Privacy Policy — City Offers

Introduction

This is a translation for convenience. The Arabic version is the authoritative text and prevails in case of any difference.

Your privacy matters to us. This Policy explains what data we collect about you, 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.

The summary: We collect only what is needed to run the game: your mobile number, your in-game name, your date of birth and gender, and your location while you play. We do not sell your data, we do not show ads that track you, and Merchants do not see your name or number. We do not store what the camera sees. And you can delete your account whenever you wish.

This Policy forms part of the Terms and Conditions, and applies to the City Offers app for players and its website.

Who Is Responsible for Your 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: Settings → 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 (your account or play cannot work without it) or optional.

Account Data

Mobile number (required): for signing in and verification by code, because each person has only one account, and to contact you when you win an in-kind prize.
Username (required): visible to other players.
Date of birth and gender (required): to verify that you are 18 or older, and to show you offers that a Merchant has aimed at your group. They are not shown to other players or to Merchants, and they are included in aggregated statistics without identity (see What Others See).
Profile photo (optional): visible to other players.
Email and password (optional): to recover your account if you lose your number. The password is stored by the sign-in system and we cannot see it.
Player Code: a six-character code we create for you so that your friends can add you.
City: determined from your location, and shown on your profile and in your ranking.

Location

Your location while playing (required for play): used on your device to show the Boxes around you. When you open a Box, we receive your location coordinates and their accuracy to verify that you are actually close to it, and with each Box you have opened we store the location and time of opening (the history of opened Boxes), as well as your last opening location.
Approximate activity without identity: every five minutes while the App is open, we send an approximate square (about one kilometer), not your precise location, and players in it are counted without names to see where activity is in the city. The count is not read after a few minutes and is deleted automatically within about a day. We store on your account the last time you sent it (not the square) so that you are not counted twice.
Determining your city: we send your coordinates from our servers to the open map service (OpenStreetMap) solely to find the name of the city, without your name or number.
Walking route (when you request it): we send your location and the Box's location to Google's routes service to draw the walking route to it.
"Nearby Boxes" alerts (optional): if you enable them, your phone uses your location in the background to alert you to a nearby Box, and sends us your location when it updates so that we can return the list of nearby Boxes. We do not store this location; we store only which Boxes we have alerted you about, so that we do not repeat them.

Camera and Photos

The camera while playing: displays Boxes over what you see in front of you on your device only. We do not record, store, or upload what the camera sees.
Photos you choose: your profile photo, and photos you send in chats or Rooms, are uploaded to our servers to be shown to those you sent them to.

Play and Progress

The Boxes you have opened, your XP, level, and Rank, your Coins and their transaction history, Quests and Badges, your Daily Login streak, the number of Coupons you have redeemed in each neighborhood and city (for "Map Dominance"), and the Items you own or have activated.

"Visit Shop" in the Shop Directory: for each shop we count its taps and visitors per day without your name, and we store on your account the last day you visited each shop so that you are counted only once per day — and this is deleted with your account.

Coupons and Prizes

Your Coupons and their status, the time and branch of each Coupon redemption, Event prizes, their collection status and code, and cash balances, if any, and their transaction history.

Purchases and Withdrawals

In-app purchases: payment is made with Apple or Google Play, and we do not see your card details. We receive the transaction receipt from them (its number, the pack, and its time) to give you what you bought and to prevent duplication.
Withdrawing your Earnings Balance: your full name as shown on your ID, your bank account number (IBAN) in your name, what is needed to verify your identity in accordance with the law, and the history of your withdrawal requests and their status.

Your friends list and friend requests, blocks, your messages and photos in private chats and Rooms, reports you send or that are sent about you, support tickets and their content, your ratings of help articles, and the shops you follow.

Device and Security

Notification token and operating system type (Android or iOS), to deliver notifications.
Session identifier: an encrypted code for the App installation on your device and the sign-in time, to keep your account active on one device.
IP address, recorded in security logs with sensitive operations (opening Boxes, changing your name or number, deletion, reports, and others).
Cheating indicators: such as a fake location or an impossible speed between two Boxes.
Your consents and preferences: the version of the Terms and the Policy you accepted and when, and your choices regarding notifications and appearing on the map.

What We Do Not Collect

We do not ask for your contacts, the microphone, your bank card details, or any health or sensitive data. We do not collect images of your ID, unless it is necessary to verify your identity in order to withdraw your balance or hand over a large prize in accordance with the law, in which case we review what is necessary and keep only what the law requires us to keep. We do not use third-party advertising, tracking, or analytics tools inside the App.

How We Collect It

Directly from you: when you register, complete your profile, and write messages and tickets.
From your device: location, camera, and sensors (the compass and motion, used to display Boxes, which stay on your device) — after your permission.
Automatically during use: play history, session data, and security logs.
From the Merchant upon redemption: the cashier scans the Coupon code and we record the redemption.

Why We Process Your Data and the Legal Basis

To provide the service you requested (performance of our agreement with you): creating your account and signing in, displaying Boxes and verifying openings, issuing and redeeming Coupons, prizes, the Wallet, friends and chats, and support.
For a legitimate interest, after balancing it against your rights: preventing cheating and fraud and protecting accounts, ensuring fair play, moderating content, and aggregated statistics without identity to improve the App and the distribution of Boxes.
With your consent: "Nearby Boxes" alerts using background location, notifications about offers and Events, and your profile photo and email. You may withdraw your consent at any time without affecting the rest of your use.
To comply with the law: when requested by the competent authorities in accordance with the law.

We do not make your consent to anything optional a condition for using the App.

What Others See

Other players see your public profile: username, photo, city, XP and Rank, Badges, and the date you joined. Your friends see your code. Your messages in public Rooms are visible to everyone in them.
"Map Dominance": your name and photo do not appear in it unless you choose to appear, and your marker appears at the center of the neighborhood or city, never at your location.
Your precise location is not visible to anyone, whether players or Merchants.
Merchants do not see your name, number, or code. Upon redemption, they record: the Coupon, its time, and the branch. Merchants subscribed to "Plus" see aggregated statistics without names or identifiers: the age-group and gender proportions of their customers (not shown before 30 redemptions, and no group with fewer than five people is displayed), neighborhood activity (five players or more), redemption counts by the Box's distance from the branch, and the numbers of new and returning customers. Merchants see how many followers they have, not their names. If you complain that a Coupon was refused, we send the merchant your complaint text and the Coupon code, without your name or number.
An Event's organizing body: after the Event ends, we may share with it the text of its Room's messages without names to evaluate it.
The authorized administration and moderation team accesses only what is needed for its work: your account data during support and verification, and reported messages. Its tools do not allow your private chats to be read.

Where We Store Your Data

Your 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 your data outside the Kingdom.
Basis for the transfer: providing the service you requested, 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 Your Data

Account, play, Coupon, and ticket data: for as long as your account exists. When it is deleted, this data is deleted after a 30-day grace period (see Account Deletion). For your messages and photos in other people's chats and in Rooms, see below.
History of opened Boxes and their locations: for as long as your account exists, and deleted when it is deleted.
Approximate activity: the live count is deleted automatically within about a day, and the daily maps remain aggregated without identity.
Notifications in the bell: 90 days, then deleted automatically.
Financial records (Coins and balances): when your account is deleted, they are moved to an archive without your identity for accounting purposes.
Security logs (including IP address), reports and their evidence, moderation and suspension decisions, cheating indicators, cancelled prize claims, and server operation logs: we keep them for one year to protect accounts, prevent fraud, resolve complaints, and comply with the law, after which they are deleted or anonymized.
The "Map Dominance" counter (how many Coupons you redeemed in each neighborhood and city) and the link between your device's notification token and your account: deleted with your account when the deletion grace period ends, and not kept after it.
Messages and photos you sent to others: they remain in the other party's chat, where your account appears as "Deleted account", and likewise your messages in public Rooms remain there without your name or photo ("Deleted account"). You may ask us to delete them entirely before or after your account is deleted.
The redemption record held by the Merchant: does not contain your identity, and remains with the Merchant.

How We Protect Your Data

Balances, Boxes, Coupons, and prizes are not written by the App itself but go through our servers, and every other write (messages and some profile fields) is governed by strict rules that determine who writes what and who reads it.
Data is encrypted in transit and at rest.
Administrative access is limited by permissions, and administrative actions on your account are logged.
You can lock the App with your fingerprint, and your account is active on one device at a time.
If a breach of your data 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, 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, or to delete your account.
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 profile, notifications, appearing on the map, and "A Copy of My Data" (Settings → Account Settings — you receive a copy in JSON format), and deleting your account from Settings. Location and camera permissions are managed from your phone's settings.
By request: open a ticket from Settings → Help Center (choose "Account and Sign-in"), 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.

Location in Detail

"While using the App" is enough for all play. "Always" is needed only for "Nearby Boxes" alerts, if you enable them.
You can turn off the alerts from Settings → Notifications → "Nearby Boxes", and withdraw the location permission from your phone's settings at any time.
We do not sell your location, show it to anyone, or use it for third-party advertising. We use your city to send you offers and Events in your city if you have enabled those notifications, and your location for "Nearby Boxes" alerts if you have enabled them.
At high speed, play stops automatically for your safety.

Notifications and Promotional Messages

Service notifications (support replies, account, maintenance, and prize delivery) reach you because they are part of the service.
Notifications about offers and Events are optional: we ask you about them when you register, and you can change them at any time from Settings → Notifications. All other notification types (messages, gifts, Coupons, campaigns from shops you follow…) have their own switches there.
A private-message notification contains the sender's name and the message text, and passes through Google's or Apple's notification service. You can mute any chat.
We do not send promotional text messages (SMS) to your mobile.

Minors

The App is for people aged 18 or older, and we do not knowingly collect data from anyone younger. If we learn of an account belonging to a minor, we will close it and delete its data. If you are a parent or guardian and believe that a minor is using the App, please contact us.

Account Deletion

How: Settings → Account Settings → "Delete Account", or the Account Deletion page on our website.
Grace period: 30 days during which you can restore your account. Your profile is not visible to others during this period.
After the grace period we delete: your account data, profile, and photo, your Coupons and prizes, the history of your Boxes and their locations, your friends and preferences, your notifications and tickets; we release your username and code, and delete your sign-in account.
We keep what is set out in How Long We Keep Your Data (the financial archive without identity, security logs and reports, and messages in other people's chats and Rooms under the name "Deleted account" — which you may ask us to delete).
The "Start Over" option immediately deletes your profile, Coupons, belongings, friends, and history, and starts a new account for you with the same number; we keep what is kept upon deletion.

How We Destroy Data

We delete data permanently from the database and storage, and convert what we need to keep (such as financial records) into a form that does not identify you. Automatic backups held by the hosting provider remain for a short period and are then replaced: 30 days.

What We Store on Your Device

The App stores on your phone your settings (appearance, language, sounds, fingerprint lock), a copy of your notification preferences, a history of recent opening games so that they do not repeat, and an identifier for the App installation. 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.

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 your 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.