Welcome to Sanbuk’s Privacy Policy.

Sanbuk was born to give people an opportunity to explore, learn, and connect. We are building a community based on trust. A fundamental part of earning that trust means being clear about how we use your information and protect your human right to privacy.

This Privacy Policy describes how Sanbuk and its affiliates (“we,” “us,” or “Sanbuk”), process personal information that we collect through our websites, our customer app (IOS & Android), and our Provider app (IOS & Android) (“Sanbuk Platforms”). It is important that you read this Privacy Notice together with our Terms & Conditions, and Payment Terms, which apply if you purchase new products or services from our platforms.

1. DEFINITIONS

The Sanbuk Platforms offer an online venue that enables users (“Users”) to publish, offer, search for, and book services. Users who publish and offer services are “Providers” and Users who search for, book, or use services are “Guests.” Providers offer accommodations, and rentals (“Rentals”), activities, excursions, and events (“Experiences”), and a variety of travel and other services (collectively, “Provider Services,” and each Provider Service offering, a “Listing”). You must register an account to access and use many features of the Sanbuk Platform and must keep your account information accurate.

Sanbuk Platforms are operated by Sanbuk. We are registered in Kuwait under company number 444565 and have our registered office at Qibla, Block 13, Mohammed Thunayyan AlGhanim street, Tower 3, Floor 9, Office 1, Kuwait City, Kuwait.

To contact us, please email support@sanbukadventures.com.

Undefined terms in this Privacy Policy have the same definition as in our Terms & Conditions (“Terms”).

2. PERSONAL INFORMATION WE COLLECT

We only collect, process, use, share and store your personal information where we are satisfied that we have an appropriate legal basis to do this.

2.1 Information needed to use the Sanbuk Platforms.

We collect personal information about you when you use the Sanbuk Platforms. Without it, we may not be able to provide you with all services requested. This information includes:

• Contact Information, Account, Profile Information. Such as your first name, last name, phone number, postal address, email address, date of birth, and profile photo, some of which will depend on the features you use.
• Identity Verification and Payment Information. Such as images of your government issued ID (as permitted by applicable laws), your ID number or other verification information, bank account or payment account information.

2.2 Information you choose to give us.

You can choose to provide us with additional personal information. This information may include:

• Additional Profile Information. Such as gender, preferred language(s), city, and personal description. Some of this information as indicated in your account settings is part of your public profile page and will be publicly visible (if applicable)
• Address Book Contact Information. Address book contacts you import or enter manually.
• Other Information. Such as when you fill in a form, add information to your account, respond to surveys, post to community forums, participate in promotions, communicate with our customer care team and other Users, or share your experience with us. This may include health information if you choose to share it with us.

2.3 Information Automatically Collected by Using Sanbuk Platforms and our Third Party Payment Services (“Payment Services”).

When you use the Sanbuk Platforms and Payment Services, we automatically collect personal information. This information may include:

• Geo-location Information. Such as precise or approximate location determined from your IP address or mobile device’s GPS depending on your device settings. We may also collect this information when you are not using the app if you enable this through your settings or device permissions.
• Usage Information. Such as the pages or content you view, searches for Listings, bookings you have made, and other actions on the Sanbuk Platforms.
• Log Data and Device Information. Such as details about how you’ve used the Sanbuk Platforms (including if you clicked on links to third party applications), IP address, access dates and times, hardware and software information, device information, device event information, unique identifiers, crash data, cookie data, and the pages you’ve viewed or engaged with before or after using the Sanbuk Platforms. We may collect this information even if you haven’t created a Sanbuk account or logged in.
• Cookies and Similar Technologies as described in our Cookie Policy.
• Payment Transaction Information. Such as payment instrument used, date and time, payment amount, payment instrument expiration date and billing postcode, IBAN information, or other banking details, your address and other related transaction details.

2.4 Personal Information We Collect from Third Parties.

We collect personal information from other sources, such as:.

• Third-Party Services. If you link, connect, or login to the Sanbuk Platforms with a third party service (e.g. Google, Facebook, Microsoft), you direct the service to send us information such as your registration, friends list, and profile information as controlled by that service or as authorized by you via your privacy settings at that service.
• Background Information. To the extent permitted by applicable laws, we may obtain reports from public records of criminal convictions or other offenses We may use your information, including your full name and date of birth, to obtain such reports.
• Enterprise Product Invitations and Account Management. Organizations that use our Enterprise products may submit personal information to facilitate account management and invitations to use enterprise products.
• Referrals and co-travelers. If you are invited to the Sanbuk Platforms such as a co-traveler on a trip, the person who invited you can submit personal information about you such as your email address or other contact information.
• Other Sources. To the extent permitted by applicable law, we may receive additional information about you, such as references, demographic data or information to help detect fraud and safety issues from third party service providers and/or partners, and combine it with information we have about you. For example, we may receive background check results or fraud warnings from identity verification service providers for use in our fraud prevention and risk assessment efforts. We may receive information about you and your activities on and off the Sanbuk Platforms, or about your experiences and interactions from our partners. We may receive health information, including but not limited to health information related to contagious diseases.

3. HOW WE USE INFORMATION WE COLLECT

3.1 Provide, Improve, and Develop the Sanbuk Platforms. We use personal information to:

• enable you to access the Sanbuk Platforms and make and receive payments,
• enable you to communicate with other Users,
• perform analytics, debug and conduct research,
• provide customer service,
• send you messages, updates, security alerts, and account notifications,
• if you provide us with your contacts’ information such as your friends or co-travelers, we may process this information: (i) to facilitate your referral invitations, (ii) to share your trip details and facilitate trip planning, (iii) for fraud detection and prevention, and (iv) to facilitate your requests or for any other purpose you authorize,
• personalize and customize your experience based on your interactions with the Sanbuk Platforms, your search and booking history, your profile information and preferences, and other content you submit, and
• enable your use of our enterprise products.

3.2 Create and Maintain a Trusted and Safer Environment. We use personal information to:

• detect and prevent fraud, spam, abuse, security and safety incidents, and other harmful activity,
• conduct security investigations and risk assessments,
• verify or authenticate information provided by you,
• conduct checks against databases and other information sources, including background or police checks,
• comply with our legal obligations, protect the health and well-being of our Guests, Providers, Providers’ employees and members of the public,
• resolve disputes with our Users,
• enforce our agreements with third parties,
• comply with law, respond to legal requests, prevent harm and protect our rights
• enforce our Terms and other policies and
• in connection with the activities above, we may conduct profiling based on your interactions with the Sanbuk Platforms, your profile information and other content you submit to Sanbuk, and information obtained from third parties.

3.3 Provide, Personalize, Measure, and Improve our Advertising and Marketing. We may use personal information to:

• send you promotional messages, marketing, advertising, and other information based on your preferences and social media advertising through social media platforms,
• personalize, measure, and improve our advertising,
• administer referral programs, rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by Sanbuk or its third-party partners,
• analyze characteristics and preferences to send you promotional messages, marketing, advertising and other information that we think might be of interest to you, and
• invite you to events and relevant opportunities.

3.4 Provide Payment services. Personal information is used to enable or authorize third parties to use Payment Services:

• Detect and prevent money laundering, fraud, abuse, security incidents.
• Conduct security investigations and risk assessments.
• Comply with legal obligations (such as anti-money laundering regulations).
• Enforce the Payment Terms or other payment policies.
• With your consent, send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your preferences.
• Provide and improve the Payment Services.

4. SHARING & DISCLOSURE

4.1 Sharing With Your Consent or at Your Direction.

Where you provide consent, we share your information as described at the time of consent, such as when authorizing a third-party application or website to access your Sanbuk account or participating in promotional activities by Sanbuk partners or third parties.

Where permissible with applicable law, we may use certain information about you, such as your email address and telephone number, de-identify it, and share it with social media platforms, to generate leads, drive traffic to Sanbuk or otherwise promote our products and services.

4.2 Sharing Between Users.

To help facilitate bookings or other interactions between Users, we may need to share certain information such as:

• When a booking request is made or dispute is submitted, certain information may be shared between Guest(s) and Provider(s), including profile, name, names of any additional Guests, cancellation history, review information, age of guest (unless prohibited by applicable law), dispute outcome (when applicable) and other information you choose to share and submit. When a booking is confirmed, additional information is shared to assist with coordinating the trip, like profile photo and phone number. When you as a Provider have a confirmed booking, certain information is shared with the Guest (and the additional Guests they invite, if applicable) to coordinate the booking, such as your profile, full name, phone number, and address.
• When you as a Provider invite another User to Provide Services with you, you authorize that person to access and update your information and User Content, including but not limited to certain information like your full name, phone number, Business address, calendar, Activity information, Activity photos, and email address.
• When you as a Guest invite additional Guests to a booking, your full name, travel dates, Provider name, Activity details, the Activity location, and other related information will be shared with each additional Guest.

4.3 Information You Publish in Profiles, Activity Listings, and other Public Information.

You can make certain information publicly visible to others, such as:

• Your public profile page, which includes your profile photo, first name, description, and city.
• Listing pages that include information such as the Activity or Experience’s approximate or precise location description, calendar availability, profile photo, aggregated demand information (like page views over a period of time), and additional information you choose to share.
• Reviews, ratings and other public feedback.
• Content in a community or discussion forum, blog or social media post.

We may display parts of your public profile and other Content you make available to the public like Listing details on third-party sites, platforms and apps.

Information you share publicly on the Sanbuk Platforms may be indexed through third-party search engines. In some cases, you may opt-out of this feature in your account settings.

4.4 Providers use of Third Party Services

Providers may use third-party services to help create or deliver part of their services, such as cleaning services or gear providers. Providers may use features on the Sanbuk Platforms to share information about the Guest (like check-in and check-out dates, Guest name, Guest phone number) with such third-party service providers.

4.5 Complying with Law, Responding to Legal Requests, Preventing Harm and Protecting our Rights.

We may disclose your information to courts, law enforcement, governmental or public authorities, tax authorities, or authorized third parties, if and to the extent we are required or permitted to do so by law or where disclosure is reasonably necessary: (i) to comply with our legal obligations, (ii) to comply with a valid legal request or to respond to claims asserted against Sanbuk, (iii) to respond to a valid legal request relating to a criminal investigation to address alleged or suspected illegal activity, or to respond to or address any other activity that may expose us, you, or any other of our users to legal or regulatory liability, (iv) to enforce and administer our agreements with Users, or (v) to protect the rights, property or personal safety of Sanbuk, its employees, its Users, or members of the public.

Where appropriate, we may notify Users about legal requests unless: (i) providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law, or (ii) we believe that providing notice would be futile, ineffective, create a risk of injury or bodily harm to an individual or group, or create or increase a risk of fraud upon or harm to Sanbuk, our Users, or expose Sanbuk to a claim of obstruction of justice.

In jurisdictions where Sanbuk facilitates or requires a registration, notification, permit, or license application of a Provider with a local governmental authority through Sanbuk in accordance with local law, we may share information of participating Providers with the relevant authority, both during the application process and, periodically thereafter, such as the Provider’s full name and contact details, Activity address, Listing details, and type of activities booked.

4.6 Service Providers.

We share personal information with affiliated and unaffiliated service providers to help us run our business, including service providers that help us: (i) verify your identity or authenticate your identification documents, (ii) check information against public databases, (iii) conduct background or police checks, fraud prevention, and risk assessment, (iv) perform product development, maintenance and debugging, (v) allow the provision of the Sanbuk Services through third-party platforms and software tools (e.g. through the integration with our APIs), (vi) provide customer service, advertising, or payments services, (vii) process, handle or assess insurance claims or similar claims, or (viii) facilitate non-profit and charitable activities consistent with Sanbuk’s mission. These providers are contractually bound to protect your personal information and have access to your personal information to perform these tasks.

4.9 Business Transfers.

If Sanbuk undertakes or is involved in any merger, acquisition, reorganization, sale of assets, bankruptcy, or insolvency event, then we may sell, transfer or share some or all of our assets, including your information in connection with such transaction or in contemplation of such transaction (e.g., due diligence). In this event, we will notify you before your personal information is transferred and becomes subject to a different privacy policy.

4.10 Corporate Affiliates.

To support us in providing, integrating, promoting and improving the Sanbuk Platform, Payment Services, and our affiliates’ services, we may share personal information within our corporate family of companies that are related by common ownership or control.

We’ll notify you in advance in specific situations where we apply any practices that differ from what is described in this Privacy Policy (including practices pertaining to disclosures to government agencies).

5. OTHER IMPORTANT INFORMATION

5.1 Analyzing your Communications.

We may review, scan, or analyze your communications on the Sanbuk Platform for reasons outlined in the “How We Use Information We Collect” section of this policy, including fraud prevention, risk assessment, regulatory compliance, investigation, product development, research, analytics, enforcing our Terms & Conditions and Payment Terms, and customer support purposes. For example, as part of our fraud prevention efforts, we scan and analyze messages to mask contact information and references to other sites. In some cases, we may also scan, review, or analyze messages to debug, improve, and expand product offerings. We use automated methods where reasonably possible. Occasionally we may need to manually review communications, such as for fraud investigations and customer support, or to assess and improve the functionality of these automated tools. We will not review, scan, or analyze your messaging communications to send third-party marketing messages to you and we will not sell reviews or analyses of these communications.

5.2 Linking Third-Party Accounts.

You may be able to link your Sanbuk account with certain third-party services like social networks. Your contacts on these third-party services are referred to as “Friends.” When you direct the data sharing by creating this link:

• some of the information provided to us from linking accounts may be published on your public profile,
• your activities on the Sanbuk Platforms may be displayed to your Friends on the Sanbuk Platforms and/or that third-party service,
• a link to your public profile on that third-party service may be included in your Sanbuk public profile,
• other Sanbuk users may be able to see any Friends that you may have in common with them, or that you are a Friend of their Friend if applicable,
• other Sanbuk users may be able to see any schools, hometowns or other groups you have in common with them as listed on your linked social networking service,
• information you provide to us from the linking of your accounts may be stored, processed and transmitted for fraud prevention and risk assessment purposes, and
• publication and display of information that you provide to the Sanbuk Platforms through this linkage is subject to your settings and authorizations on the Sanbuk Platforms and the third-party service.

5.3 Third-Party Partners & Integrations.

Parts of Sanbuk may link to third-party services, not owned or controlled by Sanbuk, such as Payment Service and Google Maps/Earth. Use of these services is subject to the privacy policies of those providers, such as Google Maps/Earth Additional Terms of Use, Google Privacy Policy. Sanbuk does not own or control these third parties and when you interact with them you are providing your information to them. We are not responsible for the privacy practices of websites that are not operated by us and encourage you to read the privacy statements of any such third-party site.

6. Sanbuk Cookie Policy

Sanbuk uses cookies, mobile identifiers, tracking URLs, log data and similar technologies to help provide, protect, and improve the Sanbuk Platform.

If you choose to decline cookies, some parts of the Sanbuk Platforms may not work as intended or may not work at all.

6.1 Why Sanbuk Uses These Technologies

We use these technologies for a number of purposes, such as:

• to enable you to use and access the Sanbuk Platforms and the Payment Services
• to enable, facilitate and streamline the functioning of and your access to the Sanbuk Platforms
• to better understand how you navigate through and interact with the Sanbuk Platforms and to improve the Sanbuk Platforms
• to serve you tailored advertising (such as on the Sanbuk Platforms, emails and on third-party websites)
• to show you content (e.g., advertisements) that is more relevant to you
• to monitor and analyze the performance, operation, and effectiveness of the Sanbuk Platforms and Sanbuk advertisements
• to enforce legal agreements that govern use of the Sanbuk Platforms
• for fraud detection and prevention, trust and safety, and investigations
• for purposes of our own customer support, analytics, research, product development, and regulatory compliance.

6.2 Cookies

When you visit the Sanbuk Platforms we may place cookies on your device. Cookies are small text files that websites send to your computer or other Internet-connected device to uniquely identify your browser or to store information or settings in your browser. Cookies allow us to recognize you when you return. They also help us provide a customized experience and can enable us to detect certain kinds of fraud. In many cases the information we collect using cookies and other tools is only used in a non-identifiable manner without reference to personal information. For example, we may use information we collect to better understand website traffic patterns and to optimize our website experience. In some cases we associate the information we collect using cookies and other technology with your personal information. Our business partners may also use these tracking technologies on the Sanbuk Platforms or engage others to track your behavior on our behalf.

There are two types of cookies used on the Sanbuk Platforms: (1) “session cookies” and (2) “persistent cookies.” Session cookies normally expire when you close your browser, while persistent cookies remain on your device after you close your browser, and can be used again the next time you access the Sanbuk Platforms.

In many cases you can manage cookie preferences and opt-out of having cookies and other data collection technologies used by adjusting the settings on your browser. All browsers are different so visit the “help” section of your browser when to learn about cookie preferences and other privacy settings that may be available. Please note that if you choose to remove or reject cookies or clear local storage this could affect the features, availability, and functionality of the Sanbuk Platforms.

6.3 Flash Cookies

We may use Flash Cookies, also known as Local Stored Objects, and similar technologies to personalize and enhance your online experience. A Flash cookie is a small data file placed on a computer using Adobe Flash technology. The Adobe Flash Player is an application that allows rapid development of dynamic content, such as video clips and animation.

We use Flash cookies to personalize and enhance your online experience and to deliver content for Flash players. We may also use Flash cookies for security purposes, to gather certain website metrics and to help remember settings and preferences. Flash cookies are managed through a different interface than the one provided by your web browser. To manage Flash cookies, please visit Adobe’s website.

If you disable Flash cookies or other similar technologies, please note that you may not have access to certain content and product features such as your device remembering a Listing that you viewed during a previous visit.

6.4 Pixel Tags, Web Beacons, and Trackers

Pixel tags, web beacons, and tracking urls are tiny graphic images and/or small blocks of code placed on website pages, ads, or in our emails that allow us to determine whether you performed a specific action. When you access these pages, or when you open an email, let us know you have accessed the web page or opened the email. These tools help us measure response to our communications and improve our web pages and promotions.

6.5 Server Logs and Other Technologies

We collect many different types of information from server logs and other technologies. For example, we collect information about the device you use to access the Sanbuk Platforms, your operating system type, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone where your device is located. Our server logs also record the IP address of the device you use to connect to the Internet. An IP address is a unique identifier that devices require to identify and communicate with each other on the Internet. We may also collect information about the website you were visiting before you came to the Sanbuk Platforms and the website you visit after you leave the Sanbuk Platforms. These tools help us improve user experience and deliver our services.

6.6 Device Information

We may use device-related information to authenticate users. For example, we may use your IP address, browser information, or other data provided by your browser or device to identify the device being used to access our platform. We may also use these device-related techniques for associating you with different devices that you may use to access our content including for fraud-protection purposes and to better target advertising.

6.7 Third Parties

Third parties, including Facebook, place technologies such as pixels and SDKs on the Sanbuk Platforms. These technologies (1) help us analyze how you use the Sanbuk Platforms, such as by noting the third party services from which you arrived, (2) market and advertise Sanbuk services to you on the Sanbuk Platforms and third party websites, (3) help us detect or prevent fraud or conduct risk assessments, and (4) collect information about your activities on the Sanbuk Platforms, other sites, and/or the ads you have clicked on. For example, to help us better understand how people use the Sanbuk Platforms, we work with a number of analytics partners, including Google Analytics. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-Out Browser.

Third parties, including Facebook, may also use such tracking technologies to collect or receive information from the Sanbuk Platforms and elsewhere and use that information to serve ads that they believe are most likely to be of interest to you and measure the effectiveness of their ads both on the Sanbuks Platform and on other websites and online services. Targeting and advertising cookies we use may include Google, and other advertising networks and services we use from time to time. To opt out of Google Analytics for display advertising or customize Google display network ads, you can visit the Google Ads Settings page. To the extent advertising technology is integrated into the Sanbuk Platforms and you opt-out of tailored advertising, you may still receive advertising content. In that case, the advertising content will just not be tailored to your interests. Also, we do not control any of these opt-out links and are not responsible for the availability or accuracy of these mechanisms. Users can opt-out of the collection and use of information for ad targeting by updating their Facebook account ad settings and by contacting support@sanbukadventures.com with a description of your request and validation information.

6.8 Third Party Social Plugins

The Sanbuk Platforms may use social plugins provided and operated by third parties, such as Facebook’s Like Button. As a result of this, you may send to the third party the information that you are viewing on a certain part of the Sanbuk Platforms. If you are not logged into your account with the third party, then the third party may not know your identity. If you are logged in to your account with the third party, then the third party may be able to link information or actions about your interactions with the Sanbuk Platforms to your account with them. Please refer to the third party’s privacy policies to learn more about its data practices.

7. YOUR RIGHTS

7.1 Managing Your Information.

You can access and update some of your personal information through your Account settings. If you connected your Sanbuk Account to a third-party service, like Facebook or Google, you can change your settings and unlink from that service in your Account settings. You are responsible for keeping your personal information up to date.

7.2 Retention.

We keep records for as long as required to manage orders and provide the other relevant products or services anticipated by this section including keeping you up to date with our marketing, and where we are required to by law or for records purposes. We also retain your information to make your future interactions with us convenient and to personalize the products, services and communications with you.

In some circumstances we may store your personal information for longer periods of time, for example, where we are required to do so in accordance with legal, regulatory, tax, or accounting requirements, so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your personal information or dealings.

7.3 CONSENT

By choosing to provide us with your personal information you are consenting to its use in accordance with the principles outlined in this Privacy Notice and as outlined at the time you are asked to provide any personal information.

You can exercise any of the rights described in this section consistent with applicable law. Please note that we may ask you to verify your identity and request before taking further action on your request.

7.4 WITHDRAWING YOUR CONSENT

You do not have to provide us with your personal information. However, if you choose not to provide certain personal information we request and/or require or consent to its use and disclosure, you will still be able to visit our site, but you may be unable to access certain options, products or services, and in some cases, we may not be able to fulfil your order.

8. SECURITY

While no organization can guarantee perfect security, we are continuously implementing and updating administrative, technical, and physical security measures to help protect your information against unauthorized access, loss, destruction, or alteration. Our security procedures mean that we may occasionally request proof of identity before we disclose personal information to you.

As the security of information depends in part on the security of the computer you use to communicate with us and the security you use to protect user IDs and passwords (where applicable), please take appropriate measures to protect this information.

9. CHANGES TO THIS PRIVACY POLICY

We reserve the right to modify this Privacy Policy at any time in accordance with applicable law. If we do so, we will post the revised Privacy Policy and update the “Last Updated” date at the top. In case of material changes, we will also provide you with notice of the modification by email at least thirty (30) days before the effective date. If you disagree with the revised Privacy Policy, you can cancel your Account. If you do not cancel your Account before the date the revised Privacy Policy becomes effective, your continued access to or use of the Sanbuk Platforms will be subject to the revised Privacy Policy. To cancel your account please email us at support@sanbukadventurtes.com

10. GOVERNING LAW AND JURISDICTION

This Privacy Notice is governed by and construed in accordance with the laws of Kuwait. You agree, as we do, to submit to the exclusive jurisdiction of the Kuwaiti courts.

11. HOW TO CONTACT US

If you have any questions, concerns or complaints regarding our compliance with this Privacy Notice, we encourage you to first contact support@sanbukadventures.com. We will investigate and attempt to resolve complaints and disputes as quickly as possible and, in any event, within the timescales provided by applicable data protection laws.