Sociogram’s Privacy Policy

At Sociogram, we respect your privacy and want to give you the best possible experience to ensure that you enjoy our Service. Your privacy and the security of your Personal Data are, and will always be, enormously important to us. So, we want to transparently explain how and why we collect, store, share and use your Personal Data - as well as outlining the rights, controls and choices you have in respect of Personal Data we hold about you.

Capitalised terms used in this Privacy Policy have the meanings given to them in the Definitions section below. Unless specifically defined, any capitalized term used throughout this Privacy Policy (but not defined herein) shall have the same meaning attributed to it in Sociogram’s General Terms and Conditions.

Please read this Privacy Policy carefully before using the Platform or submitting any information to us. This Privacy Policy will be binding upon you when you accept the Privacy Policy by clicking on the “agree” button on the Platform.  We may, from time to time, amend this Privacy Policy or parts of it in accordance with clause 1.2 below. If you do not agree to any part of this Privacy Policy, you must immediately cease accessing our Platform or using any of our Services.

Sociogram Technologies (company number 1061675) is incorporated in the Dubai Economic Department. Sociogram will act as the Controller for the purposes of the applicable laws (including the DIFC Data Protection Law No 5 of 2020, as may be amended) and can be contacted as indicated in the “How to Contact Us” section in clause 14 below.


This Privacy Policy aims to give you information on how Sociogram collects and processes your Personal Data through your use of the Platform, including any Data you may provide throughout the Platform when you install and sign up to Sociogram’s mobile application, register an Account, use any Service and/or sign up to our newsletter.

This Privacy Policy applies to your use of our Services and all information we collect through our Services. By clicking on the agree button on the Platform, you (i) agree irrevocably and without condition to this Privacy Policy, (ii) consent to your Personal Data being collected, processed, used and shared in accordance with this Privacy Policy, and (iii) agree that we may provide notices to you electronically on the terms and conditions set forth in this Privacy Policy and Sociogram’s General Terms and Conditions.

It is important that you read this Privacy Policy together with Sociogram’s General Terms and Conditions, and any fair processing notice we may provide on specific occasions when we are collecting or processing Personal Data about you so that you are fully aware of how and why we are using your Personal Data. This Privacy Policy supplements the other notices and is not intended to override them.

If you are a resident of the European Union, you may be protected by and enjoy additional rights under the European Union’s General Data Protection Regulation 2016/679, also known as GDPR.

You agree that Sociogram may amend this Privacy Policy from time to time, and in Sociogram’s sole discretion. Sociogram will, where possible, provide you with 7 days’ notice of any amendments to this Privacy Policy.

Sociogram will publish any amendment or change to this Privacy Policy or any part of it on the Platform and will specify the date on which such amendment becomes effective. Your continued use of the Platform and/or any Service after the stated effective date constitutes your acceptance of the relevant revised policy, amendment or change.

You agree and undertake to review our Privacy Policy each time you visit our Platform and/or prior to each use of our Services. If you do not agree to our Privacy Policy, as updated from time to time, you undertake to cease using our Platform and/or Services immediately.

Please note that it is crucial to the Performance of our Services and correct working of the Platform that the Personal Data we hold about you is accurate and current. Please keep us informed and updated if your Personal Data changes during your relationship with us. You can review and update your Personal Data in your Account settings at any time by logging in to your Account.

This Privacy Policy does not apply to information that you have provided or made accessible to other Users (including Creators) or third parties. Each User is solely responsible for complying with all requirements of applicable privacy laws in connection with the information that they obtain and process for the purposes of managing their contacts or joining, organizing or communicating through Activities, Groups or Clans.

Our Platform may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share Data about you. We do not control these third-party websites, plug-ins and applications, whether or not they operate on top of the Platform or on an external website, and are not responsible for their privacy statements. When you engage such third-party website, plug-in or application, whether or not you have left our Platform, we encourage you to read the privacy policy of each website, plug-in or application you visit or engage.

We use different methods to collect Personal Data from and about you through the following categories of sources:

4.4   Information shared with our service providers: We may share your Personal Data with:

We may collect, use and share your Personal Data for the following reasons:

We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your Personal Data without your knowledge or consent, in compliance with this Privacy Policy, where this is required or permitted by law.

Your data security is important to us, and we take reasonable steps to ensure that your Personal Data is treated securely and to minimize unauthorised access to, collection, use, disclosure of your Personal Data, or similar risks.
We have put in place suitable physical, electronic and managerial procedures to put our Users at ease and to safeguard and secure the information we collect. Notwithstanding Sociogram’s culture of transparency, in order to minimise the likelihood of security breaches we do not publicly disclose the nature of such security measures.
Although we aim to create a safe and secure environment, we cannot guarantee absolute security of the transmission or storage of your information. To the extent permitted by applicable law, we expressly exclude any liability arising from any unauthorised access to your Personal Data.
Please contact us at immediately if you become aware of any unauthorised use of your Account by anyone else or any other breach of security.

You may access, review, change, or correct information that you have provided by logging into your Sociogram Account (in your Account settings) at any time. We may require additional information to verify your identity before granting access or otherwise changing or correcting your information.

If you wish to deactivate your account, you can do so via the general settings on the Platform. If you face any issue regarding deactivation, you can contact us as described under clause 13 below.

In order to provide certain Services, we may need to access to your location information, including precise geolocation information collected from your device. We will collect information about your location, which we use to make better recommendations for Groups and Activities in your area, and to improve our Platform. If you do not consent to collection of this information, certain Services will not function properly and you will not be able to use those Services. You can stop our collection of location information at any time via the user settings on the Platform or via your phone’s location service settings. If you do so, some of our Services will no longer function.

You can opt out of receiving in-app and/or push notifications containing promotional information from us via the notification settings on the Platform or by clicking on the unsubscribe button provided at the bottom of each promotional notification sent. If you decide to opt out, we may still send you non-promotional communications via in-app or push notifications or via email and SMS, such as message notifications.

You may withdraw your consent to us processing your Personal Data at any time if we process your Personal Data on the grounds of your consent. If you withdraw your consent to our processing of your Personal Data, Sociogram will respect your decision and will stop processing your Personal Data as soon as reasonably practicable. This will not affect the legality of our processing of your Personal Data up until the point at which you withdraw your consent.
If you withdraw your consent to our processing of your Personal Data however, our Services will not function properly and you will no longer be able to use our Services.
Please note that after your withdrawal of consent, we may still process and retain your Personal Data for a period of time that complies with applicable law or as we believe is reasonably necessary to comply with applicable law, regulation, legal process, or governmental request.

You may have the right to receive Personal Data that you have provided to us in a structured, commonly used and machine-readable format where the processing is:

You have the right to not be discriminated against your exercise of these privacy rights. We will not discriminate against you, deny, charge different prices for, or provide a different quality of goods or services if you choose to exercise your rights under this Privacy Policy.

You have the right to inquire as to whether we disclose your Personal Data to third parties for their direct marketing purposes at any time. Sociogram currently do not disclose your Personal Data for others’ direct marketing purposes.

If you feel that we have processed your Personal Data unfairly or unlawfully, you have the right to complain about us to the Commissioner as per the DIFC laws and regulations. We would appreciate it if you would please contact us first so that we can try to put things right for you.

If you choose to exercise your rights under this Privacy Policy, you may do so online at or by contacting us as indicated in the “How to Contact Us” section below. In order to help protect your privacy and maintain security, we take steps to verify your identity and will require you to be logged in to your account before granting you access to your personal information or complying with your request.

To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.

The Personal Data we collect from you may be transferred to, and stored at, a destination outside the DIFC as it may be processed by our affiliates and group companies, or by our service providers when they are located outside of the DIFC.

Where Personal Data is transferred between Sociogram’s affiliates and group companies to locations which the Commissioner has not deemed to have “adequate level of protection”, we have put in place contracts that include standard data protection clauses as adopted by the Commissioner.

Where required for certain matters, we may use service providers located outside the DIFC and transfer Personal Data to such service providers (for example, technology services).
Depending on the circumstances we may also need to transfer Personal Data to other kinds of third parties, for example regulators, government authorities as necessary.
Where the recipient is located in a jurisdiction which has not been deemed by the Commissioner to have adequate level of protection in place, we transfer the Personal Data using one of the following measures:

We will only retain your Personal Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances, we may anonymize your Personal Data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

If you have questions or concerns regarding this Privacy Policy, or any feedback pertaining to your privacy and the Services that you would like us to consider, please contact us at

If you believe our privacy notice or applicable laws relating to the protection of your personal information have not been respected, you may file a complaint with our team as described above. If you file a complaint with our team, we will respond to let you know when you can expect a further response. We may request additional details from you regarding your concerns and may need to engage or consult with other parties in order to investigate and address your issue. We may keep records of your request and any resolution.

Effective as of 30th of May2022