1. Introduction

This Privacy Policy explains how the RankUp marketplace ("RankUp," "we," "us," or "our") collects, uses, stores, shares, and protects your personal data when you use the RankUp mobile application, website, and related services (the "Service"). RankUp is operated by CyberForge Software Co. (شركة سايبر فورج لتصميم و برمجة البرمجيات الخاصة), a company based in Kuwait. RankUp is a peer-to-peer marketplace for gaming products operating in Kuwait and the wider Gulf region (Saudi Arabia, UAE, Qatar, Bahrain, and Oman).

We process your personal data in line with Kuwait's Personal Data Protection Law No. 26 of 2024 (the "DPL"), the user-rights principles set out in CITRA Resolution No. 26 of 2024 issued by the Communications and Information Technology Regulatory Authority (which we adopt as best practice even where it does not formally bind us), and other applicable Kuwaiti laws including the Electronic Transactions Law No. 20 of 2014.

By using RankUp, you confirm that you have read and understood this Policy. If you do not agree with how we handle your data, please stop using the Service.

2. Data We Collect

2.1 Account & Profile

• Name, username, email address, phone number (optional), and password (stored as a one-way hash)
• Profile photo and city / area of residence
• Sign-in identifiers when you choose to sign in with a third-party identity provider

2.2 Listings & User Content

• Photos you upload for your listings (auto-watermarked on upload to help prevent theft)
• Listing titles, descriptions, prices, categories, and item conditions
• Messages, reviews, and ratings exchanged with other users

2.3 Transactions & Gold

• Gold top-up history, balance, and in-app spending
• Payment metadata returned by our payment provider (transaction reference, status, masked card or wallet identifier). We do not see or store your full card number, CVV, or banking credentials

2.4 Device & Technical Data

• Device model, operating system and version, app version, language, and timezone
• IP address and approximate (city-level) location derived from it
• Push notification token used to deliver app notifications to your device
• Crash reports and basic diagnostic events to help us fix bugs

2.5 Camera & Photo Library

We only access your camera or photo library after you grant permission and only when you actively choose to take or pick a photo (for example, when adding a listing or changing your profile photo). We do not access these in the background.

3. How We Use Your Data

We use your data to:

• Create your account, sign you in, and keep your session secure
• Show your listings to other users and let buyers contact you
• Process Gold top-ups and keep an accurate balance
• Send transactional notifications (messages, listing activity, account & security alerts)
• Detect and prevent fraud, abuse, and policy violations, including through user reports and content moderation
• Improve performance and fix crashes
• Comply with legal obligations and respond to lawful requests from Kuwaiti authorities

4. Legal Bases for Processing

Under Kuwait's Personal Data Protection Law, we rely on the following bases:

• Your consent — for camera, photo library, push notifications, and optional features. You can withdraw consent at any time
• Performance of a contract — to deliver the Service you signed up for, including listings, messaging, and Gold top-ups
• Our legitimate interests — to keep the marketplace safe, prevent fraud, and improve the app, balanced against your rights
• Legal obligation — when we must process data to comply with Kuwaiti law or a lawful order

5. Sharing With Third Parties

We do not sell your personal data.

We may share limited information with trusted third-party service providers who help us operate, host, secure, and improve the Service. These providers are contractually bound to use your data only for the purposes we specify and to apply appropriate security safeguards. We share only what is reasonably necessary for them to perform their function.

Other RankUp users will see your username, profile photo, listings, and reviews. Buyers and sellers may exchange names and contact details when arranging a deal.

We may also disclose data to courts, regulators, or law enforcement in Kuwait or the Gulf when required by law, subpoena, or to protect the rights, property, or safety of RankUp, our users, or the public.

6. Data Security

We apply technical and organizational measures appropriate to the risks involved in handling your data. These include:

• Encrypted connections for all data in transit
• Encrypted storage of your data at rest
• One-way hashing of passwords — they are never stored or transmitted in readable form
• Secure storage of authentication tokens on your device
• Access controls so users and staff can only see what they are permitted to see
• Rate limiting and anti-abuse checks on sensitive operations

No system is perfectly secure. If we ever experience a personal data breach that affects you, we will notify you and the relevant authorities in line with Kuwait's Personal Data Protection Law.

7. International Data Transfers

Some of our service providers operate servers outside Kuwait. When we transfer your data abroad, we rely on industry-standard contractual protections and security certifications maintained by those providers, and on your acceptance of this Policy as informed consent for such transfers, as permitted by the DPL.

8. Data Retention

• Account data — kept while your account is active
• Listings — kept while active; expired or removed listings may be retained briefly for fraud and dispute checks
• Messages — kept while either party still has an account, then deleted
• Transaction & Gold records — retained for up to seven (7) years to meet accounting and legal requirements
• Crash logs — retained for up to 90 days
• After account deletion — your personal data is deleted within 30 days, except records we are legally required to keep

9. Your Rights

Under Kuwait's Personal Data Protection Law you have the right to:

• Access the personal data we hold about you
• Correct data that is inaccurate or incomplete
• Delete your data ("right to be forgotten") subject to our legal retention obligations
• Object to or restrict certain processing
• Receive a copy of your data in a portable, machine-readable format
• Withdraw consent at any time, without affecting the lawfulness of processing carried out before withdrawal
• Lodge a complaint with the relevant Kuwaiti supervisory authority

You can exercise most of these rights inside the app (Settings) or by contacting us. We respond within 48 hours and complete verified requests within 30 days.

10. Account Deletion

You can delete your account at any time from Settings > Account > Delete Account in the app, or by contacting us. Deletion is permanent and removes your profile, listings, and messages from public view. Some records may be retained as described in Section 8.

11. Children's Privacy

RankUp is intended for users aged 13 and older. Users under 18 must have permission from a parent or legal guardian to use the Service and to make any payment. We do not knowingly collect personal data from children under 13. If you believe a child has provided us with personal data, contact us and we will delete it promptly.

12. Cookies & Local Storage

Our mobile app does not use browser cookies. It stores small amounts of data on your device to remember your session, language, theme, and similar preferences. Our website uses minimal local storage and does not run third-party advertising trackers.

13. Apple App Tracking Transparency

RankUp does not track you across other companies' apps and websites for advertising purposes. We do not use the iOS IDFA for cross-app tracking and we do not show you advertising. Because of this, the Service does not present an App Tracking Transparency prompt.

14. Push Notifications

If you allow notifications, we send you alerts about messages, listings, transactions, and important account events. You can disable notifications at any time:

• iOS: Settings > Notifications > RankUp
• Android: Settings > Apps > RankUp > Notifications

15. Camera & Photo Permissions

You can review or revoke camera and photo permissions any time:

• iOS: Settings > RankUp > Photos / Camera
• Android: Settings > Apps > RankUp > Permissions

16. Changes to This Policy

We may update this Privacy Policy from time to time. When we do, we update the "Last Updated" date and, for material changes, notify you in the app or by email. Your continued use of the Service after the change becomes effective means you accept the updated Policy.

17. Governing Law

This Privacy Policy is governed by the laws of the State of Kuwait, including the Personal Data Protection Law No. 26 of 2024. Any dispute relating to this Policy is subject to the exclusive jurisdiction of the competent courts of Kuwait, unless local mandatory law in your country of residence requires otherwise.

18. Contact Us

For privacy questions, requests, or complaints, contact the operator of the Service:

Please put "Privacy" in the subject line so we can route your message to the right team.