Legal
Privacy Policy
Last updated September 18, 2026
This policy explains what [SAWA LEGAL ENTITY] collects when you use Sawa, why we collect it, who can see it, how long we keep it, and what rights you have over it. It covers the public website, the member and psychologist portals, and the emails Sawa sends. It applies together with our Terms of Service, and using Sawa means you have read and accepted both.
Who is responsible for your data
The data controller for the information described in this policy is [SAWA LEGAL ENTITY], registered at [REGISTERED ADDRESS] in [COUNTRY OF INCORPORATION].
For any question about this policy, or to exercise any of the rights described below, write to [PRIVACY EMAIL].
What we collect
We collect the following categories of data about you when you use Sawa, and nothing beyond what the service needs to work.
- Account details: your name, email address, language and timezone, and a password held by our authentication provider, or the identity from your Google account if you sign in with Google.
- Your quiz answers: what you are carrying, and the language, gender and availability you prefer in a psychologist, so we can suggest a match.
- Your bookings: which psychologist, the date and time, the session status, and the meeting link. Sessions themselves are never recorded.
- The messages you exchange with your psychologist through Sawa.
- Payment references: a customer and subscription identifier held at [PAYMENT PROVIDER], and your credit balance. We never see or store your card details.
- Messages you send us through the public contact form.
- Technical data: a hashed form of your IP address and email, kept for 24 hours to limit abuse of the contact form, and security logs of access to the service.
Your health information
What you tell your psychologist, and what you share in the quiz and in your messages, may reveal information about your physical or mental health. Under data-protection law, this is a special category of data that deserves extra care.
Sawa processes your health information only with your explicit consent, given through the checkbox you tick when you join. It is visible to your psychologist and to the Sawa staff who support the service; every time a staff member accesses it, that access is recorded. You may withdraw your consent at any time; doing so ends your care through Sawa.
Why we use your data, and on what basis
We use your data for the following purposes, each resting on a specific legal basis.
These purposes are carried out under the EU General Data Protection Regulation for members in the European Union, and under Lebanese Law No. 81 of 2018 on electronic transactions and personal data.
- To provide the service you asked for — matching, booking, video invitations, messaging and payments — under our contract with you.
- To process your health data, resting on your explicit consent.
- To keep the service safe and prevent abuse, such as rate limits and access logs, resting on our legitimate interest.
- To meet our legal obligations, such as accounting and tax.
- To write to you about your account and your sessions, under our contract with you; we never send marketing email without your separate consent.
Where your data is kept, and international transfers
Your data is hosted in the European Union. Your psychologist, who provides your sessions from Lebanon, accesses it under the [GOVERNING LAW] framework and under contractual commitments of confidentiality and data protection with each psychologist.
[VIDEO PROVIDER] and [PAYMENT PROVIDER] may process data outside the European Union in the course of providing their services, under their own safeguards.
How long we keep it
We keep your data only for as long as it is needed.
- Account data: while your account exists, and [RETENTION PERIOD] after you delete it.
- Bookings and messages: while your account exists.
- Records your psychologist must keep under their professional rules: for the period those rules require.
- Payment records: for as long as tax and accounting law requires.
- Security and access logs: [RETENTION PERIOD].
- Contact-form rate-limit counters: 24 hours.
- Contact messages: until handled, and [RETENTION PERIOD] after.
Your rights
You have rights over your data under applicable data-protection law.
To exercise any of these rights, write to [PRIVACY EMAIL]; we reply within one month. You also have the right to complain to [SUPERVISORY AUTHORITY] (the CNIL for members in France).
- Access — a copy of the data we hold about you.
- Correction — to fix data that is inaccurate or incomplete.
- Deletion — to have your data removed, subject to what the law requires us to keep.
- Restriction — to limit how we use your data.
- Portability — to receive your data in a portable format.
- Objection — to object to how we use your data.
- Withdrawal of consent — at any time, without affecting what was done before you withdrew it.
How we protect it
We protect your data with encryption in transit, encrypted credentials and connected-account tokens at rest, and role-based access to every system that holds it. Every staff access to member data is recorded, and database access is denied by default and granted only where the service needs it.
No method of transmission or storage is perfectly secure. If a breach affects your data, we will tell you and the relevant supervisory authority as the law requires.
Children
Sawa is for adults. We do not open accounts for anyone under 18. If we learn that an account belongs to a minor, we close it and delete its data.
Changes to this policy
The date at the top of this page shows when it was last updated. When we make a material change to this policy, we announce it, and where your consent is the basis for using your data, we ask you to agree again before you continue using Sawa.
Contact
For privacy matters, write to [PRIVACY EMAIL]. For anything else, write to [CONTACT EMAIL]. [SAWA LEGAL ENTITY], [REGISTERED ADDRESS].