Privacy Policy

© Tryli FZ LLC. All rights reserved.

Last Modified Date: 17 January 2026

Introduction

Tryli FZ LLC, its subsidiaries, affiliates, and operating entities (collectively, "Tryli," "Company," "we," "us," or "our") recognize the importance of protecting the privacy of all consumers ("you" or "user") who access and/or use, whether as a guest or a registered user, our websites, or portions of our websites, including any content, functionality, and services offered on or through our websites, any webpages, our online or offline mobile applications that run on smartphones, tablets, and other devices (including the Tryli Mobile App and associated Tally forms) which provide dedicated non-browser-based interaction between you and our sites (all of which are collectively called our "Sites").

This Privacy Policy will inform you as to our purposes for collecting and processing your personal information, our practices for collecting, using, maintaining, retaining, protecting, and disclosing your personal data when you visit this and all of our Sites (regardless of where you visit it from) and inform you about your privacy rights and how the law protects such rights.

1. IMPORTANT INFORMATION AND WHO WE ARE

PURPOSE OF THIS PRIVACY POLICY

This Privacy Policy aims to give you information on how the Company collects and processes your personal data through your use of any of its Sites, including any data you may provide through this Site when you register or sign in on any of our Sites, participate in a dining activation, upload proof of purchase, submit feedback, or claim a cashback reward.

We will only use your personal data to provide you with our services, for legitimate business purposes, and to fulfil legal obligations. It is important that you read this Privacy Policy together with any other privacy notice or 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 data. This Privacy Policy supplements these other notices and is not intended to override them.

PERSONS UNDER AGE OF 18 YEARS

The Sites are not intended for children, and we do not knowingly collect data relating to children. Our Sites are not intended for use by persons under 18 years of age without legal parental or guardian consent. No one under age 18 may provide any personal information to or on our Sites without legal parental or guardian consent. We do not knowingly collect personal information from persons under 18 if such information is provided without legal parental or guardian consent. If you are under 18, do not use or provide any information on our Sites, or on or through any of their features, register on the Sites, make any purchases or submissions through our Sites, use any of the interactive or public comment features of our Sites, or provide any information about yourself to us, including your name, address, telephone number, e-mail address, or any screen name or user name you may use without legal parental or guardian consent. If we learn we have collected or received personal information from a person under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a person under 18 for which there is no legal parental or guardian consent, please contact us.

CONTROLLER

The Company is made up of different legal entities. This Privacy Policy is issued on behalf of the Company so when we mention "Company", "Tryli", "we", "us" or "our" in this Privacy Policy, we are referring to the relevant company responsible for processing your data.

We have appointed a data protection officer ("DPO") who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

CONTACT DETAILS

Attention: Data Protection Officer

Email address: marko@tryli.io

You have the right to make a complaint at any time to the relevant supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the relevant supervisory authority so please contact us in the first instance.

CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

This version was last updated on 17 January 2026 and shall come into effect on 17 January 2026 (“Effective Date”). Historic versions of this document can be obtained by contacting us.

It is important that the personal data we hold about you is accurate and current (specifically your banking details for payouts). Please keep us informed if your personal data changes during your relationship with us.

THIRD-PARTY LINKS

The Sites may include links to third-party websites (such as delivery platforms like Talabat, Deliveroo, Careem, or Noon), 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 and are not responsible for their privacy statements. When you leave our Sites, we encourage you to read the privacy policy of every website or other site you visit.

2. THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

Depending on which of our products and/or services you use and how you interact with our Sites, we collect different kinds of information from or about you. We may collect, use, store, and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data includes first name, last name, address, username or similar identifier, marital status, title, date of birth, gender, profile image, country of residence, nationality, and phone number.
Contact Data includes billing address, delivery address, location, email address, and/or telephone numbers (including mobile numbers linked to AANI or other payment networks).
Financial Data includes your bank IBAN, Swift Code, and account holder name necessary for us to process cashback payouts to you. We do not store your credit card information used for purchasing meals; this is handled by your chosen delivery platform or restaurant.
Verification Data includes images of itemized receipts, screenshots of digital delivery confirmations, order reference numbers, and timestamps used to verify your participation in a campaign.
Content Data includes photos of food, packaging, or menus uploaded onto any of our Sites by you, or shared with other users of our Sites by you via our Sites.
Transaction Data includes details about payouts sent to you from Tryli and details of activations you have participated in.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, make and model (mobile phones only), operating system, hardware version, platform, device settings, and other technology identification on the devices used to access our Sites, file and software names and types, device identifiers, time zone setting and location, device locations such as through GPS, Bluetooth or WiFi signals, browser plug-in types and versions, operating system and platform, connection information such as the name of your mobile operator or ISP, browser type, language and time zone, mobile phone number and IP address.
Profile Data includes your username and password, participation history, your interests, preferences, feedback, and survey responses regarding Partner Restaurants.
Usage Data includes information about how you use our Sites, products, and services including the claiming of our offers, how you use your devices to access our Sites, including the screens you visit and searches you make.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use, and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Site feature or to provide a Partner Restaurant with an average rating score. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

We do not collect the following Special Categories of Personal Data: your philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. Nor do we collect any information about criminal convictions and offences.

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you (for example, the requirement to upload a receipt to claim a reward), and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with the cashback reward). In this case, we may have to cancel or reject a submission you have made with us, but we will notify you if this is the case at the time.

3. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity, Contact, Financial, Verification, and Content Data by filling in forms (including third-party forms embedded in our service, such as Tally) or by corresponding with us by post, phone, email, or otherwise. This includes personal data you provide when you:
- Create an account or register on our Sites.
- Join an event or activation campaign.
- Upload proof of purchase (receipts/photos).
- Provide feedback or survey responses about a restaurant.
- Request payouts or marketing to be sent to you.
- Enter a competition, promotion, or survey.
- Correspond with us (online or offline including via email addresses and phone numbers), if you contact us.
- Post material on our Sites.
You also may provide information to be published or displayed (hereinafter, "posted") on public areas of our Sites or transmitted to other users of our Sites or third parties (collectively, "User Contributions"). Your User Contributions are posted on and transmitted to others at your own risk. Although we limit access to certain pages, you may set certain privacy settings for such information by logging into your account profile or by contacting us. Please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of our Sites with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.
Automated technologies or interactions. As you interact with our Sites, we may automatically collect Technical and analytics Data about your equipment, location, browsing actions; user behavior, interactions, and patterns. We collect this personal data by using cookies, IP address, server logs, web beacons, and other similar technologies. We may also receive Technical Data about you if you visit other Sites employing our cookies.
- Cookies: We automatically capture some information through the use of cookies. A cookie is a small file that is placed onto your desktop or mobile device when you visit our Sites in order to enable certain features and functionality of our Sites.
- Category 1: Strictly necessary cookies. These cookies are essential for enabling our Sites to provide certain of your requested services such as retaining your login session.
- Category 2: Performance cookies. Performance cookies collect anonymous information on the users of our Sites to enable us to improve the operation of our Sites.
- Category 3: Functionality cookies. These cookies retain choices you make such as member ID, email ID, and other preferences.
- Category 4: Targeting or advertising cookies. These cookies collect information about your browsing habits to allow us to provide advertising relevant to you.
- Web beacons: Pages of our Sites and our e-mails may contain small electronic files known as web beacons that permit the Company to count users who have visited those pages.
- Log files: We may use log files to capture your activities on our apps as they interact with our Sites.
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
- Technical Data from analytics providers (e.g., Google Analytics), advertising networks, and search information providers.
- Contact and Financial Data from providers of technical, payment, and delivery services.
- Identity and Contact Data from social media platforms (if you log in via Google/Facebook).

4. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Where we need to perform the contract we are about to enter into or have entered into with you (e.g., validating your order to pay your reward).
Where we need to perform a contract we have with a third party (e.g., reporting your feedback to the Partner Restaurant).
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third-party direct marketing communications to you via email, text message, or other means. You have the right to withdraw consent to marketing at any time by contacting us.

5. PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below, in a tabular format, a description of all the purposes and methods for which we plan to use your personal data, and which of the legal bases we rely on to do so.

6. USE OF AUTOMATED VERIFICATION SYSTEMS

The Website and Application may employ automated systems (including AI and OCR technology) to assist in the verification of receipts and photos submitted for campaigns. When you use our services, we may process certain information to validate your submission automatically.

Information We Collect:

User Inputs: Receipts, timestamps, and order values extracted from images.
Usage Data: Frequency of submissions and approval rates.

How We Use Your Information:

Detecting duplicate receipts or manipulated images (Fraud Detection).
Verifying that the order date and value meet the campaign criteria.
Improving the accuracy of our verification algorithms.

Data Retention:

Images submitted for verification may be retained securely to prevent future duplicate submissions and for audit purposes.

7. MARKETING

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Direct Marketing by the Company

If you do not wish to have your personal data used by the Company to promote our own or third parties' products or services, you can opt-out by contacting us. If we have sent you a promotional e-mail, you may send us a return e-mail asking to be omitted from future e-mail distributions.

Targeted Advertising

If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers' target-audience preferences, you can opt-out by contacting us.

OPTING OUT

You can ask us or third parties to stop sending you marketing messages at any time by logging into the Site and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting us at any time.

8. COOKIES

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our Sites may become inaccessible or not function properly.

9. LOCATION INFORMATION

You can choose whether or not to allow our Sites to collect and use real-time information about your device's location through the device's privacy settings. If you block the use of location information, you may not be able to see events or campaigns specific to your geographic area.

10. CHANGE OF PURPOSE

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.

11. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 5 above.

Partner Restaurants: We share your feedback, ratings, and photos (Content Data) with the restaurants you order from. We generally anonymize this data unless specific issue resolution is required.
Internal Third Parties: Our companies, subsidiaries, and affiliates.
External Third Parties:
- Service providers acting as processors who provide IT and system administration services (e.g., Bubble, Tally, Amazon Web Services).
- Professional advisers including lawyers, bankers, auditors, and insurers.
- Regulators and other authorities acting as processors or joint controllers who require reporting of processing activities.
Business Transfers: Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

12. INTERNATIONAL TRANSFERS

We share your personal data within the Company. This may involve transferring your data outside the European Economic Area (EEA) or the United Arab Emirates (UAE). Many of our external third parties (such as cloud hosting providers) may be based outside the UAE/EEA.

Whenever we transfer your personal data, we ensure a similar degree of protection is afforded to it by ensuring safeguards are implemented, such as using specific contracts which give personal data the same protection it has in Europe/UAE.

13. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

14. DATA RETENTION

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

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, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure, and the applicable legal requirements.

15. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the following:

Request access to your personal data.
Request correction of your personal data.
Request erasure of your personal data.
Object to processing of your personal data.
Request restriction of processing your personal data.
Request transfer of your personal data.
Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us.

16. UNFOUNDED ACCESS REQUESTS

If your request to access your personal data is clearly unfounded, unsubstantiated, repetitive or excessive, we may refuse to comply with your request in these circumstances.

17. WHAT WE MAY NEED FROM YOU

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.

18. TIME LIMIT TO RESPOND

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex.

19. GLOSSARY

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

20. UPDATES TO THIS PRIVACY POLICY

We may amend this Privacy Policy from time to time to keep it up to date with legal requirements and the way we operate our business. If we decide to change our Privacy Policy, we will place any updates on our Sites.

21. LEGAL

Without prejudice to your rights under applicable laws, our Privacy Policy is not a contract and does not create any legal rights or obligations.