Last Updated: 30/11/2021
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.
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 email@example.com.
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:
2.2 Information you choose to give us.
You can choose to provide us with additional personal information. This information may include:
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:
2.4 Personal Information We Collect from Third Parties.
We collect personal information from other sources, such as:.
3. HOW WE USE INFORMATION WE COLLECT
3.1 Provide, Improve, and Develop the Sanbuk Platforms. We use personal information to:
3.2 Create and Maintain a Trusted and Safer Environment. We use personal information to:
3.3 Provide, Personalize, Measure, and Improve our Advertising and Marketing. We may use personal information to:
3.4 Provide Payment services. Personal information is used to enable or authorize third parties to use 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:
4.3 Information You Publish in Profiles, Activity Listings, and other Public Information.
You can make certain information publicly visible to others, such as:
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.
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.
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:
5.3 Third-Party Partners & Integrations.
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:
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 firstname.lastname@example.org 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.
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.
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.
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.
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 email@example.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.