Privacy Policy

1. Overview and scope

This policy applies to the Gaylan Media mobile application and our web platforms. For the terms governing your use of the App and Services generally, see our separate Terms of Service.

Where you access our Services via our website, we also use cookies and similar tracking technologies; details are provided in our separate Cookie Policy.

2. Data we collect

We collect data to provide personalised news reporting, maintain app security, and fulfil subscription services. Data collection is divided into three categories:

3. Legal bases for data processing (GDPR)

We process personal data under the following legal frameworks:

• Contractual necessity: To fulfil our agreement to provide access to app content, manage user accounts, and process subscriptions.
• Legitimate interests: To improve news recommendations, enhance app stability, prevent fraud, and optimise user experience.
• Consent: For sending push notifications, processing promotional updates, or serving personalised advertisements where required by law.

4. International data transfers

Where personal data is transferred outside the EEA or United Kingdom (for example, to cloud hosting or analytics providers located in other countries), we rely on recognised transfer mechanisms such as the European Commission's Standard Contractual Clauses (SCCs) or an applicable adequacy decision to ensure your data continues to receive an equivalent level of protection.

5. How we use your data

Gaylan Media uses collected information strictly for specified operational purposes:

• To deliver, maintain, and optimise mobile application stability and user interfaces.
• To curate personalised article feeds and documentary recommendations based on reading history.
• To send breaking news alerts and push notifications (managed via user settings).
• To facilitate customer support and address technical inquiries or payment disputes.
• To monitor network security, prevent unauthorised access, and protect intellectual property.

6. Data sharing and third-party disclosures

We do not sell, rent, or trade your personal data to third parties. Data may be disclosed strictly under limited operational circumstances:

• Service providers: Trusted third-party vendors who provide essential infrastructure (for example cloud hosting, push notification gateways, subscription analytics). These providers are bound by strict non-disclosure and data protection agreements.
• Payment providers: Waafi and PayPal process payments and confirm them back to us. They receive only what is needed to take the payment; we never receive or store your full card or mobile-money credentials.
• Categories of service providers: Our infrastructure partners include cloud hosting providers, crash-reporting and analytics tools, and push-notification delivery services.
• Legal requirements: Disclosures required by law, valid legal process, subpoena, or court order to protect the safety, rights, or property of Gaylan Media, its users, or the public.

7. Sign-in and tracking

Accounts are created with an email address and a password. We do not offer social sign-in, so no third party passes us your profile data when you register.

We do not use the advertising identifier (IDFA on iOS, GAID on Android), and we do not track you across other companies' apps or websites.

8. Data retention and account deletion

We retain your personal data only as long as your account remains active or as needed to provide you with Services. For users who do not delete their account, we retain reading history and usage analytics for a rolling period of 12 months, and crash reports for 90 days, after which they are aggregated or deleted.

Account and data deletion right: users may initiate full account deletion directly within the mobile application by navigating to Account › Delete account and typing DELETE to confirm, or by submitting a request to privacy@gaylanmedia.com. Step-by-step instructions in Somali, English and Arabic are at gaylanmedia.com/delete-account.

Upon account deletion, all associated personal data, reading logs, and credentials will be permanently erased or anonymised within 30 days, except where retention is required for tax, legal, or audit obligations.

9. Your privacy rights and choices

Depending on your jurisdiction (for example the EU/EEA under GDPR, or California under CCPA), you hold specific rights regarding your personal data:

• Right of access and portability: Request a copy of the personal data we hold about you.
• Right to rectification: Request correction of inaccurate or incomplete personal records.
• Right to erasure (“right to be forgotten”): Request deletion of your personal data.
• Opt out of push notifications: Disable push notification permissions directly in your device settings.
• Right to restrict processing: Request that we limit how we use your personal data under certain circumstances.
• Right to object: Object to processing carried out on the basis of legitimate interests, including profiling for content personalisation.
• Right to lodge a complaint: EU/EEA users may lodge a complaint with their local data protection supervisory authority if they believe their rights have been violated.
• CCPA — right to opt out of sale or sharing: We do not sell or share personal information for cross-context behavioural advertising. California residents may nonetheless submit a verifiable request confirming this at privacy@gaylanmedia.com.
• CCPA — right to non-discrimination: We will not deny you Services, charge different prices, or provide a different level of service because you exercised a privacy right.
• CCPA — authorised agent: You may designate an authorised agent to submit privacy requests on your behalf, subject to identity verification.

10. Children's privacy

Our Services are directed at general audiences and are not intended for children under the age of 13 (or 16 in certain jurisdictions), or the higher minimum age set by applicable law in the user's EU/EEA member state under the GDPR. We do not knowingly collect personal data from children. If we discover that a child under the requisite age has provided us with personal information, we will delete such data immediately from our servers.

11. Security safeguards

Gaylan Media implements administrative, technical, and physical security measures — including TLS encryption for data in transit and AES encryption for data at rest — to prevent unauthorised access, loss, or misuse of your personal information. However, no internet transmission or electronic storage method is 100% secure.

12. Updates to this policy

We may update these Terms of Service and Privacy Policy periodically to reflect technological changes, legal requirements, or platform policy updates from Apple or Google. Material changes will be communicated via in-app notifications or app release notes prior to becoming effective.

13. Contact us and privacy officer

If you have any questions, privacy concerns, or wish to exercise your data protection rights, please contact our Legal and Compliance Team:

Gaylan Media Legal & Compliance Office — general enquiries: legal@gaylanmedia.com · privacy requests: privacy@gaylanmedia.com