Privacy Policy
Great Spirits Limited ("Great Spirits," "we," "our," or "us") is committed to protecting the privacy of individuals who access or use our mobile application, website, and associated digital services (collectively, the "Services").
This Privacy Policy outlines how we collect, use, disclose, and protect your personal data when you use our Services, in accordance with the UAE Federal Decree Law No. 45 of 2021, the Abu Dhabi Global Market (ADGM) Data Protection Regulations 2021, the EU General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA), and other applicable global privacy laws.
By using our Services, you consent to the practices described in this Privacy Policy.
Scope of This Policy
This Policy applies to all users of our Services worldwide. Although Great Spirits is incorporated in the Abu Dhabi Global Market (ADGM), we process and transfer data globally. This Policy reflects our commitment to comply with data protection frameworks across all jurisdictions where our users reside.
Categories of Personal Data We Collect
Depending on your interaction with our Services, we may collect:
Identity & Contact Data: Name, email, phone number, profile photo
Account Credentials: Username, encrypted password
Payment Data: Card details (last 4 digits), billing address, transaction metadata
Consultation Data: Bookings, practitioner interactions (excluding clinical/medical advice unless otherwise stated)
Usage Data: App interactions, content engagement, referral links
Technical Data: IP address, device ID, browser type, OS
Location Data: Inferred from IP address
Communication Data: Support queries, messages
Voice Data: If you choose to record or send voice messages through our Services (e.g., in comments or community threads), we collect and store the audio recordings and associated metadata (e.g., duration, timestamp). We do not perform voice recognition or identification unless explicitly stated and consented to.
Marketing Preferences
If we introduce features that process sensitive data (such as wellness check-ins or health metrics), we will request explicit consent before collecting or processing it.
Sources of Personal Data
We collect your data from:
You (e.g., account registration, purchases, interactions)
Automated means (e.g., cookies, mobile SDKs, pixels)
Linked services (e.g., Google, Apple login)
Third-party providers (e.g., analytics, advertising partners)
Public sources and affiliate networks (for referrals or attribution)
Lawful Basis for Processing (For EEA/UK Users)
We process your personal data under the following lawful bases:
Contractual necessity
Legitimate interests
Consent (where required, e.g., marketing, cookies, AI personalization)
Legal obligation
How We Use Your Personal Data
We use your data to:
Create and manage accounts
Deliver digital content and consultations
Process payments
Customize content recommendations
Enable practitioner discovery and interactions
Send transactional and promotional communications
Improve our platform through analytics (This includes tools such as Microsoft Clarity, which provides heatmaps and session replays to help us understand usage patterns and improve our Services)
Prevent fraud and ensure security
Comply with regulatory obligations
Voice Messages: We process your voice messages to facilitate communication within community features. This includes storing, transmitting, and enabling playback of audio messages. We do not analyze voice content beyond playback unless otherwise disclosed and consented to.
We may use artificial intelligence (AI) technologies to personalize your experience, recommend content, or enhance user engagement.
How We Disclose Your Personal Data
We share data with:
Service Providers: Hosting, payments, analytics, support
Business Partners: Affiliate partners, wellness experts
Legal Authorities: Where required by law or regulation
Successors: Mergers, acquisitions, asset transfers
Research Partners: In de-identified or aggregated form
Public: Only if you choose to publish content or participate in communities
We do not sell your personal data.
International Data Transfers
Your personal data may be stored on servers located outside your country, including the EU. Where required, we implement Standard Contractual Clauses or other approved mechanisms to safeguard international transfers.
Data Retention
We retain data as long as needed to:
Provide Services
Maintain legitimate business records
Comply with legal and tax obligations
Data may be anonymized and retained for research or statistical purposes.
Your Rights
Depending on your jurisdiction, you may have the right to:
Access your data
Correct inaccuracies
Delete your data (with some exceptions)
Restrict or object to processing
Withdraw consent
Data portability
Opt out of personalized advertising or AI-based recommendations
Request access to or deletion of your voice messages
To exercise your rights, contact privacy@greatspirits.com
Children’s Privacy
Our Services are not intended for children under 16. We do not knowingly collect data from children. If such data is discovered, we will delete it promptly.
Community Features & Public Content
Some areas of our Services (e.g., public profiles, content threads, comments) are public by design. Users should consider this before posting personal information.
You may control privacy settings within your account. Content posted publicly may be indexed by search engines or referenced by third-party platforms.
We moderate user-generated content to maintain a safe community. Users can flag or report objectionable material or block other users. Reported content may be reviewed and, if necessary, removed in accordance with our Terms of Use.
Terms of Use
These Terms of Use govern your access and use of the Services provided by Great Spirits Limited. By accessing or using our Services, you acknowledge and accept these Terms as part of our broader commitment to transparency, privacy, and lawful use.
Eligibility
You must be at least 16 years old (or older if required by your local law). By using the Services, you confirm you meet this requirement and are legally capable of entering into a binding agreement.
User Accounts
Users must register an account to access specific features. You agree to provide truthful, accurate information and to safeguard your credentials. You are responsible for activity conducted through your account. We reserve the right to suspend or terminate accounts that violate our policies.
Acceptable Use
Users must not:
● Post unlawful, abusive, misleading, harmful, or sexually explicit content
● Engage in harassment, bullying, hate speech, or discriminatory behavior
● Infringe upon others’ privacy, dignity, or intellectual property rights
● Reverse engineer, hack, or compromise platform security
● Republish or distribute unauthorized third-party content
Zero-Tolerance Policy:
Great Spirits maintains a zero-tolerance policy for objectionable content and abusive conduct. Any user who posts or engages in prohibited activity will have their content removed and may be permanently banned from the platform.
We review all reported or flagged content promptly and take action, including content removal or account suspension, within 24 hours of receiving a report.
3A. Community Moderation and Reporting
To maintain a respectful and safe environment, Great Spirits provides tools for users to report and block objectionable or abusive content or users.
Flagging Objectionable Content:
Users may flag or report posts or comments that violate our Terms of Use by emailing support@greatspire.io
Blocking Users:
Users may block abusive users to prevent unwanted communication or interaction. This feature allows individuals to control their visibility and engagement within community areas.
Developer Action:
Upon receiving a report, Great Spirits will investigate and, if necessary, remove the content and suspend or terminate the offending account within 24 hours.
We reserve the right to permanently ban users who repeatedly violate our policies or engage in harmful conduct.
Digital Marketplace
Practitioners may offer digital content and services. Purchases are processed via trusted third parties (e.g., Stripe) and governed by our refund terms. Great Spirits is not responsible for third-party processor errors.
Content Ownership
You retain ownership of your content. By submitting content, you grant us a non-exclusive, royalty-free license to display and distribute it within our platform to deliver the Services.
Intellectual Property
All non-user-generated materials (e.g., brand assets, platform code) are owned or licensed by Great Spirits. Unauthorized use is prohibited.
Wellness Disclaimer
Our Services are designed to support general wellness and education. They do not substitute for professional medical, legal, or financial advice.
Limitation of Liability
We disclaim liability for indirect or incidental damages arising from use of the Services.
Indemnification
You agree to indemnify Great Spirits against claims arising from misuse of the Services or violation of these Terms.
Governing Law
These Terms are governed by the laws of the Abu Dhabi Global Market (ADGM). Disputes will be resolved by ADGM courts.
Updates
We may modify these Terms. Continued use after updates constitutes acceptance. When changes are made, we will communicate them to you through email notifications and/or in-app notifications. It is your responsibility to review communications regarding updates to stay informed.
Contact
Great Spirits Limited, ADGM, Abu Dhabi, UAE
Email: privacy@greatspirits.app
Tracking Technologies and Cookies
We use cookies, pixels, and similar technologies for:
Authentication
Session management
Analytics
Retargeting and advertising
What We Use Cookies For:
Login and authentication
Site performance and user experience
Analytics (e.g., Google Analytics)
Marketing and retargeting
Analytics and user experience tools (e.g., Microsoft Clarity)
Microsoft Clarity: We use Microsoft Clarity and Microsoft Advertising to capture how users interact with our Services through behavioral metrics, heatmaps, and session replay. This helps us improve and optimize the Services, support security/fraud prevention, and inform our marketing and advertising. Data is collected via first- and third-party cookies and similar technologies. Microsoft processes this data under its own privacy practices. For more information, see the Microsoft Privacy Statement.
Types of Cookies:
Essential cookies (required for functionality)
Performance cookies (e.g., to measure engagement)
Functional cookies (e.g., language settings)
Targeting/Advertising cookies (used by advertising partners)
You can manage or revoke your cookie preferences via:
Our Cookie Banner
Your browser settings
Global Privacy Control signals (GPC)
We honor Do Not Track where legally required.
Financial Incentives
If we run referral programs, testimonials, or giveaways, we may collect data (e.g., name, contact info) to administer these programs. Incentives will always be disclosed and participation is voluntary.
Data Security
We implement security measures including:
Encryption of data in transit and at rest
Two-factor authentication for user accounts
Role-based access controls
Regular audits and incident response plans
No method is 100% secure. Users are responsible for safeguarding login credentials.
App & Onboarding Consent
During sign-up and onboarding (web or app), users will be presented with:
"By continuing you agree to Great Spirits’s Terms & Conditions and acknowledge the Privacy Policy"
Optional checkboxes:
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ADGM Compliance Notice: Great Spirits Limited is subject to the Abu Dhabi Global Market (ADGM) Data Protection Regulations 2021. Our collection and processing of personal data, including voice messages, align with ADGM principles of purpose limitation, data minimization, and lawful processing. We do not use voice data for biometric analysis or profiling without explicit consent.
Contact Us
Great Spirits Limited
ADGM, Abu Dhabi, United Arab Emirates
Email: privacy@greatspirits.app
If you have concerns about this policy or how we handle your data, please reach out. We’re committed to respecting your privacy and transparency.
