Effective Date: [Apr,1,2024]

I. Introduction

When you use Mithu, you trust us with your personal data. We’re committed to keeping that trust. That starts with helping you understand our privacy practices.

This notice describes the personal data (“data”) we collect, how it’s used and shared, and your choices regarding this data. We recommend that you read this along with our privacy overview, which highlights information about our privacy practices and provides summaries of the data we collect and how we use it.

II. Overview

A. Scope

This notice applies to users of Mithu’s apps, websites, and other services globally.

This notice describes how Mithu and its affiliates collect and use data. This notice applies to all Mithu users globally, unless they use a service covered by a separate privacy notice. This notice specifically applies to:

• Consumers: Those who participate in Mithu’s loyalty programs and use our platform to earn and redeem rewards.
• Restaurant Partners: Those who offer rewards and promotions through Mithu.
• Service Providers: Those who provide services through Mithu’s platform, including delivery services.
• Guest Users: Those without a Mithu account who use services ordered by other Mithu account owners.

This notice also governs Mithu’s other collections of data in connection with its services. For example, we may collect contact information of restaurant employees or those who manage and use accounts owned by our partners.

Our privacy practices are subject to applicable laws in the places in which we operate. This means that we engage in the practices described in this notice in a particular country or region only if permitted under the laws of those places.

In addition, please note the following:

• For users in Saudi Arabia: The Saudi Data and Artificial Intelligence Authority (SDAIA) oversees compliance with local data protection regulations.
• For users in the European Economic Area (EEA), United Kingdom (UK), and Switzerland: Due to data protection and other laws in these regions, including the European Union’s General Data Protection Regulation (GDPR), Mithu does not perform certain data collections and uses described in this notice in the EEA, UK, or Switzerland.

Please contact us here with any questions regarding our practices in a particular country or region.

III. Data Collections and Uses

A. The Data We Collect

Mithu collects data:

• Provided by users to Mithu
• Created during use of our services
• From other sources

Mithu collects the following data from these sources:

1. Data Provided by Users. This includes:

   • Account Information: When users create or update their Mithu accounts or place orders via guest checkout features. This includes first and last name, email, phone number, address, profile picture, payment or banking information, user settings, and loyalty program information.
   • Profile Information: Preferences, feedback, and survey responses.
   • Communication Information: Messages, customer service inquiries, and any user-generated content such as reviews.
   • Identity Verification Documents and Photos: Government-issued identification such as driver’s license or passport, and user-submitted photos such as selfies and profile pictures.
   • Demographic Data: Such as birth date/age, gender, and occupation when necessary to enable certain features or provide access to age-restricted products or services.

2. Data Created During Use of Our Services. This includes:

   • Location Data: Precise and approximate location data from users’ mobile devices.
   • Transaction Information: Details about your use of our services, including transaction history and rewards earned and redeemed.
   • Usage Data: Data about how users interact with our services, including access dates and times, app features or pages viewed, browser type, and app crashes.
   • Device Data: Data about the devices used to access our services, including hardware models, device IP address, operating systems, software, preferred languages, advertising identifiers, and mobile network data.
   • Communications Data: Data regarding communications between users enabled through Mithu’s apps.

3. Data from Other Sources. These include:

   • Users participating in our referral programs.
   • Mithu account owners who request services for or on behalf of other users.
   • Users or others providing information in connection with claims or disputes.
   • Mithu business partners through which users create or access their Mithu account.
   • Service providers who help us verify users’ identity and background information.
   • Marketing partners and service providers.

B. How We Use Data

Mithu uses data to enable reliable and convenient services. We also use data to:

1. Provide Our Services. This includes using data to create/update accounts, enable transactions and rewards, and personalize users’ experiences.
2. Safety, Fraud Protection, and Security. This includes verifying users’ accounts and identities, detecting and preventing fraud, and ensuring the safety and security of our services.
3. Customer Support. This includes using the information we collect to provide customer support and improve our customer support responses and processes.
4. Research and Development. This includes using data for analysis, machine learning, product development, research, and testing to improve our services and develop new features.
5. Enabling Communications Between Users. For example, enabling users to message or call each other to confirm details about their transactions.
6. Marketing and Advertising. This includes using data to send personalized communications about Mithu products, services, features, offers, and promotions.
7. Non-Marketing Communications. This includes sending surveys and other communications that are not for marketing purposes.
8. Legal Proceedings and Requirements. This includes using data to investigate or address claims or disputes, comply with legal requirements, and respond to governmental requests.

C. Cookies and Third-Party Technologies

Mithu and its partners use cookies and other identification technologies on our apps, websites, emails, and online ads for purposes described in this notice.

Cookies are small text files that are stored on browsers or devices by websites, apps, online media, and ads. Mithu uses cookies and similar technologies for purposes such as:

• Authenticating users
• Remembering user preferences and settings
• Determining the popularity of content
• Delivering and measuring the effectiveness of advertising campaigns
• Analyzing site traffic and trends

We may also allow others to provide audience measurement and analytics services for us, to serve ads on our behalf across the internet or for other companies’ products and services on our apps, and to track and report on the performance of those ads.

D. Data Sharing and Disclosure

Some of Mithu’s services and features require that we share data with other users, or at users’ request or with their consent. We may also share such data with our affiliates, subsidiaries, and partners, for legal reasons or in connection with claims or disputes.

Mithu may share data:

1. With Other Users. This includes sharing consumers’ first name and reward details with restaurant partners, and sharing restaurant partners’ details with consumers.
2. At Users’ Request or With Users’ Consent. This includes sharing data with other people at a user’s request, Mithu business partners, emergency services, insurance companies, and merchants or restaurants.
3. With Mithu Subsidiaries and Affiliates. We share data with our subsidiaries and affiliates to help us provide our services or conduct data processing on our behalf.
4. With Mithu Service Providers and Business Partners. This includes payment processors, background check providers, cloud storage providers, customer support platforms, marketing partners, and research partners.
5. For Legal Reasons or in the Event of a Dispute. This includes sharing data to comply with applicable laws, regulations, legal processes, or governmental requests.

E. Data Retention and Deletion

Mithu retains user data for as long as necessary for the purposes described above. Users may request account deletion through the Mithu apps and websites.

Following an account deletion request, we delete the user’s account and data, except as necessary for purposes of safety, security, fraud prevention, compliance with legal requirements, or because of issues relating to the user’s account.

IV. Choice and Transparency

Mithu enables users to access and/or control data that Mithu collects, including through:

• Privacy settings
• Device permissions
• In-app ratings pages
• Marketing and advertising choices

Mithu also enables users to request access to or copies of their data, make changes or updates to their accounts, request deletion of their accounts, or request that Mithu restrict its processing of user data.

1. Privacy Settings

Users can set or update their preferences regarding location data collection and sharing, emergency data sharing, and notifications in Mithu’s Privacy Center, which is accessible via the Privacy menu in the Mithu apps.

2. Device Permissions

Most mobile device platforms have defined certain types of device data that apps cannot access without the device owner’s permission. Users should check the available settings on their devices or check with their provider.

3. In-App Ratings Pages

After every transaction, consumers and restaurant partners are able to rate each other. An average of those ratings is associated with a user’s account and is displayed to other users for whom they provide or receive services.

4. Marketing and Advertising Choices

Mithu provides users with choices regarding how their data is used for marketing and advertising:

• Personalized marketing communications from Mithu: Users may choose whether Mithu may use their data to send personalized communications about Mithu products and services.
• Data Sharing and Tracking: Users may choose whether Mithu may share their data with third parties for purposes of personalized ads.
• Personalized Ads: Users may choose whether Mithu uses their transaction history to personalize the ads they see on Mithu’s platform.

5. User Data Requests

Mithu provides users with a variety of ways to learn about, control, and submit questions and comments about Mithu’s handling of their data. Users may submit data requests via our Privacy Inquiry Form.

V. Legal Information

A. Data Controllers and Data Protection Officer

Mithu is the controller of the data processed in connection with the use of Mithu’s services globally, except where it is joint controller with other Mithu affiliates.

Users may submit requests to exercise their rights regarding their data through Mithu’s Privacy Center. Users may also contact Mithu’s Data Protection Officer at [Insert Contact Information].

B. Legal Framework for Data Transfers

Mithu operates and processes user data globally. We comply with applicable legal frameworks relating to the transfer of data.

Mithu operates and processes user data globally, which may result in processing of your personal data in countries whose data protection laws may differ from those where you live. This includes processing of your data on Mithu’s servers and transferring or enabling access to your data globally.

Mithu is committed to protecting our users’ personal data regardless of where they are located or where, or by whom, their personal data is processed. This includes implementing global measures to protect users’ data, such as:

• Securing user data when in transit and at rest
• Mandating company-wide training regarding privacy and data security
• Implementing internal policies and procedures to limit access to, and use of, users’ data
• Limiting government and law enforcement access to user data, except where required by law

C. Updates to This Privacy Notice

We may occasionally update this notice. If we make significant changes, we will notify users in advance of the changes through the Mithu apps or through other means, such as email. We encourage users to periodically review this notice for the latest information on our privacy practices.

Use of our services after an update constitutes consent to the updated notice to the extent permitted by law.

By using Mithu’s services, you acknowledge that you have read and understood this Privacy Notice and agree to the collection and use of your information as described herein.