Welcome, and thank you for your interest in TREEMA TECH LTD (“TREEMA”, “we”, “us”, or “our”).

This Privacy Policy (“Policy”) explains how we collect, use, process, disclose, and safeguard Personal Data when you access or use our websites, mobile applications, AI agents, software platform, and related services (collectively, the “Service”).

This Policy forms part of and is incorporated into the TREEMA Terms and Conditions. Capitalized terms not defined here have the meanings given in the Terms.

1. APPLICABLE LAW & REGULATORY FRAMEWORK

This Policy is designed to comply with:

• DIFC Data Protection Law No. 5 of 2020

• EU General Data Protection Regulation (GDPR)

• UK GDPR

• Google Play User Data Policy

• Apple App Store Privacy & Data Deletion Guidelines

Where multiple regimes apply, TREEMA applies the highest applicable standard.

2. DEFINITIONS

• “Client” – an organization subscribing to the Service

• “User” – an authorized individual acting on behalf of a Client

• “Visitor” – an individual accessing public website areas

• “Client Data” – data uploaded or processed within the SaaS platform

• “Personal Data” – information relating to an identified or identifiable individual

• “Restricted Area” – authenticated areas of the Service

• “Public Area” – non-authenticated areas of the Service

3. DATA CONTROLLER & PROCESSOR ROLES

• TREEMA acts as Data Controller for Personal Data collected directly from Visitors and Users

• TREEMA acts as Data Processor for Client Data processed on behalf of Clients

• Clients remain Data Controllers of Client Data

4. LAWFUL BASES FOR PROCESSING

We process Personal Data based on:

• Contract performance

• Legal obligations

• Legitimate interests

• Consent (where required, including marketing cookies)

5. INFORMATION WE COLLECT

5.1 Information You Provide

Including but not limited to:

• Name, email address, phone number

• Billing and payment details

• Account credentials

• Support communications

5.2 Client Data

Clients and Users may upload Client Data into the Service.

TREEMA:

• Has no direct relationship with individuals whose data is included in Client Data

• Processes Client Data only on documented Client instructions

• Does not determine purposes of Client Data processing

5.3 Automatically Collected Information

A. Website Analytics & Marketing (Public Areas)

On our public website only, we use:

• Facebook Pixel (Meta)

• Website analytics tools

These may collect:

• IP address

• Device and browser data

• Interaction and conversion events

📌 These tools are not used inside the authenticated SaaS platform.
📌 Where required, cookies and pixels are deployed only after consent.

B. SaaS Platform (Restricted Areas)

Inside the authenticated Service:

• No Facebook Pixel

• No advertising or marketing tracking

• Only essential security and session data

6. COOKIES & TRACKING TECHNOLOGIES

• Website: analytics and marketing cookies (subject to consent)

• Platform: essential session tokens only (no tracking, no marketing)

7. USE OF PERSONAL DATA

We use Personal Data to:

• Operate and secure the Service

• Manage accounts and subscriptions

• Provide support

• Improve website performance and marketing effectiveness

Client Data is used solely to provide the Service.

8. AI, AGENTS & LLM DATA PROCESSING

8.1 AI Features

The Service includes AI agents, automation workflows, and large language models.

8.2 No AI Training on User or Client Data

Unless expressly agreed in writing:

• Personal Data and Client Data are not used to train or fine-tune AI or LLMs

• Data is used only for real-time inference and automation execution

• TREEMA bears no responsibility for third-party model training practices

9. CLOUD HOSTING & INFRASTRUCTURE

TREEMA uses:

• Amazon Web Services (AWS)

• Google Cloud Platform (GCP)

TREEMA provides no guarantees beyond the hosting terms of these providers and is not liable for incidents outside its reasonable control.

10. INTERNATIONAL DATA TRANSFERS

Where data is transferred internationally, appropriate safeguards are applied, including Standard Contractual Clauses or equivalent mechanisms.

11. DATA DISCLOSURE

We disclose data only to:

• Authorized subprocessors (e.g., AWS, GCP, analytics providers)

• Authorities where legally required

• Business successors (with safeguards)

We do not sell Personal Data.

12. USER DATA DELETION & ACCOUNT DELETION (ANDROID & iOS COMPLIANCE)

12.1 Right to Request Deletion

In accordance with:

• DIFC Data Protection Law

• GDPR

• Google Play User Data Policy

• Apple App Store Guidelines

Users have the right to request deletion of their Personal Data.

12.2 How to Request Data Deletion

Users may request deletion by:

• Emailing support@treema.ai, or

• Using in-app account deletion functionality (where available)

Requests must be submitted from the registered email address or authenticated account.

12.3 Scope of Deletion

Upon a valid request:

• Personal Data collected directly by TREEMA will be deleted or anonymized

• Account access will be permanently removed

• Backup copies will be deleted within a reasonable retention period unless legally required

📌 Client Data:
Where a User account is associated with a Client:

• Deletion requests must be approved or initiated by the Client

• Certain data may be retained if required for contractual or legal reasons

12.4 Retention Exceptions

We may retain limited data where:

• Required by law

• Required for fraud prevention or security

• Necessary for billing, dispute resolution, or legal compliance

Such data is restricted and securely stored.

12.5 App Store Transparency

TREEMA does not prevent users from requesting deletion and does not condition deletion on unreasonable steps, in compliance with Apple and Google policies.

13. DATA SECURITY

We implement appropriate technical and organizational safeguards, including:

• Encryption in transit

• Access controls

• Secure cloud infrastructure

• Least-privilege policies

14. DATA RETENTION

• Personal Data is retained only as necessary

• Client Data deletion requests must come from the Client

• Data is deleted or anonymized upon termination unless legally required otherwise

15. CHILDREN’S PRIVACY

The Service is not intended for individuals under 18 years of age.

16. DO NOT TRACK

We do not respond to browser Do Not Track signals.

17. POLICY CHANGES

We may update this Policy from time to time. Continued use of the Service constitutes acceptance.

18. CONTACT INFORMATION

TREEMA TECH LTD
Email: support@treema.ai