Privacy Policy

Effective Date: 2025-04-28

Last Updated: 2025-04-28

Effective Date: 2025-04-28

Last Updated: 2025-04-28

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.

  1. 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.

  1. 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.

  1. 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)

  1. 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

  1. 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

  • 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.

  1. 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.

  1. 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.

  1. 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.

  1. 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

  1. 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.

  1. 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.

  1. 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


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.

  1. 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.

  1. 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.

  1. 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.

  1. 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.

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