Privacy Policy

Your privacy matters to us. This Privacy Policy explains what personal data MYLO collects, why we collect it, how we use and protect it, and what rights you have over your data. Please read this document carefully.

1. WHO WE ARE AND HOW TO CONTACT US

MYLO Middle East FZE (‘MYLO’, ‘we’, ‘us’, ‘our’) is a Free Zone Establishment registered at Dubai Silicon Oasis under Dubai Law No. 16 of 2005, licensed by the Dubai Silicon Oasis Authority (DSOA). We operate the MYLO loyalty program aggregation platform at www.mrmylo.com and via the MYLO mobile application.

Data ControllerMYLO Middle East FZE
Registered AddressDubai Silicon Oasis, Dubai, UAE [complete address to be inserted]
Privacy Contactprivacy@mrmylo.com
Data Protection Officer[Name to be appointed] — privacy@mrmylo.com
Regulatory AuthorityUAE Data Office | Dubai Silicon Oasis Authority (DSOA)

Under UAE Federal Decree-Law No. 45 of 2021 on Personal Data Protection (‘UAE DPL’), MYLO acts as the Data Controller for Personal Data collected through our Services. Where we process data on behalf of business clients, we act as a Data Processor subject to the terms of the applicable Data Processing Addendum.

2. PERSONAL DATA WE COLLECT

2.1 Data You Provide to Us

When you register for or use MYLO, you provide us with the following categories of Personal Data:

Data CategoryExamplesPurpose
Registration DataFull name, email address, phone number, nationality, date of birthAccount creation and identity verification
Authentication CredentialsPassword (hashed), two-factor authentication dataSecure account access
Loyalty Program TokensOAuth tokens, API keys, read-only access credentials for connected programsProgram aggregation (no raw passwords stored)
Payment InformationBilling name, payment method details (processed by third-party payment processor; MYLO does not store full card data)Premium subscription billing
User ContentReviews, ratings, community posts, tips submitted by youPlatform features and community
CommunicationsEmails, support tickets, feedback submitted to MYLOCustomer support and service improvement
PreferencesNotification settings, display preferences, opted-in communicationsService personalisation

2.2 Data We Collect Automatically

When you use MYLO, we automatically collect certain technical and usage data:

Data CategoryExamplesPurpose
Device DataDevice type, operating system, browser type, unique device identifiers, mobile advertising IDsService operation and security
Log DataIP address, access timestamps, pages visited, features used, error logs, referral URLsSecurity monitoring and debugging
Usage AnalyticsFeature interactions, session duration, navigation patterns, click data, search queries within MYLOService improvement and personalisation
Location DataApproximate location derived from IP address (we do not collect precise GPS location unless you explicitly grant permission)Regional service delivery
Cookie and Tracking DataSession cookies, persistent cookies, local storage, analytics identifiersSee Section 5 — Cookies and Tracking

2.3 Data from Third-Party Loyalty Programs

When you connect Loyalty Programs to MYLO, we receive data from those programs via their APIs. This data typically includes:

  • Program account identifiers and membership numbers
  • Points, miles, cashback, or reward balances
  • Transaction history (as made available by the program’s API)
  • Tier or membership status
  • Points expiry dates and eligibility information
  • Redemption options and availability data

This data is collected on your behalf under your authorisation. MYLO treats Loyalty Program data as Personal Data and applies equivalent protections. We access only the minimum data necessary for the aggregation and display features of the Services (data minimisation principle).

2.4 Data from Third-Party Services

If you connect your MYLO account with social media or third-party identity providers (where available), we may receive basic profile data such as your name and email address from that service, subject to that platform’s privacy settings.

2.5 Data We Do NOT Collect

For clarity, MYLO does not:

  • Store your raw Loyalty Program passwords
  • Process or store full payment card numbers (PCI DSS compliant via processor)
  • Collect your precise GPS location without explicit consent
  • Access Loyalty Program transaction capabilities — our access is read-only
  • Sell or rent your Personal Data to third-party marketers

3. HOW WE USE YOUR PERSONAL DATA

MYLO processes your Personal Data only where we have a valid legal basis to do so under UAE Federal Decree-Law No. 45 of 2021. The legal bases we rely on are: (a) Contractual Necessity — processing necessary to provide the Services you have contracted for; (b) Legitimate Interests — processing for our legitimate business interests where not overridden by your rights; (c) Consent — where you have given explicit consent, which you may withdraw at any time; (d) Legal Obligation — processing required by applicable law.

PurposeLegal BasisData Used
Account creation and managementContractRegistration data, credentials
Loyalty Program aggregation and displayContractLoyalty tokens, program data
Sending transactional notifications (balances, expiry alerts)Contract / Legitimate InterestContact info, loyalty data
Processing subscription paymentsContractPayment info, billing data
Responding to customer support requestsContract / Legitimate InterestCommunications, account data
Improving and developing the ServicesLegitimate InterestUsage analytics, feedback
Security monitoring and fraud preventionLegitimate Interest / Legal ObligationLog data, device data
Sending marketing and promotional communicationsConsentContact info, preferences
Personalising your experienceLegitimate Interest / ConsentUsage data, preferences
Complying with legal and regulatory obligationsLegal ObligationAll relevant data
Analytics and business intelligence (anonymised)Legitimate InterestAggregated usage data
KYC and identity verification (where required)Legal ObligationRegistration data

3.1 Marketing Communications

We will only send you marketing emails, push notifications, or promotional content if you have explicitly opted in. You may withdraw consent and unsubscribe at any time via: (a) the unsubscribe link in any marketing email; (b) Account Settings > Notifications > Marketing Preferences; (c) emailing privacy@mrmylo.com.

Withdrawal of marketing consent does not affect transactional communications related to your account or services.

3.2 Automated Decision-Making

MYLO may use automated processing to personalise loyalty program recommendations and expiry alerts. These automated processes do not constitute solely automated decision-making with significant legal effects. You have the right to request human review of any automated decision that significantly affects you by contacting privacy@mrmylo.com.

4. SHARING YOUR PERSONAL DATA WITH THIRD PARTIES

4.1 Categories of Recipients

MYLO shares Personal Data with third parties only where necessary, as follows:

Recipient CategoryPurposeSafeguards
Cloud Infrastructure (e.g. AWS, Azure, GCP — UAE region)Hosting, storage, and processing of ServicesData Processing Agreement; UAE-based servers
Analytics Providers (e.g. Google Analytics, Mixpanel)Usage analytics and service improvementData anonymisation; DPA; opt-out available
Email / Marketing Platform (e.g. Mailchimp, Braze)Transactional and marketing email deliveryData Processing Agreement; consent-based
Payment Processors (e.g. Stripe, Telr, PayTabs)Processing Premium subscription paymentsPCI DSS compliant; DPA; minimum data only
Third-Party Loyalty ProgramsAPI data retrieval on your behalfRead-only access; your authorisation
Legal and Compliance AdvisorsLegal advice, regulatory complianceProfessional confidentiality obligations
Law Enforcement / Regulatory AuthoritiesWhere required by law or court orderOnly to extent legally required

4.2 No Sale of Personal Data

MYLO does not sell, rent, or trade your Personal Data to any third party for their independent marketing or commercial purposes. Your data is used solely to provide and improve the Services.

4.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of MYLO’s assets, your Personal Data may be transferred to the successor entity as part of the transaction. MYLO will notify you via email and/or prominent in-app notice before your data is transferred and becomes subject to a different privacy policy.

4.4 Aggregated and Anonymised Data

MYLO may share aggregated, anonymised, or de-identified data (which cannot reasonably identify you) with third parties for business analytics, research, and industry insights. This data is not Personal Data and is not subject to this Privacy Policy.

5. COOKIES AND TRACKING TECHNOLOGIES

5.1 What Are Cookies

Cookies are small text files placed on your device when you visit a website or use an application. MYLO uses cookies and similar technologies (including local storage, pixel tags, and SDKs) to operate and improve our Services.

5.2 Categories of Cookies We Use

Cookie TypePurposeCan You Opt Out?
Strictly NecessaryEssential for core functionality: authentication, session management, security. Cannot be disabled.No — required for the service to function
FunctionalRemember your preferences, language settings, and customisations.Yes — via cookie settings
Analytics & PerformanceUnderstand how users interact with MYLO; measure performance; improve features. Data is aggregated.Yes — via cookie settings or opt-out links
Marketing & AdvertisingDeliver relevant promotional content. Only used with your consent.Yes — by withdrawing consent

5.3 Cookie Consent

When you first access MYLO’s website, you will be presented with a Cookie Consent Banner allowing you to accept, reject, or customise your cookie preferences (see Cookie Banner document). Your preferences are stored and can be updated at any time via the ‘Cookie Settings’ link in the website footer or Account Settings.

5.4 Third-Party Cookies

Third-party services integrated with MYLO (such as analytics providers) may set their own cookies subject to those providers’ privacy policies. MYLO does not control third-party cookies but endeavours to list them in our Cookie Declaration available at www.mrmylo.com/cookies.

5.5 Analytics Opt-Out

You may opt out of Google Analytics tracking by installing the Google Analytics Opt-Out Browser Add-on available at tools.google.com/dlpage/gaoptout. For other analytics providers, opt-out mechanisms are available within Cookie Settings.

5.6 Do Not Track

Some browsers include a ‘Do Not Track’ (‘DNT’) feature. MYLO currently does not respond to DNT signals. However, you may achieve similar privacy by adjusting your cookie preferences as described above.

6. DATA RETENTION

MYLO retains your Personal Data only for as long as necessary for the purposes for which it was collected, or as required by applicable law. The following retention periods apply:

Data CategoryRetention PeriodReason
Account and Registration DataDuration of account + 3 years after closureContractual records; legal obligations
Loyalty Program DataDuration of connection + 12 months after disconnectionService provision; dispute resolution
Payment and Billing Records7 years from transaction dateUAE commercial and tax law requirements
Usage Analytics Data26 months (aggregated indefinitely in anonymised form)Service improvement; industry practice
Customer Support Communications3 years from resolutionQuality assurance; dispute resolution
Marketing Opt-In RecordsUntil consent is withdrawn + 3 years thereafterCompliance evidence
Security and Access Logs12 months (90 days for detailed logs)Cybersecurity; incident investigation
User Content (reviews, posts)Duration of account; 12 months after deletion requestCommunity integrity; moderation
Legal Hold DataAs directed by applicable legal authorityLegal compliance

After applicable retention periods, MYLO will securely delete or anonymise your Personal Data. Anonymised data is not Personal Data and may be retained indefinitely for research and analytics purposes.

7. DATA SECURITY

7.1 Security Measures

MYLO implements appropriate technical and organisational measures to protect your Personal Data against unauthorised access, loss, destruction, alteration, or disclosure. Our security measures include:

  • Encryption of data in transit (TLS 1.2+) and at rest (AES-256)
  • No storage of raw Loyalty Program passwords — OAuth 2.0 tokens only
  • Role-based access controls limiting staff access to Personal Data
  • Regular security assessments, vulnerability scanning, and penetration testing
  • Two-factor authentication available for all user accounts
  • Secure SDLC (Software Development Lifecycle) practices
  • Staff training on data protection and information security
  • Physical security of UAE-based data centre facilities
  • Incident response procedures and business continuity planning

7.2 UAE Data Residency

All Personal Data collected from MYLO users is stored on servers located exclusively within the United Arab Emirates. MYLO does not transfer Personal Data outside the UAE except as described in Section 8 of this Policy.

7.3 User Responsibility

While MYLO implements robust security measures, security of your account also depends on your actions. You are responsible for maintaining the confidentiality of your Account credentials and for immediately notifying us of any suspected unauthorised access.

7.4 ISO and Industry Standards

MYLO targets compliance with internationally recognised information security standards including ISO 27001 (Information Security Management) and SOC 2 Type II (Service Organisation Controls). Certification status is available upon request.

8. DATA BREACHES AND INCIDENT NOTIFICATION

8.1 Breach Response

In the event of a Personal Data breach, MYLO will:

  • Immediately activate our incident response procedure upon discovery
  • Assess the scope, nature, and risk of the breach
  • Notify the UAE Data Office within 72 hours of becoming aware of a breach that poses a risk to individuals’ rights, in accordance with UAE Federal Decree-Law No. 45 of 2021
  • Notify affected users without undue delay when the breach is likely to result in high risk to their rights and freedoms
  • Document all breaches in our internal data breach register

8.2 User Notification

Where you are required to be notified of a breach, MYLO will contact you via your registered email address with: (a) a description of the nature of the breach; (b) the categories and approximate volume of data affected; (c) likely consequences of the breach; (d) measures taken or proposed to address the breach and mitigate its effects; (e) contact details for follow-up questions.

8.3 KSA Breach Requirements

For users in Saudi Arabia, MYLO will additionally comply with any breach notification requirements under the Saudi Personal Data Protection Law and will notify the Saudi Data and Artificial Intelligence Authority (SDAIA) as required.

9. INTERNATIONAL DATA TRANSFERS

9.1 Primary Data Residency

MYLO stores all user Personal Data on servers located in the United Arab Emirates. We do not routinely transfer Personal Data outside the UAE.

9.2 Limited International Transfers

In limited circumstances, Personal Data may be accessed by or transferred to third parties outside the UAE, including:

  • Cloud provider infrastructure teams for support and maintenance (subject to strict contractual controls)
  • Global analytics providers processing anonymised or aggregated data
  • Legal advisors in connection with cross-border legal matters

9.3 Transfer Safeguards

Where Personal Data is transferred outside the UAE, MYLO applies appropriate safeguards including:

  • Standard Contractual Clauses (SCCs) or equivalent contractual protections
  • Adequacy assessments of the destination country’s data protection framework
  • Data Processing Agreements with all international recipients
  • Technical controls including encryption during transfer

9.4 GCC Regional Transfers

Transfers within the GCC region (Saudi Arabia, Qatar, Kuwait, Bahrain, Oman) are subject to the data protection requirements of the destination country. MYLO applies appropriate safeguards for each GCC jurisdiction.

9.5 GDPR Considerations

If you are an EU or EEA resident accessing MYLO, your data is processed in accordance with applicable GDPR requirements. The UAE has not been granted an EU adequacy decision; therefore, MYLO relies on Standard Contractual Clauses for any data transfers from the EU. EU users may contact privacy@mrmylo.com for a copy of applicable SCCs.

10. YOUR DATA RIGHTS

10.1 Rights Under UAE Law

Under UAE Federal Decree-Law No. 45 of 2021 on Personal Data Protection, you have the following rights regarding your Personal Data:

RightWhat It MeansHow to Exercise
Right of AccessObtain a copy of the Personal Data we hold about youEmail privacy@mrmylo.com
Right to RectificationCorrect inaccurate or incomplete Personal DataAccount Settings or email privacy@mrmylo.com
Right to ErasureRequest deletion of your Personal Data where no longer necessary or where consent is withdrawnAccount Settings > Delete Account or email privacy@mrmylo.com
Right to RestrictionRequest that we limit processing of your data in certain circumstancesEmail privacy@mrmylo.com
Right to Data PortabilityReceive a copy of your data in a structured, machine-readable formatEmail privacy@mrmylo.com
Right to ObjectObject to processing based on legitimate interests or for direct marketing purposesEmail privacy@mrmylo.com or unsubscribe links
Right to Withdraw ConsentWithdraw consent for consent-based processing at any time without affecting prior processingAccount Settings or email privacy@mrmylo.com
Right to Lodge a ComplaintFile a complaint with the UAE Data Office or applicable GCC regulatorContact details in Section 12

10.2 How to Submit a Request

To exercise any of the rights above, contact privacy@mrmylo.com with: (a) your full name and registered email address; (b) a clear description of the right you wish to exercise; (c) a copy of a valid identity document for verification purposes. MYLO will respond within 30 days of receipt of a valid request.

10.3 Limitations on Rights

MYLO may decline to comply with a rights request where: (a) the request is manifestly unfounded or excessive; (b) compliance would conflict with a legal obligation; (c) compliance would adversely affect the rights of others. MYLO will explain any refusal in writing.

10.4 KSA-Specific Rights

Users in Saudi Arabia have additional rights under the Saudi Personal Data Protection Law (PDPL), including the right to be informed of the purposes of processing, the right to access and correct data, and the right to withdraw consent. Saudi users may also lodge complaints with SDAIA at www.sdaia.gov.sa.

11. CHILDREN’S PRIVACY

11.1 Minimum Age

MYLO does not knowingly collect Personal Data from children under the age of 13. Our Services are directed at users aged 13 and older, with parental or guardian consent required for users aged 13-17.

11.2 Parental Consent for Minors (Ages 13-17)

Users between 13 and 17 years of age may only use MYLO with verifiable parental or guardian consent. Parents or guardians who consent on behalf of a Minor accept responsibility for the Minor’s use and agree to the Terms of Service and this Privacy Policy on the Minor’s behalf.

11.3 Limited Data Processing for Minors

For users identified as Minors, MYLO limits data collection and processing to what is strictly necessary for the Services. We do not use Minors’ data for targeted advertising or profiling.

11.4 Parental Rights

Parents or guardians of Minor users have the right to: (a) review the Personal Data collected about their child; (b) request correction or deletion of their child’s data; (c) withdraw consent and request Account closure. To exercise these rights, contact privacy@mrmylo.com with proof of identity and guardianship.

11.5 Discovery of Underage Users

If MYLO discovers that a user under 13 has registered without parental consent, we will immediately suspend the Account, notify the parent or guardian (if contact information is available), and delete all associated Personal Data. If you are a parent who believes your child under 13 has created a MYLO Account, please contact privacy@mrmylo.com immediately.

12. REGULATORY AUTHORITIES AND COMPLAINTS

If you believe MYLO has not handled your Personal Data in accordance with applicable law, you have the right to lodge a complaint with the relevant supervisory authority:

UAE Data OfficeUAE Data Protection authority | Website: [To be confirmed] | Email: [To be confirmed]
DSOADubai Silicon Oasis Authority — MYLO’s primary regulator | www.dso.ae | +971 4 501 5000
Dubai Consumer RightsConsumer complaints | consumerrights.ae | 600 545 555
SDAIA (KSA Users)Saudi Data and Artificial Intelligence Authority | www.sdaia.gov.sa
CITC (KSA Users)Saudi Communications and Information Technology Commission | www.citc.gov.sa

We encourage you to contact us first at privacy@mrmylo.com before lodging a regulatory complaint, as we are committed to resolving privacy concerns promptly and fairly.

13. CHANGES TO THIS PRIVACY POLICY

13.1 Right to Update

MYLO may update this Privacy Policy from time to time to reflect changes in our data practices, applicable law, or our Services. We will always publish the current version at www.mrmylo.com/privacy with the effective date.

13.2 Notice of Material Changes

For material changes — meaning changes that significantly affect your rights or how we process your data — MYLO will:

  • Send an email notification to your registered email address at least 30 days before the change takes effect
  • Display a prominent banner or in-app notification alerting you to the changes
  • Where required by UAE law, seek your renewed consent for new processing activities

13.3 Continued Use

Your continued use of MYLO after the effective date of an updated Privacy Policy constitutes acceptance of the updated terms. If you do not agree to the changes, you should delete your Account before the effective date.

14. CONTACT INFORMATION

For all privacy-related inquiries, data rights requests, or concerns:

Data ControllerMYLO Middle East FZE
Privacy Emailprivacy@mrmylo.com
Data Protection Officer[Name to be appointed] — privacy@mrmylo.com
General Supportsupport@mrmylo.com
Postal AddressMYLO Middle East FZE, Dubai Silicon Oasis, P.O. Box [Insert], Dubai, UAE
Response TimeWithin 30 days of receiving a valid request
DPO Registration[To be completed upon DPO appointment]

Last Updated: [INSERT DATE] | Version 1.0

Compliant with: UAE Federal Decree-Law No. 45 of 2021 (DPL) | Dubai Law No. 16 of 2005 | DSOA Regulations | Saudi PDPL (secondary) | GDPR-aligned principles

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