection is not reduced.

Audit

The Customer may audit our compliance with this DPA:

  • no more than once per 12 months, unless a breach or regulator requires more;
  • on 30 days' written notice;
  • during business hours, without unreasonable disruption;
  • subject to confidentiality;
  • at the Customer's cost, unless the audit finds material non-compliance.

We may satisfy an audit request by providing a current third-party certification or audit report (for example ISO 27001 or SOC 2) where that reasonably addresses the Customer's concerns.

Return and deletion

On termination, at the Customer's choice, we will return the personal data in a commonly used format or delete it.

  • Export is available for 30 days after termination.
  • Deletion follows within 30 days of the export window closing.
  • Backups are overwritten within 90 days.
  • We may retain data we are legally required to keep, and will tell the Customer what and why.

One exception: where a Tribute has already been delivered to a recipient, the recipient's copy is theirs and is not deleted. The Customer should make this clear to employees before using the Platform — it is a consequence of how the product works and cannot be configured away.

International transfers

Personal data is stored in the UAE. Transfers outside the UAE occur only as described in Section 9 of the Privacy Policy — international delivery, payment processing, and AI features — and are made under appropriate safeguards, including Standard Contractual Clauses where the GDPR applies.

Data subject requests

If we receive a request from one of the Customer's data subjects, we will forward it to the Customer without undue delay and will not respond ourselves, except to acknowledge and redirect, unless the Customer instructs otherwise or the law requires us to respond.

We will assist the Customer in responding, taking into account the nature of the processing.

Precedence

If this DPA conflicts with the Business Account Terms or the Terms of Service on a data protection matter, this DPA prevails.

Contact

Data Protection Officer: dpo@letshoraro.com

Business enquiries: billing@letshoraro.com

Legal notices: legal@letshoraro.com