Sister Safe

The data controller responsible for the information described in this Policy is Pitch Marketing LLC-FZ, a limited liability company established in a free zone of Dubai, United Arab Emirates, with its registered office at 6th Floor, Business Center 1, Meydan Hotel, Nad Al Sheba, Dubai, United Arab Emirates. You may contact us regarding this Policy at [email protected].

We collect the following categories of information in connection with the Service:

• Account information. A self-selected anonymous username, a hashed password, and the dedicated email address you provide for account verification and notices, as described in Section 3 of the Terms.
• Safety Session and check-in data. Encrypted Date/session details, all-clear code hashes, check-in timestamps, and interval configuration.
• Location data. Approximate or precise device location collected during an active Safety Session where you have enabled location sharing, and associated timestamps.
• Media and audio. Photographs, videos, screenshots, and audio recordings you choose to upload or that are generated through the audio-recording feature described in Section 8 of the Terms.
• Safe Contact information. Encrypted label, username, email, phone number, and name information you provide for the people you designate as Safe Contacts.
• Counterparty and matching data. Social-media handles, contribution records, reviews, and other information you submit about Counterparties, and, if you use the View My Data Service, the matching information you submit about yourself (social profiles, contact identifiers, photographs, or video).
• Health Contact Tracing data. If you opt in, anonymized self-reported health-condition results, anonymized contact-linkage data, and the subscription email/payment identifier needed to route alerts, as described in Section 13 of the Terms and Section 9 of this Policy.
• Payment data. Where you use a paid feature (the View My Data Service or a Health Contact Tracing Service subscription for non-exempt Users), payment details are collected and processed by our third-party payment processor; we do not store full payment-card numbers on our own systems.
• Technical and device data. IP address, device identifiers, push-notification tokens, app version, operating system, and diagnostic/log data.

The Service is designed around anonymous usernames and does not require government identification for ordinary safety features. However, anonymity within our systems is not the same as anonymity from all possible correlation. If you use an email address, phone number, photograph, or social-media handle for the Service that you also use elsewhere — including on other websites, applications, marketing lists, or accounts — that shared identifier can function as a bridge that allows the data associated with it inside the Service to be soft-matched, correlated, or linked to your identity on those other platforms by anyone who separately obtains or already holds that identifier, including data brokers, advertisers, or, in the event of a data breach affecting us or a third party, malicious actors.

We strongly recommend using an email address created for the sole purpose of using the Service to minimize this risk. We apply industry-standard technical and organizational security measures, described in Section 8, but no security measure is perfect, and we cannot control, and are not responsible for, re-identification risk that arises from your own reuse of identifying information across contexts outside our control.

We use the information described in Section 2 to: operate and provide the Service, including Safety Sessions, Safety Alerts, and Safe Contact notifications; verify your Account and secure it against unauthorized access; deliver transactional emails (such as verification codes, safety alerts, and recovery emails) through our email service provider; process payments for the View My Data Service and Health Contact Tracing Service subscriptions; perform the human- and AI-assisted matching described in Section 7 of this Policy; operate the Health Contact Tracing Service described in Section 9 of this Policy; maintain audit, security, and abuse-prevention logs; comply with legal obligations and respond to lawful requests as described in Section 6; and improve, troubleshoot, and secure the Service. We do not use your information for third-party advertising, and we do not build advertising profiles about you.

Where applicable data-protection law (including the Thailand Personal Data Protection Act and comparable regimes) requires a legal basis for processing, we rely on: your consent (for example, when you opt in to location sharing, audio recording, or the Health Contact Tracing Service); performance of our contract with you under the Terms (for example, operating your Account and Safety Sessions); our legitimate interests in operating, securing, and improving the Service, provided those interests are not overridden by your rights; and compliance with a legal obligation (for example, responding to a lawful law-enforcement request under Section 6). Where processing relies on consent, you may withdraw that consent at any time by adjusting your settings or contacting us, without affecting the lawfulness of processing before withdrawal.

We do not sell your personal data to third parties. We disclose information only in the following circumstances:

• Service providers. To infrastructure and processing partners who perform services on our behalf, including email delivery, push notification, cloud storage/CDN, mapping, and payment processing, under contractual confidentiality and data-protection obligations.
• Safe Contacts and authorized viewers. Information relevant to a Safety Alert is shared with your designated Safe Contacts and, where a viewer link/code has been authorized, with the authorized incident viewer.
• Law enforcement and government authorities. As described in Section 9 of the Terms, we may disclose information (a) in response to a valid official legal request, subpoena, warrant, or court order, or (b) on an expedited basis, prior to a formal legal process, where explicit in-application consent for faster release has been given by a User, Safe Contact, or authorized viewer — for example, to help locate a User quickly during a genuine emergency or duress alert.
• Legal and safety reasons. Where we form a good-faith belief that disclosure is necessary to prevent death or serious bodily harm, to prevent fraud or abuse of the Service, or to protect the rights, property, or safety of the Company, our Users, or the public.
• Business transfers. In connection with a merger, acquisition, financing, or sale of assets, subject to appropriate confidentiality protections.

We do not disclose the identity of a User who anonymously submits a Counterparty review or a Health Contact Tracing self-report to any other User under any circumstance.

Uploaded Counterparty information (images, screenshots, social-media links, contact details, and reviews) is stored without any verified association to a specific identified individual. We do not, at the time of collection, know or record whose personal identity corresponds to that data.

When you submit a request through the View My Data Service, you provide matching information about yourself (which may include social-media handles, contact identifiers, and photographs or a short video) and payment information to cover the applicable fee. A combination of trained human reviewers and automated tools, which may include facial-recognition-assisted image comparison, compares your submitted matching information against the anonymously stored Counterparty data to identify data that reasonably appears to correspond to you, and that data is then released to you.

Because payment necessarily identifies the payer, completing a request temporarily links your payment identity to your search request and its result. To limit the duration and scope of this exposure, we delete the association between (a) your search request and submitted matching information, and (b) the specific report and search criteria used to generate your result, immediately after the result has been delivered to you. Following this deletion, no record in our databases links your payment information to the underlying, still-anonymous Counterparty data, and the underlying data continues to be stored without any verified owner. We retain only the minimum transactional/accounting record required by Applicable Law (such as tax and payment-processor records), which does not include the substantive matching content or search result itself.

We implement industry-standard technical and organizational measures designed to protect information against unauthorized access, alteration, disclosure, or destruction, including encryption of sensitive fields at rest, hashed and peppered storage of codes and passwords, access controls, rate limiting, and audit logging. No method of transmission over the internet, and no method of electronic storage, is completely secure, and we cannot guarantee absolute security. In the event of a data breach affecting your information, the risk described in Section 3 (that reused identifiers such as an email address, phone number, or photograph may allow correlation with your identity on other platforms) means that a breach could have consequences beyond the Service itself. We will notify affected Users and relevant authorities where required by Applicable Law.

If you opt in to the Health Contact Tracing Service, we process the following data specifically for that feature: an anonymized linkage record connecting your subscription to other subscribing Users' anonymized contact-chain data; your self-reported health-condition result, if any, which is stored without any identifying link to your Account username or profile visible to other Users; and the subscription email address and payment/citizenship-exemption status needed to determine whether, and to whom, an alert should be routed.

When a positive result is self-reported for HIV or syphilis, we identify subscribing Users within the reporting User's contact chain during the trailing ninety (90) day window described in Section 13.5 of the Terms and send those subscribers an alert naming the specific condition. For any other supported health condition, alerted subscribers receive only a generic notice (“Health alert received from your contact chain”) without further detail. In no case is any information identifying the reporting User included in an alert, and no other User is ever informed that a specific person made a report.

We retain contact-chain linkage data only as long as necessary to operate the rolling ninety (90) day window and to deliver alerts to active subscribers, and we do not use Health Contact Tracing data for any purpose other than operating this feature and complying with legal obligations. As explained in Section 13.5 of the Terms, alerts are only generated for and delivered to actively subscribed Users at the time of processing; we do not retroactively reconstruct or deliver missed alerts for a period during which your subscription had lapsed.

We retain information for as long as necessary to provide the Service, comply with legal, tax, and regulatory obligations, resolve disputes, and enforce our agreements. Specific retention practices include: Safety Session and incident data is retained to support the safety functions of the Service and is eligible for erasure following the periods and conditions described in the Service’s data-lifecycle rules; View My Data Service search associations are deleted immediately upon delivery of a result, as described in Section 7; Health Contact Tracing linkage data is retained only as long as necessary to operate the rolling window described in Section 9; and Account information is retained until you request deletion or your Account is terminated, subject to residual copies retained where required by Applicable Law (for example, financial records) or preserved in connection with a legal hold, dispute, or law-enforcement request.

The Company is established in the United Arab Emirates and may use service providers located in other countries, including Thailand and other jurisdictions where our infrastructure or vendors operate. Where information is transferred across borders, we take reasonable steps to ensure it is protected in a manner consistent with this Policy, including through contractual safeguards with service providers.

Subject to Applicable Law and the practical limits inherent in an anonymized system (described further below), you may have rights to: request access to information we hold about your Account; request correction of inaccurate information; request deletion of your Account and associated data, subject to retention obligations described in Section 10; withdraw consent for optional features such as location sharing, audio recording, or the Health Contact Tracing Service; and lodge a complaint with a competent data-protection authority. Because Counterparty data and Health Contact Tracing linkage data are stored without a verified association to any specific identified individual, we may only be able to act on a request relating to such data through the identity-adjacent process described in Section 7 (the View My Data Service) or, for Health Contact Tracing, by ceasing further processing of your own subscription going forward. To exercise any right, contact us at [email protected].

The Service does not verify age and does not identify Users. We recognize that individuals under eighteen (18) years of age may face safety risks that make anonymous safety reporting especially important, and we do not exclude minors from the Service’s core safety features.

As described in Section 2 of the Terms, if you are under eighteen (18), you are required to designate a parent, legal guardian, and/or the police as at least one of your Safe Contacts, so that a responsible adult or the appropriate authority receives any Safety Alert generated on your behalf. We do not independently verify a User’s age or verify that a designated Safe Contact is in fact a parent, legal guardian, or police contact.

Because we do not collect date of birth or other information that would let us determine a User’s age, we do not have actual knowledge of which Accounts belong to minors. Where Applicable Law imposes specific obligations regarding the personal data of children (such as a requirement for parental consent for certain processing), we will comply with those obligations to the extent we become aware that a User is a minor, including, where appropriate, by directing any such request to the parent or legal guardian designated as a Safe Contact under this Section. As noted in Section 2 of the Terms, the fee-based View My Data Service and Health Contact Tracing Service subscription require the involvement of a parent or legal guardian able to lawfully complete payment on behalf of a minor.

The sistersafe.io website uses only strictly necessary cookies and similar local-storage mechanisms required for core functionality, such as maintaining your admin session or language preference. We do not use third-party advertising or cross-site tracking cookies.

The core safety features of the Service are provided to Users free of charge, and we do not sell your personal data to third parties for money or other valuable consideration, whether in connection with the free features or the fee-based View My Data Service and Health Contact Tracing Service described above. Fees charged for those optional services compensate us for the operational, human-review, and infrastructure costs of providing them, and are not payment for your data.

We may update this Policy from time to time in our sole discretion. Where a change is material, we will use reasonable efforts to provide notice through the Service or by email to your Account address. Your continued use of the Service after a change takes effect constitutes your acceptance of the updated Policy. The then-current version of this Policy will always be available at sistersafe.io/privacy.

If you have questions about this Policy or wish to exercise any of your rights, contact:

Pitch Marketing LLC-FZ
6th Floor, Business Center 1, Meydan Hotel, Nad Al Sheba, Dubai, United Arab Emirates
Email: [email protected]