Privacy Policy

1. Who We Are and Scope of This Policy

Klaim operates a promotions platform where brands ("Vendors") create discount codes ("Codes") that End Users can claim through the App, redeem in-store or online, and then post about on the App to potentially earn an additional Code from the same brand. This Policy covers the Android app, any iOS or web version of Klaim, and our backend systems that support these features.

This Policy is intended to comply with applicable data protection laws, including but not limited to the EU/UK General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA/CPRA), and Google Play's User Data policy and Developer Program Policies. Where local law grants you additional or different rights than described here, that law controls.

2. Information We Collect

2.1 Information You Provide Directly

From End Users:

• Full name
• Email address
• Phone number
• Date of birth (collected at signup solely to confirm you meet our minimum age requirement of 16; see Section 10)
• Display/profile picture
• Photos or videos you choose to upload from your device's photo gallery or camera (e.g., to create a redemption post)
• Content of posts, captions, comments, and any text you submit
• Account credentials (e.g., password, or third-party sign-in tokens if you use Google/Apple/Facebook login)
• Customer support communications

From Vendors/Brands:

• Business name, contact person's name, email, and phone number
• Business address and tax/billing information (for invoicing the promotion creation fee)
• Display picture/logo
• Promotion details (discount terms, redemption rules, budget, code quantity)
• Payment method details (processed by our third-party payment processor; Klaim does not store full card numbers)

2.2 Information Collected Automatically

• Location data: With your permission, we collect precise or approximate device location (GPS, Wi-Fi, cell tower, or IP-based) to show nearby brand promotions, verify redemption at a physical store location, and detect fraudulent claims.
• Device and usage data: device model, operating system and version, unique device identifiers (such as Android Advertising ID), IP address, app version, crash logs, and general diagnostics.
• Photo gallery/camera access: we request access to your photo library or camera only when you actively choose to upload a profile picture or a redemption post image; we do not scan or access your gallery in the background.
• Code lifecycle data: every event in a Code's lifecycle — generation by the brand, issuance to a specific user, claim timestamp, redemption timestamp and location, whether a post was made afterward, and whether a follow-up Code was issued — is logged and tied to your account.
• Frequency/behavioral data: the number of times you have claimed and redeemed Codes from a specific brand, which we use to build a per-user, per-brand engagement profile.
• Cookies and similar technologies (web only): session cookies, analytics cookies, and similar identifiers used to keep you logged in and understand site usage. See Section 9.

2.3 Information from Third Parties

• If you sign in using a third-party account (e.g., Google), we receive basic profile information (name, email, profile photo) as authorized by you through that provider.
• Brands may share redemption confirmation data with us (e.g., point-of-sale confirmation that a Code was used) where they have that capability.

3. How We Use Information

We use the information described above to:

1. Operate the Services — create and manage your account, issue and track Codes, verify redemption, and enable posting.
2. Facilitate brand promotions — connect End Users to Vendor promotions and give Vendors visibility into aggregate and individual redemption activity for promotions they fund.
3. Analyze usage patterns and, in the future, train AI systems. We currently collect and accumulate code-lifecycle data (generation, claim, redemption, and post-redemption activity), user redemption frequency, and related behavioral data. At present this data is used for operating the Services, analytics, and internal reporting. We are building toward, and reserve the right to use this accumulated data in the future to train, test, and improve machine learning models — for example, to help brands self-generate promotions and to recommend more tailored discount offers to specific users based on their claim/redemption history with a given brand. We will update this Policy and, where required by law, seek any additional consent needed before any new AI-training use goes into effect.
4. Personalize offers — analyze how often you have claimed and redeemed Codes from a specific brand so that brand can choose to offer you improved discounts or targeted promotions, now or as this capability is rolled out.
5. Fraud prevention and security — detect duplicate claims, Code abuse, fake redemptions, or fraudulent posts, and enforce our Terms of Service.
6. Billing — invoice and (in the future, once an automated payment processor is introduced) charge Vendors the fixed promotion-creation fee and manage billing records.
7. Communications — respond to support requests and send essential transactional/operational messages related to your account (e.g., Code issued, redemption confirmed). We do not currently send marketing emails or push notifications. If we introduce email or push marketing in the future, we will update this Policy and provide appropriate opt-in/opt-out controls before doing so.
8. Legal compliance — comply with applicable law, respond to lawful requests from public authorities, and enforce our agreements.

4. How We Share Information

We do not sell your personal information for money. We do share information as follows:

• With Vendors/Brands: A brand can see claim and redemption data, and post content, related to its own promotions, including how many times a specific user has claimed/redeemed its own Codes, so it can decide whether to offer that user better terms in the future. Brands do not receive your data related to other brands' promotions.
• Publicly, within the App: Posts you create after redeeming a Code (including photos/videos and captions) are visible to other users of the App. Do not include sensitive personal information in your posts that you do not want visible to the Klaim community.
• With service providers: we currently use Google Firebase (hosted in the asia-south1 / Mumbai region) for authentication, database, and backend infrastructure. As we add features, we may engage additional service providers such as customer support tools, crash/analytics reporting, or a payment processor (see below), each of which will process data on our behalf under contractual confidentiality and data protection obligations.
• Payments: We do not currently use a third-party payment processor to bill Vendors; billing is handled manually/offline. When we introduce an in-app or automated payment processor (e.g., for Vendor billing), we will update this Policy to name that processor and describe how payment data is handled. Klaim will never store full card numbers.
• For legal reasons: to comply with a legal obligation, protect our rights, investigate fraud, or protect the safety of users or the public.
• Business transfers: if Klaim or Nine71Media LLC is involved in a merger, acquisition, financing, or sale of assets, your information may be transferred as part of that transaction, subject to this Policy or a policy at least as protective.
• With your consent: for any other purpose disclosed to you at the time of collection with your consent.

We do not use advertising SDKs or ad networks, and we do not share your data for third-party advertising purposes. We do not share your photo gallery contents, full contact list, or precise location history with brands beyond what is reasonably necessary to verify a redemption occurred (e.g., store-level location, not continuous tracking).

5. Vendor/Brand Responsibility and Disclaimer

Promotions, discount terms, and Codes are created and controlled entirely by the participating brand, not by Klaim. Accordingly:

• Klaim is not responsible for, and does not guarantee, the honoring of any promotion or Code by any brand. Whether a Code is accepted, honored, or redeemable is solely at the discretion and responsibility of the issuing brand.
• Klaim does not provide refunds, compensation, or reimbursement if a brand fails to honor a Code, changes promotion terms, or if a promotion is discontinued.
• Klaim charges brands a fixed fee at the time of promotion creation. In most promotions, the brand retains 100% of the proceeds from the underlying sale at the point of redemption; Klaim does not take a share of that transaction.
• Any dispute regarding a promotion, discount, or redemption must be resolved directly between the End User and the relevant brand. Klaim may, at its discretion, assist in communications but has no obligation to resolve such disputes.

This section describes our business practices and liability position and is not, by itself, a substitute for the liability and disclaimer language that should also appear in your Terms of Service.

6. Data Retention

We retain personal data for as long as your account is active and as needed to provide the Services. Code lifecycle and redemption-history data used for AI training and brand personalization purposes may be retained longer in aggregated or de-identified form, even after account deletion, unless applicable law requires deletion of underlying personal identifiers upon request (see Section 8). We retain billing and tax-related data from Vendors for the period required by applicable financial and tax laws.

7. Data Security

We use administrative, technical, and physical safeguards designed to protect your information, including encryption in transit, access controls, and regular security review of our systems. No method of transmission or storage is 100% secure, and we cannot guarantee absolute security.

8. Your Rights and Choices

Depending on your location, you may have the right to:

• Access the personal data we hold about you.
• Correct inaccurate or incomplete data.
• Delete your account and associated personal data, subject to legal retention obligations and our need to retain de-identified/aggregated data for AI training as described above.
• Object to or restrict certain processing, including profiling used to determine personalized discounts.
• Data portability, where applicable.
• Withdraw consent at any time where processing is based on consent (e.g., location access, marketing communications), without affecting the lawfulness of prior processing.
• Opt out of the sale or "sharing" of personal information for cross-context behavioral advertising, where applicable under CCPA/CPRA (Klaim does not currently sell personal information as defined by CCPA).

Device-level controls

• You can enable or disable location, camera, and photo gallery permissions at any time in your device settings.
• You can delete your account within the App or by contacting us at the email below; some data may be retained as described in Section 6.

To exercise any of these rights, contact us using the information in Section 13.

9. Cookies and Tracking Technologies (Web)

Our website uses cookies and similar technologies to:

• Keep you signed in
• Remember preferences
• Understand aggregate usage through analytics tools (e.g., Firebase Analytics)

We do not use cookies or SDKs for third-party advertising, and we do not run ad networks within the App or website. You can control cookies through your browser settings. Disabling cookies may limit some website functionality.

10. Age Requirement and Children's Privacy

The Services are intended for users aged 16 and older. To enforce this, we ask all End Users to confirm their date of birth when creating an account. If the date of birth provided indicates the user is under 16, we will not permit account creation.

We do not knowingly allow users under 16 to create an account or use the Services, and we do not knowingly collect personal information from anyone under 16 beyond the date-of-birth check itself, which is used only to confirm eligibility and is not shared with brands or other users. If we learn that a user under 16 has gained access to an account despite this check, we will delete that account and the associated data promptly.

If you become aware that a user under 16 has created an account or provided us with personal data, please contact us using the details in Section 13 so we can investigate and take appropriate action.

11. Android / Google Play Specific Disclosures

In accordance with Google Play's Developer Program Policies and Data Safety requirements:

• Permissions requested by the App: Location (approximate/precise), Camera, Photos/Media/Files (gallery), Storage, and Network/Internet access.
• Purpose of each permission: as described in Section 2 and Section 3 above — no permission is used for a purpose beyond what is disclosed in this Policy.
• Data shared with third parties: as described in Section 4. We use Google Firebase for backend infrastructure and analytics; we do not use advertising IDs for ad targeting and do not integrate third-party ad SDKs.
• Data encrypted in transit: Yes (via Firebase/Google Cloud infrastructure).
• User-initiated data deletion: Users may request account and data deletion through the App or by contacting support; see Section 8.
• Ephemeral experiences: Redemption posts, once made, are public within the App to other Klaim users, as described in Section 4.

We will maintain and update our Google Play Data Safety section to remain consistent with this Policy.

12. International Data Transfers

We currently host our backend infrastructure and database on Google Firebase, in the asia-south1 (Mumbai, India) region. As a result, your information is processed and stored in India, and may also pass through Google's global infrastructure for delivery and backup purposes, even though you and the brands you interact with may be located in the UAE or elsewhere. Where required by applicable law, we rely on appropriate safeguards (such as Google's standard contractual clauses) for these transfers. If we change hosting providers or regions, we will update this Policy accordingly.

12A. UAE Data Protection and Governing Law

Klaim is headquartered in Dubai, United Arab Emirates, and operates from in5 Tech, Dubai Internet City. As a UAE-based entity, we process personal data in accordance with UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (PDPL) and its executive regulations, in addition to any foreign laws (such as GDPR or CCPA) that may apply to specific users based on their location.

Under the PDPL, you may have rights including the right to be informed, the right to access your data, the right to request correction or erasure, the right to restrict or object to processing, and the right to data portability, subject to the exceptions set out in the PDPL. Where our processing relies on your consent (for example, location or photo access), you may withdraw that consent at any time as described in Section 8.

This Privacy Policy, and your use of the Services, is governed by the laws of the United Arab Emirates, without prejudice to any mandatory consumer or data protection rights you may have under the law of your own country of residence.

13. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or your personal data, please contact us at:

14. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or for legal, operational, or regulatory reasons. We will notify you of material changes through the App or by other reasonable means, and will update the "Last Updated" date above. Continued use of the Services after changes take effect constitutes acceptance of the revised Policy.