Sulam Tech LLC ("Sulam", "we", "our", or "us") respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, store, disclose, and safeguard your information when you use the Sulam mobile application (the "App").
The App is a personal finance education and self-tracking tool. By design, it stores your financial data locally on your device — we do not collect, host, or process your financial entries on our servers.
By downloading, installing, or using the App, you agree to this Privacy Policy. If you do not agree, please discontinue use of the App.
We may collect the following information when you use the App:
Important: Sulam does not require you to link bank accounts or upload sensitive banking credentials.
The current version of the App does not automatically collect technical telemetry from your device. Specifically:
Any technical details are shared only if you choose to provide them manually via customer support. If we introduce automatic data collection in a future version, we will update this Privacy Policy and obtain your consent where required by law before such collection begins.
We use the limited information we receive to:
We do not sell, rent, or trade your personal data, and we do not use your personal data for advertising or marketing by third parties.
Where data protection laws apply (including the EU GDPR, UK GDPR, Oman Personal Data Protection Law, UAE Personal Data Protection Law, and similar laws), we process your personal data on the following legal bases:
Your financial data is stored locally on your device using secure system storage and encryption. We implement industry-standard security practices, including biometric authentication, PIN protection, and on-device encryption.
The limited information we receive (such as your Sign in with Apple identifier) is stored securely and is processed only as needed to operate the App.
Despite our efforts, no system is completely secure. You acknowledge and accept this inherent risk.
We do not share your personal data with third parties, except in the following limited circumstances:
All disclosed data is limited to the minimum necessary.
Sulam is based in the Sultanate of Oman. If you are located outside Oman, the limited information we receive may be transferred to and processed in Oman or other countries where Apple or our service providers operate. These countries may have data protection laws that differ from those in your country.
Where required by applicable law, we put in place appropriate safeguards (such as standard contractual clauses) for international transfers.
Your financial data remains stored locally on your device until you delete it within the App or uninstall the App. We do not retain copies of your local financial data on our servers.
The limited account information we receive (such as your Sign in with Apple identifier) is retained only as long as you maintain an Account, plus a reasonable period afterward to comply with legal obligations, resolve disputes, and enforce our agreements.
Your Data Stays With You. Because your financial data is stored only on your device, it remains accessible to you at all times — even if you cancel your subscription, terminate your Account, or stop using the App. Your data is removed only when you delete it within the App or uninstall the App from your device.
Depending on your location and applicable law (including the EU GDPR, UK GDPR, California Consumer Privacy Act / CPRA, Brazil LGPD, Canada PIPEDA, Oman PDPL, UAE PDPL, and similar laws), you may have the following rights:
How to exercise your rights:
To exercise any of these rights, please contact us at sulam.app@hotmail.com with the words "Privacy Request" in the subject line. We will respond within thirty (30) days, or earlier if required by applicable law. We may need to verify your identity before responding.
Most of your data is stored only on your device. To delete it, you can erase your data within the App or uninstall the App from your device.
If you are located in the EEA, the UK, or Switzerland, our processing of your personal data is subject to the EU GDPR, UK GDPR, or Swiss Federal Act on Data Protection, as applicable. You have the rights described in Section 8. The data controller is Sulam Tech LLC, Muscat, Sultanate of Oman. You may lodge a complaint with your local supervisory authority.
If you are a California resident, the California Consumer Privacy Act (as amended by the CPRA) gives you specific rights regarding your personal information, including the rights described in Section 8 and the right not to be discriminated against for exercising your rights. We do not "sell" or "share" personal information as those terms are defined under California law.
If you are located in Brazil, our processing is subject to the Lei Geral de Proteção de Dados (LGPD). You have the rights described in Section 8.
If you are located in Canada, our processing is subject to the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial laws.
If you are located in the Middle East, our processing may be subject to the Oman Personal Data Protection Law, UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data, the Saudi Arabia Personal Data Protection Law, and similar laws in your country. You have the rights described in Section 8.
If we become aware of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify you and the relevant data protection authority without undue delay, in accordance with applicable law (such as within 72 hours where required by GDPR).
The App uses services provided by Apple, including Sign in with Apple and Apple In-App Purchase. The App may integrate additional third-party services in the future (such as additional payment gateways).
Your use of any Apple service is governed by Apple’s Privacy Policy and terms. Sulam is not responsible for the privacy practices of Apple or any other third party.
In the current version of the App, we do not automatically collect analytics or telemetry data, including anonymous or aggregated usage statistics. If analytics tools are introduced in a future release, this Privacy Policy will be updated and, where required by law, your consent will be obtained before any such collection begins.
The App is a native mobile application and does not use cookies. If you visit our website, our website may use limited cookies as described on the website itself.
The App is not intended for users under 18 years old. We do not knowingly collect personal data from individuals under 18. If we learn that we have collected personal data from a person under 18, we will delete it promptly. If you believe a person under 18 has provided personal data to us, please contact us at sulam.app@hotmail.com.
We may update this Privacy Policy from time to time. When we make material changes, we will notify you through the App or by email at least thirty (30) days before the changes take effect, where reasonably practical. Your continued use of the App after the effective date constitutes acceptance of the updated Privacy Policy.
This Privacy Policy is made available in English and Arabic. In the event of any conflict or inconsistency between the English and Arabic versions, the English version shall prevail.
If you have questions, concerns, or wish to exercise your rights under this Privacy Policy, please contact:
Last Updated: May 5, 2026