Introduction
This Policy explains what data we collect about your business, about you, and about your Team when you use the City Offers app for Merchants, why, how we store, protect, and delete it, who sees it, and what your rights are and how to exercise them — in accordance with the Personal Data Protection Law (PDPL) of the Kingdom of Saudi Arabia and its Implementing Regulations.
This is a translation for convenience. The Arabic version is the authoritative text and prevails in case of any difference.
The summary: We collect what is needed to run your Store on the Platform: each member's mobile number and name, the business's documents, its Branches, and its Campaigns and financial transactions. We do not sell data, and we do not use advertising or tracking tools. We do not track your phone's location. And players see your Store, not the people on your Team.
- This Policy applies to the Owner, Team members, and registration applicants, and forms part of the Merchant Terms and Conditions.
- Data about the business itself (its name, Commercial Registration, and numbers) is not personal data, but we protect it with the same care and explain it here.
- Players' data is governed by the Player Privacy Policy, and you see only what is described in What You See About Players.
Who Is Responsible for the Data
- Controller: [Entity name] — Commercial Registration number [Commercial Registration number] — [National Address], Kingdom of Saudi Arabia.
- Privacy contact: privacy@city-offers.com · Phone or WhatsApp: [Contact number] · or from inside the App: Menu → Help Center → "Open a Ticket".
- Data Protection Officer: [Data protection officer's name and email — if appointed]
- Registration number in the National Register of Controllers: [Registration number — if any]
The Data We Collect
For each item of data, we state whether it is required (the account cannot work without it) or optional.
Account and Sign-in
- Mobile number (required): for each member, to sign in with a verification code sent to them. The Owner's number is the business's contact number with the Platform. We also store the number of anyone you invite to your Team until they accept the invitation or it expires.
- Name (required for the Owner, and recommended for every member): visible to your Team and in the activity log, and not visible to players.
- Email (optional): to contact the business.
- Role, permissions, and Branch: what the Owner sets for each member, the date they were added and who added them, and their status (active or suspended).
- Your consents and preferences: the version of the Terms and the Policy you accepted and when, your notification preferences, and the interface language (so that the server sends its messages in it).
Business Documents
- Required: the Commercial Registration number, its expiry date, and a copy of it, and the logo.
- Optional: the VAT number and its certificate, the municipal license, and the attachment to a request to change the name or logo.
- For payments and balance refunds: what the licensed payment service provider and the law require to verify the business, such as the bank account number (IBAN) in the business's name, the Owner's ID, and the National Address. We review what is necessary and keep only what the law requires us to keep.
Your Store and Business
- Business profile: the Store's name, category, and cities, its opening hours, the phone number displayed to the public, and your online store link.
- Branches: each Branch's name and address, and the location you choose for it on the map. We send the Branch's coordinates to the open map service (OpenStreetMap) to find the name of its city.
- Campaigns and Sponsorship: offers, their terms and images, covers, Branches, area, dates, and targeting, the discount license number, and the text of every confirmation you accepted, its time, and who accepted it.
- Money: the Wallet balance and Box Credit, the history of every transaction (the amount, the reason, the time, and the balance after it), invoices, and payment transactions (their number, amount, and status — without your card details).
- Redemption: for each redeemed Coupon: its time, code, offer, and Branch, the Team member who redeemed it, and the entry method (scanned or typed); as well as how many Coupons each Cashier has redeemed and their last redemption.
- Performance: daily counts of openings, wins, redemptions, and spending; Plus requests and subscription; the tips each member has hidden; the number of followers; and Store page visit counts.
- Support: tickets, their content and attachments, the articles you read before opening a ticket, and your ratings of help articles.
Device and Security
- Notification token and operating system type (Android or iOS) for each member, to deliver notifications.
- IP address, recorded with sensitive operations (applying, invitations, creating and ending Campaigns, purchases, refused redemptions, and others) in the security and audit log, together with the necessary details of the operation (including, for invitations, the invitee's mobile number and role).
- Rate-limit counters for each account, to prevent abuse.
Camera and Location
- Camera: to scan Coupon codes upon redemption, and to photograph the logo, documents, and prize images if you choose to. We do not record or store what the camera sees while scanning.
- Location: used on your device only to center the map when you choose your Branch's location ("My Location"). What reaches us is the Branch location you choose, not your phone's location. The App does not use location in the background.
What We Do Not Collect
We do not ask for your contacts, the microphone, your bank card details, or any health or sensitive data, and we do not track your phone's location. We do not use third-party advertising, tracking, or analytics tools inside the App.
How We Collect It
- Directly from you: the registration request, the business profile, Branches, Campaigns, the Team, and tickets.
- From the Owner or a manager: when they add you to the Team with your number, name, and role.
- From your device: the camera and location (with your permission), and the notification token.
- Automatically during use: the activity, redemption, and security logs.
- From the payment service provider: the result and amount of each payment transaction.
Why We Process Data and the Legal Basis
- To perform the agreement with your business: reviewing and approving its application, operating the account and the Team, publishing Campaigns, issuing and redeeming Coupons, the Wallet and invoices, Plus and Sponsorship, and support.
- For a legitimate interest, after balancing it against your rights: preventing fraud, cheating, and misuse, protecting accounts, verifying the authenticity of documents, aggregated statistics to improve the Platform and the distribution of Boxes, and the anonymous comparison between similar Stores.
- To comply with the law: verifying the Merchant's details and Commercial Registration as required by the E-Commerce Law, keeping financial records and invoices, and responding to requests from the competent authorities.
- With your consent: general and promotional notifications. You may withdraw your consent at any time without affecting the rest of your use.
Who Sees What
- Players see your Store, not the people on your Team: the Store's name, logo, and category, the Branches and their locations, the offer, its terms, and its license number, and the opening hours, the displayed phone number, and your online store link. They do not see your private mobile number, your email, your documents, or your Team's names.
- Your Team sees according to each member's role: the Owner sees everything, the General Manager sees what is within their scope, and the Branch Manager and Staff members see their Branch and the permissions they have been granted. The Wallet, its history, and the documents are for the Owner alone. Team members' names and roles, and who redeemed each Coupon, are visible to whoever manages the Team.
- A ticket is read only by the person who opened it and the support team.
- Other Stores see none of your data. Your Store's figures go into an anonymous median for similar Stores in your category and city, without names or rankings, and it is shown only when there are at least five Stores other than the Store itself.
- The authorized administration team accesses only what is needed for its work, with specific permissions: reviewing applications and documents, support, monitoring Campaigns and violations, and the Wallet. Documents are kept in locked storage that can be opened only through a temporary link for the reviewer.
What You See About Players
- You do not see a player's name, number, code, or location. Upon redemption, the following is recorded: the Coupon code, the offer, the time, the Branch, and who redeemed it.
- In Plus, you see aggregated statistics without names or identifiers: redemption counts by hour and day, and by the Box's distance from your Branch; gender and age-group proportions (not shown before thirty redemptions in the period, and no group with fewer than five people is shown); neighborhood activity (five players or more); and the numbers of new and returning customers.
- You see how many followers you have, not their names.
- You may not try to identify a player or collect their data through the Platform (see the Terms).
Where We Store Data
- Data is stored and processed on Google Cloud servers in Frankfurt, Germany (European Union), and some global Google services (sign-in and notifications) may process data in other countries. This is a transfer of data outside the Kingdom.
- Basis for the transfer: providing the service requested by the business, in accordance with the Personal Data Protection Law (PDPL) and the Regulation on Personal Data Transfer Outside the Kingdom.
- Safeguards: the data processing terms to which Google is committed, encryption of data in transit and at rest, and limiting what is transferred to the minimum necessary.
- We may in future move our data to data centers inside the Kingdom, in which case we will update this paragraph.
How Long We Keep Data
- For as long as the Store's account exists: we keep the data of the business, its Branches, Campaigns, Team, and transactions to operate the service.
- Financial records (the Wallet and its transactions, invoices, and payment transactions) and your contract and Commercial Registration documents: ten years from account closure, to comply with the laws on commercial books, zakat, and tax, after which they are deleted.
- Other Store data (Campaigns, redemptions, statistics, tickets, the Team, and requests): one year after final closure, after which it is deleted or anonymized so that it does not identify anyone.
- A Team member who is removed or suspended: their name stays linked to the record of Coupons they redeemed, and their data is then anonymized one year after their removal. They may ask for their personal data to be deleted, in which case we anonymize it in the records that must be kept.
- A rejected application and its documents: one year from the last rejection unless you reapply, after which they are deleted.
- An invitation that was not accepted: deleted after it expires.
- Notifications in the bell: ninety days, then deleted automatically.
- Security and audit log (including IP address): one year, then deleted.
- Backups: replaced automatically within thirty days.
- Aggregated statistics that do not identify anyone (including the anonymous peer median) may remain after that.
How We Protect Data
- Balances, Campaigns, Coupons, and redemptions are not written by the App itself but go through our servers, and every other write is governed by strict rules that determine who writes what and who reads it.
- Documents are in locked storage that no one can read except through a temporary link for the authorized reviewer.
- Data is encrypted in transit and at rest.
- Administrative access is limited by permissions, and administrative actions on your account are logged.
- Suspending a member signs them out of the Store's account immediately, and you can lock the App with your fingerprint.
- If a data breach occurs, we will notify the competent authority within the statutory period (72 hours), and notify you without delay if it may harm you, together with our advice to you.
Your Rights and How to Exercise Them
Under the law, whether you are the Owner, a Team member, or an applicant, you have the right:
- To be informed of what we collect and why (this Policy).
- To access your data and obtain a copy of it in a commonly used electronic format.
- To correct, complete, or update your data.
- To request the destruction of your data that we no longer need — while what the law requires us to keep (such as financial records) remains until its period ends.
- To withdraw your consent to anything based on consent.
- To complain to the competent authority, and to claim compensation for harm you suffered as a result of a violation of the Personal Data Protection Law, in accordance with the law.
How?
- Directly from the App: editing your name from Settings → Account, notification and language preferences, and "A Copy of My Data" from Settings → Account. The Owner also has the Store's performance reports, and the Wallet history and its invoices.
- Leaving the Team: a member requests it from Settings → Account, or the Owner suspends them, and they are removed from the Store's account.
- Closing the Store's account: by the Owner, from Settings → "Request Account Closure" (see "Account Closure" in the Terms).
- By request: open a ticket (choose "Account and Documents") or write to us at privacy@city-offers.com. We verify that the request comes from you through your account or number, and we reply within 30 days, which we may extend by another 30 days after informing you of the reason.
- Changing your mobile number is done through support after your identity has been verified.
Your Data in the Player App
- The account tied to your mobile number is one and the same in the Merchant and player apps. If you use the player app with the same number, your data there is governed by the Player Privacy Policy.
- Your Store sees nothing more about your player account than it sees about any other player.
Notifications
- Service notifications (Store status, a Campaign being stopped, prices, documents, support replies, and the Team) reach you because they are part of the service.
- Business notifications (a Coupon redeemed, a Campaign ended, Boxes run out, Sponsorship, a Wallet deposit, and your Commercial Registration nearing expiry) have their own switches in Settings → Notifications.
- General and promotional notifications are optional, and you can turn them off from Settings → Notifications.
- We do not send promotional text messages or emails without your consent.
What We Store on Your Device
The App stores on your phone your settings (appearance, language, and fingerprint lock) and a copy of your notification preferences. None of this is sent to any other party, and it is deleted when the App is deleted. Our website does not use cookies or tracking tools.
Age
The Merchant app is for people aged 18 or older. Do not add anyone younger to your Team.
Changes to This Policy
- We will notify you of any material change inside the App at least fifteen days before it takes effect, and explain what has changed in the What Has Changed section.
- If we add a new purpose for processing data, we will ask for your consent before starting it.
Contact and Complaints
- Write to us: privacy@city-offers.com or through the Help Center in the App.
- If your complaint is not resolved, you may submit it to the Saudi Data and Artificial Intelligence Authority (SDAIA) through its Data Governance Platform: dgp.sdaia.gov.sa.
What Has Changed
- Version 1 — [Effective date]: First version.