Privacy Policy

This document “Privacy Policy” (hereinafter referred to as the “Policy”) sets forth the terms for processing of Personal Information by Washa (hereinafter referred to as “Washa”, “we”, or “us”). This Policy applies to the Washa website and, in particular, to the Washa mobile application made available through app stores (including Google Play and Apple App Store).

1. User’s Consent

By checking the box “I agree” accompanied by a link to this Policy, you (“User”) freely and for your own benefit give written consent to the processing of your Personal Information for the purposes and under the terms and conditions set out in this Policy.

2. Terms and Definitions

2.1. Agreement — Agreement on use of the Washa platform, executed based on the Terms of Service available at: business.appwasha.com/en/terms-and-conditions, as well as other agreements entered into with the User. 2.2. Washa Platform (Platform) — means Washa’s software platform that includes the website appwasha.com (including subdomains), mobile application, products and other software applications and databases designed for online booking and business process automation. 2.3. User — means a person or entity that has entered into the Agreement with Washa. 2.4. Client — any third party that books a service online from a User through software tools provided by Washa.

3. General Provisions

3.1. This Policy is an integral part of the Agreement and other documents referenced therein. 3.2. Methods of processing include any operation with Personal Information, such as collection, recording, storage, updating, use, transfer, depersonalization, deletion, etc., with or without automated means. 3.3. Terms and definitions not specified here shall be interpreted according to the applicable laws and business practices.

4. Personal Information

4.1. Personal Information in this Policy includes: a) Data provided by the User during registration or use of the Platform; b) Automatically collected depersonalized data (e.g., browser, device, IP). 4.2. Washa may set mandatory data fields required for Platform use. 4.3. During registration, the User provides: name, email, phone number, and company name (if applicable). 4.4. For end users (Clients of Users/partners) using the mobile application and booking flows, Washa and its partners may process: phone number, booking history, visited locations/stations, and related activity (including booking creation, modification, cancellation, attendance status, and service interactions). 4.5. Phone numbers are used for authentication and account access via one-time passwords (OTP). OTP codes may be delivered through SMS or functionally equivalent messaging/verification channels provided by authorized service providers. 4.6. Washa may collect and store log data related to activity on the Platform (including app events, technical diagnostics, and security logs). 4.7. Washa may use third-party analytical services such as Google Analytics, Firebase Analytics, Yandex Metrica, and similar tools, which process data under their own privacy policies.

5. Legal Basis of Processing

Washa processes Personal Information on the following bases: - The User has given consent; - Processing is necessary for the performance of an Agreement; - Processing is required for compliance with a legal obligation.

6. Policy Regarding Children

Washa does not knowingly collect personal data from children under the age of 16. If we learn that such data has been collected, we will delete it immediately.

7. Purposes of Data Processing

Washa processes Personal Information to: - Provide and improve the Platform and related services; - Communicate with Users for support and service updates; - Conduct statistical and analytical research; - Send marketing or informational materials (where legally permitted); - Authenticate users and clients by OTP verification; - Synchronize booking data and share relevant booking details with the business (partner/User) selected by the client for service fulfillment. Mobile permissions (Calendar): - The mobile application may request access to the device calendar only with the user’s explicit permission; - Calendar access is used solely to create or update booking reminders/events requested by the user; - Washa does not write to calendar without a direct user action and permission grant.

8. User Rights

Users have the right to: - Access, correct, or delete their personal data; - Restrict or object to processing; - Withdraw consent at any time; - Request data portability. Requests can be made by contacting Washa at contact@appwasha.com.

9. Data Retention

Washa stores Personal Information only as long as necessary for the purposes described in this Policy or as required by applicable law. In particular: - Data is retained while the account is active and/or as needed to provide booked services and support; - Certain records may be retained for legally required periods (for security, accounting, dispute resolution, and compliance); - Users and clients may request deletion of personal data at any time by contacting contact@appwasha.com, subject to legal retention obligations.

10. Data Protection

Washa stores Personal Information securely and protects it against unauthorized access, modification, or disclosure, in accordance with internal security procedures.

11. Transfer of Personal Information

Washa may transfer Personal Information to third parties when: - The User has consented; - It is necessary for providing services; - Required by law or for protection of Washa’s rights. Transfers may include: - Businesses (partners/Users) with whom the client books services, strictly for booking fulfillment and customer support; - Analytics providers (including Google Analytics, Firebase Analytics, Yandex Metrica, and similar services); - Messaging/SMS/verification providers used to deliver OTP authentication codes; - Hosting, cloud infrastructure, and technical service providers. Such providers may process personal data under their own privacy policies and contractual terms, including as independent or separate controllers where applicable.

12. Amendments

This Policy may be updated periodically. The new version becomes effective upon publication at business.appwasha.com/en/privacy-policy.

13. Washa Contact Details

Washa Sole Proprietor: German Gribanov Identification Code: 306460790 Georgia Email: contact@appwasha.com Phone: +351 927 661 510