Privacy Policy

Thara Systems (U) Limited is the operator of SantaPool and is responsible for determining how personal data is handled for the core service. Our contact address is Valley Road, Nsasa, Kampala, Uganda. You can reach our privacy contact at [email protected].

Some service providers may process information on our behalf under contractual instructions. In other situations, such as purchases through an independent app store or payment processor, that provider may separately determine how it handles transaction data under its own privacy notice.

This notice covers visitors, registered members, event hosts, co-hosts, invited recipients, business representatives, support requesters and people whose contact details were supplied by a host for an invitation. It applies to the SantaPool website, mobile apps, API-backed features and transactional communications.

It does not govern the independent practices of retailers, couriers, messaging apps or outside websites you choose to visit. An organizer must only supply another person’s data for a legitimate exchange purpose and must not use SantaPool as an address-book harvesting service.

Account and identity information can include your name, email address, verified contact details, account identifier, authentication credentials in protected form, account security preferences and verification history. We do not need or ask you to email us plain-text passwords.

Gift-exchange information can include circle names, dates, invitation status, participant and host roles, manually added contact details, preferences, wishlist descriptions, gift ideas, budgets set by members, relationship constraints, consent choices, assignments and event activity.

When you use optional features, we may process messages, celebration photographs, memory content, support correspondence, reports, accessibility settings and notification preferences. Information you share with other members is visible only to people authorized by the relevant feature and its privacy settings.

Technical and security records may include login events, device and browser details, IP addresses, request timestamps, crash diagnostics, application version, security alerts, token activity and logs required to maintain and protect the service.

We receive information directly from you when you sign up, edit a wishlist, create a circle, accept an invitation or contact us. Some contact information reaches us from a host or another authorized member who invites you or manages a group.

We may also receive essential technical events from the device and software you use. If third-party sign-in or payment services are enabled in the future, we will receive only the account or transaction information necessary to provide the requested service and will disclose the relevant provider at that time.

We use personal information to create and secure accounts, verify access, deliver requested invitations, maintain eligible rosters, support matching and consent controls, display wishlists to authorized people and help hosts manage exchanges.

We also process information to deliver relevant notifications, respond to assistance or data-rights requests, prevent fraud, enforce platform rules, troubleshoot failures, protect the secrecy of private assignments and meet applicable legal obligations.

Where optional research, analytics or promotional messages are introduced, we will explain those activities and respect relevant consent and preference controls. We do not use protected gift-assignment details to build advertising profiles.

We process information where necessary to deliver the service you request or perform our agreement with you, comply with legal duties, protect accounts and the integrity of the service or pursue legitimate operational and safety interests where permitted by applicable law.

Where consent is required, such as certain optional notifications, device permissions or promotional communications, we request it separately and allow withdrawal through the relevant settings or by contacting us. Withdrawal does not invalidate lawful processing already performed or data that must be retained for an independent legal reason.

For invited people who have not registered, we process limited information to deliver and administer the invitation, respond to rejection or expiry and prevent abusive or repeated contact, subject to applicable law and the rights of the invitee.

The matching experience uses relevant roster, eligibility, consent and relationship-constraint information to determine possible assignments. This processing helps avoid conflicts and preserves a fair private exchange. Certain matching data is kept separately from general public-facing account information.

We restrict assignment access based on participant permissions and current event state. Organizers do not automatically have access to a complete secret assignment map. Authorized operational staff may need tightly controlled access for security, investigation or legal compliance.

A participant may voluntarily disclose their own assignment or reveal information outside SantaPool. We cannot prevent another person from copying content once they are legitimately shown it, so sharing controls do not replace discretion.

Depending on your role and the state of an exchange, authorized participants may see your display name, roster presence, invitation status, shared wishlist items, consent state or relevant event activity. They should not automatically see your private assignment or confidential account security information.

Hosts and co-hosts can manage only the people and data permitted by their role. Team and business use does not give an employer unrestricted access to personal accounts, confidential gifts or private matching details.

Our website uses session, security and preference mechanisms necessary for login, request integrity and a consistent experience. Browser storage or cookies may remember settings such as appearance or session state.

If optional analytics, personalization or advertising technologies are later enabled, we will provide the required notice and consent mechanisms under applicable law. You can use browser controls to manage cookies, although disabling essential storage may prevent sign-in or other necessary features.

The mobile app may use device identifiers, push notification tokens, app version, crash diagnostics and authentication information to provide secure sessions and messages. Notification permission is controlled through your device settings and app preferences.

If an optional feature needs access to photos, files, the camera or contacts, that access must be requested through the device permission interface and connected to the feature you choose. Manual entry of participant details remains an available approach. We do not treat installing the app as blanket permission to read your address book or media library.

Removing an app or disabling a permission does not itself erase information already stored in your SantaPool account. To request deletion use the rights process described below.

We may send account verification, invitation, security, password recovery, service change and privacy request notices needed to operate SantaPool. With appropriate preferences or consent we may also send optional gifting reminders, event updates and future promotions.

You can adjust available notification and quiet-hour settings. Some essential security or legal notices may still be delivered when nonessential notifications are disabled. Device push delivery is also subject to platform permissions and network conditions.

If SantaPool enables paid plans, vouchers, credits, business purchases or recurring subscriptions, we may process purchase and entitlement records, payment status, transaction identifiers, billing country, applicable currency, refund history, invoices and fraud-prevention data necessary to provide and reconcile the transaction.

A card network, bank, mobile-money provider, app store or payment processor may collect payment credentials independently. SantaPool will explain the provider and its separate notice in the relevant checkout. We do not claim to offer live card or subscription processing where the application has not enabled it.

If recurring billing becomes available, we will identify the billing platform, price, renewal terms and cancellation process before purchase. Records legitimately needed for tax, fraud, audit or payment disputes may remain after an account deletion request for the legally required period.

We share data only as reasonably necessary with authorized exchange participants, service providers that host or maintain the platform, email and push delivery services, security and technical support contractors, independent payment providers when enabled or authorities where legally required.

Those recipients should receive no more information than needed for their task and be subject to appropriate confidentiality, access and data-protection controls. We do not sell personal account records or secret assignments to advertisers.

We may disclose information to protect people from credible harm, investigate suspected fraud, comply with lawful requests, defend legal claims or support a business reorganization where permitted and subject to appropriate protection of personal data.

SantaPool is operated from Uganda. Some infrastructure, email, push, app-store or other service providers may process information in other countries. Where a cross-border transfer occurs, we apply safeguards required by applicable law, including appropriate contractual protections, access controls and due diligence.

A particular service provider or country should not be inferred from the general categories in this notice. Material changes involving new external providers or processing purposes will be disclosed as applicable.

We use technical and organizational measures appropriate to the data and risk, including authenticated access, authorization checks, protected credentials, restricted private matching information, audit controls and security review of sensitive actions.

No system can guarantee absolute security. If you discover a vulnerability or suspect account compromise, contact us promptly and do not attempt to access another person’s data as proof. We will evaluate and address incidents, notify affected people and regulators when legally required and cooperate with relevant authorities.

We keep personal data for the period reasonably necessary to provide the relevant feature, fulfill a request, maintain active events, prevent abuse or satisfy an applicable legal obligation. This may depend on account activity, event status, invitation expiry, the selected feature, complaint history and any lawful preservation requirement.

When data is no longer needed we delete, anonymize or isolate it as appropriate. Security logs, legal records, audit evidence and future payment or tax records may require different retention periods. We do not represent an arbitrary universal deletion period as applying to every type of record.

If a request concerns information necessary to preserve an active draw’s integrity, we assess the effect on other participants and any lawful retention basis rather than automatically revealing or invalidating private assignments.

Depending on applicable law you may ask to access your personal information, correct inaccurate details, obtain a copy, object to particular uses, withdraw optional consent, restrict processing where applicable or request deletion. You may also complain to a competent data-protection authority.

Available signed-in web and mobile privacy controls allow users to submit export or erasure requests. These are subject to secure identity confirmation and an authorized review. Submission is not the same as immediate fulfillment. You can also contact our privacy email if you cannot access an account.

We will communicate any verification or lawful retention conditions and respond within periods required by applicable law. We do not charge for ordinary rights requests except where permitted for manifestly unfounded or excessive requests.

To request deletion, open the account Privacy Center on the web or use the privacy-request pathway available in the mobile app. If you cannot sign in or no longer have the app, email [email protected] with the subject “SantaPool account deletion”. Do not send passwords, private invitation tokens or complete financial details.

We may require a reasonable identity check to avoid deleting another person’s account. Once a valid request is approved and any applicable legal retention issue is resolved, we will delete or anonymize information that no longer has a lawful retention basis and explain material exceptions. Account closure or mere deactivation is not presented as completed erasure.

If you bought a future auto-renewing subscription through Apple, Google or another provider, cancel it through that provider’s subscription controls. Deleting your SantaPool account may not stop external recurring charges. We will provide help identifying the applicable management pathway.

SantaPool is not designed for unsupervised use by children under 13. Parents and guardians should supervise minors participating in family exchanges and avoid submitting unnecessary personal details or photos of children.

If you believe a child’s information has been provided without appropriate authority, please contact us so we can investigate and take necessary action in accordance with applicable law.

We may update this notice to reflect service changes, new integrations, regulatory requirements or improved safeguards. The published effective date will be revised and material changes will be communicated through appropriate website, app or email notices where required.

Any newly enabled processing that requires consent or a separate disclosure will be introduced with those controls, not treated as automatically authorized by an earlier general policy.

Send privacy questions, access concerns or complaints to Thara Systems (U) Limited at [email protected] or the address below. Please describe the relevant account and request without including confidential gift assignments or security credentials.

If you believe your data-protection rights have been infringed, you can seek guidance from the Personal Data Protection Office in Uganda or the competent authority in your jurisdiction. Contacting us first may help resolve the matter but does not remove your right to approach a regulator.