Privacy Policy & Sensitive Data Handling — سياسة الخصوصية
Khatawaat · Version 1.9 · Effective date: [Effective Date]
Data controller: [Company Legal Name], [Company Address], [Country of Incorporation] (the " Company", "we", "us"). Privacy contact: privacy@khatawaat.com · Data Protection Officer (where appointed): [DPO Name / Email] EU representative (Art. 27 GDPR, if applicable): [EU Representative] · UK representative: [UK Representative]
Summary (not a substitute for the full policy). Khatawaat helps you track your weight and build healthy habits with a community. To do that we process information about your body — height, weight and targets — which the law treats as sensitive health data. We ask for your explicit consent before collecting it, encrypt it in transit and at rest, never sell it, never use it for advertising, and never share it with employers or insurers. You own your progress photos, choose who sees them (public, circle-only or private), can blur your face before they leave your device, and can delete any photo — or your whole account and all of its data — at any time.
1. Scope
This Policy explains how we collect, use, share and protect personal data when you use the Khatawaat mobile applications (iOS and Android), the Khatawaat web application and website at https://khatawaat.com, and related support channels (together, the "Service"). It applies to everyone who uses the Service, wherever they are located, and is supplemented by the regional disclosures in Section 16.
It does not cover third-party websites or services that we link to, which have their own privacy policies.
2. Definitions
- Personal data: information relating to an identified or identifiable person.
- Health data / sensitive data: data about your physical health, including body measurements such as weight, height, body-mass index and target weight, and anything that reveals them (for example a progress photo), and — if you connect a health app (Section 5a) — the activity, sleep, heart-rate, body and nutrition data synced from it. Such data is treated as a special category of personal data under the GDPR and as sensitive personal data under the UAE, Saudi and other regional data-protection laws.
- Circle: a milestone-based group of members with the same goal direction that shares a leaderboard and a feed.
- Content: anything you post or upload — progress photos, posts, comments, reactions ("cheers") and challenge check-ins.
- Processor: a service provider that processes personal data on our behalf and under our instructions.
3. Data we collect
3.1 Data you give us
| Category | Examples | Required? |
|---|---|---|
| Account & identity | Email address, display name, avatar, authentication identifiers issued by Firebase Authentication, sign-in provider (email/password or Google) | Required to create an account |
| Demographic data | Date of birth (to calculate your age and confirm eligibility), gender | Gender is optional ("prefer not to say" is available); date of birth is required for age verification and used, with your consent, for metabolic estimates |
| Physical / health data (sensitive) | Height, current weight and your history of weigh-ins, start weight, target weight, goal direction (lose / gain / maintain), activity level, optional body-fat percentage and waist circumference, your chosen weekly pace, your answers to the onboarding health check (pregnancy or breastfeeding, history of an eating disorder, chronic conditions such as diabetes or high blood pressure, weight-affecting medication — each optional, with a Prefer not to say answer), and figures we derive from them (BMI, estimated BMR and TDEE, weight change, remaining progress). We use the health-check answers only to make your suggested target, pace and calorie estimates safer; they are never shown to other members | Required for the core tracking features; collected only after your explicit consent (see Section 5) |
| Health data synced from your phone (sensitive) | Only if you connect Health Connect (Android) — or Apple Health (iPhone), once our iPhone app is available — and give the separate consent in Section 5a: one total per day for each type you allow — steps, distance, floors climbed, workout time and number of workouts, active and total calories burned, sleep time and sleep stages, average / lowest / highest and resting heart rate, weight and body-fat percentage (for example from a smart scale), height, basal metabolic rate, calories and macronutrients eaten, water drunk — together with the names of the apps that recorded them and whether each value was measured by a device or typed in. Never minute-by-minute readings, locations, routes, or the individual records | Optional; nothing is read until you connect, and you choose the types |
| Progress photos | Photos you attach to weigh-ins or posts, their privacy level (public / circle / private) and whether face-blur was applied | Optional |
| Social data | Posts, comments, reactions, challenge check-ins, reports you submit about other members' content, who you cheer | Optional |
| Preferences | Language (Arabic / English), numeral system, time zone, theme, notification choices, privacy settings (weight visibility, default photo privacy, milestone sharing, anonymous leaderboard) | Set by you; some have safe defaults |
| Communications | Messages you send to support, feedback, survey answers | Optional |
3.2 Data generated when you use the Service
| Category | Examples |
|---|---|
| Gamification data | XP events and totals, level, badges and when you earned them, streak counts and state, circle membership history, leaderboard rank and consistency score, challenge participation and progress |
| Technical & device data | Device model and operating system, app version, language, time zone, IP address and approximate region derived from it (for security and localisation only), push-notification tokens, crash reports and performance data, request identifiers and server logs |
| Usage analytics | Which screens and features you use, session length and interaction events (collected through the analytics provider in Section 9; where the law requires it, only with your consent) |
3.3 Data from third parties
If you sign in with Google, Google sends us your name, email address, profile picture and a unique identifier. We never receive your Google password. If we add further sign-in providers (for example Apple), the same applies to the profile data they send us. We do not import contacts. We import health data from other apps and devices only if you connect Health Connect (Android) or Apple Health (iPhone) yourself in our app, after the separate consent and the per-type permissions described in Section 5a.
3.4 Data we do not collect
We do not collect precise geolocation, contact lists, biometric identifiers (face-blur runs on your device and does not create a face template), payment card numbers (payments, if any, are handled by the app stores) or government identification numbers.
4. Why we process your data and on what legal basis
| Purpose | Data used | Legal basis (GDPR and equivalent regional laws) |
|---|---|---|
| Create and secure your account, sign you in, keep you signed in across devices | Account & identity, technical data | Performance of a contract (the Terms of Service) |
| Provide weight tracking, calculators, milestone circles, streaks, XP, badges and challenges | Physical / health data, demographic data, gamification data | Explicit consent for health data (GDPR Art. 9(2)(a)); performance of a contract for the rest |
| Sync health data from your phone (Section 5a): show it back to you, count measured activity toward activity quests, and record a weigh-in from a smart-scale reading (with the usual weigh-in XP) | Synced health data, gamification data | Explicit consent (GDPR Art. 9(2)(a)), separate from the onboarding consent; withdraw any time by disconnecting (Section 5a) |
| Show your Content and profile to other members according to your privacy settings | Social data, progress photos, display name, avatar, level, circle | Performance of a contract; your privacy settings control the audience |
| Send push notifications and emails about your progress, circle activity, challenges and account | Push tokens, email, gamification data | Consent (you can turn each category off at any time); legitimate interest for essential account messages |
| Send tips & product news by email | Email address, language | Consent — off until you turn it on; withdraw any time with the unsubscribe link in every email or in Settings → Privacy |
| Keep the Service safe: detect abuse, cheating, spam and security incidents; handle reports; enforce the Community Guidelines | Technical data, social data, gamification data, reports | Legitimate interests (protecting members and the Service); legal obligation where applicable |
| Fix bugs and understand how the Service is used, to improve it | Crash reports, usage analytics (pseudonymous) | Consent — off until you turn it on in Settings → Privacy (Section 13); iOS App Tracking Transparency is not used |
| Produce aggregated, anonymous statistics (e.g. "members logged 1.2 million weigh-ins this year") | Aggregated data that no longer identifies anyone | Not personal data once anonymised; legitimate interests for the anonymisation step |
| Respond to your requests and support tickets | Communications, account data | Performance of a contract; legal obligation for rights requests |
| Comply with the law, respond to lawful requests, establish or defend legal claims | Any category, as strictly necessary | Legal obligation; legitimate interests |
Automated processing. The Service automatically places you in a milestone circle, awards XP and badges, computes streaks and ranks members on circle leaderboards according to published rules (see the Terms of Service). These are game mechanics inside the Service; they have no legal or similarly significant effect on you and are not used for credit, insurance, employment or pricing decisions. You can contact us to have any automated outcome reviewed by a person.
No sale, no advertising. We do not sell personal data, we do not share it with data brokers, and we do not use health data to target advertising. The Service contains no third-party advertising.
5. Sensitive data: our commitments
Because weight, height, targets and progress photos reveal information about your health, we apply stricter rules to them than to ordinary account data:
- Explicit, separate consent. We ask you to consent to the processing of your health data in a dedicated step during onboarding, separately from accepting the Terms. You may withdraw consent at any time (Section 12); because the data is essential to the Service, withdrawal means we will delete your health data and close the account. Syncing health data from your phone has its own, optional consent that you can withdraw without closing the account (Section 5a).
- Data minimisation. We only ask for what the features need. Gender can be left unspecified; body-fat percentage, photos and notes are optional.
- Encryption. Health data is encrypted in transit (TLS 1.2 or higher) and at rest in our database and backups, and progress photos are stored encrypted at rest with access-controlled, expiring links.
- Access control. Only a small number of authorised staff can access production systems, under role-based permissions, multi-factor authentication and audit logging, and only for support, security or legal reasons. Staff never browse members' health data for curiosity or marketing.
- Private by default. Your weight history and figures are visible only to you unless you change your weight visibility setting. Progress photos default to Circle-only and face-blur is on by default. Other members see your current circle, display name, avatar, level and badges — never your weight, height or targets. Leaderboards can show you anonymously.
- No secondary use. We do not use health data for advertising, do not share it with insurers, employers or governments except where the law compels us, and do not combine it with data from other companies.
- Pseudonymisation and aggregation. Analytics and crash reports are keyed to pseudonymous identifiers, never to your name or email, and never contain weight values. Statistical insights are produced from aggregated data.
- Regional storage. Health data is stored in our PostgreSQL database at Neon, Inc. (a Databricks company) in the European Union (Frankfurt, Germany); our API runs at Render Services, Inc. in the European Union (Frankfurt, Germany). Encrypted backups of the database are kept in Cloudflare R2 object storage (Section 9). Where local law requires health data to remain in a specific country, we host it there or do not offer the Service in that country (see Section 16).
5a. Health data synced from your phone
If you choose to connect Health Connect on Android (or Apple Health on iPhone, once our iPhone app is available), these rules apply on top of Section 5:
- Separate, optional consent. Connecting is never required. We ask for your explicit consent on the connect screen, separately from the consent you gave during onboarding, and then your phone asks for permission for each data type; you can allow only some of them. We record your consent (version, date, language and device type) as described in Section 10.
- Daily totals only. Our app reads one total per day for each type you allowed (Section 3.1) and sends only those totals, the names of the apps that recorded them and whether each value was measured or typed in. It never sends minute-by-minute readings, locations or routes. It syncs when you open the app, when you pull to refresh and, where your phone allows it, once a day in the background; it sends only the days that changed, at most the last 35 days at a time.
- Measured, not typed. Only values measured by a device count as proof: they can complete activity quests and, for weight, create a weigh-in. Values typed into a health app are shown to you but never earn anything. Values outside a plausible range are rejected and logged to keep the game fair (Terms of Service, fair play).
- Weigh-ins from a smart scale. A measured weight creates at most one weigh-in per day, only for days from the day you connect onward, never replaces a weigh-in you entered yourself, and is marked as verified. You can delete it like any other weigh-in, and it will not come back.
- Who sees it. Your synced data is visible only to you (in the app, and read-only on the website). Other members see your quest progress as they do today, never the underlying numbers.
- Limited use. We use data obtained through Health Connect or Apple Health only to provide the health features described here. We do not sell it, use it for advertising or profiling for advertising, or transfer it to anyone except our processors that run the Service (Section 9), where the law requires it, or in a business transfer with prior notice (Section 7). Our staff do not read it except with your permission, to investigate security incidents or abuse, or to comply with the law. Our use of information received from Health Connect follows the Health Connect Permissions policy, including its Limited Use requirements.
- Disconnect = delete. Settings → Health data → Disconnect (in the app or on the website) stops syncing and immediately deletes every day of synced health data from our database (from backups within [Backup Retention]); we record the withdrawal of your consent. Weigh-ins and quest check-ins that were already created stay part of your weight and quest history, and you can delete them individually. Removing our app's permissions in Health Connect or Apple Health stops new reads but does not delete what we already hold — use Disconnect for that. Withdrawing this consent does not affect the rest of your account.
6. Progress photos: ownership and controls
- You own your photos. Uploading a photo does not transfer ownership to us. You grant us only the limited licence described in the Terms of Service, which is needed to store the photo and show it to the audience you chose, and which ends when you delete the photo (subject to the deletion timelines below).
- Face-blur before upload. When you choose face-blur, the blur is applied on your device before the photo is uploaded; the un-blurred original never leaves your device, and we cannot reverse the blur. Face detection for blurring runs locally and creates no biometric template.
- Metadata stripping. Location (GPS) and other EXIF metadata are stripped on your device before upload, and the photo is resized so that only a web-sized copy ever leaves your device.
- Audience you control. Each photo carries one of three privacy levels, and you can change it at
any time:
- Public — visible to all signed-in members of Khatawaat;
- Circle-only — visible only to current members of your milestone circle;
- Private — visible only to you, in your own history. New photos take your default photo privacy setting, which starts at Circle-only; you can change it to Private or Public at any time in Settings → Privacy.
- Deletion. You can delete any photo from your weigh-in history or post. Deletion removes it from the Service immediately, from our storage provider and content-delivery caches within [Photo Purge Window, e.g. 7 days], and from encrypted backups within [Backup Retention, e.g. 30 days]. We cannot delete copies that other members may have saved or screenshotted while the photo was visible to them — choose your audience carefully.
- Minors. Photos of children, and photos that show nudity, are not permitted (see the Community Guidelines).
7. How we share data
We share personal data only in the following circumstances:
- With other members, as you choose. Your display name, avatar, level, badges, current circle and streak are visible to other members. Posts, comments, reactions, challenge activity and photos are visible according to their privacy level. Weight, height, targets and calculator results are never shown to others unless you set weight visibility to circle or public. Leaderboards show your rank; you can appear anonymously.
- With processors acting on our instructions (Section 9), under contracts that require confidentiality, security and use only for the purposes we specify.
- For legal reasons. Where required by law, regulation, court order or enforceable request from a public authority; to enforce our Terms; or to protect the rights, property or safety of members, the public or the Company. We will challenge requests we consider unlawful or overbroad and, where permitted, notify you.
- Business transfers. If the Company is involved in a merger, acquisition, financing or sale of assets, personal data may be transferred as part of that transaction, subject to this Policy and prior notice to you.
- With your direction or consent, for example if you ask us to share a progress summary with your doctor or you share a link outside the Service.
We never share personal data with advertisers, data brokers, insurers or employers.
8. International transfers
Our processors, including Google (Firebase), Cloudflare, Apple (which hosts our e-mail) and Bird (which delivers the emails we send you, from its United States region), may process data in countries other than yours, including the United States. Where data leaves the EEA, the United Kingdom, Switzerland or another jurisdiction with transfer rules, we rely on an adequacy decision or on appropriate safeguards such as the European Commission's Standard Contractual Clauses (and the UK Addendum/IDTA), together with supplementary measures where needed. Health data stored in our primary database stays in the European Union (Frankfurt, Germany). You can request a copy of the relevant safeguards at privacy@khatawaat.com.
9. Third-party services we use
| Service | Provider | What it does for the Service | Data it processes | Provider privacy policy |
|---|---|---|---|---|
| Firebase Authentication (including Google Sign-In) | Google LLC | Creates and verifies your account, issues sign-in tokens, handles password resets | Email, password hash (held by Google), Google profile data if you use Google Sign-In, sign-in timestamps, IP address, device identifiers | [Google Privacy Policy URL] |
| Firebase Cloud Messaging | Google LLC | Delivers push notifications | Device push token, notification payloads (no weight values) | as above |
| Firebase Analytics (Google Analytics for Firebase) | Google LLC | Pseudonymous usage statistics in the apps and on the website (screens viewed, feature use) and, on the website, error reports — only with your consent | App-instance identifier, device and OS details, coarse region, event names and enumerated event values (e.g. goal direction, level range); error type and screen for website error reports; no health values, names or e-mail addresses | as above |
| Firebase Crashlytics | Google LLC | Crash reports from the mobile apps — only with your consent | Crash stack traces, device state, app version, app-instance identifier; no health values | as above |
| Database (PostgreSQL) | Neon, Inc. (Databricks), the European Union (Frankfurt, Germany) | Stores your account, health, gamification and social data, encrypted at rest | All categories in Section 3 | [Provider Privacy Policy URL] |
| API hosting | Render Services, Inc., the European Union (Frankfurt, Germany) | Runs our servers | All categories pass through; server logs (IP address, request identifiers) | [Provider Privacy Policy URL] |
| Web hosting and edge cache | Cloudflare, Inc. | Serves the website and the web app and briefly caches some responses at the edge; protects our staff console (Cloudflare Access, staff sign-in only) | IP address, request logs | [Provider Privacy Policy URL] |
| Bot protection (Cloudflare Turnstile) | Cloudflare, Inc. | Checks that sign-ups and reports made on the website come from a person, not a bot | IP address, browser and device signals used for the check | [Provider Privacy Policy URL] |
| Backup storage (Cloudflare R2) | Cloudflare, Inc. | Stores encrypted backups of our database (Section 10) | All categories in Section 3, encrypted | [Provider Privacy Policy URL] |
| Media storage and delivery | Cloudinary Ltd. | Stores and serves progress photos and avatars; photos are uploaded directly from your device after blurring, resizing and metadata stripping | Photos (blurred), upload and access logs | [Cloudinary Privacy Policy URL] |
| Email (our mailboxes) | Apple Inc. (iCloud+) | Hosts our khatawaat.com mailboxes (support@, privacy@, legal@, abuse@, appeals@) and so receives the e-mails you send us | Your e-mail address, message content and attachments | [Apple Privacy Policy URL] |
| Email delivery | Bird B.V. (Amsterdam, the Netherlands), using its United States region | Sends account and security emails (password reset, email verification, a one-time welcome email, the notices before an inactive account is deleted, account-deletion confirmation) and, only if you opt in, tips & product news; open and click tracking are off. Bird tells us when you unsubscribe through it or mark one of our emails as spam (we then turn tips & product news off in your settings) and when an address permanently bounces (we then stop sending it tips & product news) | Email address, language, message content (including one-time links and your personal unsubscribe link), delivery logs | [Bird Privacy Policy URL] |
| App stores | Apple Inc., Google LLC | Distribute the apps; handle any in-app purchases | Governed by their own terms; we receive no card details | — |
Health Connect and Apple Health are stores on your own phone (provided by Google and Apple) where you and your apps keep health data. Our app reads from them only with your permission (Section 5a); they are not our processors, and the data reaches our servers only as the daily totals our app sends.
We review our processors for security and data-protection compliance and keep this list current. Analytics and crash reporting are off until you turn them on (Section 13). Errors on our own servers are recorded only in our server logs (see API hosting above).
10. Retention
| Data | Kept for | Then |
|---|---|---|
| Account, health, gamification and social data | As long as your account is active | Deleted according to Section 11 when you delete your account |
| Deleted individual items (a weigh-in, a photo, a post) | Removed immediately from the Service | Purged from storage within [Photo Purge Window]; from backups within [Backup Retention] |
| In-app notifications (the inbox) | 90 days | Deleted |
| Encrypted backups | Rolling [Backup Retention, e.g. 30 days] | Overwritten |
| Server and security logs | [Log Retention, e.g. 90 days] | Deleted or anonymised |
| Crash and analytics data | As set by the provider, up to [Analytics Retention, e.g. 14 months] | Deleted |
| Abuse, fraud and ban records | Up to [Abuse Record Retention, e.g. 2 years] after the event, in minimised form (identifier, reason, date) | Deleted — kept longer only if needed for legal claims |
| Support correspondence | [Support Retention, e.g. 2 years] | Deleted |
| Health data synced from your phone (daily totals, Section 5a) | While you stay connected and your account exists | Deleted immediately when you disconnect or delete your account; from backups within [Backup Retention] |
| Records of the tips & product news emails sent to you (which email, when, delivery status) | As long as your account exists | Deleted with your account (Section 11) |
| Records of your consents | For as long as the account exists plus the applicable limitation period | Deleted |
| Aggregated, anonymous statistics | Indefinitely | — (not personal data) |
| Inactive accounts | After 24 months without a sign-in we email you twice — 30 days and again 7 days before — and then delete the account; signing in at any point keeps it. If a notice cannot be sent in time, the deletion waits until 30 days after the first and 7 days after the second | As Section 11 (the confirmation email says the account was deleted for inactivity) |
11. Right to erasure: deleting your account and all your data
You can permanently delete your account and wipe your personal data from our servers at any time, free of charge, without contacting support:
In the app: Profile → Settings → Account → Delete account, then sign in again to confirm (we require a fresh sign-in within the last 10 minutes for this action). On the web: https://khatawaat.com /account/delete, or Settings → Account → Delete account. By email: write to privacy@khatawaat.com from the address registered to your account; we will verify your identity and complete the deletion. If you can no longer sign in: use Forgot password first, or email us; we may ask for proof of identity to protect your data from being deleted by someone else.
What happens next
Deletion is immediate and cannot be undone — export your data first if you want a copy.
- Immediately: your account is deactivated and your sign-in identity (including your record in Firebase Authentication) is deleted, so nobody can sign in to it again. Your email address, display name and avatar are removed from our database, your profile, photos, posts, comments and leaderboard entries disappear from the Service, and push notifications stop. Health data synced from your phone (Section 5a) and the connection are deleted at once, without waiting for the purge below.
- Within [Purge Window, e.g. 30 days] we permanently delete everything else: demographic and health data, every weigh-in and derived metric, progress photos (purged from our media provider), posts, comments, reactions and challenge check-ins, XP, badges, streaks and circle memberships, device tokens, preferences and support tickets linked to your account.
- Backups holding your data are overwritten within [Backup Retention], and photos are purged from delivery caches within [Photo Purge Window].
- We send a confirmation to your email address and then delete the address itself.
What may remain
- Aggregated statistics that cannot identify you (for example circle totals and anonymous trends).
- Comments other members wrote on their own posts referring to your (now deleted) content are not deleted, but your name and avatar are replaced by "Deleted member" wherever your identity was shown.
- Minimal records we must keep to comply with the law or to defend legal claims — for example a record that a banned account was deleted, or proof that we honoured your deletion request — kept in minimised form for the periods in Section 10.
- Data that other members copied or screenshotted while your Content was visible to them.
Deleting the app from your phone does not delete your account; please use the steps above.
12. Your rights
Depending on where you live, you have some or all of the following rights, which you can exercise in the app, on the web or by writing to privacy@khatawaat.com:
- Access — obtain a copy of the personal data we hold about you.
- Rectification — correct inaccurate data (most data can be edited directly in Profile).
- Erasure — delete individual data (weigh-ins, photos, posts) or your whole account (Section 11).
- Restriction — ask us to pause processing while a dispute is resolved.
- Portability — receive your weigh-in history, synced health data, metrics, posts and gamification data in a machine-readable format (JSON/CSV export under Settings → Account → Export my data).
- Objection — object to processing based on legitimate interests, including analytics.
- Withdraw consent — at any time, without affecting processing that already took place. Withdrawing consent to health-data processing triggers account deletion; withdrawing consent to syncing health data from your phone (disconnecting) deletes the synced data and keeps your account; withdrawing consent to notifications or analytics only turns those off.
- Not to be subject to solely automated decisions with legal or similarly significant effects (we make none).
- Complain to a supervisory authority: [Supervisory Authority Name and URL] in your country, or any EEA authority if you are in the EEA.
We respond within one month (extendable by two months for complex requests, in which case we will tell you), free of charge unless requests are manifestly unfounded or excessive. We may ask you to verify your identity. We will not discriminate against you for exercising your rights.
13. Cookies, local storage and analytics choices
The web app uses strictly necessary cookies and local storage only: a sign-in hint cookie, your language choice and session state. Firebase Analytics is not loaded on the website until you turn on Usage analytics under Settings → Privacy; website error reports are sent through it only when Crash reports is on as well. You can change either choice at any time, and turning one off stops that collection straight away. We honour Global Privacy Control signals where the law requires.
The mobile apps store a cache of your profile, weigh-in history and queued offline weigh-ins on your device so the app works without a connection; this data is protected by the operating system's sandbox and, for session secrets, by the device keychain/keystore. Analytics (Firebase Analytics) and crash reporting (Firebase Crashlytics) are off until you turn them on under Settings → Privacy, and can be turned off there again at any time. We do not track you across other companies' apps, so iOS does not ask for App Tracking Transparency permission.
14. Notifications
Push notifications and emails about streaks, level-ups, milestones, circle activity and challenges are optional and can be turned off per category under Settings → Notifications or in your device settings. We will still send essential account and security messages (for example a password reset you requested, an email-address verification, a one-time welcome email when you create your account, the two notices before we delete an account that has not been used for 24 months (Section 10), the confirmation that your account was deleted, or a notice of a data breach).
Tips & product news by email are sent only if you turn them on (Settings → Privacy). They include, at most once a month, a short note when you have not used Khatawaat for two weeks ("Your circle is still here"), which mentions your circle, level and best streak — never your weight. Every such email has a one-click unsubscribe link; unsubscribing turns the option off in your settings too. We do not track whether you open these emails or click their links.
Every notification is also kept in the in-app inbox for 90 days, including those whose push you turned off. Notifications never contain your weight. We do not send pushes between 11 pm and 7 am in your time zone, except the evening streak reminder. Share images (for a level, badge, streak or circle) are made on your device and only leave it if you share them; your weight appears on them only if you switch on Include my progress for that image.
15. Children
The Service is intended for adults. You must be at least 18 years old to create an account, and we do not knowingly collect personal data from anyone younger. Weight-loss tools are not appropriate for children and adolescents without medical supervision. If you believe a child has created an account, contact privacy@khatawaat.com and we will delete it promptly. Photos of children are prohibited in the Service.
16. Regional disclosures
European Economic Area, United Kingdom and Switzerland. The legal bases above apply (GDPR / UK GDPR / FADP). Our representative for data-protection matters is [EU Representative] / [UK Representative]. You may lodge a complaint with your local supervisory authority.
United Arab Emirates. We process personal data in accordance with Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data and treat health data as sensitive data requiring explicit consent. Where the UAE health data law (Federal Law No. 2 of 2019 and its implementing resolutions) applies to data we process about members in the UAE, health data is stored and processed within the UAE at [UAE Hosting Region] unless an exemption applies. [Counsel to confirm applicability and hosting approach before launch.]
Kingdom of Saudi Arabia. We comply with the Personal Data Protection Law (Royal Decree M/19) and its Implementing Regulations, including the rules on sensitive data and cross-border transfer. [KSA Hosting / Transfer Statement].
Egypt. We comply with Law No. 151 of 2020 on the Protection of Personal Data, including the licensing and sensitive-data requirements that apply to health data. [Egypt Statement].
California (CCPA/CPRA). We do not "sell" or "share" personal information as defined by the CCPA and have not done so in the past 12 months. You have the rights to know, delete, correct, limit the use of sensitive personal information and to non-discrimination; exercise them as described in Section 12. Authorised agents may act for you with written permission.
Other regions. Where your local law grants rights beyond those listed above, we will honour them. Contact privacy@khatawaat.com.
17. Security
We protect personal data with technical and organisational measures appropriate to its sensitivity, including: TLS for all connections; encryption at rest for databases, backups and photo storage; token-based authentication with short-lived credentials verified on every request; role-based access with multi-factor authentication for staff; network isolation and least-privilege service accounts; dependency and vulnerability monitoring; audit logging of administrative access; secure development practices and code review; and an incident-response plan. No system is perfectly secure. If a breach affects your data in a way likely to put your rights at risk, we will notify you and the competent authority without undue delay and, where the law sets a deadline (for example 72 hours under the GDPR), within it.
18. Changes to this Policy
We may update this Policy to reflect changes in the Service or the law. We will post the new version with a new effective date and, for material changes — especially any change in how health data or photos are used — we will ask for your renewed consent in the app before the change applies to you. Earlier versions are available on request.
19. Contact
[Company Legal Name] [Company Address] Privacy requests: privacy@khatawaat.com · General support: support@khatawaat.com · Safety reports: abuse@khatawaat.com Data Protection Officer (if appointed): [DPO Name / Email]
This Policy is provided in English and Arabic. In case of conflict, the [Prevailing Language] version prevails, except where the law of your country requires otherwise. See also the Terms of Service and the Medical & Health Disclaimer.