Privacy Policy and Personal Data Protection

1. Legal Relationship with Terms of Use

This Privacy Policy is an integral part of Twleef Platform's Terms of Use, and both are considered one legal unit:

• Personal data usage is subject to the provisions of this policy
• Platform, services, and tools usage is subject to the Terms of Use
• In case of conflict, the provisions of this policy regarding personal data protection shall prevail

2. Regulatory Framework and Compliance (PDPL)

Al-Zawiya Al-Sabaa Information Technology Establishment is fully committed to:

• Saudi Personal Data Protection Law (PDPL) issued by Royal Decree No. (M/19)
• Its executive regulations
• Any decisions or instructions issued by the competent authority in the Kingdom

3. Definitions

For the purposes of this policy, the following terms have the following meanings:

• Personal Data: Any data that leads to identifying a natural person directly or indirectly
• Data Owner: The user to whom the personal data relates
• Processing: Any procedure performed on personal data (collection, storage, use, transfer, destruction)
• Controller: Al-Zawiya Al-Sabaa Information Technology Establishment
• Processor: Any third party that processes data on behalf of the Controller under a contract

4. Policy Scope

This policy applies to:

• All Twleef Platform users
• Website visitors
• Subscribers to free or paid plans
• Data collected through the website, application, APIs, or official communication channels

5. Types of Personal Data Collected

6. Purposes of Data Collection and Processing

Personal data is processed for the following regulatory purposes only:

1. Account creation and user verification
2. Contract execution and service operation according to Terms of Use
3. Providing AI services
4. Subscription and billing management
5. Communication and technical support
6. Improving platform performance and user experience
7. Compliance with regulatory obligations
8. Protecting the platform from fraud or abuse

7. Legal Basis for Processing

Twleef relies on one of the following bases for processing personal data:

• Explicit consent from the data owner
• Execution of a contractual obligation (according to Terms of Use)
• Regulatory obligation
• Legitimate interest that does not conflict with the data owner's rights

8. Data Sharing and Disclosure

Personal data may be shared within the following limits only:

• Technical service providers, cloud services, and electronic payment
• Government or judicial authorities upon regulatory request
• Contracted processors under confidentiality agreements and PDPL compliance

9. Data Transfer Outside the Kingdom

Personal data is not transferred outside the Kingdom of Saudi Arabia except in accordance with the controls stipulated in the PDPL system and after taking approved legal guarantees.

10. Data Security and Protection

Twleef applies appropriate technical and organizational security measures including:

• Data encryption during transmission and storage
• Infrastructure and server protection
• Access privilege restriction
• Periodic security reviews

11. Data Retention Period

Data is retained for the period necessary to achieve the purpose for which it was collected. After the purpose ends, data is: destroyed, anonymized, or retained only for the required regulatory period.

12. Data Owner Rights (According to PDPL)

The data owner has the right to:

1. Right to know
2. Right to access
3. Right to request correction
4. Right to request destruction
5. Right to withdraw consent

13. Rights Exercise Mechanism

Data owners can submit their requests via email: support@twleef.com, and they will be processed within the regulatory period after identity verification.

14. Minors Privacy

The platform does not target collecting data from those under (18) years of age, and any data collected without knowledge is deleted immediately.

15. Policy Amendments

Al-Zawiya Al-Sabaa Information Technology Establishment reserves the right to amend this policy at any time. Continued use of the platform after publishing amendments constitutes explicit consent.