نخلتي (Nakhlati) — Privacy Policy (DRAFT)

⚠️ THIS IS A DRAFT — not yet legally binding. Before publishing it must be:

1. Translated to Arabic (the authoritative version for Saudi users; this English draft is the working copy).
2. Reviewed by a KSA-PDPL-qualified advisor (I am not a lawyer; this covers the substance, not legal sign-off).
3. Have every [PLACEHOLDER] filled in.
4. Hosted at a public URL (required for App Store / Google Play submission and linked in-app).

Effective date: 2026-09-10 Last updated: 2026-09-10

1. Who we are

نخلتي ("Nakhlati", "the app", "we", "us") is a private, family-run family-tree application for building and sharing your family's lineage. The app is operated by غادة عبدالرحمن عبدالله الغريري (Ghadah Abdurrahman Abdullah Alghurairi), an individual developer registered with the Saudi Ministry of Human Resources and Social Development under freelance-practitioner certificate (وثيقة العمل الحر) no. FL-851804199, who is the data controller for the purposes of the Saudi Personal Data Protection Law (PDPL).

Contact: Alghurairi.dev@gmail.com · +966553461911 (WhatsApp)

This policy explains what personal data we collect, why, how we protect it, who we share it with, where it is stored, and the rights you have under the PDPL.

2. Summary (plain language)

• Your phone number is your login identity. Your name and family details live inside each family tree you belong to, not on your account.
• Family admins build the tree, which necessarily includes information about relatives who are not app users (including, in some cases, minors and deceased persons).
• We host data with reputable cloud providers. At present, due to regional circumstances, data is hosted in the European Union (Germany); we are migrating to in-Kingdom (Saudi Arabia) hosting. See §8.
• We do not sell your data. We share it only with the service providers needed to run the app, and with the members of your own family tree (subject to your privacy settings).
• You can view, correct, and delete your data, and delete your account, from within the app. See §10.

3. Data we collect

a. Account data (tied to you):

• Mobile phone number (your identity and login).
• Preferred language and privacy settings (whether your phone, birth year, occupation, and city are visible to other family members).

b. Family-tree profile data (per family, stored on your node in that tree):

• Name and family lineage/relationships; gender; birth year; city; occupation; deceased status; profile and cover photos.
• Note: the same person may appear in more than one family with different names/details — this is by design.

c. Data about relatives entered by family admins:

• To build a family tree, an admin enters names and relationships of relatives, some of whom are not app users and have not personally consented (potentially including minors and deceased persons). See §6.

d. Content you create:

• Announcements (births, marriages, deaths), calendar occasions, and related details (dates, places, organizer contact you choose to include).

e. Technical & diagnostic data:

• Device push-notification token (if you enable notifications).
• Crash and error diagnostics (via our crash-reporting provider) to keep the app stable.
• Basic server logs (e.g., IP address, timestamps) for security and operation.

f. Payment data:

• Subscriptions are processed by Apple App Store / Google Play. We do not receive or store your card details — only whether your subscription is active.

4. How we use your data

• To provide the core service: build and display your family tree, announcements, and calendar.
• To authenticate you (one-time passcodes sent by SMS).
• To send notifications you have enabled.
• To operate subscriptions and, where applicable, apply complimentary or special access granted to family and friends.
• To keep the app secure and stable (diagnostics, abuse prevention).
• To provide customer support and respond to your requests.

5. Legal bases (PDPL)

• Performance of a contract / your request — to provide the app and your subscription.
• Your consent — for your own account data and for enabling notifications; you may withdraw consent at any time (see §10).
• Legitimate interest — for the family-genealogy data that admins enter about relatives, which is necessary to the app's purpose (preserving family lineage) and balanced against those individuals' rights (see §6).

6. Family data and relatives

A family tree by its nature contains information about people beyond the app's registered users. Family admins may record relatives — including individuals who are not users, minors, or deceased persons — as part of the curated family record.

• We process this data on the basis of legitimate interest in family genealogy and record-keeping, and we limit it to the information needed for that purpose (name, relationship, and optional details the admin adds).
• Visibility is restricted to members of that specific family tree, subject to privacy settings.
• If you believe your personal data has been included in a family tree and you wish to object or request its removal, contact us at Alghurairi.dev@gmail.com (see §10 and §16).

7. How your data is shared

a. With your family: members of a family tree can see that tree, subject to each member's privacy settings (e.g., you can hide your phone number, birth year, occupation, or city).

b. With service providers (processors), only as needed to run the app:

• Cloud hosting & storage — Amazon Web Services (AWS): the Frankfurt region (eu-central-1) during the interim beta period, moving to the Riyadh region (me-central-2) for the in-Kingdom launch. Hosts the application, database, and photos. See §8.
• Phone verification (one-time passcodes) — Google Firebase Authentication, which delivers the SMS code used to verify your phone number. This involves processing outside the Kingdom — see §8.
• Push notifications — Apple Push Notification service and Google Firebase Cloud Messaging.
• Payments — Apple App Store and Google Play.
• Crash/error diagnostics — Sentry (only when enabled; otherwise diagnostics stay on-device).

We do not sell your personal data or share it for advertising.

c. Legal: we may disclose data where required by Saudi law or a valid legal request.

8. Where your data is stored (data residency)

The Saudi PDPL presumes personal data of residents is processed inside the Kingdom.

• Current (interim): due to regional circumstances affecting in-Kingdom cloud availability, application data is currently hosted in the European Union (Germany) with a reputable cloud provider under appropriate safeguards. This is a temporary measure for the current phase.
• Planned: we are moving to in-Kingdom (Saudi Arabia) hosting and will update this policy when the migration is complete.
• Phone-verification passcodes are delivered via Google Firebase Authentication, which processes the phone number outside the Kingdom (see §7).
• Push notifications and payments are processed by Apple and Google outside the Kingdom; notification content is kept generic and does not include sensitive family details.

By using the app during this interim period, you acknowledge and consent to this cross-border processing, which is limited to what is necessary to operate the service and is protected by appropriate safeguards.

9. Data retention and account deletion

• We keep your data while your account and family memberships are active.
• Deleting your account (from the app's settings) starts a 30-day grace period: your sessions are revoked and access is suspended; signing back in within 30 days cancels the deletion. After 30 days, your account contact details (phone number) are permanently removed and your account is anonymized.
• Important: deleting your account is not the same as deleting your record in a family tree. Because the family tree is a shared, admin-curated record, your name and lineage may be retained as part of that family's history, unlinked from your account. Your profile photo is deleted.
• Content you authored (announcements, occasions) may be retained as part of the family record.

10. Your rights (PDPL)

Subject to the PDPL, you have the right to:

• Access the personal data we hold about you;
• Correct inaccurate data (you can edit your profile in the app);
• Delete your account and request erasure of your account data (see §9);
• Object to / restrict certain processing;
• Withdraw consent (e.g., turn off notifications; note some data is needed to provide the service);
• Request a copy of your data.

To exercise these rights, use the in-app controls or contact us at Alghurairi.dev@gmail.com. We aim to respond within 30 days.

11. Children's data

The app is intended for adults who manage a family record. Admins may include information about minors who are relatives, as part of the family tree, under the legitimate-interest basis in §6. We do not knowingly create accounts for children. A parent or guardian may contact us to review or remove a minor's information.

12. Security

We protect your data with measures including: encrypted connections (HTTPS), row-level database isolation between families, hashed one-time passcodes, secure storage of authentication tokens on your device, and least-privilege access controls. No system is perfectly secure, but we work to protect your information and to respond promptly to any incident.

13. Notifications and communications

• We send SMS one-time passcodes to verify your phone number.
• If you enable push notifications, we send alerts about relevant family activity; notification content is kept generic. You can turn notifications off at any time in settings or your device.

14. Payments

Subscriptions are billed through the Apple App Store or Google Play under their terms. We receive confirmation of your subscription status but not your payment card details. Complimentary or special access is applied on our side and does not involve charging you through the stores.

15. Changes to this policy

We may update this policy (for example, when we complete the move to in-Kingdom hosting). We will post the updated version with a new "Last updated" date and, for material changes, notify you in the app.

16. Contact and complaints

• Us: Alghurairi.dev@gmail.com · +966553461911 (WhatsApp)
• Regulator: you have the right to lodge a complaint with the Saudi Data & AI Authority (SDAIA), the PDPL supervisory authority.

Draft prepared 2026-08-05; placeholders filled 2026-09-10 (controller identity, contact, providers, dates). Still to do before publishing: an Arabic translation (authoritative for KSA users) and a KSA-PDPL legal review.