Privacy Policy

Theema ("we", "us", or "our") operates the theema.co website and mobile application as a celebration marketplace in the State of Kuwait. This Privacy Policy explains how we collect, use, disclose, store, and protect personal data when you browse our website, use our app, place orders, or apply to become a vendor partner. We process personal data in accordance with Kuwait Law No. 30 of 2024 on Personal Data Protection (PDPL), applicable regulations, and other relevant laws of the State of Kuwait.

1. Data controller

Theema is the data controller responsible for personal data processed through theema.co and the Theema mobile application, unless otherwise stated for vendor-specific processing.

Privacy enquiries: contact@theema.co · Phone: 66915157 · Address: State of Kuwait.

2. Scope and applicability

This policy applies to customers, guest browsers, vendor applicants, approved vendor partners, and other users of our digital services in Kuwait.

By using our services, you acknowledge that you have read this Privacy Policy. Where consent is required under Kuwait law, we will request it separately for specific processing activities.

3. Personal data we collect

We collect only personal data that is adequate, relevant, and limited to what is necessary for the purposes described below.

• Identity and contact details: name, phone number, email address, delivery address, and preferred language.

• Account and order data: login credentials, order history, product customizations, payment status, delivery instructions, and customer support messages.

• Vendor application data: business name, contact person, trade categories, commercial information submitted during onboarding.

• Technical data: device type, operating system, app version, IP address, browser type, cookies, and usage analytics.

• Communications: records of emails, WhatsApp messages, or calls when you contact support.

4. How we use personal data

We use personal data for lawful purposes connected to operating our marketplace, including:

• Creating and managing user accounts and vendor partner accounts.

• Processing orders, payments, deliveries, refunds, and customer support requests.

• Matching customers with vendors and transmitting order details to fulfilment partners.

• Reviewing vendor applications and managing partner onboarding.

• Improving app performance, security, product discovery, and user experience.

• Sending service notifications, order updates, and—where permitted—marketing communications.

• Detecting fraud, abuse, and violations of our Terms & Conditions.

• Complying with legal obligations, regulatory requests, and valid court orders in Kuwait.

5. Legal bases for processing

Under Kuwait PDPL and applicable law, we rely on one or more of the following bases, as appropriate:

• Performance of a contract: to provide marketplace services, process orders, and manage vendor relationships.

• Consent: for optional marketing, certain cookies, or processing where consent is specifically required.

• Legal obligation: to comply with tax, consumer protection, anti-fraud, or regulatory requirements in Kuwait.

• Legitimate interests: to secure our platform, prevent misuse, and improve services, balanced against your rights.

6. Sharing and disclosure

We do not sell personal data. We may share personal data only with:

• Approved vendors and delivery partners, to the extent necessary to fulfil your order.

• Payment processors and banking partners, to authorize and settle transactions.

• Technology providers hosting, analytics, messaging, or customer support tools bound by confidentiality obligations.

• Professional advisers, auditors, or insurers where reasonably required.

• Public authorities when required by Kuwaiti law, regulation, or a valid legal process.

7. Cross-border transfers

Our primary operations and data storage are oriented toward users in Kuwait. If personal data is transferred outside the State of Kuwait, we implement appropriate safeguards consistent with Kuwait PDPL requirements, including contractual protections and transfer assessments where applicable.

8. Retention

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, including legal, accounting, and dispute-resolution requirements. When data is no longer required, we delete or anonymize it using reasonable technical and organizational measures.

9. Security

We apply administrative, technical, and physical safeguards designed to protect personal data against unauthorized access, loss, misuse, or alteration. No method of transmission or storage is completely secure; please use strong credentials and notify us promptly of any suspected unauthorized access.

10. Your rights under Kuwait law

Subject to Kuwait PDPL and applicable exceptions, you may have the right to:

• Request access to personal data we hold about you.

• Request correction of inaccurate or incomplete personal data.

• Request deletion or restriction of processing in permitted circumstances.

• Withdraw consent where processing is consent-based, without affecting prior lawful processing.

• Object to certain processing where provided by law.

• Lodge a complaint with the competent authority in the State of Kuwait when applicable.

11. Cookies and similar technologies

Our website may use cookies and similar technologies to remember preferences, maintain sessions, measure traffic, and improve performance. You can manage cookies through your browser settings. Disabling certain cookies may affect site functionality.

12. Children

Our services are intended for users who can lawfully enter into transactions under Kuwait law. We do not knowingly collect personal data from children without appropriate parental or guardian consent where required.

13. Changes to this policy

We may update this Privacy Policy from time to time. Material changes will be posted on this page with an updated "Last updated" date. Continued use of our services after changes take effect constitutes acceptance of the revised policy, unless otherwise required by law.

14. Governing law and contact

This Privacy Policy is governed by the laws of the State of Kuwait. For privacy requests or questions, contact contact@theema.co or 66915157.

This Privacy Policy is provided for transparency and general information. It does not constitute legal advice. If you have questions about your rights or our obligations, contact us using the details below.