Effective Date: [Date]
Welcome to EasySpare (“we”, “our”, “us”)
We are committed to protecting your personal information and your right to privacy under the Saudi Personal Data Protection Law (PDPL) and its Implementing Regulations. If you have any questions or concerns about this privacy notice, please contact us at:
· Email: [Your Email]
· Phone: [Your Phone Number]
· Commercial Registration No.: [Your CR Number]
When you use our mobile application (“App”) and website (“Site”), or use any of our services (“Services”), you trust us with your personal information. We take your privacy very seriously.
1. Information We Collect
We collect personal information that you voluntarily provide to us when you register on the App or Site, place an order, or contact us.
1.1 Personal Information You Provide:
· Names, phone numbers, email addresses, mailing addresses (for shipping), usernames and passwords, and contact preferences.
1.2 Payment Data:
We collect data necessary to process your payment, such as credit card number and security code. Payment processing is handled by a third-party payment gateway compliant with Saudi Central Bank (SAMA) regulations.
1.3 Automatically Collected Information:
· Device information (hardware model, operating system, unique device identifiers)
· Mobile network information
· IP address
· App usage data and browsing behavior
1.4 Sensitive Data:
We do not collect sensitive personal data (such as health data, biometric data, or credit history) unless required by law and with your explicit consent.
2. Legal Basis for Processing
We process your personal information only when we have a valid legal basis under the PDPL.
Consent: When you agree to receive marketing communications.
Contract Performance: To process your orders, deliver products, and manage returns and exchanges.
Legal Obligation: To comply with Saudi tax laws, e-commerce regulations, and consumer protection laws.
Legitimate Interest: To improve our Services, prevent fraud, and secure our App, provided your rights do not override our interests.
3. How We Use Your Information
We use your personal information for the following purposes:
· Create and manage your account (contract performance)
· Process and deliver your orders (contract performance)
· Process returns, exchanges, and warranty claims (contract performance / legal obligation)
· Send administrative information such as order confirmations and shipping updates (contract performance)
· Send marketing and promotional communications with an opt-out option (consent)
· Protect our Services against fraud and unauthorized access (legitimate interest / legal obligation)
· Comply with legal requests from Saudi authorities (legal obligation)
· Improve our App and customer experience (legitimate interest)
4. Sharing Your Information
We share your personal information only in the following circumstances.
With Your Consent: We share data when you have given us explicit consent.
Service Providers: We share data with third parties who perform services on our behalf, such as shipping companies, payment processors, and IT hosting. All processors are bound by written agreements to comply with PDPL requirements.
Legal Obligations: We disclose information when required by Saudi law, court order, or government request, including law enforcement or national security purposes .
Vital Interests: We may disclose information to investigate fraud, prevent harm to individuals, or respond to legal claims.
We Do NOT Sell Your Data: We do not sell, rent, or trade your personal information to third parties for marketing purposes.
5. Data Retention
We retain your personal information only for as long as necessary to fulfill the purposes for which it was collected, including satisfying legal, accounting, or reporting requirements (PDPL Implementing Regulation). Generally:
· Account data is retained until you close your account.
· Transaction data is retained for 10 years to comply with Saudi tax laws.
· Marketing data is retained until you withdraw consent.
Once the retention period expires, we securely destroy or anonymize your data.
6. Your Privacy Rights
Under the Saudi PDPL, you have the following rights.
Right to Access: Request a copy of your personal data we hold.
Right to Correction: Request correction of inaccurate or incomplete data.
Right to Destruction: Request deletion of your data when no longer needed.
Right to Withdraw Consent: Withdraw your consent at any time. This does not affect prior processing.
Right to Object: Object to processing based on legitimate interests.
To exercise these rights, contact us using the information above. We will respond within 30 working days as required by PDPL Implementing Regulations. There is no fee for access requests.
7. Data Security
We implement appropriate technical and organizational security measures to protect your personal information, including encryption of data in transit (SSL/TLS), access controls and authentication, regular security assessments, and employee training on data protection.
However, no electronic transmission is 100% secure. While we strive to protect your data, we cannot guarantee absolute security.
8. Data Breach Notification
In the event of a personal data breach that may harm you or your data, we will:
· Notify the Saudi Data and Artificial Intelligence Authority (SDAIA) within 72 hours of becoming aware.
· Notify you without undue delay if the breach could harm your rights or interests.
9. Cross-Border Data Transfer
We do not transfer your personal data outside the Kingdom of Saudi Arabia unless:
· We have obtained your consent, and
· The transfer is necessary for contract performance, or
· The destination country provides adequate protection, or
· We have implemented SDAIA-approved safeguards such as Standard Contractual Clauses.
All cross-border transfers comply with SDAIA’s Transfer Regulation.
10. Direct Marketing
We will not send you marketing communications unless you have given your consent. You may withdraw your consent at any time by clicking the “unsubscribe” link in any marketing email or contacting us. Upon withdrawal, we will stop sending marketing materials without undue delay.
11. Children’s Privacy
Our Services are not directed to individuals under the age of 18. We do not knowingly collect personal data from minors. If we discover that we have collected data from a minor without parental consent, we will delete it immediately.
12. Updates to This Privacy Policy
We may update this privacy policy from time to time. We will notify you of material changes by posting the updated policy on our App and Site and sending an email notification for significant changes.
The “Effective Date” at the top of this policy indicates when it was last revised.
13. Contact Us and Complaints
To exercise your rights or file a complaint, please contact us using the information below.
· Email: [Your Email]
· Phone: [Your Phone Number]
· Address: [Your Registered Address]