1. Introduction

This Privacy Policy describes how Myata Global DMCC (“Company,” “we,” “us,” “our”) collects, uses, discloses, and protects your personal data in accordance with the UAE Federal Law No. 45 of 2021 on Personal Data Protection (“Law”) and other applicable regulations. By using the loyalty program via the Myata Lounge mobile application (“App”) and/or digital loyalty cards via Google Pay Pass and/or Apple Wallet Pass (hereinafter referred to as “Digital Loyalty Cards”), you agree to the terms of this Policy. We are committed to ensuring compliance with UAE data protection requirements and international platform guidelines, such as Google Play and the App Store.

2. Types of Data Collected

2.1 Personal Data

We may collect the following categories of personal data that you provide when registering and using the App and/or Digital Loyalty Cards:

• Full name (including first name and surname)
• Phone number
• Date of birth (day, month, year)
• City and country of residence
• Order and transaction history
• Payment details related to Apple Wallet or Google Pay
• Email address

2.2 Technical Data

We may automatically collect data related to your use of the loyalty program, including:

• Device information (device model, operating system)
• IP address and log files
• Location data (with your explicit consent, granted by allowing location tracking during app usage and/or background activity)

3. Legal Bases for Data Processing

3.1 User Consent

We process your personal data based on your consent, provided when downloading the App and/or Digital Loyalty Cards, registering for the loyalty program, using the App and/or Digital Loyalty Cards, and actively participating in the loyalty program.

3.2 Necessity for Contract Performance

Processing of personal data is necessary for the performance of the user agreement, including ensuring the functionality of the loyalty program (points accrual and redemption, offers, promotions, and notification dispatch).

3.3 Legitimate Interests

In certain cases, we may process your data based on our legitimate interests, including improving the loyalty program, the App, and the conditions of Digital Loyalty Cards, analyzing user behavior to optimize the services offered, and preventing fraud.

3.4 Compliance with Legal Obligations

We may be required to process your data to fulfill obligations under UAE law, including Federal Law No. 45 of 2021 and other regulatory provisions.

4. Purposes of Data Use

4.1 Primary Purposes

Your personal data is used for:

• Managing your account and the loyalty program (points accrual and redemption)
• Providing access to personalized offers and promotions
• Communicating with you via push notifications, SMS, and email

4.2 Additional Purposes

• Analyzing app usage to improve functionality
• Conducting marketing campaigns and researching user preferences
• Protecting our legitimate interests, including preventing fraudulent activities

5. Data Sharing with Third Parties

5.1 Partners and Service Providers

We may share your data with the following third parties:

• Myata Lounge network restaurants for managing the loyalty program
• Payment systems and processors (Apple Wallet, Google Pay) for transaction processing
• Providers of marketing and analytical services for data analysis and targeted offers (in this case, anonymized data is shared)

5.2 International Data Transfers

If we transfer your data outside the UAE (for example, for cloud services or within network establishments), we ensure that the transferred data is protected in accordance with UAE law and applicable international standards.

6. Data Retention Period

6.1 Retention Period

We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected or as required by UAE law. Data collected for the loyalty program will be stored as long as you participate in the program or until your consent is revoked.

6.2 Right to Data Deletion

You have the right to request the deletion of your personal data if further processing is no longer necessary for fulfilling obligations or complying with legal requirements. To request deletion, please send an email with the subject “Request for Data Deletion” to notice@myata.com. After receiving a deletion request, we will delete your data within 30 calendar days unless otherwise required by UAE law.

7. User Rights

You have the following rights regarding your personal data, as provided under Federal Law No. 45 of 2021:

• Right to access your data
• Right to correct inaccurate data
• Right to deletion (where permitted by law)
• Right to restrict data processing
• Right to data portability
• Right to object to data processing for marketing purposes

To exercise your rights, you may submit a request to notice@myata.com.

8. Data Security

We apply modern technical and organizational security measures to protect your data from unauthorized access, alteration, disclosure, or destruction. This includes encryption, secure servers, and access controls. All transactions via Apple Wallet and Google Pay are protected by the security standards of these platforms.

9. Policy Changes

We reserve the right to modify this Policy at any time. We will notify you of any changes via the App or email. By continuing to use the loyalty program, the App, or Digital Loyalty Cards after the changes take effect, you consent to the updated terms.

10. Contact Information

If you have any questions regarding this Privacy Policy or the processing of your data, you can contact us via email at notice@myata.com.