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Privacy Policy

Last updated: August 26, 2026

This Privacy Policy explains how Sugarpp, the operator of the Sugar Partnership mobile content service, collects and processes your personal data when you use this website and our subscription service. It is provided in accordance with the EU General Data Protection Regulation (Regulation (EU) 2016/679, "GDPR"), the ePrivacy Directive 2002/58/EC as amended, the UAE Personal Data Protection Law (Federal Decree-Law No. 45 of 2021), and, where applicable, the California Consumer Privacy Act (CCPA/CPRA).

1. Who we are (data controller)

Sugarpp, Avangate Hospitality Services FZE, Al Shmookh Business Center M 1003, UAQ Free Trade Zone Authority, PO Box 7072, UAQ, United Arab Emirates, is the data controller for the personal data described in this policy. Contact: support@orderkarey.com.

2. Data we collect

• Mobile number (MSISDN) — required to deliver content and bill the subscription via your carrier.
• Subscription status and history — subscription start date, cancellations, PIN confirmations.
• Billing records — charges processed through your mobile operator.
• Technical data — IP address, device type, browser, approximate location derived from IP, timestamps of visits.
• Support communications — messages you send us, including any data you include.

We do not collect payment card data and we do not collect special categories of personal data.

3. Purposes and legal bases

Purpose	Data	Legal basis (GDPR)
Providing the subscription service and delivering content	MSISDN, subscription status	Performance of a contract, Art. 6(1)(b)
Billing through your mobile operator	MSISDN, billing records	Performance of a contract, Art. 6(1)(b); legal obligation, Art. 6(1)(c)
PIN confirmation (double opt-in)	MSISDN	Your consent, Art. 6(1)(a)
Handling support and refund requests	Support communications, MSISDN	Performance of a contract, Art. 6(1)(b); legitimate interest, Art. 6(1)(f)
Security, fraud prevention, legal compliance	Technical data, billing records	Legitimate interest, Art. 6(1)(f); legal obligation, Art. 6(1)(c)

4. Who we share data with

We share personal data only as necessary: with your mobile operator for billing purposes, with our hosting and technical service providers (as data processors bound by data processing agreements), and with authorities where required by law. We never sell your personal data.

5. Retention

Billing and subscription records are kept for as long as required by applicable tax and commercial law (up to 10 years where mandated). Technical logs are deleted or anonymised after 12 months. Support correspondence is kept for 24 months.

6. International transfers

Your data is processed on secure servers located within the United Arab Emirates and the European Economic Area. Where personal data is transferred outside these regions, we apply appropriate safeguards, such as the EU standard contractual clauses.

7. Your rights

Under the GDPR you have the right to:

• Access (Art. 15) — obtain a copy of the personal data we hold about you.
• Rectification (Art. 16) — correct inaccurate data.
• Erasure (Art. 17) — request deletion ("right to be forgotten").
• Restriction (Art. 18) — limit processing in certain cases.
• Data portability (Art. 20) — receive your data in a machine-readable format.
• Objection (Art. 21) — object to processing based on legitimate interest.
• Withdraw consent (Art. 7(3)) — withdraw consent at any time (e.g., by cancelling the subscription).
• Complaint (Art. 77) — lodge a complaint with your national data protection supervisory authority.

To exercise any right, email support@orderkarey.com. We respond within one month.

8. California residents (CCPA/CPRA)

If you are a California consumer, you may request to know the categories and specific pieces of personal information we collect, request deletion, and opt out of the sale or sharing of personal information. We do not sell or share personal information as defined by the CCPA. Submit requests to support@orderkarey.com; we will not discriminate against you for exercising your rights.

9. Cookies

This website uses only essential cookies required for the site to function (e.g., remembering your cookie preference). No advertising or cross-site tracking cookies are used. You can disable cookies in your browser settings. See our Cookie Policy below.

10. Changes

We may update this policy; the current version is always published on this page with the date above. Material changes are announced on this website.

Terms of Service

Last updated: August 26, 2026

1. Service description

Sugar Partnership provides a mobile content subscription service: daily quizzes, brain games, horoscopes and wallpapers delivered to your mobile phone via SMS and our mobile website ("the Service"). The Service is operated by Sugarpp, Avangate Hospitality Services FZE, Al Shmookh Business Center M 1003, UAQ Free Trade Zone Authority, PO Box 7072, UAQ, United Arab Emirates.

2. Subscription and double opt-in

A subscription is created only after you (a) enter your mobile number, and (b) confirm by entering the PIN sent to your number by SMS (double opt-in). By confirming, you accept these Terms and authorise the weekly charge.

3. Price and billing

The price is $4.99 per week, VAT included where applicable, charged to your mobile phone bill via your mobile operator (carrier billing). The first charge occurs upon PIN confirmation. The charge appears on your bill as "Sugar Partnership". Standard data charges by your operator may apply when you access content online. Prices may change with reasonable prior notice; you will be informed before any change takes effect.

4. Cancellation

You may cancel at any time by sending STOP to 1020 (free of charge) or by emailing support@orderkarey.com. Cancellation is effective immediately and no further charges are applied after we receive your request.

5. Eligibility

You must be at least 18 years old or have the permission of the mobile account holder. The Service must be available on your operator's network.

6. Acceptable use

The content is for your personal, non-commercial use. You may not copy, redistribute, or resell it, or use the Service for unlawful purposes.

7. Intellectual property

All content, names, and marks of the Service belong to Sugarpp or its licensors. Apple, Google, and mobile operator names are trademarks of their respective owners; this Service is not affiliated with them.

8. Liability

The Service is provided "as is" and we do not guarantee uninterrupted availability. To the extent permitted by law, our liability is limited to the amounts you paid in the 12 months before the event giving rise to liability. Nothing in these Terms limits liability that cannot be limited by law, or your statutory consumer rights.

9. Changes to the Terms

We may amend these Terms; the current version is always available on this page. For ongoing subscriptions, material changes are announced with at least 14 days' notice; you may cancel before they take effect.

10. Governing law

These Terms are governed by the laws of the United Arab Emirates. If you are a consumer in the EU, you also benefit from the mandatory consumer protection laws of your country of residence.

11. Contact

support@orderkarey.com — Sugarpp, Avangate Hospitality Services FZE, Al Shmookh Business Center M 1003, UAQ Free Trade Zone Authority, PO Box 7072, UAQ, United Arab Emirates.

Cookie Policy

Last updated: August 26, 2026

Cookies are small text files stored on your device. This website uses only essential cookies: one cookie remembers your cookie-banner choice; the web server writes standard access logs (IP address, date, requested page) for security and statistics, as do most websites. We do not use advertising, analytics, or cross-site tracking cookies, and we do not share your browsing behaviour with third parties.

You can delete or block cookies in your browser settings at any time; the website remains fully usable. For more details on our data processing, see our Privacy Policy.

Refund Policy

Last updated: August 26, 2026

Right of withdrawal. If you are a consumer in the EU, you have a statutory 14-day right of withdrawal from distance contracts under Directive 2011/83/EU. However, for digital content not supplied on a tangible medium, the right of withdrawal ends once delivery of the digital content has begun with your prior express consent and acknowledgement of the loss of the withdrawal right (Art. 16(m)). Delivery of the first content begins immediately after your PIN confirmation.

How to request a refund. Email support@orderkarey.com within 14 days of the charge, stating your mobile number, charge date and amount. We review every request individually and respond within 48 hours. Approved refunds are processed within 14 days to the original payment method (credited via your mobile operator where applicable).

Disputed or unintended charges. If you believe a charge was made in error or without your confirmation, contact us immediately; we will investigate the double opt-in record for your number and, where the charge cannot be evidenced, refund it in full.