Subprocessors

1. Why we publish this list

DSH is a controller of personal data under UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (the "UAE PDPL"). When we use a third party to process data on our instructions, that third party becomes our processor.

Article 10 of the UAE PDPL requires the controller to:

• Pick processors that give enough technical and organisational guarantees.
• Sign a written contract that binds the processor to the same duties we owe you.
• Stay liable to you for what our processors do.

Article 16 of the UAE PDPL governs cross-border transfers. Personal data may leave the UAE only when the destination country offers an adequate level of protection, or when the controller puts a recognised safeguard in place such as standard contractual clauses, binding corporate rules, or your explicit consent.

We have the right to engage subprocessors to deliver our services. When we add or replace a subprocessor we will notify you in advance through the customer portal and by email. You have the right to object, as set out in section 5 below.

2. Subprocessors by category

2.1 Cloud hosting, CDN, and edge

2.2 Smart-home cloud platforms

These platforms are activated only when you choose the matching brand of lighting, control, audio, or voice. The vendor is the data controller for its own end-user account; DSH is a processor on your behalf during installation and remote support.

2.3 Surveillance and access cloud

2.4 Energy stack monitoring

2.5 Remote monitoring, management, and observability

2.6 Productivity and customer operations

2.7 Backup

2.8 Payment processing

When you pay an invoice or a deposit, the card data is captured by the payment processor and is never stored on DSH systems.

2.9 Web analytics

2.10 Voice and AI

We use AI services only as a fall-back path or to assist our support staff. They are not used to process biometric data inside customer villas without your written consent.

2.11 Government API

2.12 Secure remote support

3. How we vet a new subprocessor

Before any vendor in the table above is given access to customer data, our operations team runs a four-step check:

• Contract. A signed Data Processing Addendum that binds the vendor to UAE PDPL Article 10 duties, including breach notice, audit rights, and deletion on termination.
• Security evidence. Current ISO 27001 certificate, SOC 2 Type II report, or equivalent. Where the vendor is a hardware-control cloud, we accept an IEC 62443 attestation.
• PDPL Article 16 transfer check. We confirm the destination country and pick a lawful transfer mechanism. We prefer UAE-resident processing first, then EU adequacy, then SCCs.
• Sub-region preference. Where the vendor offers UAE or GCC region hosting we select that region by default. EU is our second preference. United States is the last resort and only with SCCs in place.

4. How we notify you of new subprocessors

Whenever we add or replace a subprocessor we will:

• Email the account contact listed in your project file.
• Post a portal notice with the vendor name, the data category, and the lawful transfer mechanism.
• Update this page and the Last updated date.

The notice goes out at least 30 days before the new subprocessor goes live. This 30-day window is your objection window, in line with UAE PDPL principles on transparency and the data subject right to object under Article 13.

5. Your right to object and your right to terminate

You may object to a new subprocessor by emailing support@dubaismarthome.ae during the 30-day notice window. We will then either:

• Offer a workaround, for example a regional alternative or an on-prem-only deployment of the same function.
• Pause the rollout for your account until we can offer a workaround.
• Allow you to terminate the affected service line for cause, with a pro-rata refund of any prepaid fees, where no workaround is possible.

You may also raise a complaint with the UAE Data Office under Article 25 of the UAE PDPL.

6. Last updated

This list was last updated on 22 June 2026. We review the list at least every six months and on every onboarding of a new platform.

For privacy questions please contact:
support@dubaismarthome.ae
One Central, 8th and 9th Floor, Trade Centre 2, Dubai, United Arab Emirates
+971 50 506 1871