1. Introduction

Saniservice LLC (“us”, “we”, “our”, or “Saniservice”) operates https://saniservice.com and other websites owned and operated by Saniservice LLC, as well as the SaniApp mobile application (collectively referred to as the “Service”).

This Privacy Policy informs you of our policies regarding the collection, use, disclosure, and protection of personal data when you use our Service and the choices you have associated with that data. This Privacy Policy should be read in conjunction with our General Terms and Conditions.

We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our General Terms and Conditions.

2. Compliance with UAE Laws

This Privacy Policy is designed to comply with applicable laws and regulations in the United Arab Emirates (UAE), including but not limited to:

• UAE Federal Decree Law No. 45 of 2021 regarding Personal Data Protection
• UAE Federal Law No. 5 of 2012 on Combating Cyber Crimes
• Cabinet Resolution No. (56) of 2024 regarding the Do Not Call Registry (DNCR)
• Relevant provisions of the Dubai International Financial Centre (DIFC) Data Protection Law No. 5 of 2020 where applicable

This Privacy Policy applies to all websites, applications, and digital platforms owned and operated by Saniservice LLC, regardless of the domain name or access method.

3. Definitions

• Service: All websites owned and operated by Saniservice LLC (including but not limited to https://saniservice.com and any other domains used by Saniservice LLC) and the SaniApp mobile application.
• Personal Data: Any information relating to an identified or identifiable natural person who can be identified, directly or indirectly, by reference to an identifier such as a name, identification number, location data, online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
• Usage Data: Data collected automatically that is generated by the use of the Service or from the Service infrastructure itself (e.g., duration of a page visit, app features used).
• Cookies: Small files stored on your device (computer or mobile device).
• Data Controller: The natural or legal person who determines the purposes and means of the processing of Personal Data. For the purposes of this Privacy Policy, Saniservice LLC is the Data Controller of your Personal Data.
• Data Processor (or Service Provider): Any natural or legal person who processes data on behalf of the Data Controller.
• Data Subject (or User): Any living individual who is using our Service and is the subject of Personal Data.

4. Information Collection and Use

We collect several different types of information for various purposes to provide and improve our Service to you.

4.1 Types of Data Collected

4.1.1 Personal Data

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you. Personally identifiable information may include, but is not limited to:

• Email address
• First name and last name
• Phone number (including for WhatsApp communication)
• Address, State, Province, ZIP/Postal code, City
• Location data
• Device information (for mobile app users)
• Payment information (handled securely through our payment processors)
• Service history and preferences
• WhatsApp profile information (when you communicate with us via WhatsApp)
• Cookies and Usage Data

4.1.2 Sensitive Personal Data

We do not collect sensitive personal data such as information about your race, ethnicity, religious beliefs, health data, or biometric data unless specifically required for the provision of our services and with your explicit consent.

4.1.3 Usage Data

We collect information on how the Service is accessed and used. This Usage Data may include:

• Your computer’s or mobile device’s Internet Protocol address (e.g., IP address)
• Browser type and version
• Pages of our Service that you visit
• Time and date of your visit
• Time spent on those pages
• Unique device identifiers
• Diagnostic data
• App usage statistics and analytics (for mobile app users)

4.1.4 Location Data

We may collect and process information about your location if you give us permission to do so. We use this data to provide features of our Service, including service scheduling, technician tracking, and to improve and customize our Service.

You can enable or disable location services when you use our Service at any time through:

• Your device settings
• The SaniApp settings menu
• Your account preferences on our website

4.1.5 Cookies and Tracking Technologies

We use cookies and similar tracking technologies to track activity on our Service and hold certain information. Cookies are small files stored on your device (computer or mobile device) that contain a small amount of data, which may include an anonymous unique identifier.

Types of Cookies We Use

We use the following types of cookies:

• Essential/Necessary Cookies: These cookies are strictly necessary for the functioning of our websites and platforms. They enable core functionality such as security, network management, and account access. You cannot opt out of these cookies as the services cannot function properly without them.
• Preference/Functionality Cookies: These cookies allow us to remember choices you have made and provide enhanced, personalized features. They may be set by us or by third-party providers whose services we have added to our pages.
• Analytics/Performance Cookies: These cookies help us understand how visitors interact with our websites by collecting and reporting information anonymously. They help us measure and improve the performance of our site.
• Marketing/Targeting Cookies: These cookies are used to track visitors across websites. They are set to display targeted advertisements based on your interests and online behavior. They also help measure the effectiveness of advertising campaigns.
• Third-Party Cookies: Some cookies are placed by third parties on our behalf. These third parties may include analytics providers (like Google Analytics), advertising networks, and social media platforms. These cookies collect information about your browsing habits and are used to make advertising more relevant to you.

Cookie Duration

Cookies on our Service may be either “persistent” or “session” cookies:

• Session Cookies: These temporary cookies remain on your device until you leave our websites, at which point they are deleted.
• Persistent Cookies: These remain on your device for a set period (ranging from minutes to years, depending on the cookie’s purpose) or until you delete them manually.

Cookie Consent and Management

When you first visit our Service, you will be presented with a cookie banner that allows you to accept or decline non-essential cookies.

You can manage your cookie preferences at any time through the following methods:

• Using our Cookie Preference Center [accessible via the “Cookie Settings” link in the footer of our websites]
• Adjusting your browser settings to refuse all or some cookies, or to alert you when websites set or access cookies
• Using private browsing mode, which allows you to browse the internet without storing local data

Most web browsers allow some control of cookies through browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org.

Please note that if you disable or refuse cookies, some parts of our Service may become inaccessible or not function properly.

Do Not Track

Some browsers feature a “Do Not Track” (DNT) setting that, when enabled, signals to websites that you do not want to be tracked. Because there is not yet a common understanding of how to interpret the DNT signal, our websites currently do not respond to DNT signals. We will continue to monitor developments around DNT browser technology and the implementation of a standard.

4.2 Use of Data

Saniservice LLC uses the collected data for various purposes:

• To provide and maintain our Service
• To notify you about changes to our Service
• To allow you to participate in interactive features of our Service when you choose to do so
• To provide customer support and respond to inquiries through various channels, including WhatsApp
• To gather analysis or valuable information so that we can improve our Service
• To monitor the usage of our Service
• To detect, prevent and address technical issues
• To process transactions and manage your account
• To fulfill any other purpose for which you provide the information
• To provide service scheduling, tracking, and updates through the SaniApp and WhatsApp
• To send service appointment reminders and updates via WhatsApp
• To process customer communications and service requests through our AI-assisted systems
• To train and improve our AI systems for better customer service
• To provide you with news, special offers, marketing communications, and other information about our products, services, and events

4.3 Legal Basis for Processing Personal Data

Saniservice LLC may process your Personal Data because:

• We need to perform a contract with you
• You have given us permission to do so
• The processing is in our legitimate interests and it is not overridden by your rights
• For payment processing purposes
• To comply with applicable laws and regulations

5. Marketing Communications

5.1. Opt-In for Marketing

By creating an account or using Saniservice’s services, you may opt-in to receive marketing communications from Saniservice through various channels including email, SMS, WhatsApp messages, push notifications (for app users), and direct mail.

When you provide your contact information, we will ask for your explicit consent to receive marketing communications in accordance with UAE Federal Decree Law No. 45 of 2021 regarding Personal Data Protection.

5.2 Managing Your Marketing Preferences

You have the right to:

• Opt-out of marketing communications at any time
• Manage communication preferences through your account settings
• Request deletion of your contact information from our marketing databases
• Select which types of communications to receive or not receive

5.3 Marketing Communication Methods

Marketing communications may be sent through:

• Email newsletters
• SMS messages
• WhatsApp messages
• Push notifications through the SaniApp
• Direct mail
• Social media communications
• In-app messages for SaniApp users
• Telemarketing calls (subject to DNCR compliance)

5.4 Third-Party Marketing

We do not sell, rent, or lease your Personal Data to third parties for their marketing purposes without your explicit consent.

5.5 DNCR Compliance

Saniservice LLC respects customer privacy and complies with the UAE Do Not Call Registry (DNCR) regulations. We do not contact individuals listed on the DNCR for telemarketing purposes unless explicit consent has been obtained.

5.6 Telemarketing Rules

Saniservice LLC ensures that all telemarketing calls adhere to UAE regulations, including calling only during approved hours and maintaining records of customer consent. Customers may opt-out at any time as stated in Section 5.2 under “Managing Your Marketing Preferences.”

5.7 Consumer Complaints

If you receive unwanted marketing calls or messages, you may report the issue by contacting our Data Protection Officer at dpo@saniservice.com or filing a complaint through the TDRA.

6. Data Retention

Saniservice LLC will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to:

• Comply with our legal obligations
• Enforce our General Terms and Conditions
• Resolve disputes
• Provide you with ongoing service and support

Our specific retention periods, which begin from the date of your last transaction or interaction with us, include:

• Financial and tax-related records (including invoices): 7 years from your last transaction
• Customer account information and contact details: 5 years from your last transaction
• Service history records: 5 years from your last transaction
• Marketing data: 2 years from your last transaction unless consent is renewed
• Customer correspondence: 3 years from your last transaction
• Complaint records: 5 years from your last transaction

For customers with ongoing relationships or recurring services, we may retain your data for longer periods to maintain service continuity and historical context. We regularly review our retention practices and securely delete or anonymize personal data that is no longer needed.

We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer periods.

7. Data Transfer

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

If you are located outside the United Arab Emirates and choose to provide information to us, please note that we transfer the data, including Personal Data, to the United Arab Emirates and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Saniservice LLC will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place, including the security of your data and other personal information.

8. Disclosure of Data

8.1 Business Transaction

If Saniservice LLC is involved in a merger, acquisition, or asset sale, your Personal Data may be transferred. We will provide notice before your Personal Data is transferred and becomes subject to a different Privacy Policy.

8.2 Disclosure for Law Enforcement

Under certain circumstances, Saniservice LLC may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g., a court or a government agency).

8.3 Legal Requirements

Saniservice LLC may disclose your Personal Data in the good faith belief that such action is necessary to:

• Comply with a legal obligation
• Protect and defend the rights or property of Saniservice LLC
• Prevent or investigate possible wrongdoing in connection with the Service
• Protect the personal safety of users of the Service or the public
• Protect against legal liability

8.4 Service Providers

We may employ third-party companies and individuals to facilitate our Service (“Service Providers”), to provide the Service on our behalf, to perform Service-related services, or to assist us in analyzing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

8.4.1 Communication Service Providers

Saniservice LLC utilizes external service providers to manage and deliver various types of communications, including:

• Email service providers for sending newsletters, marketing communications, and service notifications
• SMS gateway services for text message communications
• WhatsApp Business API service providers for WhatsApp message delivery
• Push notification services for mobile app alerts
• Automated calling systems for appointment reminders

When you provide contact information to Saniservice LLC, your data may be processed through these third-party communication platforms. These service providers act as data processors on our behalf and are contractually obligated to handle your information securely and in compliance with applicable data protection laws.

The specific service providers we use may change periodically, but all are selected based on their commitment to data security and privacy compliance. These providers may have servers located in various countries, and data transfers are conducted with appropriate safeguards in place.

All communications sent through these platforms include options to unsubscribe or manage your communication preferences.

8.5 Artificial Intelligence and External LLM Services

Saniservice LLC utilizes artificial intelligence (AI) technologies internally to enhance our services, improve customer experience, and optimize our operations. As part of these AI systems, we may process certain data through external Large Language Model (LLM) services and similar AI platforms. In relation to this processing:

• Customer inquiries, service requests, or feedback may be processed through these AI systems to provide faster and more accurate responses
• We implement reasonable safeguards when sharing data with external AI services and limit sharing of sensitive personal information when feasible
• Where business needs require, we may process personal data through these systems in accordance with our legitimate business interests and service improvement goals
• Our agreements with external AI service providers include appropriate data protection terms
• We conduct regular assessments of these AI tools to ensure compliance with our privacy standards
• Data processed through these services is subject to the privacy policies of the respective AI service providers in addition to this Privacy Policy
• You have the right to request human intervention instead of AI-assisted processing for any of your requests

9. Data Security

The security of your data is important to us, but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

We implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk, including:

• Encryption of personal data where appropriate
• Regular testing and evaluation of the effectiveness of security measures
• Secure servers and storage systems
• Access controls and authorization procedures
• Regular staff training on data security
• Incident response procedures
• Secure processing protocols for AI-assisted systems
• Data anonymization and pseudonymization practices for AI processing

10. Your Data Protection Rights

You have certain data protection rights. Saniservice LLC aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.

You have the right to:

• Access your data: You can request copies of your Personal Data.
• Rectification: You can request that we correct any information you believe is inaccurate or complete information you believe is incomplete.
• Erasure: You can request that we erase your Personal Data under certain conditions.
• Restrict processing: You can request that we restrict the processing of your Personal Data under certain conditions.
• Object to processing: You can object to our processing of your Personal Data under certain conditions.
• Data portability: You can request that we transfer the data we have collected to another organization or directly to you under certain conditions.
• Opt out of AI processing: You can request that your data not be processed through our external AI services.

If you wish to exercise any of these rights, please contact us using the contact information provided at the end of this Privacy Policy. We may ask you to verify your identity before responding to such requests.

11. SaniApp and WhatsApp Specific Privacy Information

For users of our SaniApp mobile application and WhatsApp Business messaging service, the following additional privacy information applies:

11.1 App Permissions

The SaniApp may request certain permissions on your device, including:

• Location access (for service scheduling and technician tracking)
• Camera access (for scanning QR codes or documenting service issues)
• Storage access (for saving information or documents)
• Push notification access
• Contacts access (for sharing the app or service information)

You can manage these permissions through your device settings at any time.

11.2 App-Specific Data Collection

The SaniApp collects additional information specific to mobile usage:

• Device information (model, operating system version)
• App version and installation data
• App usage patterns and interactions
• Performance data and crash reports
• In-app booking and purchase history

11.3 Data Storage on Mobile Devices

Some of your Personal Data and preferences may be stored locally on your device to improve app performance. You can clear this data by:

• Using the “Clear Cache” or “Clear Data” option in the app settings
• Uninstalling the application

11.4 WhatsApp Business Communication

When you communicate with us via WhatsApp:

• We collect and process the phone number associated with your WhatsApp account
• Message content sent between you and Saniservice will be accessible to our customer service team
• Chat history may be retained for service improvement and record-keeping purposes
• WhatsApp’s own privacy policy (available at https://www.whatsapp.com/legal/privacy-policy) also applies to your use of the WhatsApp platform
• You can opt out of WhatsApp communications at any time by notifying our customer service team
• Service updates, appointment reminders, and marketing messages (if you’ve opted in) may be sent via WhatsApp

12. Third-Party Services

12.1 Analytics

We may use third-party Service Providers to monitor and analyze the use of our Service, including:

• Google Analytics
• Firebase Analytics (for mobile app)
• Other analytics tools

These services collect information sent by your browser or mobile app and may use cookies or other tracking technologies to collect and analyze your usage patterns.

12.2 Behavioral Remarketing

Saniservice LLC uses remarketing services to advertise on third-party websites to you after you visited our Service. We and our third-party vendors use cookies to inform, optimize and serve ads based on your past visits to our Service.

These remarketing services may place cookies on your browser to collect information about your online activity after you leave our websites. These cookies allow us and our third-party vendors to display targeted advertisements that are relevant to your interests. The information collected through this process does not personally identify you but is used to optimize ad delivery.

Remarketing services we may use include:

• Google Ads (AdWords) remarketing
• Meta plateforms and Custom Audiences
• Twitter Tailored Audiences
• LinkedIn Insight Tag
• Other advertising networks

Each of these platforms offers ways to opt out of targeted advertising:

• For Google, you can adjust your advertising settings at https://adssettings.google.com
• For Facebook, you can adjust ad preferences in your Facebook account settings
• For Twitter, you can disable interest-based advertising in your privacy settings
• For LinkedIn, you can manage your advertising preferences in your account

You can also opt out of many third-party vendors’ use of cookies for targeted advertising by visiting:

• http://www.aboutads.info/choices/ (US)
• http://www.youronlinechoices.eu/ (EU)

12.3 Payments

We use third-party services for payment processing. When you make a purchase through our Service, your payment information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy.

These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express, and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

We utilize multiple payment methods to provide you with flexibility and convenience:

• Credit/debit card payments through our website payment gateway
• In-app purchases through Apple Store and Google Play payment systems
• Physical Point of Sale (POS) terminals for in-person transactions
• Bank transfers for certain service agreements
• Electronic payment platforms and digital wallets

For each payment method, we ensure that:

• Your complete payment card details are never stored on our systems
• Transactions are processed through secure, encrypted connections
• We only retain the minimum information necessary for transaction records and customer service
• Our payment service providers are compliant with relevant financial regulations and security standards

Any payment data we maintain (such as the last four digits of your card or transaction IDs) is handled with strict security protocols and retained in accordance with our data retention policy and applicable financial regulations.

13. Links to Other Sites

Our Service may contain links to other sites that are not operated by us. If you click a third-party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

14. Children’s Privacy

Our Service does not address anyone under the age of 18 (“Children”).

We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Child has provided us with Personal Data, please contact us immediately. If we become aware that we have collected Personal Data from children without verification of parental consent, we will take the following measures:

• Immediately cease processing such data
• Take prompt steps to delete the information from our records
• Implement additional verification measures to prevent future collection of children’s data
• Document the incident and our response actions

Parents or guardians who believe we may have inadvertently collected personal information from a child can contact our Data Protection Officer using the details provided in this Policy.

15. Data Protection Impact Assessments

For processing operations that are likely to result in a high risk to your rights and freedoms, particularly when implementing new technologies or when processing sensitive data at scale, Saniservice LLC conducts Data Protection Impact Assessments (DPIAs). These assessments help us:

• Identify and minimize data protection risks
• Assess the necessity and proportionality of processing
• Ensure compliance with applicable data protection requirements
• Implement appropriate safeguards before initiating high-risk processing activities

We perform DPIAs when implementing new AI systems, significant changes to our data processing activities, or when beginning to process new categories of sensitive data.

16. Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and, where appropriate, via email and/or a prominent notice on our Service.

We will update the “Last Updated” date at the top of this Privacy Policy. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

In case of material changes to this Privacy Policy, we will provide at least 30 days’ notice before the changes take effect, unless changes are required by law to be implemented sooner.

This Privacy Policy applies universally to all websites, online platforms, and applications operated by Saniservice LLC. If Saniservice LLC launches a new website or online service, this Privacy Policy will automatically apply to that service unless explicitly stated otherwise.

17. Contact Us

If you have any questions about this Privacy Policy or wish to exercise any of your data protection rights, please contact us:

• By email: privacy@saniservice.com
• Through the contact form on any of our websites
• Through the Support section in the SaniApp
• Through our official WhatsApp Business account
  +971 43215505
• By phone: +971 43215505

18. Data Protection Officer

For inquiries specifically related to data protection, you can contact our Data Protection Officer at:

• Email: dpo@saniservice.com
• Phone: +971 43215505 ext 1900

19. Data Breach Notification

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, Saniservice LLC commits to:

• Notify the relevant data protection authority without undue delay and, where feasible, within 72 hours of becoming aware of the breach
• Notify affected individuals promptly if the breach is likely to result in a high risk to their rights and freedoms
• Provide clear information about the nature of the breach, likely consequences, and measures taken to address the breach and mitigate possible adverse effects
• Document all data breaches, including facts, effects, and remedial action taken

Our response to any data breach will prioritize the protection of your personal data and compliance with applicable UAE data protection regulations.