Privacy Policy
Last updated: [TODO: publish date]
Before this goes live
This draft was written to follow the structure UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (PDPL) expects, plus common practice for consumer platforms. It is not legal advice, and it has not been reviewed by a lawyer. Several details below are placeholders marked [TODO] and must be filled in with real, verified information. Parts of the PDPL's Executive Regulations, including exact breach notification deadlines and administrative penalties, were still pending at the time this was written, so this policy should be checked against the current regulations before publishing. Have a UAE-qualified lawyer review this in full before it is relied on.
Privacy Policy
1. Who we are
Savara ("Savara," "we," "us," or "our") operates savaraworld.com and the Savara platform, a curated savings and offers service for the United Arab Emirates. This policy explains what personal data we collect, why, how we use and protect it, and the rights you have over it.
Legal entity name: [INSERT LEGAL ENTITY NAME]. Registered address: [INSERT REGISTERED ADDRESS]. Trade licence number and issuing authority: [INSERT TRADE LICENCE DETAILS]. If Savara operates from a UAE free zone, the free zone name should also be listed here.
2. What we collect
We collect personal data in a few ways:
Information you give us directly: your name, email address, and message content when you use the contact form; your email address when you subscribe to the newsletter; and any information you provide if you list a business with us as a partner.
Information collected automatically: [TODO — list any analytics, cookies, or tracking tools actually in use, e.g. a specific analytics platform, and what they collect. At the time of writing, this site does not run analytics or non-essential cookies. Update this section the moment that changes, and add a cookie consent banner if required.]
3. Why we use it
We use personal data to respond to enquiries submitted through the contact form, to send the newsletter to people who have subscribed to it, to operate and improve the Savara platform, to evaluate and manage partnerships with businesses whose offers we list, and to meet legal and regulatory obligations.
Under the PDPL, we rely on your consent for the newsletter and for responding to enquiries you initiate, and on legitimate business interests for operating and securing the platform. Where we rely on consent, you can withdraw it at any time, as described in Section 6.
4. Who we share it with
We do not sell personal data. We share it only where necessary: with service providers who help us run the platform (for example, hosting and email delivery — [TODO: name the actual providers in use, such as the hosting platform and the email service selected for the newsletter]), and with partner businesses only where you have specifically asked us to connect you with one.
Some of our service providers may process data outside the UAE. Where that happens, we take steps required by the PDPL to make sure the transfer is protected, such as confirming the receiving country offers an adequate level of protection, using standard contractual clauses, or relying on your explicit consent. [TODO: confirm and list where each provider actually stores and processes data, for example the region used by the hosting platform.]
5. How long we keep it
We keep contact form submissions for [TODO: retention period, e.g. 24 months] after your last interaction with us, and newsletter email addresses for as long as you remain subscribed. We keep data longer only where the law requires it. [TODO: confirm retention periods against actual practice and any UAE record-keeping requirements that apply to the business.]
6. Your rights
Under the PDPL, you have the right to ask us for a copy of the personal data we hold about you, to correct it if it is inaccurate, to have it deleted, to restrict how we use it, to object to us using it for direct marketing or other specific purposes, to receive certain data in a portable, machine-readable format, and to withdraw consent at any time where we rely on consent. To exercise any of these rights, contact us using the details in Section 10. We will respond within the timeframe the PDPL requires.
7. Security
We take reasonable technical and organisational measures to protect personal data against loss, misuse, and unauthorised access. No method of transmission or storage is completely secure, and we cannot guarantee absolute security. [TODO: describe actual measures in place once decided, e.g. encryption in transit, access controls.]
8. Children
Savara is not directed at children, and we do not knowingly collect personal data from anyone under 18. If you believe a child has provided us with personal data, contact us and we will delete it.
9. Changes to this policy
We may update this policy as the platform, our providers, or the law changes. We will update the date at the top of this page when we do, and where changes are material, we will take reasonable steps to let you know.
10. Contact us
For questions about this policy or to exercise your rights, contact us at [INSERT PRIVACY/DPO EMAIL ADDRESS]. If a Data Protection Officer has been appointed, their contact details should be listed here. You may also have the right to lodge a complaint with the UAE Data Office.