DRAFT - not legal advice. Pending review by UAE counsel; not yet in force.

Privacy Policy

Version 2026-09-v2 (draft) · Effective date: set on publication

1. Who is responsible for your data

The controller of your personal data is OWNER-ACTION: legal entity name, registered address and licence number ("Rotspit"). This policy explains how we handle personal data under the UAE Personal Data Protection Law (Federal Decree-Law No. 45 of 2021).

2. Data we collect

3. Why we use it and our legal bases

PurposeLegal basis
Provide your account, wishlists, pledges, purchases and deliveriesPerformance of our contract with you
Place card holds and charge pledges under your payment authorisationContract; your explicit consent to the authorisation
Share recipient details with retailers and carriers to deliver a giftContract; legitimate interest of the recipient in receiving the gift
Service and transactional notificationsContract
Marketing emails and waitlist updatesConsent (you can withdraw at any time)
Product analytics to improve the appConsent (off until you opt in; you can switch it off in Settings → Privacy)
Fraud prevention, security, rate limitingLegitimate interests; legal obligations
Error monitoring and service reliabilityLegitimate interests
Accounting, tax and dispute recordsLegal obligation

4. Who we share it with

We share personal data only with service providers that process it for us under contract, and with retailers and carriers to deliver gifts. The current list of subprocessors:

Other users see only what you choose to share. Anonymous contributions hide your identity and amount from other users. We do not sell personal data.

5. International transfers and hosting

Some providers store or process data outside the UAE. Product analytics are processed in PostHog's EU cloud. We transfer data only where the destination offers adequate protection or under safeguards such as data processing agreements with standard contractual protections. OWNER-ACTION: confirm the production hosting region and the transfer mechanism for each subprocessor after counsel review.

6. How long we keep it

DataRetention
Account and profileUntil you delete your account
AddressesUntil you delete them or your account; delivered order addresses are redacted after the return window
Payment, order and ledger recordsAs required by UAE commercial and tax law OWNER-ACTION: confirm period (expected 5 years)
Consent recordsFor the legal claims period, kept without your name after account deletion
Notifications180 days
Security and rate-limit logsUp to 30 days
Data exports you request7 days
WaitlistUntil 12 months after launch, or until you unsubscribe

7. Your rights

You can:

8. Children

Rotspit is for people aged 18 and over. We do not knowingly collect data from children. If you believe a child has an account, contact us and we will delete it.

9. Security

Data is encrypted in transit and at rest by our providers, access is restricted by role, and card data is handled only by Stripe.

10. Changes

We will notify you in the app about material changes. Each version is numbered and dated.

11. Contact and data protection officer

OWNER-ACTION: privacy contact email, postal address and data protection officer (if appointed)