1. ABOUT THIS PRIVACY POLICY

This Privacy Policy explains how Personal Data is collected, used, disclosed, stored, transferred and protected when you access or use the Newshunt website at www.newshunt.io, the Newshunt mobile applications for iOS and Android, and related Newshunt services (together, the "Platform").

Newshunt is a digital news aggregation and discovery service that enables users to discover and access news, live media, videos, short-form content and other material obtained from third-party publishers and other sources. Newshunt also provides personalised news feeds and recommendations.

This Privacy Policy is intended to operate as a global master privacy notice. It is designed to address the Saudi Personal Data Protection Law ("PDPL") and its Implementing Regulations and, where applicable to a particular user or processing activity, other data protection and privacy laws that may apply to your local jurisdiction.

Applicable law may provide additional or different rights depending on where you live or how Newshunt offers the Platform in your country. Newshunt may publish country- or region-specific privacy notices or supplements where required or appropriate. A regional supplement or mandatory local law will prevail to the extent it provides protections that cannot lawfully be reduced by this Privacy Policy.

2. WHO IS RESPONSIBLE FOR YOUR PERSONAL DATA?

The controller or responsible business for Personal Data processed through Newshunt is THREE PILLARS FOR TECHNOLOGY AND COMMUNICATIONS CO ("Newshunt", "we", "our" or "us"), except where another entity is expressly identified as controller for a particular processing activity.

Commercial Registration Number: 1010353205

Registered address: Building No. 6737, Al Olaya Street, King Fahd District, Riyadh 12271, Kingdom of Saudi Arabia

Website: www.newshunt.io

Privacy contact: info@newshunt.io

3. PERSONAL DATA WE COLLECT

The Personal Data we collect depends on how you use Newshunt, whether you are signed in, the device and features you use, the permissions you grant and the choices you make. In this Privacy Policy, "Personal Data" also includes "personal information" or an equivalent term where applicable law uses a different expression.

3.1 Account and contact information

Where you create or use an account, we may process:

• name, email address, telephone number, username, User ID and profile information;

• authentication credentials or securely protected authentication information;

• identifiers or account information received from supported authentication providers, including Google Sign-In and Apple Sign-In; and

• information required to create, administer, secure or delete your account.

3.2 News preferences and Platform activity

We may collect information about how you use and interact with Newshunt, including:

• news sources and categories you follow or select;

• articles, stories, videos or other content you view;

• searches and search history;

• saved articles and bookmarks;

• reactions and other interactions with content;

• reading history;

• language, country and regional preferences; and

• other activity used to operate, personalise, analyse or improve the Platform.

When you use the Platform without signing in, the data collected depends on the platform. On the website, Newshunt determines country from the IP address (or uses a country manually selected by the user), sends that country code with API requests, and receives standard request-level technical data such as the request-origin IP address. In the mobile applications, logged-out use may involve a device identifier, product-interaction information and crash data or logs. Where you are signed in, relevant preferences and activity may be associated with your account so that account features and personalised feeds can operate.

3.3 Device, network and diagnostic information

When you use the Platform, we may automatically receive or generate technical information including IP address, device type and model, operating system, browser information, device or application identifiers, application version, language and regional settings, push-notification token, security and authentication logs, crash information, error logs and other diagnostic information.

3.4 Location information

Location practices differ by platform. On the website, Newshunt uses the user's IP address to determine country or region for location-relevant content and does not collect approximate or precise GPS/device location. The iOS application likewise uses IP-derived country/city information and does not request or collect approximate or precise device/GPS location. The Android application may request optional approximate or precise location permission. If the user grants permission, the app obtains the current latitude and longitude and sends those coordinates to the Newshunt API to determine country and language code. If permission is denied or location is unavailable, the Android app can use network/geocoding information and, if necessary, the country associated with the device SIM/network instead. Location permission is optional and the Android app can function without granting it.

3.5 Photos or media you choose to provide

Where a Newshunt feature allows you to select or upload a profile image, photo or other media, we may process the content you choose to provide and information reasonably necessary to provide that feature. Profile images and comments submitted through public-facing features may be visible to other users and members of the public. The method used to select media and the device permissions requested may differ by operating system and application version. You can manage available device permissions through your device settings.

3.6 Communications and privacy requests

If you contact us, submit feedback, make a complaint, report content or exercise a privacy right, we may process your contact details, account details where relevant, the contents of your communication and information reasonably necessary to investigate and respond.

3.7 Consent, preference and compliance records

We may record privacy choices and related compliance information, such as cookie or analytics preferences, consent or withdrawal records, notification settings, location-permission status, rights-request records and information reasonably necessary to demonstrate compliance with applicable law.

4. HOW WE COLLECT PERSONAL DATA

We collect Personal Data:

• directly from you, for example when you create an account, select preferences, search, follow sources, save or react to content, choose a profile image, contact us or exercise a privacy right;

• automatically from your device or use of the Platform, including through server logs, cookies, local-storage technologies, SDKs, analytics, application identifiers and crash-reporting technologies;

• from authentication providers where you choose to use Google Sign-In, Apple Sign-In or another supported sign-in method; and

• from technology and service providers where they provide information to us in connection with services they perform for Newshunt.

Information needed to create or authenticate an account, establish a secure connection or provide a feature may be required for that feature. Other information, such as optional location access, non-essential analytics, optional notifications or other consent-based processing, is optional where applicable law requires a choice. If you do not provide optional information, the relevant optional feature may not work, but unrelated functionality should remain available where reasonably possible.

5. WHY WE USE PERSONAL DATA AND OUR LEGAL BASES

We process Personal Data for specified purposes and only where an appropriate legal basis applies. The exact legal basis can differ by jurisdiction and by processing activity. We may use Personal Data to:

• provide, operate, maintain and secure Newshunt;

• create, authenticate and administer accounts;

• provide requested functions such as followed sources, selected categories, searches, bookmarks, reactions and account preferences;

• remember language, country, region and other preferences;

• organise, rank and personalise news feeds and recommendations;

• deliver push notifications where enabled;

• analyse how Newshunt is used and improve functionality and performance;

• identify and resolve crashes, errors and technical problems;

• prevent fraud, misuse, unauthorised access and security incidents;

• respond to enquiries, complaints, content reports and privacy requests;

• establish, exercise or defend legal rights; and

• comply with applicable laws, regulatory requirements and lawful requests.

5.1 Contract or requested services

Where recognised by applicable law, we process account and authentication information and information about sources or categories you choose to follow, bookmarks, saved articles, language and country preferences where processing is necessary to implement our agreement with you, take steps at your request or provide the Newshunt services and features that you request.

5.2 Consent

We rely on consent where it is legally required for optional processing. This may include non-essential website analytics, analytics based on articles viewed, searches, reading history and other interactions, behavioural personalisation based on observed use of the Platform, optional Android location information, direct marketing if introduced, non-essential cookies or similar technologies, and optional notifications where applicable law requires consent. The Android application currently initializes Firebase Analytics without a separate in-app analytics consent choice; Newshunt will keep this configuration under review and implement consent controls where required by applicable law. Where consent is the legal basis, you may withdraw it using the relevant settings or by contacting us. Withdrawal does not affect processing that was lawful before consent was withdrawn.

Where personalisation is based solely on choices you make expressly, such as selecting categories, following sources or choosing language or regional preferences, we may process those choices where necessary to provide the personalised service or feature you requested. Where personalisation instead involves analysing reading, search or other behavioural activity to infer interests, we use consent where required by applicable law.

5.3 Legitimate interests

Where permitted by applicable law, we may rely on legitimate interests for limited operational purposes such as preventing fraud and misuse, protecting network and information security, maintaining service integrity, and identifying and resolving technical failures, including crash and diagnostic reporting. We rely on legitimate interests only where the processing is necessary for the relevant purpose, is proportionate, is within reasonable expectations, and does not override the rights and interests of the individual. Under the Saudi PDPL, we do not rely on legitimate interests to process Sensitive Personal Data, and we carry out and document the assessment required by the PDPL and its Implementing Regulations before relying on that basis.

5.4 Legal obligations and other lawful bases

We may process Personal Data where necessary to comply with applicable legal or regulatory obligations, respond to legally binding requests from competent authorities, establish or defend legal rights, protect vital interests where applicable, or rely on another lawful basis recognised under the law that applies to the processing.

6. PERSONALISATION AND AUTOMATED TECHNOLOGIES

Newshunt may use automated technologies to select, organise, rank or recommend news and other content. Personalisation may take account of sources you follow, categories you select, articles and media you view, searches, bookmarks, reactions, reading history, language, country or region and location information where available and permitted. These signals may be used to determine content shown in features such as My Feed.

Newshunt does not intentionally use reading or search activity to infer Sensitive Personal Data or sensitive characteristics for advertising or unrelated purposes unless that processing is lawfully permitted and all additional requirements applicable to Sensitive Personal Data have been satisfied. In particular, Sensitive Personal Data is not processed on the basis of legitimate interests where the Saudi PDPL prohibits that basis.

The personalisation described in this Privacy Policy concerns the selection and ranking of news and related content. If Newshunt introduces solely automated decision-making that produces legal or similarly significant effects on individuals, we will provide any additional notice, lawful basis, choice and safeguards required by applicable law before or at the time the processing begins.

7. COOKIES, ANALYTICS AND SIMILAR TECHNOLOGIES

7.1 Website

The Newshunt website uses essential or functional cookies or equivalent storage items for login or authentication, country selection or detection and language preferences. The currently identified functional items are described as the login token, country code, detected country code and language code. These technologies are provided by Newshunt and may operate without optional consent where they are reasonably necessary to provide a service requested by the user or to operate essential functionality.

The website uses Google Analytics and Firebase technologies for analytics and technical purposes. The website displays a privacy/cookie banner that distinguishes essential from non-essential technologies and gives users the option to accept or reject non-essential technologies.

Where applicable law requires consent for non-essential analytics, advertising or similar storage/access technologies, Newshunt will apply the user's privacy choice in accordance with applicable law. Users can make an accept or reject choice through the website privacy/cookie banner.

At the date of this Privacy Policy, Newshunt does not use Facebook/Meta tracking technologies or advertising or marketing cookies on the website.

7.2 Mobile applications

The Newshunt mobile applications currently use or integrate the following technologies, with availability differing by platform and feature:

• Firebase Analytics (Google) in the Android application to measure application use and interactions;

• Firebase Crashlytics (Google) to identify crashes, errors and technical problems;

• Firebase Cloud Messaging (Google) to deliver push notifications where enabled and to process device identifiers needed for messaging;

• Google Sign-In as an optional authentication method;

• Apple Sign-In as an optional authentication method on supported Apple devices; and

• YouTube technologies to provide or enable access to YouTube video or related content.

Newshunt does not currently use a Facebook/Meta SDK as an analytics or tracking tool. Advertising functionality or advertising tools may be introduced in the mobile applications. Before any such processing is used in a manner that requires additional notice or consent, Newshunt will update this Privacy Policy, relevant consent mechanisms and app-store disclosures as required by applicable law.

7.3 Browser and platform privacy signals

Where applicable law requires Newshunt to recognise a legally valid opt-out preference signal or comparable browser or platform privacy control for a particular processing activity, Newshunt will treat that signal in accordance with the applicable legal requirements.

8. THIRD-PARTY CONTENT, SERVICE PROVIDERS AND DISCLOSURES

Newshunt uses service providers to support operation of the Platform. Current confirmed third-party technologies include Google services such as Google Analytics, Firebase Analytics (Android), Firebase Crashlytics, Firebase Cloud Messaging and Google Sign-In; Apple Sign-In on supported Apple devices; and YouTube technologies for video or related content. Other infrastructure, hosting, database, email, content-delivery or support providers may also process Personal Data for Newshunt where used to operate the Platform. Newshunt reviews its provider inventory and will update this Privacy Policy where a provider or processing arrangement materially changes the disclosures required by applicable law.

When you choose to play YouTube, live television or other third-party media through Newshunt, your device may connect to YouTube or another relevant third-party provider through Newshunt's technical integration. The third party may receive technical information needed to deliver the requested content, such as IP address and device or browser information, and will process information under its own terms and privacy practices.

We may also disclose Personal Data to professional advisers subject to confidentiality obligations; within our corporate group where necessary and legally permitted; to competent government, regulatory, judicial or law-enforcement authorities where required or permitted by law; or in connection with a corporate reorganisation, acquisition, sale or transfer, subject to applicable safeguards.

Where a service provider processes Personal Data on our behalf, we require appropriate contractual, confidentiality, security and organisational protections in accordance with applicable law and remain responsible for our controller obligations to the extent required by law.

9. INTERNATIONAL TRANSFERS

Newshunt is established in the Kingdom of Saudi Arabia and some technology or service providers used by Newshunt may process Personal Data in other countries. Where Personal Data is transferred or disclosed outside the Kingdom, Newshunt will comply with the PDPL and the applicable Regulation on Personal Data Transfer Outside the Kingdom, including by using an available legal basis, limiting the transfer to what is necessary and implementing any required safeguard or transfer risk assessment.

Where the EU GDPR, UK GDPR or another transfer regime applies, Newshunt will use a legally recognised transfer mechanism where required, which may include an adequacy decision, approved standard contractual clauses, the UK International Data Transfer Agreement or UK Addendum, binding corporate rules, another approved safeguard, or a legally available derogation. Where applicable law gives you a right to obtain information about the relevant transfer safeguards, you may request that information using the privacy contact in Section 16.

10. RETENTION AND DELETION

We retain Personal Data only for as long as necessary for the purpose for which it was collected or processed, or for a longer period where retention is required or permitted by law. In determining retention periods, we consider the purpose of processing, the nature and sensitivity of the information, whether an account or feature remains active, security and fraud-prevention needs, legal and regulatory obligations, limitation periods and the need to establish or defend legal rights.

Different categories of Personal Data may therefore have different retention periods. Consent and preference records may be retained for as long as reasonably necessary to demonstrate compliance; security and diagnostic records may be retained for periods appropriate to security, reliability and legal requirements; and account information may be retained while the account is active and for a limited period afterwards where necessary for lawful purposes.

When Personal Data is no longer required and there is no legal reason to retain it, it will be securely destroyed, deleted or irreversibly anonymised in accordance with applicable requirements.

You may request deletion of your Newshunt account and associated Personal Data through the in-app account-deletion functionality, by using the website deletion page at https://newshunt.io/profile/delete, or by contacting info@newshunt.io. The website deletion page is publicly accessible without an active login session and requests account credentials as part of identity verification before the deletion request is processed. Following a valid request, we will destroy, delete or anonymise Personal Data that is no longer required, subject to any retention permitted or required by law.

11. YOUR PRIVACY RIGHTS AND CHOICES

Depending on where you live and the law that applies to the processing, you may have some or all of the following rights:

• to be informed about how and why your Personal Data is collected and processed;

• to access Personal Data held about you;

• to obtain a readable copy of Personal Data and, where applicable, receive it in a portable format;

• to request correction, completion or updating of inaccurate, incomplete or outdated Personal Data;

• to request deletion, erasure or destruction of Personal Data where the applicable legal conditions are met;

• to request restriction of processing where applicable;

• to object to certain processing, including processing based on legitimate interests, where applicable;

• to withdraw consent at any time where processing is based on consent;

• to opt out of certain sale, sharing, targeted advertising or qualifying profiling where applicable law provides that right;

• to limit certain uses or disclosures of Sensitive Personal Data where applicable law provides that right;

• to appeal a refusal of a privacy request where applicable law provides an appeal right;

• to use an authorised agent to make a request where applicable law permits it;

• to receive equal service and not be unlawfully discriminated against for exercising a privacy right; and

• to complain to Newshunt and to a competent supervisory, data-protection or consumer-privacy authority.

To exercise a privacy right, contact us at info@newshunt.io or use any rights-request functionality made available through the Platform. We may take reasonable and proportionate steps to verify your identity and, where applicable, the authority of an agent before acting on a request. We will respond within the time required by the law that applies to the request.

If the EU GDPR or UK GDPR applies to you, you may have a right to object to processing based on legitimate interests and a right to object at any time to direct marketing processing. These rights are subject to the conditions and exceptions in applicable law.

You may also manage certain choices through the Platform, your browser or your device settings, including location permissions, push notifications, cookie choices and supported account preferences. Where consent is withdrawn, we will stop the relevant consent-based processing without undue delay unless another lawful basis requires or permits it to continue.

12. REGIONAL PRIVACY INFORMATION

12.1 Kingdom of Saudi Arabia

If the Saudi PDPL applies, you have the rights provided by the PDPL and its Implementing Regulations, including rights to be informed of the legal basis and purpose of collection, access Personal Data, obtain a readable and clear copy where applicable, request correction or completion, request destruction where the legal conditions are met, and withdraw consent where processing is based on consent. You may also submit a complaint to Newshunt and, where applicable, to the competent Saudi data-protection authority, the Saudi Data & AI Authority (SDAIA).

12.2 European Economic Area, United Kingdom and Switzerland

If the EU GDPR, UK GDPR or comparable Swiss data-protection law applies, you may have rights including access, rectification, erasure, restriction, objection, data portability, withdrawal of consent and the right to lodge a complaint with the competent supervisory authority. Where required, Newshunt will identify the relevant data-protection officer or representative and provide their contact details. International transfers will be made using an applicable legal transfer mechanism where required.

12.3 United States state privacy rights

If a United States state privacy law applies to Newshunt and to you, you may have rights to know or access Personal Data, obtain a portable copy, delete Personal Data, correct inaccuracies, opt out of qualifying sale or sharing, targeted advertising or certain profiling, limit certain uses or disclosures of Sensitive Personal Data, use an authorised agent, appeal certain request decisions and receive non-discriminatory treatment for exercising your rights, subject to the conditions and exceptions in applicable law.

For California consumers, the categories of Personal Data Newshunt may collect are described in Section 3; the sources are described in Section 4; the business and commercial purposes are described in Sections 5 to 7; and the categories of recipients are described in Section 8. The practices described in this Privacy Policy do not include selling Personal Data for monetary consideration. However, depending on the advertising, analytics or other technologies actually used, certain disclosures may be treated as a "sale", "sharing" or targeted advertising under applicable United States privacy laws even where no money changes hands. Where such rules apply, Newshunt will provide the required notice and opt-out methods, including recognition of legally required opt-out preference signals where applicable.

If Newshunt has actual knowledge that a California consumer is under 16, Newshunt will not sell or share that consumer's Personal Data without the affirmative authorisation required by applicable California law.

12.4 Other countries

Users in other countries may have additional privacy rights under local law. Newshunt will honour mandatory rights that apply to the relevant processing and may provide country-specific notices, contact details or mechanisms where required.

13. CHILDREN AND PERSONS WHO LACK LEGAL CAPACITY

Newshunt is a general news service and the Platform is not intended for children under 13. A user must be at least 13 years old to use the Platform or create an account, subject to any higher minimum age or additional consent requirement imposed by applicable local law for a particular feature or processing activity.

Where a person does not have the legal capacity required to provide a valid consent or exercise a privacy choice, Newshunt will comply with applicable requirements concerning the involvement, authorisation or consent of that person's parent or legal guardian. Where local law requires parental or guardian authorisation for a consent-based processing activity, Newshunt will obtain that authorisation or will not make that consent-based activity available to the user until the applicable requirement is satisfied.

Newshunt does not knowingly collect Personal Data from a child in circumstances where doing so would be unlawful. If we learn that Personal Data has been collected in breach of an applicable children's privacy requirement, we will take appropriate steps to delete or otherwise lawfully handle the information.

14. SECURITY AND PERSONAL DATA BREACHES

We implement administrative, organisational and technical measures designed to protect Personal Data against unauthorised or unlawful access, use, alteration, disclosure, loss or destruction. Measures are selected having regard to the nature of the processing, the sensitivity of the Personal Data, reasonably foreseeable risks and applicable legal requirements.

Where a Personal Data breach meets applicable statutory notification thresholds, Newshunt will notify the competent authority, affected individuals or other parties within the time and in the manner required by applicable law.

No online service can guarantee absolute security. You should also take reasonable steps to protect your account and device, including protecting your login credentials and installing appropriate device and software updates.

15. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy where our services, technology, processing activities, service providers or legal obligations change. The current version will be published on the Platform with the date of the latest update.

Where a change materially affects how we process Personal Data, we will provide additional notice where required. Where applicable law requires a new or renewed consent, we will request that consent before the relevant consent-based processing begins or continues.

16. CONTACT US AND COMPLAINTS

Questions, complaints and requests concerning this Privacy Policy or Newshunt's processing of Personal Data should be sent to:

Email: info@newshunt.io