Privacy Policy

1. Introduction

SchoolSwap (“Platform”, “we”, “us”, “our”) is owned and operated by Spirit Arabia Ventures F.Z.E., a Free Zone Establishment incorporated in the United Arab Emirates.

This Privacy Policy explains how Spirit Arabia Ventures F.Z.E. collects, uses, processes, stores, and protects personal data through the website schoolswap.me.

This Policy is issued in compliance with:

• UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (PDPL)
• UAE Federal Law No. 3 of 2016 concerning Child Rights (Wadeema's Law)

By using the Platform, you agree to this Privacy Policy.

2. Data Controller

For the purposes of UAE data protection law, the Data Controller is:

Spirit Arabia Ventures F.Z.E. determines the purposes and means of processing personal data collected through SchoolSwap.

3. Use by Minors

SchoolSwap is designed for school communities and may be used by individuals under 18 years of age (“Minors”).

Minors may only use the Platform with the consent of a parent or legal guardian.

By allowing a Minor to register, the Parent/Guardian confirms that they:

• Consent to the processing of the Minor's personal data by Spirit Arabia Ventures F.Z.E.
• Accept this Privacy Policy
• Understand how the Platform operates

Parents or Guardians may contact Spirit Arabia Ventures F.Z.E. at support@schoolswap.me to request access to, correction of, or deletion of a Minor's data.

4. Personal Data Collected by Spirit Arabia Ventures F.Z.E.

Spirit Arabia Ventures F.Z.E. collects only the data necessary to operate the Platform.

4.1 Account Information

• Full name
• Email address
• Role (Student / Parent / Teacher)
• School name
• Profile photo (optional)
• Short biography (optional)

4.2 Marketplace Data

• Item listing details
• Photos uploaded
• Pricing or barter information
• Item condition and category

4.3 Communication Data

• Messages exchanged within the Platform
• Reports and complaints

4.4 Technical Data

• IP address
• Browser and device type
• Login timestamps
• Account creation records
• Acceptance of Terms

5. Data Not Collected

Spirit Arabia Ventures F.Z.E. does not collect:

• Emirates ID numbers
• Payment card information
• Precise GPS location data
• Biometric information
• Sensitive personal data
• Advertising tracking data

Personal data is not sold or rented to third parties.

6. Purpose of Processing

Spirit Arabia Ventures F.Z.E. processes personal data to:

• Create and manage user accounts
• Enable item listings and exchanges
• Facilitate messaging
• Moderate content and ensure safety
• Protect minors using the Platform
• Enforce Terms and Conditions
• Comply with UAE legal obligations

Personal data is not used for behavioural advertising.

7. Legal Basis for Processing

Under UAE PDPL, Spirit Arabia Ventures F.Z.E. processes personal data based on:

• Consent (including parental consent for Minors)
• Contractual necessity
• Legal obligations
• Legitimate interest (platform safety, fraud prevention, moderation)

Consent may be withdrawn at any time by contacting support@schoolswap.me.

8. Sharing of Personal Data

Spirit Arabia Ventures F.Z.E. does not sell personal data.

Data may be shared with service providers necessary to operate the Platform, including:

• Cloud hosting providers
• Database and authentication providers
• Email delivery services

All providers process data under contractual confidentiality and security obligations.

Personal data may also be disclosed if required by UAE law or competent authorities.

9. International Transfers

If data is processed outside the UAE, Spirit Arabia Ventures F.Z.E. ensures appropriate safeguards are implemented in accordance with UAE PDPL.

10. Data Security

Spirit Arabia Ventures F.Z.E. implements appropriate technical and organisational measures, including:

• HTTPS encryption
• Secure cloud storage
• Access controls
• Restricted administrative access
• Account verification procedures

While reasonable safeguards are implemented, no internet-based platform is completely secure.

11. Data Retention

Personal data is retained:

• While the account remains active
• For up to 30 days after deletion
• Longer if required by UAE law or to resolve disputes

After this period, data is securely deleted or anonymised.

12. User Rights

Under UAE Federal Decree-Law No. 45 of 2021, users and Guardians have the right to:

• Access personal data
• Request correction
• Request deletion
• Withdraw consent
• Object to certain processing

Requests should be directed to: support@schoolswap.me

13. Updates to This Policy

Spirit Arabia Ventures F.Z.E. may update this Privacy Policy periodically.

Material updates will be communicated via the Platform or email.

Continued use of SchoolSwap after updates constitutes acceptance.

14. Governing Law

This Privacy Policy is governed by the laws of the United Arab Emirates.

Any disputes shall be subject to the jurisdiction of the competent courts of the UAE.

15. Contact Information