Privacy Policy (Kingdom of Saudi Arabia)

DRAFT NOTICE: This Privacy Policy is a draft. It is being prepared for review by qualified legal counsel in the Kingdom of Saudi Arabia and is not yet in force. It does not create any rights or obligations until a final version is published with an effective date. Nothing in this draft is legal advice. Text in [square brackets] is a placeholder or a point still open for counsel.

1. About this policy

This Privacy Policy explains how TokenNo collects, uses, shares, stores and protects personal data when you use TokenNo in the Kingdom of Saudi Arabia ("Saudi Arabia" or the "Kingdom"). It covers:

the TokenNo customer app, used by people who book tokens (hosts) and the people they invite (guests);
the TokenNo Business app, including the web front desk and the TV "Now Serving" board, used by businesses and their staff;
the TokenNo admin console, used by our own staff;
the TokenNo website at tokenno.com;
the TokenNo Integration API and webhooks that businesses can connect to their own systems; and
our messages to you by push notification, SMS and WhatsApp.

The TokenNo platform is operated by [TokenNo Gulf entity legal name], a [type of entity] registered in [country of registration] under [registration number], with its registered office at [registered address] ("TokenNo", "we", "us"). [Name, Commercial Registration number and national address of any Saudi entity, branch or representative, if one is appointed.] You can contact us at info@tokenno.com.

This policy is written to meet the requirements of the laws of the Kingdom, including:

the Personal Data Protection Law, issued by Royal Decree No. M/19 dated 9/2/1443H, as amended ("PDPL");
the Implementing Regulations of the Personal Data Protection Law and the Regulations on Personal Data Transfer outside the Kingdom, issued by the Saudi Data & Artificial Intelligence Authority ("SDAIA"), which is the competent authority for personal data protection;
the E-Commerce Law, issued by Royal Decree No. M/126 dated 7/11/1440H, and its Implementing Regulations;
the Electronic Transactions Law, issued by Royal Decree No. M/18 dated 8/3/1428H; and
the rules of the Communications, Space and Technology Commission ("CST") on SMS sender names and unsolicited (spam) messages.

In this policy, "personal data" means any information that identifies you, or can identify you directly or indirectly. The person the data is about is the "data subject". The organisation that decides why and how personal data is processed is the "controller", and an organisation that processes it on a controller's behalf is a "processor". The PDPL also treats some data, including health data, as "sensitive data", which has extra protection.

2. Who is responsible for your data

TokenNo is a platform. Businesses ("vendors") such as clinics, hospitals, doctors, restaurants, salons, offices and event organisers use it to issue tokens and run their queues. Because of this, responsibility is shared:

TokenNo is the controller for your TokenNo account (your mobile number, name and language), your login, the messages we send, the advance payments we collect, our fraud prevention and security, and our own analytics and improvement of the platform.
TokenNo is also the controller for the booking and queue records held on the platform (your bookings, tokens, booking history across vendors, guest invitations and queue events), which we use to run the service and for features such as "book again" and "notify me". The vendor you book with is a separate controller for its own service records of your visit and decides what service it provides to you.
Where a vendor connects its own software (for example clinic software or a point-of-sale system) through the Integration API, the data sent to that system is under the vendor's control and responsibility, and the vendor's own privacy notice applies to it.

[Counsel to confirm this allocation under the PDPL, whether TokenNo acts as a processor for any vendor activity, and the terms of the vendor data-sharing addendum (Terms of Service, section 27). The operating entity is the TokenNo Gulf entity named in section 1, whose details are filled in from the admin.]

If you are not sure who to contact, write to info@tokenno.com and we will help you or pass your request to the right vendor.

3. What personal data we collect

We follow a data minimisation approach. In the current phase of the service we collect only what is needed to give you a token and tell you when it is your turn.

3.1 If you book tokens (customers and hosts)

Mobile number. Your mobile number is your identity on TokenNo. One mobile number is one account across all TokenNo apps. We verify it with a one-time password (OTP).
Name. The name you give us, so the vendor can call you.
Language preference. The app language you choose.
Bookings and tokens. The vendor, location, service point (for example a doctor's room or a counter), session, token number, party size, status (booked, called, served, cancelled, no-show), any changes to your token number, and your booking history, including your "notify me when booking opens" requests and "book again" choices.
Party and guests. If you invite guests, the mobile numbers (and names, if you add them) of the people you invite, and whether they said they are coming.
Payment records. If a vendor asks for advance payment: the amount, currency, date, status, refund details and a reference from the payment gateway. We do not collect or store your full card number (including mada, Visa or Mastercard), CVV, or digital wallet or bank login details. These are entered directly with the payment gateway.
Live location (optional). Only if you turn on location sharing for an active token. See section 5.
Device data. A push notification token for your device, the app version, device type and operating system, and basic technical logs (such as IP address, time of access and error reports) needed to keep the service secure and working.
Support messages. What you tell us when you contact us.

3.2 If you are a guest

If a host invites you, we receive your mobile number (and possibly your name) from the host, not from you. We use it only to send you the invitation and updates about that token by push, SMS or WhatsApp, and to show you the token in the app or in a simple web page. If the host picks you from their phone's contacts, the app uses the device's contact picker: it reads only the number the host selects and never uploads the host's address book. Section 3.5 explains our legal basis and how you can stop invitations.

3.3 If you work for a vendor (vendor staff)

your name, mobile number, role (for example owner, manager, receptionist, doctor) and the locations you can access;
the actions you take in TokenNo Business (for example calling, serving, pushing back or cancelling tokens), which we record in audit logs; and
for the business: its name, addresses (including its national address), service points, schedules, holidays, refund rules, prices, bank account details (IBAN) for payouts, tax details (such as a VAT registration number), and KYC documents you upload so that we can verify the business (for example a Commercial Registration and the national ID or Iqama of owners or authorised signatories).

3.4 Health information

We do not ask for medical records, symptoms or other health details. Even for clinics and hospitals, TokenNo holds only your name, mobile number and booking. Please do not type health details into names, notes or other free-text fields. Vendors are not permitted to add health details to TokenNo in the current phase.

However, the fact that you booked with a particular clinic or doctor may itself say something about you. We protect booking data carefully and share it only as described in this policy. [Counsel to confirm: whether clinic and hospital booking data could be treated as "health data" or other "sensitive data" under the PDPL, and the effect of that on consent, on transfers outside the Kingdom and on hosting in India, including any Ministry of Health or other health-sector rules on where such data may be stored.]

3.5 If someone else gives us your number (guests, phone, walk-in, kiosk and API bookings)

Sometimes we receive your name and mobile number from someone other than you: a host who invites you as a guest; vendor staff who book a token for you when you phone the vendor, walk in, or use its QR code or kiosk; or a vendor's own system that creates a token for you through the Integration API. You may not have seen this policy before. In these cases:

Where the data came from: the host or vendor named in our first message to you.
What we use it for: only to issue that token and send you messages about it (invitation, confirmation, call alerts, changes, cancellations and any refund).
Legal basis: our legitimate interest, and the vendor's, in managing the queue you joined, which the PDPL allows for data that is not sensitive [counsel to confirm, and to confirm that a documented legitimate interest assessment is in place].
Our first SMS or WhatsApp message to a number entered by someone else names TokenNo and the host or vendor who added you, says it is a message about one visit, links to this policy and gives you a one-tap "stop inviting me" option.
How long we keep it: see section 11. If you choose "stop inviting me", we stop messaging you and keep only an irreversible hash of your number so that we can honour your request.
Vendors must tell callers and walk-ins that TokenNo will process their number to manage their token (see our Terms of Service, sections 21 and 27).

4. How and why we use your data

We use personal data for these purposes:

To create and secure your account, verify your mobile number by OTP and keep you logged in.
To issue and manage tokens: booking, showing your place in the queue and estimated waiting time, calling your token, handling cancellations, holidays and changes (including "push back" renumbering), and showing your past bookings.
To tell you about your token by push, SMS and WhatsApp: booking confirmations, "your turn is near" and "your number is called" alerts, changes to your token number, cancellations, refunds and "booking is now open" alerts that you asked for.
To handle your party: inviting guests, updating party size and keeping the host and guests informed.
To process advance payments and refunds where a vendor requires them, and to keep accounting and tax records.
To show distance and estimated arrival time, only if you turn on location sharing (section 5).
To translate vendor content (such as business and room names) into your chosen language.
To verify vendors (KYC) and to pay them out.
To keep the platform safe: preventing fraud, misuse and security incidents, and investigating complaints.
To improve the service, for example by estimating average service times at a counter. Where possible we use aggregated or anonymised data for this.
To meet legal obligations, respond to lawful requests from competent authorities in the Kingdom and enforce our Terms of Service.

We use your data only for the purpose it was collected for, or for a purpose directly related to it. If we want to use it for a new, unrelated purpose, we will tell you first and, where the PDPL requires, ask for your consent.

4.1 Legal basis

Under the PDPL, personal data may be processed with the data subject's consent, or without consent in the cases the PDPL allows, for example where processing is necessary to perform an agreement to which you are a party (such as issuing the token you booked), where it is required by law, or where it is necessary for the legitimate interest of the controller, provided this does not harm your rights and interests and does not involve sensitive data.

We rely on performance of our agreement with you for purposes 1 to 5 and 8.
We rely on your consent for live location sharing (purpose 6), for "notify me when booking opens" alerts, for WhatsApp messages where WhatsApp's rules or the law require opt-in, and for any marketing messages.
We rely on legal obligations for purpose 11 and for keeping payment and tax records.
We rely on our legitimate interest in running, protecting and improving the service for purposes 7, 9 and 10.

[Counsel to confirm: the lawful basis for each purpose under the PDPL as amended and its Implementing Regulations, including the conditions for relying on legitimate interest and whether a documented legitimate interest assessment is required.]

When we ask for consent, we will do so clearly, in plain language, and separately from other matters. You can withdraw your consent at any time (see section 9). Withdrawing consent does not affect processing that already took place, but it may mean we can no longer provide some features.

Guests and people booked by a vendor are not parties to our agreement with the host or the vendor. For their data we rely on the basis described in section 3.5, not on performance of an agreement.

5. Live location

Location sharing is off by default and optional.

You can turn it on for one active token at a time. It only runs from a set time before your expected turn until you arrive, your token closes, or you turn it off.
It stops automatically.
We use it to calculate how far away you are and your estimated arrival time, to send a "leave now" reminder, and to mark you as "arrived" when you reach the location.
The vendor and your host see your distance or estimated arrival time (for example "8 min away"), not a continuous map of where you are. [Product to confirm that no vendor or host setting shows exact coordinates or a map; if one is added, this policy will be updated first and your opt-in asked for.]
We send your location to a maps/routing provider only to calculate the route and time.
We delete raw location data soon after the visit, within [24 hours] of your token closing [counsel to confirm retention period], and keep only the fact that you arrived.

You can control location permission at any time in your device settings and in the app.

6. Messages we send (push, SMS and WhatsApp)

Service messages about your token (confirmation, call alerts, changes, cancellations, refunds) are part of the service. You can switch some of them off in the app, but you may then miss your turn.
"Notify me when booking opens" messages are sent only if you ask for them, and you can cancel each request.
We do not send marketing messages without your consent, and every marketing message will include a simple, free way to opt out, as the PDPL requires.
SMS in the Kingdom is sent through licensed providers using sender names registered under CST rules, and in line with CST rules on unsolicited and promotional messages [counsel to confirm the current CST requirements for transactional and promotional SMS, including sender name registration, labelling of promotional messages, permitted sending times and opt-out wording].
WhatsApp messages are sent through the WhatsApp Business Platform operated by Meta, and only where you have agreed to receive messages on WhatsApp or as allowed by WhatsApp's policies. You can reply "STOP" or block the business number at any time. [Product to confirm that an inbound STOP keyword handler is implemented for WhatsApp and SMS with our messaging providers in the Kingdom; otherwise this sentence will be removed.]
The vendor pays for SMS and WhatsApp messages sent for its bookings. This does not change how your data is protected.

7. Who we share your data with

We do not sell your personal data. We share it only as follows:

With the vendor you book with: your name, mobile number, token, party size, status and, if you turned on location sharing, your distance or estimated arrival time. Vendor staff see this in TokenNo Business, and your token number may be shown and announced on the vendor's TV "Now Serving" board in its waiting area. [Product to confirm whether any part of the customer's name can appear on the board.]
With your host or guests: the members of a party see each other's status (for example "coming" or "arrived") and, if location sharing is on, estimated arrival time.
With the vendor's own systems, if the vendor connects them through the Integration API and webhooks. These receive your name, mobile number, booking, token and queue details, and payment events (payment status, amount and reference). They never receive health details. Once the data reaches the vendor's system, the vendor is responsible for it.
With our service providers (sub-processors), who process data on our behalf under written contracts, only for the services they provide to us:
- Amazon Web Services (AWS) — cloud hosting and storage;
- payment gateways — in Saudi Arabia, the gateway configured for the Kingdom (currently [Moyasar or Tap Payments — to be confirmed]); our other gateways (Razorpay and Stripe) serve other countries;
- SMS and WhatsApp providers — such as Unifonic and Twilio for SMS, and Meta for the WhatsApp Business Platform (MSG91 serves other countries);
- Firebase Cloud Messaging (Google) and Apple's push notification service — to deliver push notifications;
- translation providers — to translate vendor content (not your personal messages); and
- maps and routing providers — to calculate distance and arrival times.
An up-to-date list is available on request from info@tokenno.com [or at [link to sub-processor list]].
With authorities, where required by the laws of the Kingdom, a court order or a lawful request from a competent authority in the Kingdom.
In a business transfer, such as a merger or acquisition, subject to this policy and applicable law.

8. Where your data is stored and transfers outside the Kingdom

Our main servers are in India (the AWS Asia Pacific (Mumbai) region). This means that if you use TokenNo in Saudi Arabia, your personal data is transferred outside the Kingdom to India. Some of our service providers (for example push notification, messaging, translation or maps providers) may also process limited data in other countries.

The PDPL and the Regulations on Personal Data Transfer outside the Kingdom allow personal data to be transferred outside the Kingdom only for permitted purposes (including performing an obligation to the data subject), and only where the transfer does not harm national security or the vital interests of the Kingdom, the recipient provides an appropriate level of protection, and only the minimum data needed is transferred. Where the destination country has not been recognised by SDAIA as providing an adequate level of protection, the Regulations allow transfers under appropriate safeguards, such as SDAIA's standard contractual clauses, or under certain limited exemptions, and may require a risk assessment before the transfer.

We transfer your data to India under appropriate safeguards: [SDAIA standard contractual clauses signed with AWS and with each sub-processor that receives Saudi data], supported by a documented transfer risk assessment [status: to be completed before launch]. We transfer only the minimum data needed. [Counsel to confirm: the safeguards and the transfer risk assessment; whether TokenNo must register on SDAIA's national register of controllers and appoint a representative in the Kingdom; and whether any data, such as booking data of healthcare vendors, must be kept inside the Kingdom (see section 3.4). Until counsel confirms, this section describes the intended position only. These are launch-blocking items in the KSA compliance register.]

[Business decision: if the SDAIA safeguards cannot be in place before launch, host Saudi data in a cloud region located in the Kingdom.]

9. Your rights and how to use them

Under the PDPL, you have the right to:

Be informed of the legal basis and purpose for collecting your personal data, how it is processed, who it is shared with and how long it is kept. This policy is part of how we do that.
Access your personal data held by us.
Obtain a copy of your personal data in a clear and readable format, free of charge [counsel to confirm whether the Implementing Regulations also require a machine-readable format or transfer to another controller].
Correct, complete or update your personal data.
Have your personal data destroyed when it is no longer needed for the purpose it was collected for, unless we must keep it by law (for example tax and payment records).
Withdraw your consent at any time, where we rely on consent.
Opt out of marketing messages at any time.
Complain to us and to SDAIA (see section 10).

[Counsel to confirm the full list and limits of data subject rights under the PDPL and its Implementing Regulations, including any rights to restrict or object to processing.]

You can use these rights:

In the app: go to Profile to edit your name and language, see and manage your bookings, manage notifications and location permission, and delete your account.
By email: write to info@tokenno.com with the subject "Privacy request", from or mentioning the mobile number on your account. To protect you, we may ask you to confirm a one-time password sent to that number.

We will respond within the period required by the PDPL and its Implementing Regulations, currently understood to be 30 days, which may be extended in limited cases where we will tell you the reason [counsel to confirm the response period and extension rules]. If a request relates to a vendor's own records, we will tell you and pass it to the vendor where appropriate.

10. Data Protection Officer and how to complain

If you have a question or complaint about your personal data, please contact our Data Protection Officer / Privacy Officer:

Name: [Data protection officer name]
Address: [TokenNo Gulf entity legal name], [registered address]
Email: info@tokenno.com (subject: "Privacy")
Phone: [contact phone]
Hours: [working days and hours, Saudi Arabia time]

[Counsel to confirm: whether TokenNo must formally appoint a Data Protection Officer under the Implementing Regulations (for example because of regular and large-scale processing or the nature of booking data), whether TokenNo, as a controller located outside the Kingdom, must appoint a representative in the Kingdom, and whether TokenNo must register on SDAIA's national register of controllers.]

We aim to acknowledge your complaint within [2] working days and to resolve it within [30] days [counsel to confirm].

If you are not satisfied with our response, you may submit a complaint to SDAIA, the competent authority under the PDPL [counsel to confirm SDAIA's current complaint channel and any time limit for filing a complaint]. Consumer complaints about e-commerce can also be raised with the Ministry of Commerce.

11. How long we keep your data

We keep personal data only as long as needed for the purpose it was collected for, or as long as the law requires. When that period ends, we destroy the data or make it anonymous so that it can no longer identify you. Our draft retention periods are [counsel to confirm all retention periods]:

Account data (mobile number, name, language): while your account is active. If you delete your account, we delete or anonymise it within [30] days, except what we must keep by law.
Bookings and token history: for [3 years] after the visit, so that you can see past bookings and use "book again", and so that disputes can be handled.
Guest numbers and numbers entered by vendors: deleted, or kept only as an irreversible hash to honour a "stop inviting me" request, within [30 days] after the visit, unless the person creates their own TokenNo account (section 3.5) [counsel to confirm].
Live location: deleted within [24 hours] after the token closes (section 5).
Payment, refund, payout and tax records: for at least the period required by the laws of the Kingdom, including the VAT and commercial record-keeping rules (currently understood to be at least 6 years for VAT records, and up to 10 years for some commercial records) [counsel and tax advisor to confirm].
Vendor KYC documents: for as long as the vendor uses TokenNo and for [5 years] afterwards, or longer if required by anti-money-laundering or other law [counsel to confirm].
Audit and security logs: for [1 year].
Device push tokens: until you log out, uninstall the app or the token expires.
Inactive accounts: we may delete accounts with no activity for [period] after giving you notice.

12. How we protect your data

We use appropriate technical, organisational and administrative measures, including:

encryption of data in transit (HTTPS/TLS) and at rest;
OTP-based login, role-based access for vendor staff and least-privilege access for our own team;
storing only a secure hash of Integration API keys, signed webhooks and audit logs of API use;
payment card details handled only by the PCI-DSS compliant payment gateway;
monitoring, backups and regular security reviews; and
contracts with our service providers requiring them to protect personal data.

No system is completely secure. If a personal data breach happens, we will notify SDAIA and, where the breach may cause harm to you, notify you, within the time and in the way required by the PDPL and its Implementing Regulations (currently understood to be within 72 hours of becoming aware of the breach for notification to SDAIA) [counsel to confirm the notification timelines and content].

[Counsel to confirm whether any National Cybersecurity Authority (NCA) controls or CST cloud computing rules apply to TokenNo's hosting of Saudi users' data.]

13. Children

TokenNo accounts are meant for adults aged 18 or over [counsel to confirm the minimum age and the age of full legal capacity under the laws of the Kingdom].

If you are under 18, please ask a parent or legal guardian to book for you.
A parent or legal guardian may book a token for a child (for example at a children's clinic) and enter the child's name. By doing so, they confirm they are the child's parent or legal guardian and consent, on the child's behalf, to us processing the child's name for that booking, as the PDPL requires for people who lack full legal capacity.
We do not track children, monitor their behaviour, or show them targeted advertising.

[Counsel to confirm any additional requirements under the PDPL and its Implementing Regulations on the personal data of children and others lacking full legal capacity.]

If you believe a child has created an account without consent, contact info@tokenno.com and we will delete it.

14. Cookies and similar technologies

Our website and web views (for example the guest token page) use essential cookies or local storage to keep you logged in and remember your language. We use [analytics tool, if any] only with your consent where consent is required. You can control cookies in your browser.

15. Changes to this policy

We may update this policy. If we make important changes, we will tell you in the app or by message before they take effect and, where the law requires, ask for your consent again. The "last updated" date at the top shows when it last changed.

16. Language

This policy is available in English and Urdu. The [Arabic/English] version prevails if there is any difference; the Urdu version is a translation provided for convenience. Until an Arabic version is published, the English version prevails. [Counsel to confirm: an Arabic version is very likely required in the Kingdom (the Implementing Regulations of the E-Commerce Law); when it is added it is expected to be the prevailing consumer text.]

17. Contact us

[TokenNo Gulf entity legal name] [registered address] Email: info@tokenno.com