Privacy Policy

Last Updated: 04.11.2025

This Privacy Policy explains how The Secret Society FZE (“Company”, “we”, “our”, “us”) collects, uses, stores, and protects your personal data when you access or use our website, mobile application, and services (collectively, the “Platform” or “Services”).
This Policy applies in addition to our Terms & Conditions and Cookie Policy, and you are encouraged to review all three documents for complete information on your rights and obligations.
By using our Platform, you agree to the collection and use of your personal data as described in this Privacy Policy.

1. Data We Collect
We may collect the following categories of personal data about you:
Identity & Contact Data: first and last name, email address, phone number, profile picture, social media account identifiers (e.g., Instagram handle) as part of account registration or use of the Platform.
Demographic & Eligibility Data: birthdate (for age verification), gender, location, nationality, influencer/social-media metrics, follower counts, etc.
Usage, Engagement & Device Data: information about how you access and use the Platform, e.g., IP address, browser type, device identifiers, operating system, login times, pages visited, features used.
Promotions & Social Media Content Data: information about Promotions you participate in (as a Member or Service Provider), content you post in conjunction with a Promotion, feedback from Service Providers, ratings, reviews and comments.
Payment & Subscription Data (if applicable for Service Providers): payment method details (e.g., credit card reference), billing address, subscription package, billing history.
Communications Data: correspondence between you and us (for example, email, support requests), marketing preferences, opt-in/opt-out choices.
Third-Party Data: Social media data (e.g., Facebook Insights, Instagram) if you connect your account. Service providers or payment processors for identity verification and transactions
Other data reasonably required for your use of the Platform, registration, account validation, identity verification, fraud prevention and compliance with legal obligations.

2. How We Use Your Data
We process your personal data for the following purposes:
To register and maintain your account on our Platform, verify your identity, enforce our Terms & Conditions, facilitate your participation as a Member or Service Provider.
To deliver the Platform’s services: matching Members with Promotions, facilitating interactions between Members and Service Providers, tracking participation, collecting feedback.
To manage subscriptions, billing and payments (for Service Providers).
To communicate with you: send account confirmations, notices, updates, newsletters, promotional offers (where permitted).
To customise and improve the Platform: analyse usage patterns, monitor performance, develop new features, enhance user experience.
To comply with legal obligations, respond to legal requests, protect our rights, prevent fraud, abuse or illegal activity.
Where we rely on your consent for processing (for example, for marketing communications or data transferred from third-parties), we will inform you and you may withdraw that consent at any time.
We will never sell your personal data to third parties.

3. Legal Basis for Processing
GDPR: Processing is based on contractual necessity, legitimate interests, user consent, or legal obligations
UAE PDPL: Processing is based on user consent or compliance with applicable laws

4. Cookies & Tracking
We use cookies to improve your experience and deliver personalized content.
For details, please see our Cookie Policy.
You may manage cookies through your browser, and consent can be withdrawn at any time.

5. Data Sharing & Disclosure
We may share your personal data with:
Service Providers, partners and third parties involved in the Promotions you participate in.
Payment and billing processors (for Service Providers).
Analytics and advertising partners (only where you have consented or it is otherwise lawful).
Legal, regulatory or governmental authorities as required by law.
Our affiliates and professional advisers (e.g., lawyers, auditors).
In the event of a merger, acquisition or reorganisation of The Secret Society FZE, your personal data may be transferred as part of that transaction (subject to appropriate safeguards).
All third-party partners are required to process data in accordance with GDPR/UAE PDPL standards.

6. Data Retention
We retain your personal data for the period necessary to fulfil the purposes for which we collected it (including any legal, accounting or reporting requirements). When data is no longer needed, we will securely destroy or anonymise it.
In some cases, we may retain certain information (e.g., account history, rights enforcement) for the period specified in our Terms & Conditions or as required by law.

7. Your Rights
You have the right to:
a)Access your personal data.
b)Request correction or deletion.
c)Restrict or object to processing.
d)Withdraw consent.
e)Request data portability.
Requests can be sent to support@the-secret-society.com. We will respond within a reasonable timeframe, typically 2–4 weeks.

8. Children’s Privacy
Our Platform is not intended for persons under 18 years of age (or the equivalent minimum age in your jurisdiction) to register or use. We do not knowingly collect personal data from children under this age. If you believe we have inadvertently collected personal data from a child, please contact us and we will take steps to remove it.

9. Security
We maintain appropriate technical and organisational measures designed to protect the personal data we hold from unauthorised access, collection, use, disclosure, alteration or destruction. However, no system is completely secure, and you acknowledge inherent risks of online data transmission.
If we become aware of a data breach involving your personal data, we will take appropriate steps in accordance with applicable law (which may include notifying you and/or the regulator).

10. International Transfers
Data may be transferred outside the UAE. In such cases, we ensure appropriate safeguards, including:
Standard Contractual Clauses (for GDPR transfers)
UAE PDPL-compliant transfer mechanisms

11. Changes to This Policy
We may update this Privacy Policy from time to time.
Significant changes will be communicated via email or in-app notifications.

12. Contact
For questions, complaints, or data requests:
The Secret Society FZE
Email: support@the-secret-society.com
Address: Creative Tower, PO Box 4422, Fujairah, UAE