Privacy Policy

Summary of Key Points

This summary provides key points from our Privacy Notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.

What personal information do we process? When you use the Anjum Hotel app, we process your mobile number, your name, your stay details and the services you request. If you choose to use Najma, the hotel's guest host in the app, we also process your conversations with her. Learn more about the information we collect.

Do we process any sensitive personal information? We do not ask for sensitive information. If you tell Najma or our staff about a dietary or mobility need, we keep it so we can serve you. Using our Services for Umrah or Hajj may suggest your religion. We do not use this for profiling, targeted advertising, or marketing. Learn more about sensitive information.

Do we collect any information from third parties? Your stay details come from your reservation in the hotel's reservation system. The reservation may have been made directly with us, or through a travel agent or booking website. Learn more.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Learn more about how we process your information.

In what situations and with which parties do we share personal information? We share information with service providers who work for us. If you choose to use Najma, we send your messages and some of your stay details to OpenAI, an artificial-intelligence provider, and only after you agree. We do not sell your personal information. Learn more about when and with whom we share your personal information.

How do we keep your information safe? We have adequate organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Learn more about how we keep your information safe.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Learn more about your privacy rights.

How do you exercise your rights? The easiest way to exercise your rights is by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.

How do you delete your account? In the app, go to Profile › Delete my account. If you no longer have the app, e-mail us. Learn more about deleting your account.

Want to learn more about what we do with any information we collect? Review the Privacy Notice in full.

1. What Information Do We Collect?

In Short: We collect the information you give us, your stay details from the hotel's reservation system, and some technical information from your phone.

Signing in to the Anjum Hotel app

• Mobile number. You sign in with your mobile number. We check that the number is yours by sending a one-time code by SMS or WhatsApp.
• Your stay. When you sign in, we may match your mobile number to a reservation in the hotel's reservation system (Oracle Opera), so the app can show your stay.
• Name. If you are exploring the app without a stay, we ask for your first and last name.

What the app stores

• Profile. Your mobile number, name, title, e-mail address (optional), nationality and preferred language.
• Stay details. Your room and tower, arrival and departure dates, number of adults and children, and meal plan. These are copied from the hotel's reservation system.
• Requests and feedback. Service requests, laundry orders, lost-item reports, feedback and star ratings.
• Location. Only when you press the SOS (emergency) tracker, so we can find you and help. We do not track your location in the background. You can change the location permission in your phone's settings.
• Device information. Device identifiers, the app version, the push-notification token for your phone, and the IP address your phone connects from, which we use for security.
• Room key (pilot). If you take part in the digital room-key pilot, your phone's key registration with ASSA ABLOY, the door-lock provider.
• Nujum loyalty. Your Nujum loyalty membership.
• Najma. If you choose to use Najma: your conversations with her, your voice messages, and short notes she remembers so she can serve you better. These notes come from things you ask her to remember or mention in conversation (such as your preferences, or a dietary or mobility need), from requests you make, and from notes our staff add to help serve you. Learn how Najma works with OpenAI.

Push notifications. We may ask to send you push notifications about your requests, your stay, or features of the app. You can turn them off in your phone's settings.

Visiting our website

You do not need to sign in to use this website. We count visits with analytics tools (see section 5). If you fill in a guest survey that we send you, we receive your mobile number, your rating and your comments.

Information from other sources

Your stay details come from your reservation in the hotel's own reservation system. The reservation may have been made directly with us, or through a travel agent or booking website.

Sensitive information

We do not ask for sensitive information. If you tell Najma or our staff about a dietary or mobility need (for example, a food allergy, or that you use a wheelchair), we keep it only so we can serve you. When you use Najma, these notes may be shared with OpenAI (see section 4). You can remove them at any time in the app in Profile › Najma.

Many of our guests travel for Umrah or Hajj, so using our Services may suggest your religion. We do not use this for profiling, targeted advertising, or marketing.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

2. How Do We Process Your Information?

In Short: We use your information to run the app and the services you ask for, to keep your account safe, and to comply with law. We process your information for other purposes only with your prior explicit consent.

We use your personal information to:

• Sign you in and keep your account safe. We check your mobile number with a one-time code, and we use device information and IP addresses to prevent misuse.
• Show your stay and deliver the services you ask for. This includes service requests, laundry orders, lost-item reports and, in the pilot, your digital room key.
• Run Najma, if you choose to use her. To understand your messages and your voice, answer your questions, and carry out your requests.
• Keep you informed. We send push notifications about your requests and your stay.
• Run the Nujum loyalty program.
• Improve our service. We read your feedback and ratings, and we look at statistics on which screens and features are used.
• Help you in an emergency. When you press the SOS tracker, we use your location to reach you. This protects your vital interests.
• Comply with law. For example, to keep the reservation records that hotels are required to keep.

3. What Legal Bases Do We Rely On To Process Your Information?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.

In the Anjum Hotel app:

• Najma, and sharing with OpenAI, rely on your consent. You give it in the app before you first use Najma, and you can withdraw it at any time in Profile › Najma.
• Your account and the services you request are processed to provide what you ask us for.
• Reservation records are kept to meet our legal obligations.
• Your location in an emergency is used to protect your vital interests.

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

• Consent. We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. Learn more about withdrawing your consent.
• Performance of a Contract. We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.
• Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
• Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

• If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
• For investigations and fraud detection and prevention
• For business transactions provided certain conditions are met
• If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
• For identifying injured, ill, or deceased persons and communicating with next of kin
• If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse
• If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province
• If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
• If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
• If the collection is solely for journalistic, artistic, or literary purposes
• If the information is publicly available and is specified by the regulations
• We may disclose de-identified information for approved research or statistics projects, subject to ethics oversight and confidentiality commitments

4. When And With Whom Do We Share Your Personal Information?

In Short: We share information with service providers who work for us, and in the situations described in this section. We do not sell your personal information.

Najma and OpenAI

Najma is the hotel's guest host in the Anjum Hotel app. Using Najma is optional.

• We ask first. Before you use Najma for the first time, the app shows a notice and asks your permission. You can say no and still use everything else in the app. You can withdraw your permission at any time in Profile › Najma. After that, nothing more is shared.
• Who receives it. When you use Najma (text messages, voice messages, a live voice conversation, or voice input in the feedback form), we send information to OpenAI, L.L.C. (United States), an artificial-intelligence provider. In a live voice conversation, your phone sends your voice to OpenAI directly, over a connection that our servers set up.
• What is sent. Your messages and voice recordings; your title and name; your room, tower, stay dates, number of guests and meal plan; your nationality and language; your recent requests in the app; and the notes Najma remembers about you.
• What is not sent. Your phone number, your e-mail address and your loyalty status.
• Why. So Najma can understand your question or your voice, answer it, and carry out your requests.
• How OpenAI handles it. OpenAI processes this information for us as a service provider. OpenAI states that it does not use data sent through its API to train its models, and that it keeps this data for up to 30 days to detect abuse.
• International transfer. This means your information is transferred to the United States.

Service providers

These companies process information on our behalf, only to provide their service to us:

• OpenAI: Najma (see above).
• Google Firebase: sends push notifications, checks that requests come from our genuine app, and counts which screens and features of the app are used. The usage statistics include your room number, but not your name, phone number or e-mail address.
• Twilio: sends one-time sign-in codes by SMS.
• WhatsApp (Meta): sends one-time sign-in codes by WhatsApp, if you choose WhatsApp.
• ASSA ABLOY: the door-lock provider. Registers your phone for the digital room key (pilot only).
• Microsoft (Microsoft 365 and Azure): the hotel's e-mail, including attachments of e-mails you send us.
• Cloudflare: protects and routes the traffic between the app and our servers.
• Netlify: hosts this website.
• Google Analytics and Plausible: count visits to this website (see section 5).

Your account and app data are stored on the hotel's own servers in Makkah, Saudi Arabia.

Other situations

• Legal requirements. We may share information when the law requires it, or when it is needed to protect someone's safety.
• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

We do not sell your personal information, and we do not share it for advertising.

5. Do We Use Cookies And Other Tracking Technologies?

In Short: Our website uses a few cookies and analytics tools. The app uses Google Firebase to count which screens and features are used.

Our website remembers your language choice with a cookie, and remembers your light or dark display choice on your device. We use Google Analytics, which sets cookies, and Plausible, which does not use cookies, to count visits and see which pages are used.

The Anjum Hotel app uses Google Firebase to count which screens and features are used (see section 4).

We do not show advertising, and we do not use these tools for targeted advertising.

Google Analytics

We may share your information with Google Analytics to track and analyze the use of the Services. To opt out of being tracked by Google Analytics across the Services, visit https://tools.google.com/dlpage/gaoptout. For more information on the privacy practices of Google, please visit the Google Privacy & Terms page.

6. How Long Do We Keep Your Information?

In Short: We keep your information while your account is open, and for the periods below.

• Your account. Your profile is kept until you delete your account (see section 14).
• Najma conversations and voice messages. Kept until you delete your account.
• Notes Najma remembers. They expire 12 months after they were last confirmed (24 months for preferences and needs). You can remove them sooner in the app in Profile › Najma.
• At OpenAI. OpenAI states that it keeps data sent through its API for up to 30 days to detect abuse.
• Reservation records. Kept in the hotel's reservation system for as long as Saudi regulations require hotels to keep them.
• Records of services delivered (requests, orders and feedback scores). Kept for the hotel's operations. After you delete your account, they no longer carry your name or phone number.
• System logs and backups. Overwritten in their normal cycle.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

7. How Do We Keep Your Information Safe?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

8. Do We Collect Information From Minors?

In Short: We do not knowingly collect data from or market to children under 18 years of age or the equivalent age as specified by law in your jurisdiction.

We do not knowingly collect, solicit data from, or market to children under 18 years of age or the equivalent age as specified by law in your jurisdiction, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18 or the equivalent age as specified by law in your jurisdiction or that you are the parent or guardian of such a minor and consent to such minor dependent's use of the Services. If we learn that personal information from users less than 18 years of age or the equivalent age as specified by law in your jurisdiction has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18 or the equivalent age as specified by law in your jurisdiction, please contact us at [email protected].

9. What Are Your Privacy Rights?

In Short: Depending on your state of residence in the US or in some regions, such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time, depending on your country, province, or state of residence.

In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. If a decision that produces legal or similarly significant effects is made solely by automated means, we will inform you, explain the main factors, and offer a simple way to request human review. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section "How Can You Contact Us About This Notice?" below.

We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.

If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawing your consent

If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. For Najma, withdraw your permission in the app in Profile › Najma; from then on, nothing more is shared with OpenAI. For anything else, contact us by using the contact details provided in the section "How Can You Contact Us About This Notice?" below.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

If you have questions or comments about your privacy rights, you may email us at [email protected].

10. Controls For Do-Not-Track Features

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice.

California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time.

Global Privacy Control

We treat a Global Privacy Control (GPC) signal as a request to opt out of the sale or sharing of your personal information for targeted advertising under applicable state privacy laws, including the California Consumer Privacy Act (CCPA). We do not sell personal information or share it for targeted advertising in any case. For more information about GPC, visit globalprivacycontrol.org.

11. Do United States Residents Have Specific Privacy Rights?

In Short: If you are a resident of the United States, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. More information is provided below.

Categories of Personal Information We Collect

The table below shows the categories of personal information we collect. For the full list, please refer to the section "What Information Do We Collect?"

We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:

• Receiving help through our customer support channels;
• Participation in customer surveys or contests; and
• Facilitation in the delivery of our Services and to respond to your inquiries.

Sources of Personal Information

Learn more about the sources of personal information we collect in "What Information Do We Collect?"

How We Use and Share Personal Information

Learn more about how we use your personal information in the section, "How Do We Process Your Information?"

Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Learn more about how we disclose personal information in the section, "When And With Whom Do We Share Your Personal Information?"

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" of your personal information.

We share personal information with the service providers listed in section 4, who process it on our behalf. We have not sold personal information, and we have not shared it for targeted advertising, in the preceding twelve (12) months. We will not sell or share personal information for targeted advertising in the future.

Your Rights

You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include:

• Right to know whether or not we are processing your personal data
• Right to access your personal data
• Right to correct inaccuracies in your personal data
• Right to request the deletion of your personal data
• Right to obtain a copy of the personal data you previously shared with us
• Right to non-discrimination for exercising your rights
• Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ("profiling")

How to Exercise Your Rights

To exercise these rights, you can contact us by emailing us at [email protected], or by referring to the contact details at the bottom of this document. To delete your account, see section 14.

We will honor your opt-out preferences if you enact the Global Privacy Control (GPC) opt-out signal on your browser.

Under certain US state data protection laws, you can designate an authorized agent to make a request on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with applicable laws.

Request Verification

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes.

If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request and the agent will need to provide a written and signed permission from you to submit such request on your behalf.

12. Do We Make Updates To This Notice?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated "Revised" date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.

13. How Can You Contact Us About This Notice?

If you have questions or comments about this notice, you may contact our Data Protection Officer (DPO) by email at [email protected], by phone at 966 12 5100000, or contact us by post at:

14. How Can You Review, Update, Or Delete The Data We Collect From You?

Based on the applicable laws of your country or state of residence in the US, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. To review or update your personal information, please contact us at [email protected]. You can remove the notes Najma remembers at any time in the app in Profile › Najma.

Delete your account in the app

Open the Anjum Hotel app and go to Profile › Delete my account. Confirm in two steps. Your account is deleted immediately.

What is erased:

• Your profile: name, mobile number, e-mail address, nationality and language
• Your sign-in sessions, and your device and push-notification registrations
• Your Najma conversations, voice messages and the notes Najma remembers
• Your feedback comments
• Your room-access numbers, and your room keys on every phone
• Your Nujum loyalty membership, which ends

What the hotel keeps:

• Your reservation records in the hotel's reservation system, which Saudi regulations require hotels to keep
• Records of services delivered (requests, orders and feedback scores), with your name and mobile number removed

System logs and backups are overwritten in their normal cycle.

If you no longer have the app

E-mail [email protected] and tell us the mobile number you used to sign in. We will delete your account within 30 days. We may ask you to confirm that the number is yours.

These steps are also on our account deletion page.