Last updated: June 01, 2023
Welcome to Sarya! Please carefully read this Privacy Policy before accessing the website located at www.sarya.app (“the Website”) and/or the Sarya mobile application available for download at Google Play Store and Apple App Store (“the Mobile App”). The Website and the Mobile App are hereinafter collectively referred to as the “App” or the “Service”. The App is controlled by [Sarya.App LLC – INSERT COMPANY DETAILS] a Company operating from its head office in Dubai, United Arab Emirates (hereinafter the “Company,” “we,” “us”, or “our”).
This Privacy Policy informs you how we collect, use, share and secure your personal data when you use the App and your rights relating to your personal data. We process all personal data that we collect in compliance with personal data protection laws of the jurisdictions where we offer the App, including but not limited to the EU General Data Protection Regulation 2016/679 (“EU GDPR”).
By signing up for a user account, you agree to the processing of your personal data in accordance with this Privacy Policy.
Who is covered by this Privacy Policy?
What information do we collect from you?
How do we collect and use your information?
Do we share your personal data?
To protect ourselves or our users
1. Who is covered by this Privacy Policy?
This Privacy Policy is only applicable to individuals who use the Service or subscribe to our mailing list.
2.1. The term ‘Data Controller,’ ‘Personal Data,’ and ‘Processing’ shall have the meaning as defined in Article 4 of the EU General Data Protection Regulation 2016/679 (EU GDPR);
2.2. ‘Data Subject’ refers to a natural person whose personal data is processed by the Company or its processors;
2.3. ‘Buyer’ refers to a user who purchases an itinerary through the App.
2.4. ‘Itinerary’ refers to a digital travel itinerary that a Seller creates and lists for sale through the App.
2.5. ‘Seller’ refers to a user who creates and sells itineraries to Buyers through the App.
2.6. ‘Order’ refers to the binding agreement between a Buyer and a Seller governing the sale-purchase of an itinerary through the App.
2.7. ‘User Content’ refers to any content submitted by a user through their App account, including but not limited to any itineraries, recommendations, messages sent or received through the chat features in the App.
Sarya.App LLC is the data controller of all personal data you submit through the App. We can be contacted at the following address:
[INSERT BUSINESS ADDRESS]
4. What information do we collect from you?
You voluntarily provide us with some personal data when you use the App, and there is some personal data that we can collect automatically from your use. Regardless of whether we receive your personal data directly from you or automatically, we will only process it if we have a legal basis to do so, such as your consent, the performance of a contract, or legitimate interest that does not override your data protection rights.
You may decline to provide any personal data when requested by the Company; however, you understand that your refusal may result in us not being able to deliver the Service to you.
The information we collect from you includes but is not limited to your:
● Full name;
● Email address;
● Gender;
● Date of birth;
● Mobile phone number;
● Nationality;
● Country of current residence (if different from nationality);
● Copy of national identity document;
● Copy of passport;
● Billing address;
● Bank account number linked to the wallet;
● Content of any messages you send or receive through the App;
● Content of all communication you have with the Company;
● Friends you invite to join the app;
● Transaction information (including itinerary sold and order amount);
● Information that you provide us when you participate in our surveys or promotions;
● Your log data, including your browser type, time and pages you visit, your IP address, etc.;
● Location data; and
● We also infer certain new information from your activities on the App.
5. How do we collect and use your information?
5.1. Voluntarily Submitted Information
5.1.1. Account Registration Data
When you sign-up for an App account, we collect information that you directly submit to us, including but not limited to your full name, email address, and mobile phone number (‘account registration data’).
We use your account registration data to:
● Send an OTP to your mobile number during account registration;
● Create your App account;
● Enable you to log into your App account and make use of the features and functionality;
● Communicate with you as and when required.
Our legal basis for processing this data is the performance of our contract with you.
5.1.2. User Content Data
When you upload or submit any content on the App that is intended for another user or the Company, such as itineraries, recommendations, messages, or other similar content on the App, we process all the submitted information for the following purposes:
● To make your user content data available on the App for the intended recipient/s;
● To detect and prevent any fraud or other similar unauthorised activities on the App.
Our legal basis for the processing of this data is our legitimate interest which does not override your rights as a data subject.
5.1.3. Communication Data
We collect information that you directly submit when you use our built-in messaging functionality to communicate with other users or send any support requests to the Company.
We use this information to:
● Facilitate the built-in messaging feature to enable you to communicate with other users;
● Enable you to send invitations from within the app;
● Respond to your inquiries and offer customer support services;
● Detect and prevent fraud and other similar unauthorised activities on the App.
Our legal basis for the processing of this data is our legitimate interest which does not override your rights as a data subject.
5.1.4. Location Data
The App enables you to share your current location with others on the App. If you make use of this feature, we may automatically collect information about the location of your device.
We use this information to share your current location with other App users according to your preferences.
Our legal basis for processing this data is your consent, which you may withdraw at any time by changing your location settings.
5.1.5. Financial Data
When you order an itinerary through the App, we collect some information that you directly submit, including but not limited to the order amount and the ordered itinerary.
We use this information for:
● Facilitating payments for your orders through our third-party payment processor;
○ Verify your identity and validate your in-app wallet;
● Remitting the sales revenue to the Seller in accordance with the Terms and Conditions;
● Our internal business/accounting purposes;
● Detecting and preventing fraud to protect our users and ourselves.
Our legal basis for the processing of this data is our legitimate interest which does not override your rights as a data subject.
Please note that we do not collect any sensitive payment card data from our users. Our selected third-party payment processor processes all payment data in accordance with its own legal agreements.
5.1.6. Participation Data
We collect the information you directly submit to us when you subscribe to receive marketing material from us or participate in our surveys/promotions.
We use this information for:
● Sending you marketing material that we think you will find interesting;
● Creating new service offerings or improving our existing Services;
● Fulfilling any other purpose specified at the time we collect your information.
Our legal basis for processing this data is your consent, which you may withdraw at any time by changing your location settings.
5.2. Automatically collected information
5.2.1. Log, Device, and Cookies Data
When you access the App, there is some information that we are able to collect automatically about you, including your Internet Protocol (“IP address”), your browser type or version, the pages you visit, data on the time and date of your visit, and other data collected through the use of web beacons, pixel tags, and cookies.
We may use this information to:
● Deliver and improve the Service
● Show content/information relevant to your past searches;
● Send you updates, alerts, and support messages,
● Detect and prevent fraud to protect our users and ourselves.
Our legal basis for the processing of this data is our legitimate interest which does not override your rights as a data subject.
We may also use any of the information we collect from you (voluntarily or automatically) for our compliance with the law and/or to assert our legal rights or defend any claims. Where we request your consent to the processing of your personal data for marketing purposes, you may withdraw your consent at any time by unsubscribing from the marketing emails.
6. Do we share your personal data?
We respect your personal data, and we do not engage in the practice of selling or renting our users’ personal data. We only disclose/share our users’ personal data as described hereunder:
When you make use of the in-app chat functionality to send and receive messages, and invitations, we will share the content of your message with the intended recipient along with some of your publicly visible account data such as your username, any itineraries you have bought or sold through the App and other similar information. We may also share your location data with other users according to your preferences.
We also share some aggregated demographic data about Buyers with Sellers relating to the sale of their itineraries. This demographic data is aggregated and anonymised, so it does not identify a specific Buyer.
● Third-Party Service Providers
We may disclose your personal data with our third-party service providers who provide us business services, such as web hosting, payment processing, email distribution, etc. Please note that we will only disclose your personal data that is necessary for our Service Providers to perform their functions on our behalf, and your personal data will only be used by our service providers as authorised by us. In no event will our Service Providers be allowed to use your personal data for any other purposes than those authorised by us.
If, in the future, we buy a business or are acquired by another business, our users’ personal data may be disclosed to the new entity as part of due diligence and transferred as part of the commercial transaction. We assure you that in the event of any such changes in ownership, your personal data will continue to be governed by this Privacy Policy, except in cases where you expressly consent otherwise.
● To protect ourselves or our users
We may disclose your personal data to:
○ law enforcement authorities and other government bodies to comply with the law;
○ enforce our Agreement with you;
○ defend ourselves in legal actions; or,
○ protect our users or others from threats posed by your actions by sharing your data with other organisations as part of fraud protection.
Our App is designed with the security of data in mind. We use secure third-party payment processors to collect and process our users’ payment data, so none of the sensitive financial data is collected or stored in our database. We also restrict access to data within our Company on a need-to-know basis to prevent unauthorised access. All user accounts are password-protected, and we restrict the use of an account by multiple users.
Regardless of the security measures that we have put in place, you acknowledge that data transmission over the internet is never one hundred per cent secure. Accordingly, we cannot offer any guarantees regarding the absolute security of your personal data.
8.1. Account Data
You have the right to access or edit your personal data by accessing your account settings. You can also view all your user content (such as your messages, itineraries bought or sold etc.) under your account on the App. If you wish to request the deletion of any personal data, please contact us at the email address provided at the bottom of this policy, and we will respond to your request within 30 calendar days. Please note that for security reasons, we may be required to verify your identity before deleting your account or any related data. If you fail to provide such requested information, we will not be able to delete your account or any requested data.
8.2. Marketing Data
When you opt-in and subscribe to receive marketing communication from us, we may send you marketing materials via email. You have the choice to withdraw your consent from receiving direct marketing material from us at any time by simply clicking the unsubscribe link in our email. Please note that we may still send you service-related notices and policies for as long as you have an account on the App.
8.3. Complaints
Individuals in the European Economic Area (EEA), or the United Kingdom, have the right to file a complaint against any infringement of your data rights by contacting your local data protection authority.
We do not retain your data for longer than required for the initial purpose for which we collected it. If you request account termination, we will delete all your personal data from our database within three months of the date of your account termination request. We may retain your data by anonymising it so it cannot be linked back to you as an individual.
California Online Privacy Protection Act (“CalOPPA”) requires us to inform our users how we respond to Do Not Track (“DNT”) signals. We currently do not respond to DNT signals.
We are committed to protecting children’s privacy. The App does not allow users under the age of 18 years to sign up for an App account and submit any personal information.
The App may contain links to third-party websites that are not owned or operated by us. Should you decide to click on any such third-party links, you will be directed to such a third party’s website. These third-party websites are governed by their own Terms and Conditions and Privacy Policy. We encourage our users to review the third-party Terms and Privacy Policy before using such services. The presence of any third-party links on our App does not constitute an endorsement or recommendation of such a third party, and we cannot be held responsible for such a third party’s actions.
From time to time, we may amend this Privacy Policy to reflect our new privacy practices and commitment to compliance with applicable privacy laws and regulations. We will post the updated Privacy Policy on this page and notify you of such updates by changing the last updated date on the top or by sending an email. You should review this Privacy Policy regularly to ensure that you are familiar with any changes. You understand and accept that your continued use of the App after the update’s effective date will be deemed your tacit acceptance of any updated privacy practices.