Privacy policy


This privacy notice is issued by GAWAPP, a brand of THE SYLLA GROUP FZ LLE company (all references to “GAWAPP”, “we”, “us” or “our” in this notice refer to GAWAPP). 

The purpose of this notice is to inform you of the data relating to you that we collect and use in connection with our app and the uses (including disclosures to third parties) we make of such data. 

We are not responsible for the content or privacy practices of any retailers who avail of the GAWAPP app.  As we set out below in the “Recipients of Data” section, when you participate in a particular retailer’s loyalty scheme through the GAWAPP app, we will share your personal data with that retailer.  We therefore encourage you to refer to the relevant retailer’s privacy notice.

If you have any questions about our use of your personal data, please contact us at

Personal data that we collect and process

We collect and process personal data relating to you in connection with your use of the GAWAPP app and our relationship with you. This personal data may include:

  • your name, age, gender and contact details, including your email address;
  • your social media handles or URLs, if you login to the app using Facebook or Google’s single sign-in feature; and
  • any other personal data relating to you that you provide to us or that we generate about you in connection with your use of this app

Usage data

We use an application to collate and analyse certain statistical information about the use of the app. When you use our app, the following information is retained about that use of the app:

  • the location and time when you have used the app in store; 
  • your IP address, IMEI, IMSI, and device ID; 
  • your location when you are using the map on our app; and
  • details about when the app crashes, time spent using the app,  and details of how the app is used.

No attempt is made to identify individual users or to associate the technical details listed above with any individual.

Purposes of processing and legal basis

We will use personal data relating to you for the purposes of:

  • providing services to you, including facilitating your collection of loyalty stamps in-store, maintaining a record of the loyalty stamps you have collected, and facilitating you to redeem your loyalty stamps in-store; 
  • improving and developing our app;
  • generating and analysing statistics regarding usage of the app, (where possible, personal data will be anonymised before being used for this purpose);
  • carrying out research and customer satisfaction surveys;
  • sending you promotional and marketing materials, subject to any preferences that you express when we collect your contact details or subsequently.  You can opt out of receiving promotional and marketing materials from us at any time by contacting;
  • fraud prevention, investigation and detection; and
  • establishing, exercising or defending legal claims.

The legal bases on which we process your personal data are:

  • where you have consented to our processing of your personal data;
  • to take steps at your request prior to entering into a contract with you or to perform a contract with you;
  • our legitimate interests in conducting our business in a responsible and commercially prudent manner. We will not process your personal data for these purposes if to do so would constitute an unwarranted interference with your own interests, rights and freedoms;
  • that this is necessary to comply with our legal and regulatory obligations.



Where we process your personal data on the basis of your consent, you have the right to withdraw your consent at any time.  You can withdraw your consent by contacting us at

Recipients of Data

We may disclose your personal data to other organisations in connection with the above purposes, including:

  • the retailers whose loyalty schemes you participate in through the GAWAPP app;
  • to third parties who we engage to provide services to us in connection with this app, such as outsourced service providers, IT services providers, professional advisers and auditors;
  • to third parties, their agents and professional advisors, subject to confidentiality obligations, for the purpose of a due diligence exercise by third parties in connection with any proposed merger, acquisition, re-organisation or transfer of our business and to any person proposing to participate in , or promote or underwrite or manage any such arrangement; and
  • to competent regulatory authorities and bodies as requested or required by law.



We will not hold your personal data for longer than is necessary.  We retain your personal data for as long as we need it for the purposes described in this notice, or to comply with our obligations under applicable law and, if relevant, to deal with any claim or dispute that might arise between you and us.

Requirement to Provide Personal Data

You are not under a statutory or contractual obligation to provide us with any personal data, however, in order to use the app you must provide us with the following minimum information: first name, email address, date of birth and password.  If you do not provide us with this information, we will not be able to make the functionality of the app available to you.

Transfers Abroad

In connection with the above we might transfer your personal data outside the European Economic Area, including to a jurisdiction which is not recognised by the European Commission as providing for an equivalent level of protection for personal data as is provided for in the European Union.  If and to the extent that we do so, we will ensure that appropriate measures are in place to comply with our obligations under applicable law governing such transfers. These may include entering into a contract governing the transfer that contains the ‘standard contractual clauses’ approved for this purpose by the European Commission or, in respect of transfers to the United States of America, ensuring that the transfer is covered by the EU-US Privacy Shield framework. If you would like to receive further details of the measures that we have taken in this regard, please contact us at

Your rights

You have the following rights, in certain circumstances and subject to certain restrictions, in relation to your personal data:

  • the right to access your personal data;
  • the right to request the rectification and/or erasure of your personal data;
  • the right to restrict the use of your personal data;
  • the right to object to the processing of your personal data; and 
  • the right to receive your personal data, which you provided to us, in a structured, commonly used and machine-readable format or to require us to transmit that data to another controller.

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


We may occasionally update this notice. We encourage you to periodically review this notice for the latest information on our privacy practices.