Privacy Policy

Last Updated: February 22, 2026

NASHA GROUP LLC ("we", "our", or "us") operates the TrueMap mobile application and website at https://truemap.org/. This Privacy Policy describes what data we collect, why we collect it, how it is used, and your rights under applicable law — including the UAE Federal Decree-Law No. 45/2021 on the Protection of Personal Data (PDPL).

By using TrueMap, you consent to the practices described in this policy. If you do not agree, please discontinue use of the application.

1. Who We Are

Data Controller: NASHA GROUP LLC
Contact: [email protected]
Jurisdiction: Dubai, United Arab Emirates

2. Minimum Age

TrueMap is intended for users aged 18 and older. We do not knowingly collect personal data from persons under the age of 18. If we become aware that a minor has provided personal data, we will delete it promptly. If you believe a minor has created an account, please contact us immediately.

3. Data We Collect

3.1 Account Data

• Email address (required for registered accounts)
• Optional profile fields: display name, gender, phone number
• Authentication tokens (Apple ID / Google Account sign-in, stored securely)
• For guest users: a unique device identifier (IDFV/UUID) not linked to your personal identity

3.2 Review and Content Data

• Text of submitted reviews
• Public photos attached to reviews
• Private verification materials (receipts, bank statement fragments) submitted as proof of visit — visible only to you and the assigned moderator, deleted immediately upon review completion

3.3 Technical and Fraud Prevention Data

When you submit a review, we automatically collect the following for fraud detection and quality control purposes:

• IP address
• Device model and operating system version
• Device language settings

This data is used exclusively by our internal risk monitoring system and is not shared with third parties.

3.4 Analytics and Usage Data

We collect anonymous, aggregated data about how you interact with TrueMap — including screen navigation, feature usage, and app performance. This data is used solely to debug issues, improve stability, and develop new functionality.

We use Mixpanel to collect analytics data. Mixpanel receives technical event data (e.g. "user opened promocodes screen") and does not receive your name, email, or any personally identifiable information. For details, see Mixpanel Privacy Policy.

3.5 Subscription and Payment Data

Premium subscriptions are processed through Apple App Store. We use RevenueCat to manage subscription status. RevenueCat receives only a non-personal subscription token from Apple — it does not receive your payment card details, name, or email address. For details, see RevenueCat Privacy Policy.

4. Legal Basis for Processing

Under the UAE PDPL, we process your personal data on the following bases:

• Consent — for push notifications, which you can withdraw at any time
• Contractual necessity — to provide the services you requested (account, reviews, promo codes)
• Legitimate interests — fraud prevention, platform security, and service improvement
• Legal obligation — compliance with UAE law, including content moderation requirements under Federal Decree-Law No. 34/2021 (Cybercrimes Law)

5. How We Use Your Data

• Providing and maintaining the TrueMap application and its features
• Verifying the authenticity of submitted reviews
• Moderating content before publication
• Personalizing promo code suggestions and in-app content
• Managing premium subscriptions
• Detecting and preventing fraudulent activity
• Improving app performance and developing new features
• Sending review status notifications (if enabled)
• Complying with applicable UAE laws and responding to lawful requests

6. Push Notifications

If you grant permission, TrueMap will send push notifications regarding the status of your submitted reviews (approved / rejected / under review). Notifications are never used for third-party marketing or advertising.

You may disable notifications at any time via Settings → Notifications → TrueMap on your device, or through the in-app notification settings.

7. Data Sharing

We do not sell, rent, or share your personal data with third parties for marketing purposes. Data is shared only in the following limited circumstances:

• RevenueCat — subscription status management (non-personal token only)
• Mixpanel — anonymous usage analytics (no PII)
• Law enforcement / judicial authorities — when required by UAE law or court order
• Business transfer — in the event of a merger or acquisition, users will be notified in advance

All infrastructure and user data is stored and processed on servers operated directly by NASHA GROUP LLC.

8. Private Verification Materials

Photos, receipts, or other documents submitted as private proof of visit are:

• Visible only to you and the assigned moderator
• Never published publicly under any circumstances
• Permanently and irreversibly deleted immediately after the review is approved or rejected
• Not retained, archived, or used for any other purpose

9. User-Submitted Public Photos

Photos submitted for public display within reviews are your responsibility. You must ensure that any public photo does not contain images of individuals who have not given their consent to be photographed or published, or who have not reached the age of consent under applicable law. By submitting public photos, you confirm you hold all necessary rights and consents. NASHA GROUP LLC bears no liability for user-submitted content that violates the privacy or rights of any third party.

10. Data Retention

• Account data — retained for the duration of your account plus 12 months after deletion request
• Published reviews — retained while your account is active; deleted upon account deletion
• Private verification materials — deleted immediately after review moderation is complete
• Technical/fraud data (IP, device info) — retained for up to 6 months
• Analytics data — anonymized and aggregated; no retention limit applies

11. Your Rights under UAE PDPL

Under Federal Decree-Law No. 45/2021, you have the right to:

• Access — request a copy of the personal data we hold about you
• Rectification — request correction of inaccurate or incomplete data
• Erasure — request deletion of your personal data (subject to legal retention obligations)
• Withdraw consent — revoke consent for notifications at any time
• Data portability — request your data in a structured, machine-readable format
• Objection — object to processing based on legitimate interests

To exercise any of these rights, contact us at [email protected]. We will respond within 30 days.

12. Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, loss, or disclosure. However, no method of electronic storage or transmission is 100% secure. We encourage you to use a strong password and to notify us immediately if you suspect unauthorized access to your account.

13. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be communicated by updating the "Last Updated" date on this page. Continued use of TrueMap after changes are posted constitutes your acceptance of the updated policy.