Privacy Policy – English

1. Introduction

Emprella Spark Digital Company Technical LLC, the owner and operator of SPORNATION, respects your privacy and is committed to protecting personal data in accordance with the Saudi Personal Data Protection Law, its Implementing Regulations and other applicable laws. This Policy explains how we collect, use, disclose, retain and protect personal data and the rights available to you.

2. Scope

This Policy applies to the SPORNATION app, website, pages and related services, and to users, customers, visitors, merchants and service providers. It does not govern independent third-party services accessed through external links; those services are subject to their own policies.

3. Controller

Controller: Emprella Spark Digital Company Technical LLC.

Unified National Number: 7028817786.

Address: Eastern Province Chamber Investment Tower, Building 3030, Al Hussam District, Dammam 34223, Additional Number 6512, Kingdom of Saudi Arabia.

Privacy and support email: info@spornation.com.sa.

Phone: +966 50 807 0260.

4. SPORNATION’s Role and Marketplace Providers

SPORNATION operates a digital marketplace connecting users with merchants and providers of sports products and services. The Company is the controller for data needed to operate the platform, accounts, payments, support, security and analytics. Merchants or service providers may act as independent controllers for data they receive to fulfil an order, booking or service and must use it only for lawful transaction-related purposes.

5. Data We May Collect

Depending on your actual use, we may collect:

• Identity and account data, such as name, username and date of birth where required.

• Contact details, such as email address and mobile number.

• Delivery and address data.

• Order, booking, refund and transaction records.

• Cart, favorites and preference data.

• Merchant and service-provider information.

• Device and technical data, such as IP address, device type, operating system, app identifiers, crash and security logs.

• Usage and analytics data.

• Approximate or precise location only where needed and after the appropriate device permission.

• Support communications, complaints and ratings.

• Payment-related information supplied by payment providers, such as transaction status, reference and masked card details. We do not intend to store full card data where payment is processed by a licensed external provider.

6. Sources

We receive data directly from you, through your use of the app and website, from merchants and service providers, payment and shipping companies, authentication, analytics and communications vendors, and competent authorities where legally required.

7. Purposes

We use data to:

• Create and manage accounts.

• Fulfil, confirm, modify or cancel orders and bookings.

• Process payments, refunds and invoices.

• Enable delivery and transaction communications.

• Provide support and handle complaints and disputes.

• Operate carts, favorites and notifications.

• Verify identity and prevent fraud and abuse.

• Protect platform security and manage incidents.

• Improve performance and user experience and conduct analytics.

• Personalize content and offers where legally permitted.

• Meet legal, regulatory, accounting and tax duties.

• Establish, exercise or defend legal claims.

8. Legal Bases

We rely on the appropriate legal basis, including contract performance or steps taken at your request, legal obligations, consent where required, vital interests, and legitimate interests that do not disproportionately override your rights and fundamental interests.

9. Sharing

We may share data as necessary with:

• Merchants and service providers.

• Shipping and delivery companies.

• Payment, refund and fraud-prevention providers.

• Hosting, infrastructure, backup and cybersecurity providers.

• Analytics, messaging, notification and customer-support vendors.

• Legal advisers, accountants and auditors.

• Government, judicial or regulatory authorities where legally required.

We do not sell personal data. Processors are subject to appropriate safeguards and contractual obligations.

10. International Transfers

Some data may be processed outside Saudi Arabia by international service providers. Transfers are made only after meeting applicable legal requirements, including necessity and risk assessments, protection-level review, contractual safeguards and required approvals or permits. The Company maintains an internal record of processing providers and locations; further information may be requested at info@spornation.com.sa.

11. Cookies and Similar Technologies

Our website may use cookies and similar technologies for essential operation, preferences, security, performance and analytics. Essential cookies support the service; non-essential cookies are subject to consent where applicable and may be managed through the consent tool or browser settings.

12. Retention

We retain data only as long as necessary:

• Account data: while the account is active and for up to five years after closure, unless a shorter or longer period is justified.

• Orders, bookings, invoices and payment records: ten years from the transaction or any longer applicable statutory period.

• Support and complaint records: three years after closure.

• Security, access and crash logs: twelve to twenty-four months depending on purpose and risk.

• Marketing data: until consent is withdrawn or an objection is made, while retaining a minimal suppression record to respect your choice.

Data is then deleted or anonymized unless retention is required for legal proceedings or obligations.

13. Security

We use technical and organizational measures appropriate to the data and risks, including encryption in transit, access controls, authentication, backups, logging and monitoring, vulnerability management, security testing, staff training and incident-response plans. No electronic method is completely secure.

14. Incidents and Notifications

If a breach, unauthorized access or security incident affects personal data, we take containment, investigation, documentation and remediation steps and notify the competent authority and affected individuals where and within the time required by law.

15. Your Rights

Subject to applicable law, you may have the right to:

• Be informed about collection and processing.

• Access your data and obtain a clear copy.

• Correct, complete or update inaccurate data.

• Request destruction where legally applicable.

• Withdraw consent where processing is based on consent.

• Object to or request restriction of certain processing where provided by law.

• Lodge a complaint with the Company or the competent authority.

We may verify your identity and respond within the statutory period. Requests may be sent to info@spornation.com.sa or submitted through account and support channels.

16. Account Deletion

You may request deletion in the app through Account > Settings > Delete Account or at:

https://www.spornation.com.sa/home/delete-account

Deletion disables the account and deletes or de-identifies data not subject to lawful retention. Certain transaction, complaint or security records may be retained for legal duties, fraud prevention and dispute resolution. The web page and in-app deletion flow must be operational before this Policy is published.

17. Children and Minors

The service is primarily intended for adults who can enter transactions. Users must be at least 18 years old to create an account and transact independently. A minor may use the service only under the supervision and consent of a parent or lawful guardian and where the product features and law permit. If we learn that a minor’s data was collected without a valid legal basis, we will take reasonable steps to delete or restrict it.

18. Marketing and Notifications

We may send essential operational messages about accounts, orders, bookings, payments and security. Marketing communications are sent in accordance with legal requirements and consent where required. You may opt out through app settings, an unsubscribe mechanism or by contacting us; essential operational messages may continue.

19. Automated Decisions and Personalization

We may use automated rules or models to rank search results, recommend products and services and detect unusual activity. We do not make decisions producing legal or similarly significant effects based solely on automated processing unless permitted by law and required safeguards are provided.

20. Changes

We may update this Policy when services, practices or legal requirements change. The updated version and effective date will be published, and additional notice may be provided for material changes where required.

21. Contact and Complaints

For privacy rights, questions or complaints:

Email: info@spornation.com.sa

Phone: +966 50 807 0260

Address: Eastern Province Chamber Investment Tower, Building 3030, Al Hussam District, Dammam 34223, Additional Number 6512, Kingdom of Saudi Arabia.

22. Effective Date

Effective date: 13 July 2026.

Last updated: 13 July 2026.