Tswrni Privacy Policy

First: Introduction

Your use of the Tswrni application and the provision of your personal information to us constitutes your consent to the terms outlined in this privacy policy. References to “the Company,” “we,” or “Tswrni” represent Lahza for Electronic Marketing Company, located at (Kingdom of Saudi Arabia – Riyadh), with Commercial Registration No. 1010980811, Chamber of Commerce No. 902623, and E-Commerce Authentication Certificate No. 0000097671 issued by the Saudi Business Center, referred to as “Tswrni.” The terms “you” or “the user” represent any person using the “Tswrni” application. If you do not agree to these terms, you must stop using the application.

By using the Tswrni application and website, you express complete confidence in Tswrni’s ability to protect the privacy of your personal information, and we are committed to maintaining that trust. This begins by helping you understand the privacy practices applied at Tswrni. Tswrni’s privacy principles form the foundation for how we handle privacy. This notice explains the personal data (“data”) we collect, how it is used and shared, and the choices available regarding this data. We recommend reading this policy along with the Privacy Overview, which covers the key points of our privacy practices.

Privacy Overview

At Tswrni, we handle data with care and privacy. Responsible data management is a fundamental requirement for continuous innovation. We value personal data as users expect, maintain its accuracy and integrity, and dispose of or delete it when it is no longer needed, recognizing the importance of personal data to customers and users. This improves the quality of our services, builds and strengthens user trust, and distinguishes our service from others.

We provide privacy in our services and products from start to finish. Privacy is a critical component in creating high-quality services, from inception to launch and beyond. Conducting privacy reviews on new and updated products, technologies, and services ensures an exceptional user experience. We collect only the data we need to use, aligning with our goals and values when collecting, using, or analyzing personal data. We collect personal data only to the extent necessary and use it for approved and lawful purposes.

Transparency Regarding Data Practices

We are transparent about the personal data we collect, how it is used, and how it is shared. We are committed to following this approach.

Providing Users with Choices Regarding Their Data

We provide users with clear choices regarding their privacy and easy-to-use controls to manage their data.

Maintaining the Security of Personal Data

We provide responsible and appropriate protection methods to prevent the loss, unauthorized use, or disclosure of personal data.

Second: Overview

Scope

This notice applies to users of Tswrni services in the Kingdom of Saudi Arabia, including users of applications, websites, features, and other services affiliated with Tswrni. This notice explains how Tswrni and its affiliates collect and use data. It applies to all Tswrni users in the Kingdom of Saudi Arabia, even if they use a service with a separate privacy notice. Specifically, this notice applies to:

• Customers: Individuals who request or receive photography, cinematography, drone, or related services through their Tswrni accounts.
• Photographers: Individuals who provide photography services to customers independently or through partner photography companies.
• Photography Partners: Individuals or entities (such as individuals, companies, or institutions) who provide photography services directly or indirectly.
• Guest Users: Individuals who receive photography services requested by other Tswrni account holders, including those arranged by customers (referred to as institutional customers), friends, family members, or other account holders.

All individuals addressed by this notice are referred to as (Users).

This notice also governs Tswrni’s collection of other data related to the services it provides. For example, we may collect contact information for commercial stores or other shops, contact information for individuals managing accounts owned by “institutional and corporate customers,” or data from individuals who begin applying to join as photographers or photography partners. Tswrni’s privacy practices comply with applicable laws in the regions where we offer our services. This means we engage in the practices described in this notice in a specific country or region only if permitted by the applicable laws in those regions. Additionally, please note the following:

For users in Saudi Arabia:

The Communications and Information Technology Commission is the regulatory authority responsible for protecting personal data in the Kingdom of Saudi Arabia. The Personal Data Protection System (Saudi Data and Artificial Intelligence Authority) in the Kingdom of Saudi Arabia requires Tswrni to obtain user consent before collecting or using their personal information. The Saudi Data and Artificial Intelligence Authority grants users the right to access, correct, or delete their personal information. Tswrni must obtain user consent before collecting or using their personal information, which may be explicit or implicit. Tswrni must also take steps to protect personal information from unauthorized access, use, or disclosure, including using encryption and other security technologies. Tswrni must grant users the right to access, correct, or delete their personal information. Please contact us here or through the addresses listed below if you have inquiries regarding our practices in a specific country or region.

Data Controllers and Data Transfer

Tswrni is the data controller for data collected in connection with the use of Tswrni services in the Kingdom of Saudi Arabia. The Tswrni website is the data controller for data collected in connection with the use of Tswrni services elsewhere. Tswrni manages the collection, analysis, and administration of personal data globally, enabling us to use it to provide a seamless experience for you wherever you travel. We are committed to protecting your data rights, whether you are in your home country or elsewhere. This means we may transfer your personal data to countries other than your home country to provide our services in another country upon your request. We may also transfer your personal data to another location if required to respond to a request you send to our customer support service from outside your country. Users may also access their records and requests in another country after leaving the country where the services were provided. Since multiple users may use our services simultaneously, another user in a different country may have access to only a limited amount of personal data. We take these measures to fulfill our agreements with all users of our services, based on users’ instructions or prior consents, adequacy decisions in relevant countries, or other data transfer mechanisms that may apply under applicable law. Tswrni applies strict internal procedures to handle any requests for personal information. Tswrni does not disclose personal data to third parties except in a manner consistent with the regulatory requirements of applicable laws.

To provide an adequate level of data protection, Tswrni uses the following measures:

We have established policies and procedures to restrict access to personal data and limit its use to specific purposes. We have provided specialized training for employees responsible for managing personal data. We have formulated a policy that prohibits third-party access to data unless disclosure is mandatory under applicable laws, there is an imminent risk of significant harm to individuals, or consent has been obtained. We use robust methods to protect data during transfer between Tswrni applications and our servers and when using data on our servers, such as data encryption and pseudonymization to help protect users’ full identities and prevent unauthorized disclosure. To simplify the process, you can direct any requests to exercise your data protection rights to Tswrni through any of the specified channels mentioned above, and they will be handled on behalf of the relevant controller. You can send inquiries, comments, and complaints about Tswrni’s data collection and use practices here. You can also use this form to send an inquiry to Tswrni’s data protection officer and request a copy of the standard contractual clauses or other data transfer mechanisms applied in the context of your data use inquiry. We take appropriate steps to ensure data privacy and security, including through various hardware and software methodologies. However, Tswrni cannot guarantee the security of any information disclosed online. Tswrni is not responsible for the privacy policies of linked websites. If you provide any information to these third parties, different rules regarding the collection and use of your personal information may apply. You should contact these entities directly if you have any questions about their use of the information they collect.

Third: Data Collection and Use Policies

Data We Collect

Tswrni collects the following data:

• Data provided by users to Tswrni, such as information entered during account creation.
• Data generated during the use of our services, such as location data, application usage data, and device data.
• Data from other sources, such as other users or account holders, business partners, vendors, insurance and financial solution providers, and government entities.

Tswrni collects the following data:

Data provided by users includes the following:

User Profile Information: We collect data from users when they create or update their Tswrni accounts or place orders through payment completion features. This may include the user’s name, email address, phone number, login name and password, address, profile picture, payment or banking information (including related payment verification information), and other documents issued by government entities (which may include registration date, gender, and profile picture). This also includes information about photography equipment, emergency contact information, and user settings to provide services through the Tswrni application.

Background Check Information (Photographers and Photography Partners): This includes information submitted during the application process to join Tswrni’s photography service, such as a photographer’s work history, previous experience (as permitted by law), photography license status, known aliases, previous addresses, and work eligibility. This information may be collected by an approved vendor on behalf of Tswrni.

Demographic Data: We may collect demographic data about users, such as date of birth, age, gender, or occupation, when necessary for certain services or programs at Tswrni. We may also collect demographic data, such as age group, from user surveys and use this information to promote Tswrni’s products and services. We may also infer demographic data from other collected user data. For example, we may infer a user’s gender based on their first name to enable features like the “preference for female photographers” or to display personalized advertisements for external products or services. Please refer to the section titled “How Tswrni Uses Personal Data.”

User Content: We collect data submitted by users when they contact Tswrni’s customer support service (including at Tswrni registration offices, via phone calls, or video conferencing tools), provide ratings or feedback for other users, partners, or stores, or communicate with Tswrni in any other form. This may include photographs, audio recordings, or video recordings submitted by users in the context of customer support requests. This also includes metadata related to the method used to communicate with Tswrni. Note that the content of images and recordings submitted by users is included.

Other Information: We collect order itinerary information, including order dates, times, and arrival times, to facilitate coordination.

Data generated during the use of our services includes the following:

Location Data (Photographers): We collect precise or approximate location data from photographers’ mobile devices when the Tswrni application is running in the foreground (when the app is open and visible on the screen) or in the background (when the app is open but not visible on the screen).

Location Data (Customers): We collect precise or approximate location data from customers’ and order recipients’ mobile devices when they allow us to do so through their device settings. Tswrni collects this data from the time a service is requested until completion and at any time the application is running in the foreground (when the app is open and visible on the screen). This enables customers and service recipients to allow the collection of precise location data. Customers and order recipients may use Tswrni applications without enabling location data collection from their mobile devices. However, this may affect certain features in Tswrni applications. For example, customers must enable precise location data collection to enter a meeting address. Additionally, precise location data collected from photographers’ and customers’ devices (Users) during a service is linked to the customer’s account, even if the customer has not allowed precise location data collection from their device. This data is used for purposes such as issuing receipts, customer support, monitoring fraudulent activities, insurance coverage, and litigation procedures.

Transaction Information: We collect transaction information related to the use of our services, including the type of services requested or provided, order details (such as date, time, meeting addresses, arrival time for providing the requested service, distance traveled, and requested items), and payment transaction information (such as the name and location of the hotel or store, the amount paid, and the payment method). We also link the user’s name to any person using promotional rewards or coupons provided to them.

Usage Data: We collect data about how users interact with our services. This includes access dates and times, application features or pages viewed, browser type, application crashes, and other system activities.

Device Data: We collect data about devices used to access our services, including device models, device IP address or other unique device identifiers, operating systems and versions, software, preferred languages, advertising identifiers, device motion data, and mobile network data.

Communication Data: We collect data related to phone calls, text messages, or in-app communications between users when enabled through Tswrni applications. This includes the date, time, and content of text messages or in-app messages. We may also collect the content of phone calls only when users are informed in advance of the possibility of call recording.

Data from other sources includes the following:

• Users participating in referral programs. For example, if a user invites another person, we receive the invited person’s data from that user.
• Tswrni account holders who request services on behalf of or for other users (such as friends or family members) or who allow other users to request or receive services through their business accounts.
• Users or other individuals providing information related to claims or disputes.
• Tswrni business partners through whom users use or create their Tswrni accounts, such as payment service providers, social media services, or applications or websites that use Tswrni’s APIs or whose APIs Tswrni uses.
• Tswrni partners in connection with debit or credit cards issued by a financial institution partnered with Tswrni, to the extent disclosed in the card’s terms and conditions.
• Vendors who assist us in verifying users’ identities, criminal background information, work eligibility, or who screen users for sanctions, anti-money laundering, or know-your-customer requirements.
• Insurance service providers, other intermediaries, or financial services.
• Partner photography companies (for photographers or photography partners using our services through an account linked to a similar company).
• Publicly available sources.
• Marketing partners and service providers, including banks related to cashback programs and data distributors.
• Government entities.

How Tswrni Uses Personal Data

Tswrni uses data to provide photography services and other services and products conveniently and securely. We also use this data:

• To enhance user safety and the security of the services we provide.
• To provide customer support.
• To conduct research and development.
• To facilitate communication between users.
• For marketing and advertising.
• To send non-marketing communications to users.
• In connection with legal proceedings.

We use the data we collect for the following:

Tswrni uses data to deliver, personalize, maintain, and improve our services. This includes using data for:

• Creating/updating accounts.
• Enabling photographer location services and customer order locations, as well as other services and features, such as using location data to navigate to order locations, calculate estimated execution times, and track estimated time, number of days, and types of requested orders.
• Features involving data sharing, such as sharing the photographer’s first and last name and photography equipment information through order notes with customers to facilitate meetings, as well as photographers’ profiles and order details to share estimated arrival times, user ratings, and positive feedback.
• Matching available photographers with users requesting services based on availability, proximity, user preference settings, and other factors, such as the likelihood of accepting an order based on previous behaviors or preferences.
• Features involving account linking, such as linking an email to create an itinerary or linking rewards programs to activate partnership benefits.
• Enabling a dynamic pricing system (supply and demand) based on factors like time, estimated distance, number of photographers, service days, equipment, expected routes, traffic, and the current number of users requesting services.
• Allowing customers to set a budget to receive optional photographer offers, enabling the customer to determine the appropriate price electronically.
• Processing payments. If you pay for our products or services on our website, details will be requested and provided directly to our payment provider via a secure connection. The merchant will not pass any debit/credit card details to third parties.
• Customizing user accounts, such as offering personalized location suggestions for order recipients based on their previous orders.
• Facilitating insurance coverage solutions, transportation, invoicing, or other solutions.
• Providing users with updates on orders or photography processes, generating receipts, and notifying them of changes to terms, services, or policies.
• Performing necessary operations to maintain our services, including troubleshooting software and operational issues.

Tswrni performs the above activities on the basis that they are necessary to fulfill our agreements with users, are compatible with users, or are necessary to achieve Tswrni’s and its users’ legitimate interests.

Safety and Security: We use data to help maintain the safety and security of our services and users. This includes:

• Verifying users and their eligibility to provide photography services, including through reviews of business and experience checks, to prevent unqualified or dangerous photographers or customers from using our services. This may involve real-time user verification features at Tswrni, which we may also use for other verification purposes, such as verifying changes to bank account information or restoring account access.
• Using image recognition technology in user profile photos, cinematic videos, or other user-provided methods to prevent unauthorized use of non-representative work.
• Using device, location, profile, usage, and other data to prevent, detect, and combat other types of fraudulent activities, such as identifying fraudulent accounts or service uses, preventing unauthorized photographers or photography partners from using our services, verifying users for specific payment methods, and preventing and combating unauthorized account access.
• In cases where a user misuses Tswrni’s referral program or submits fraudulent documents, such behavior may lead to automatic account suspension.
• Using user ratings, reported incidents, and other feedback to encourage compliance and as justification for suspending accounts of users with low ratings or who violate these guidelines in other ways in specific countries. Such suspensions occur only after human review or the provision of an appeal option.
• Using photographer data (e.g., previous order information and reported error rates) and customer data (e.g., previous order information, cancellation and objection rates, account information, ratings, and current meeting location and objection) to predict user matches that may increase the risk of conflict and help avoid them (e.g., if one user previously gave another a one-star rating).
• Sharing the user’s name, location, phone number, photography equipment details, and other relevant information to support the management and mitigation of personal disputes that may arise between users during photography or other services.

Customs and traditions vary across different communities, reflecting differences in history, environment, and values. Users should consider that some requests may be restricted by customs, traditions, and values (e.g., a user requesting a female photographer for a men’s wedding section or a male photographer for a women’s wedding event). Such requests may cause misunderstanding and embarrassment for all parties. Consider how your request may affect others. Is it likely to cause embarrassment or discomfort? If so, consider modifying your request, as it may be deemed inappropriate and unacceptable.

Customer Support: Tswrni uses the information we collect (which may include call recordings) to provide customer support, including troubleshooting user issues, resolving them, and monitoring and improving customer support team responses and operations.

Research and Development: We use data for testing, research, analysis, product development, and machine learning to improve user experiences. This helps make our services more suitable for a larger number of users, easier to use, safer, and enables the development of new services and features.

Facilitating User Communication: For example, a photographer may contact a customer after payment completion via in-app chat to confirm the meeting location, and customers may contact photographers via in-app chat to inquire about orders or obtain order information.

Marketing and Advertising: Tswrni uses data to market its services and those of Tswrni partners. This may include sending emails, text messages, push notifications, in-app messages, or other marketing or advertising communications about Tswrni’s products, services, features, special offers, promotions, contests, news, and events. This may involve using location, previous order and distance history, device data, and usage data to send personalized marketing messages based on observed or inferred user interests and characteristics. For example, we may send push notifications about users’ preferred destinations or locations or in-app messages offering discounts or promotions for products or items similar to those previously ordered. We also display Tswrni advertisements on external applications or websites, using location, previous order and distance history, device data, usage data, and sharing email addresses or device/user identifiers with advertising partners (e.g., Facebook, TikTok, etc.) to personalize these ads based on user interests. We display external advertisements within the Tswrni application or in the context of providing our services, including advertisements for restaurants or stores available in Tswrni. These advertisements (referred to as “sponsored ads” in the Tswrni app) include recommendations personalized based on users’ locations and previous order history. This also includes advertisements for other external products or services personalized based on observed or inferred user interests and characteristics, determined using data such as approximate location, order and distance details and history, usage data, demographic data (which may include inferred gender data), and device or user identifiers. This also includes advertisements personalized based on data related to the current trip or photography order, including order time and requested services. For example, if a user requests photography at a store, we may display in-app advertisements for external products potentially available at that store. We measure the effectiveness of Tswrni advertisements and external advertisements displayed in the Tswrni application or in the context of providing our services.

Non-Marketing Communications: Tswrni may use data to send surveys and other non-marketing communications that do not aim to market Tswrni’s or its partners’ services or products. We may also notify users about suggestions, polls, and other processes related to our services. For example, Tswrni sent an email notification to some users regarding proposed measures or legislation related to Tswrni services in their regions.

Legal Proceedings and Requirements: We may use data to investigate or resolve claims or disputes related to the use of Tswrni services, comply with applicable laws, regulations, operating licenses, or agreements, or in accordance with legal proceedings or government requests. Tswrni performs the above activities on the basis that they are necessary to fulfill our agreements with users, for Tswrni’s and its users’ legitimate safety and security interests, such as monitoring and improving customer support services, developing and improving services and new features, informing users about Tswrni’s services and features or those provided by Tswrni, and responding to them, as necessary to comply with applicable legal requirements.

Cookies

Tswrni and its partners use cookies and other identification technologies on applications, websites, emails, and online advertisements for the purposes described in this notice and Tswrni’s Cookie Notice. Cookies are small text files stored on browsers or devices by websites, applications, online media, and advertisements. Tswrni uses cookies and similar technologies for purposes such as authenticating users, user preferences and settings, determining content popularity, displaying advertising campaigns and measuring their effectiveness, analyzing site usage and trends, and understanding the general behaviors and interests of individuals interacting with our online services. We may also allow others to provide analytics and audience measurement services, display advertisements on our behalf online, and track and report on their performance. These entities may use cookies, web beacons, software development kits (SDKs), and other technologies to identify devices used by visitors to our sites, as well as when visiting other online sites and services. Please refer to the Cookie Notice for more information about the use of cookies and other technologies described below.

Cookie Notice

Tswrni and its third-party partners use “cookies” and other tracking technologies (collectively referred to as “tracking technologies”), including third-party tracking technologies, on Tswrni’s website, applications, email communications, advertisements, and other online services (collectively referred to as “online properties”). We use these features to enable, enhance, personalize, and analyze Tswrni’s services and online properties, as well as for advertising purposes. This notice describes the tracking technologies we and our partners use, how they are used, and your choices regarding these tracking technologies. For more information about personal data collection and use at Tswrni, please refer to the relevant sections.

Information Sharing and Disclosure

All credit/debit card details and personally identifiable information will not be stored, sold, shared, rented, or leased to any third parties. The merchant will not pass any debit/credit card details to third parties. Some Tswrni services and features require sharing data with other users or at the user’s request. We may also share this data with our affiliates, subsidiaries, and partners for legal reasons or in connection with claims or disputes.

Tswrni may share data:

With other users, including the following:

• The customer’s first name, rating, and meeting locations with photographers or their locations.
• The first name of order users, photography location address, and order information with hotels or users for photography and order services.
• For users or stores, partners, or as may be permitted by law, we may also share ratings, comments, or other information with hotels or users for photography services.
• Li photographers or users, we may share user data with photographers, order users, hotels, or users, including the user’s name and photograph; user type, photography equipment supplier, manufacturer, order, and photograph; location (before and during arrival); average rating provided by users, total number of orders, duration of using the Tswrni application since registering as a photographer or photography partner, contact information, and photographer or photography partner user, including positive feedback or comments and other users from previous users.
• We also provide photographers and order users with receipts containing information such as charged amounts, the photographer’s or photography partner’s first name, photograph, and route map. We also include other information in these receipts if required by law.
• For users participating in Tswrni’s referral program, we share some invited users’ user data, such as the number of orders, with the user who invited them, to the extent necessary to determine referral rewards.

At the user’s request, including sharing data with:

• Other individuals at the user’s request. For example, we share a user’s estimated arrival time and location with a friend at the user’s request or information about a user’s distance when performing a service or another service.
• Tswrni partners. For example, if a user requests a service through a partnership or promotional offer provided by a third party, Tswrni may share certain information with those third parties. This may include services, platforms, applications, or other websites integrated with our APIs, tracking or service providers offering APIs or services we integrate with, or hotels, stores, or other Tswrni business partners and their users in connection with promotions, contests, or specialized services.
• Emergency services. Providing features that enable users to share their data with police, fire, and ambulance services in emergencies or after certain incidents. For more information, please refer to the sections below titled “Transparency” and “Data Sharing in Emergencies.”
• With the public. Inquiries or comments submitted by users through public forums (Tswrni blogs and Tswrni’s social media pages) may be displayed to the public, including any data included in the inquiries or comments submitted by users.
• With Tswrni account holders. If a user receives services through an account owned by a third party, including location data, with the account owner. This occurs, for example:
  • When a customer uses an employer’s Tswrni for Business profile to perform scheduled services via the app.
  • When a photographer or photography partner uses an account owned by or linked to a service provider or participating photography company for Tswrni.
  • When a customer performs a service or an order recipient receives an order arranged by a friend or within a family profile.
  • When a photography partner acts as a substitute for another photographer.
  • Additionally, if a user creates an account using an email address, for example, provided by an employer, we may use and share their profile data (such as name and email address) with the account owner to assist the user in adding photography or order costs to that Tswrni for Business account. This procedure applies to all regions.

With Tswrni affiliates and subsidiaries. We share data with affiliates and subsidiaries to assist us in providing our services or conducting data collection/use on our behalf. For example, Tswrni may collect and store this data in the Kingdom of Saudi Arabia.

With Tswrni service providers and business partners. This includes:

• Payment processing and facilitation entities.
• Providers of criminal background checks and user verification services.
• Cloud storage service providers.
• Google, in connection with the use of “Google Maps” in the Tswrni app (see Google’s Privacy Policy for information on data collection and use).
• Social media companies, including Facebook and TikTok, and other companies in connection with Tswrni’s use of their tools in Tswrni applications and websites (see Facebook’s applicable Privacy Policy and TikTok’s applicable Privacy Policy for information on how they collect and use data).
• Marketing partners and marketing platform providers, including social media advertising services, advertising networks, third-party data providers, and other service providers to reach or better understand our users and measure advertising effectiveness.
• Advertising brokers, such as Google, who assist Tswrni in displaying targeted ads for external products likely to appear in the Tswrni app and measuring their effectiveness. We share data such as ad identifiers, device IDs, email addresses, approximate location, and current or past order or distance information. Brokers use this data to provide their services, and any other purposes are disclosed in their respective privacy notices. Users may opt out of ad personalization features through the Tswrni app. For more details on these brokers’ privacy practices, including how to submit requests related to personal data processing, please refer to their linked privacy notices.
• Research partners, including those conducting surveys or research projects in partnership with or on behalf of Tswrni.
• Vendors assisting Tswrni in enhancing safety and security in its applications and services.
• Consultants, lawyers, accountants, and other professional service providers.
• Insurance and financial service providers.
• Airports.
• Third-party photography equipment providers.

In case of disputes. Tswrni may share user data if we believe it is required by applicable law, regulations, operating licenses, agreements, legal proceedings, or government requests, or when disclosure is necessary for safety or similar concerns. This includes sharing data with government agencies, airport authorities (if requested by airport authorities as a condition for operating on airport grounds), or other third parties as necessary to enforce applicable terms of service, user agreements, or other policies; to protect Tswrni’s or others’ rights, safety, or property; or in connection with claims or disputes related to the use of our services. In cases of disputes involving the use of another person’s credit card, we may be legally obligated to share your data, including trip or order information, with the credit cardholder. This also includes sharing data with others in connection with any merger, sale of company assets, consolidation, restructuring, financing, or acquisition or partial bankruptcy of our business by another company or during related negotiations.

Data Sharing. All credit/debit card details and personally identifiable information will not be stored, sold, shared, rented, or leased to any third party. Tswrni may share user data other than as described in this notice if we notify the user and obtain their consent for sharing.

Information Retention and Deletion

Tswrni retains user data for as long as necessary for the purposes described above, including providing its services and complying with legal obligations. The retention period for user data is determined by the type of data, the user category to which the data relates, and the purposes for which the data was collected. Tswrni’s retention period may be determined by legal and regulatory requirements, safety and fraud prevention purposes, or issues related to the user’s account, such as outstanding balances, pending claims, or unresolved disputes. For example:

• We retain data for the duration of users’ active accounts if the data is necessary to provide our services, such as user profile information and credentials for up to 3 years if required for tax compliance purposes.
• We retain order or execution location information for photographers and safety partners for specific periods as necessary for safety or fraud prevention purposes. For example, we retain incomplete photography partner orders for one year and rejected photography partner requests for 3 years after account deletion requests, if necessary for safety, security, fraud prevention, or legal compliance purposes, or due to account-related issues (e.g., outstanding balances, claims, or pending disputes).

Users may delete their accounts at any time. Tswrni may retain user data after a deletion request due to regulatory requirements or for the reasons stated in this policy. Users may request account deletion at any time through the “Settings” > “Privacy” menus in the Tswrni app or via the Tswrni website. After an account deletion request, Tswrni deletes the user’s account and data unless retention is required by legal or regulatory requirements, for safety and security purposes, fraud prevention, or due to account-related issues such as outstanding balances, pending claims, or unresolved disputes. In compliance with legal and regulatory requirements related to photographers, service providers, or customers, this generally means we retain user account and data for the applicable legal retention period after a deletion request. For customers and order recipients, data is generally deleted within 90 days of the deletion request, except where retention is necessary for the reasons stated above.

Fourth: Transparency

Tswrni allows users to access or control the data it collects, including through:

• Privacy settings
• Device permissions
• In-app rating pages
• Marketing preferences

Tswrni also enables users to request access to or copies of their data, make changes or updates to their accounts, request account deletion, or request that Tswrni restrict the analysis or use of their data.

Privacy Settings

The “Settings” > “Privacy” menu in the Tswrni app allows customers and order recipients to set or update their preferences regarding the collection and sharing of location data, emergency data sharing, and notifications. The Privacy Center is also available in the web version of the app.

• Location data collection (for customers and order recipients). Customers and order recipients can enable/disable Tswrni’s collection of location data from their mobile devices through their device settings, accessible via “Settings” > “Privacy” > “Location.”
• Live location sharing (customers and order recipients). Customers can enable/disable Tswrni’s sharing of real-time location data from their mobile devices with photographers through their device settings, accessible via “Settings” > “Privacy” > “Location.”
• Emergency data sharing. Photographers and customers may enable a feature allowing Tswrni to share real-time location data from their mobile devices with event organizers, police, fire, or ambulance services in emergencies or during incidents, such as when traveling to meet customers. Photographers and customers can enable/disable this feature via “Settings” > “Privacy” > “Location” or the Safety Center.
• Notifications: Account and Order Updates. Tswrni provides users with notifications about trip status and account-related updates. These notifications are essential to using the Tswrni app and cannot be disabled. However, users may choose how they receive these notifications through “Settings” > “Privacy.”
• Notifications: Discounts and News. Users may allow Tswrni to send push notifications about discounts and news from Tswrni. These push notifications can be enabled or disabled through “Settings” > “Privacy” in the Tswrni app.
• Communication from Stores and Shops after Contracting with Photographers and Photography Partners. During an order in the Tswrni app, users may consent to sharing order details and including notes between them based on specific terms and times. Subscribers may opt out of receiving or marking these services within the Tswrni app.

Device Permissions

Most mobile device platforms (e.g., iOS, Android) restrict certain types of device data from being used by apps without the device owner’s permission. These platforms have different methods for obtaining such permissions. Please check your device’s available settings or contact your service provider.

In-App Ratings

After each service, customers and photographers can rate each other on a scale from one to five stars. The average rating is linked to the user’s account and displayed to other users providing or receiving services. For example, the photographer and photography partner rating feature is available to customers requesting a service, and the customer rating feature is available to photographers and photography partners. The mutual rating system promotes accountability for behavior, fostering a respectful and safe environment for both photographers and customers. Customers can view their average rating in the main menu under the Tswrni app and access detailed rating information in the app. Photographers and photography partners can view their average rating by accessing their profile in the Tswrni app.

Marketing and Advertising

Tswrni provides users with the following choices regarding how their data is used for marketing and advertising purposes:

• Tswrni Marketing Communications: Users can choose whether to allow Tswrni to use their data to send personalized communications (e.g., emails, push notifications, in-app messages) about Tswrni’s products and services. Users can also choose whether to receive any marketing emails or push notifications from Tswrni.
• Tswrni Advertisements: Users can choose whether their data is used and shared with advertising partners to deliver personalized ads about Tswrni’s products and services on external applications and websites or to measure the effectiveness of these ads.
• Restaurant and Store Advertisements: Users can choose whether Tswrni uses their order history and search activities to display personalized ads for stores or shops available in Tswrni.
• External Advertisements: Users can choose whether Tswrni uses their data to display ads for external products or services personalized based on observed or inferred user interests and characteristics.
• Cookies and Related Technologies: For information on how to control Tswrni’s use of cookies and related technologies, including their use for displaying personalized ads, please refer to the Cookie Notice.

User Data Requests

Tswrni provides users with various methods to learn about, control, and submit inquiries and comments regarding how Tswrni uses their data.

Data Access: Users can access their data, including profile information, orders, or order history, through Tswrni applications or the Tswrni website. Users can also use the “View My Profile” feature to view an online summary of their account information, such as the number of orders, ratings, rewards status, and duration since joining Tswrni. Users may also request access to their data (customers, order recipients, photographers, and photography partners).

Data Transfer: Users may request a copy of their data in Tswrni. For an overview of available data, users may also request a copy of their data (customers, order recipients, photographers, and photography partners).

Data Updates or Changes: Users can modify their name, phone number, email address, payment method, and account photo through the Settings menu in Tswrni applications. Users may also request updates or corrections to their data (customers, order recipients, photographers, and photography partners).

Data Deletion: Users may request account deletion at any time through Tswrni’s Privacy section or via “Settings” > “Privacy” in the Tswrni app.

Objections, Restrictions, and Complaints: Users may request that we stop using all or some of their data or restrict our use of their data (customers, order recipients, photographers, and photography partners). This includes objecting to our use of data based on Tswrni’s legitimate interests. Tswrni may continue to analyze and use data after such objections or requests to the extent required or permitted by law. Additionally, users, depending on their place of residence, have the right to file a complaint regarding Tswrni’s data analysis and use with the data protection authority in their country.

Objection: Users residing in the Kingdom of Saudi Arabia may request a review of our decision if Tswrni is unable to fulfill or denies a request regarding their data. Users can submit an appeal regarding our decision.

Fifth: Updates to This Notice

We may update this notice from time to time. If significant changes are made, we will notify users in advance through the Tswrni app or other means, such as email. We encourage users to periodically review this notice for the latest information on our privacy practices. Using our services after an update constitutes consent to the updated notice, to the extent permitted by law.

Last updated: January 1, 2025