Privacy Policy

Èsì is operated by GuestPulse Technologies Limited (“Èsì”, “we”, “us” or “our”).

This Privacy Policy explains how we collect, use, store, disclose and protect personal data when you access or use the Èsì mobile application, website and related services.

We are committed to handling personal data lawfully, fairly, transparently and securely. Depending on your location and the circumstances of our processing, our activities may be governed by applicable data protection and privacy laws, including:

• Nigeria: Nigeria Data Protection Act, 2023.
• Ghana: Data Protection Act, 2012 (Act 843).
• Côte d’Ivoire: Law No. 2013-450 of 19 June 2013 on the Protection of Personal Data.
• Kenya: Data Protection Act, 2019, and applicable regulations.
• Rwanda: Law No. 058/2021 of 13 October 2021 relating to the Protection of Personal Data and Privacy.

This list may be updated as Èsì expands into additional countries or applicable legislation changes.

Nothing in this Policy is intended to exclude, restrict or waive any mandatory right or protection available to you under applicable law. Where local law provides a higher level of protection, we will apply the requirements that legally govern the relevant processing.

GuestPulse Technologies Limited generally acts as the data controller, or equivalent under applicable law, for personal data processed to operate and manage Èsì, including account administration, platform security, user communications and community features.

Third-party service providers may process personal data on our behalf as data processors. Depending on the circumstances, other parties may independently determine how they process information they receive.

We process personal data only where we have a lawful basis under applicable law. Depending on the processing activity, these grounds may include:

• Consent: Where you have given valid consent, including where required for location permissions or other optional processing.
• Contract: Where processing is necessary to create and administer your account or provide a service you request.
• Legal obligations: Where processing is required to comply with applicable law or a lawful regulatory requirement.
• Legitimate interests: Where permitted by law, for purposes such as platform security, fraud prevention, service improvement and protection of our legal rights, provided the relevant interests do not override your rights.
• Vital interests or public interest: Where applicable law permits processing on these grounds.

Where consent is the applicable legal basis, you may withdraw it at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal. Some processing may continue where another valid legal basis applies.

Èsì may request access to your device’s precise or approximate location to support nearby venue discovery, location-based recommendations and location-verified reviews.

We will request device permissions where required and explain the purpose of location access. You may disable location permissions through your device settings. However, certain location-dependent features may no longer function as intended.

Disabling location access does not necessarily delete location information previously collected. You may contact us to exercise any applicable rights concerning that information.

Èsì is a community platform. Information you choose to publish, including reviews, ratings, photographs, comments, usernames and profile images, may be visible to other users and may be associated with your public profile.

Please avoid including sensitive personal information about yourself or another person in publicly visible content unless you have a lawful reason to do so.

We may moderate, restrict or remove content in accordance with our Terms of Service, Community Guidelines and applicable law.

Deleting your account does not necessarily mean that every review, photograph or other item of content will immediately disappear from all systems or public displays. We will handle account-associated content, backups and any content retained independently in accordance with our published retention practices and applicable legal requirements.

Ask Èsì is an AI-powered feature that helps users discover restaurants, bars, cafés, hotels and other hospitality venues using reviews and information available on Èsì.

Information processed

When you use Ask Èsì, we may process:

• Your question and the earlier messages in your current conversation (up to the 10 most recent), so the assistant can understand follow-up questions.
• Relevant reviews retrieved from Èsì, together with the venue’s name and category. Reviewer names and usernames are not included.
• Your country, where available (for example from your profile when you are signed in), to focus venue searches on the right country.
• If you are signed in, your sign-in session, which is checked to confirm your account.
• If you are not signed in, a random visitor identifier stored in your browser or app, and a count of how many questions you have asked, to apply free-question limits.
• Technical information needed to process requests and keep the service secure and working.

How we use this information

We use this information to understand your question, find relevant reviews, generate a response, apply usage limits and maintain the security and performance of Ask Èsì.

First, your question and recent conversation context are converted into a search representation (an “embedding”) using an AI model that runs on our Supabase infrastructure. This is used to find relevant reviews in Èsì’s database.

Your question, recent conversation history, your country (where available) and the selected reviews are then sent to DeepSeek’s API, which generates the answer. This may include text you have written and reviews written by other Èsì users. Your password and sign-in credentials are not sent to DeepSeek.

Please do not include passwords, financial details, sensitive personal information or other confidential information in your questions.

External AI and technology providers

Ask Èsì uses DeepSeek for response generation and Supabase for database operations, account checks and search processing. These providers process information as necessary to perform their services, under their own service terms and our arrangements with them.

DeepSeek may process and store information on servers outside your country, including in the People’s Republic of China. Such transfers are handled as described in Section 8 (International Transfers and Cross-Border Processing). We will assess and implement appropriate contractual, technical and organisational safeguards for these providers, as required by applicable law.

Conversation history and retention

Your conversation is kept in your browser or app while you are using Ask Èsì, and recent messages are sent with each new question to maintain context. We do not store the content of your Ask Èsì conversations in our databases.

For visitors who are not signed in, we store the visitor identifier, the number of questions asked and when the last question was asked, to apply free-question limits.

Limited information may remain in provider systems, security logs or backups for as long as necessary to provide the service, maintain security, resolve issues or meet legal obligations, in line with the relevant provider’s retention practices.

Accuracy and limitations

Ask Èsì generates responses using artificial intelligence and reviews from Èsì. Responses may be incomplete, inaccurate or outdated and are not a guarantee of a venue’s quality, safety, prices, opening hours or availability.

For venue recommendations, Ask Èsì is designed to rely on reviews available on Èsì rather than inventing venue experiences. Please verify important information independently before making decisions.

We will not use personal data processed through Ask Èsì for a materially different purpose without an appropriate lawful basis and any notice, consent or other safeguards required by applicable law.

Your rights

You may exercise the data protection rights described in Section 9 for personal data processed through Ask Èsì, including requesting access, correction or deletion where appropriate. Contact privacy@helloesi.com for privacy enquiries or requests.

We do not sell your personal data.

We may disclose or make personal data available to:

• Other Èsì users, where information has been made public through your profile, reviews, ratings or other community features.
• Service providers that support hosting, databases, authentication, email delivery, analytics, security and other necessary operations.
• Professional advisers, auditors and insurers where reasonably necessary and legally permitted.
• Regulators, courts, law enforcement authorities or other parties where disclosure is legally required or otherwise permitted by applicable law.
• Other parties in connection with a corporate restructuring, merger, acquisition or transfer of business, subject to applicable legal requirements and appropriate safeguards.

We seek to limit disclosures to what is reasonably necessary for the relevant purpose and to impose appropriate confidentiality, security and data protection obligations on service providers where required.

Èsì operates across multiple countries, and our service providers may process or store personal data in countries other than the country where it was collected.

Where personal data is transferred internationally, we will take the steps required by applicable law. Depending on the relevant jurisdiction and transfer, these may include obtaining valid consent, ensuring an adequate level of protection, implementing appropriate contractual or technical safeguards, or obtaining regulatory approval or authorisation where required.

We will not rely on this Policy as a substitute for any transfer mechanism, authorisation or other legal requirement that applies to a particular transfer.

You may contact us at privacy@helloesi.com for information about international processing relevant to your personal data, subject to applicable law and security considerations.

Depending on your location, the nature of the processing and applicable law, you may have the right to:

• Be informed about how your personal data is collected and used.
• Request access to personal data we hold about you.
• Request correction of inaccurate or incomplete personal data.
• Request deletion or erasure of personal data where legally applicable.
• Object to, or request restriction of, certain processing activities.
• Withdraw consent where processing is based on consent.
• Request a copy of certain personal data in a portable format where applicable.
• Challenge certain decisions made solely by automated means where applicable.
• Lodge a complaint with the competent data protection authority.
• Seek other remedies available under applicable law.

These rights are subject to applicable legal conditions and exceptions. For example, we may need to retain certain information to comply with legal obligations, resolve disputes, prevent fraud or establish, exercise or defend legal claims.

To exercise your rights, contact privacy@helloesi.com. Please identify your request and provide sufficient information for us to verify your identity and locate the relevant records. We will respond within the period required by applicable law.

If we cannot fulfil a request, we will explain the reason where required and inform you of any applicable review or complaint options.

We retain personal data only for as long as reasonably necessary for the purposes described in this Policy, unless a longer retention period is required or permitted by law.

Retention periods may vary according to the type of information, the purpose for which it was collected, account status, security needs and legal obligations.

You may request account deletion through the in-app settings or by contacting us. Subject to applicable law and necessary exceptions, we will delete or anonymise personal data in accordance with our retention and deletion procedures.

Where our existing account-deletion commitment applies, we will erase or anonymise the relevant personal information, profile data and authentication credentials from our primary databases within 30 days of account deletion, subject to lawful retention requirements. Residual copies in backups or records that must be retained may remain for the period reasonably necessary to complete secure deletion or meet legal obligations.

We implement appropriate technical and organisational measures to protect personal data against unauthorised access, disclosure, alteration, loss or destruction.

No digital service can guarantee absolute security. If a personal data breach occurs, we will assess and manage it in accordance with applicable law, including notifying affected individuals and the relevant supervisory authority where required and within the applicable time limits.

Èsì is intended for individuals aged 18 and above and is not directed to children.

We do not knowingly permit accounts belonging to individuals under 18. If we discover that we have collected personal data in circumstances inconsistent with this Policy or applicable law, we will take appropriate steps to address the situation, including deletion where required.

If you have concerns about how Èsì handles your personal data, please contact us first at privacy@helloesi.com so we can investigate and respond.

You may also have the right to complain to the data protection authority competent in your country or jurisdiction. Nothing in this Policy prevents you from exercising that right.

We may update this Policy to reflect changes to our services, data processing practices, applicable laws or regulatory guidance.

We will update the “Last updated” date and provide additional notice where required by law. Where a change requires renewed consent, we will seek it before carrying out the relevant processing on that basis.

For privacy questions, data access requests, correction requests, deletion requests, objections or other data protection matters, contact:

GuestPulse Technologies Limited (Èsì)
Email: privacy@helloesi.com
Website: https://helloesi.com/privacy

For general enquiries, contact us through our website.