Sawa — Terms and Conditions of Use

These Terms govern all use of the Sawa application and services. By accessing or using Sawa — whether as a Staff Member or Hotel Administrator — you confirm that you have read, understood, and agree to be bound by these Terms. If you do not agree, do not use the app.

1. Parties and definitions

In these Terms, the following definitions apply:

  • "Sawa" or "the Platform" means the Sawa hospitality learning application, dashboard, and all associated services operated by Sawa Hospitality Learning S.L., incorporated in Spain.
  • "Hotel Client" means the legal entity (hotel, lodge, resort, or hospitality group) that has entered into a separate B2B agreement with Sawa and administers one or more accounts.
  • "Administrator" or "Admin" means an individual designated by the Hotel Client to manage the Platform within their property, access the Manager Dashboard, and oversee Staff Member accounts.
  • "Staff Member" means any individual end-user who accesses Sawa for learning and professional development purposes under an invitation issued by a Hotel Client.
  • "User" means any Administrator or Staff Member.
  • "Content" means all lessons, audio, video, assessments, games, wellbeing modules, and other materials made available through the Platform.
  • "User Data" means any data generated by or about a User in connection with use of the Platform, including learning progress, assessment scores, module completion, wellbeing check-in responses, and device and usage information.

2. Acceptance of terms

Access to and use of the Platform is conditional on acceptance of these Terms. Acceptance occurs at the earliest of:

  • clicking "I agree" or a similar affirmation button within the Platform or onboarding email;
  • completing registration and creating an account; or
  • accessing any feature of the Platform after these Terms have been made available to you.

Users who are Staff Members additionally acknowledge that their Hotel Client has agreed to Sawa's B2B Service Agreement, which governs the relationship between Sawa and the Hotel Client, and that these Terms govern the User's own relationship with Sawa directly.

3. Account registration and security

Users must provide accurate, current, and complete information at registration and keep it updated. You are responsible for maintaining the confidentiality of your access credentials and for all activity that occurs under your account. You must notify Sawa immediately at help@sawatraining.com if you become aware of any unauthorised access or security breach.

Hotel access codes (such as those issued in onboarding emails) are confidential and must not be shared outside the property to which they relate.

4. Data collection and use

4.1 Data we collect

When you use the Platform, we collect:

  • Registration data: name, email address, job role, and property name.
  • Learning data: lesson completions, assessment scores, time spent on modules, leaderboard rankings, and game performance.
  • Wellbeing data: responses to daily and weekly wellbeing check-in questions (where the wellbeing module is enabled by the Hotel Client).
  • Device and technical data: device type, operating system, browser, IP address, and session identifiers.
  • Usage data: features accessed, navigation paths, error logs, and interaction timestamps.

4.2 How we use your data

We use User Data for the following purposes:

  • Service delivery: to provide, maintain, and improve the Platform and personalise your learning experience.
  • Analytics and platform improvement: to understand how the Platform is used, identify technical issues, and develop new features. This analysis may use aggregated and de-identified data.
  • Commercial development: aggregated, anonymised, and de-identified insights derived from User Data may be used to improve our product, develop new modules, benchmark performance across properties, and support sales and marketing activities. No individually identifiable data is used for commercial purposes without explicit consent.
  • Hotel Client reporting: Administrators receive aggregated team-level analytics (completion rates, average scores, wellbeing trends). Individual Staff Member data is not disclosed to Administrators except where the Staff Member has been notified and consented, or where required by the Hotel Client's agreement with Sawa.
  • Safety and compliance: to detect fraud, prevent misuse, and comply with applicable legal obligations.

4.3 Wellbeing data — additional protections

Wellbeing check-in responses are treated as sensitive data. Individual responses are never shared with Hotel Clients, managers, or any third party. Hotel Clients and Administrators see only anonymised team averages. Staff Members may opt out of the wellbeing module at any time without affecting their access to other features.

4.4 Legal basis for processing (GDPR / applicable law)

Where the General Data Protection Regulation (EU) 2016/679 or equivalent legislation applies, Sawa processes personal data on the following legal bases:

  • Contract performance: processing necessary to provide the Platform and deliver the service you have registered for.
  • Legitimate interests: improving the Platform, preventing fraud, and conducting aggregated analytics, where these interests are not overridden by your rights.
  • Consent: for wellbeing data and any processing beyond the above, where we will seek your explicit consent.
  • Legal obligation: where processing is required by applicable law.

4.5 Data sharing and third parties

We do not sell individually identifiable User Data. We may share data with:

  • Service providers acting as data processors on our behalf (cloud hosting, analytics, email delivery), bound by appropriate data processing agreements.
  • Hotel Clients, in the form of aggregated and anonymised reports only.
  • Law enforcement or regulatory authorities where required by law.
  • Acquirers or successors in the event of a merger, acquisition, or sale of assets, subject to equivalent data protection obligations.

4.6 International data transfers

Sawa operates globally and your data may be transferred to and processed in countries outside your country of residence, including countries that may not provide the same level of data protection as your home jurisdiction. Where such transfers occur, we implement appropriate safeguards including Standard Contractual Clauses approved by the European Commission, adequacy decisions, or equivalent mechanisms.

4.7 Data retention

We retain User Data for as long as your account is active and for a period of 36 months thereafter, unless a longer retention period is required by law or agreed with the Hotel Client. Wellbeing data is retained for 12 months and then permanently deleted. You may request earlier deletion as set out in Section 6.

5. Intellectual property

All Content on the Platform — including lessons, audio recordings, assessments, games, visual assets, the Sawa brand, and software — is owned by or licensed to Sawa Hospitality Learning S.L. Nothing in these Terms grants you any ownership right in the Platform or its Content.

You are granted a limited, non-exclusive, non-transferable, revocable licence to access and use the Platform and Content solely for your personal professional development or, in the case of Administrators, for managing your property's training programme.

You must not: reproduce, distribute, modify, or create derivative works from any Platform Content; reverse-engineer or attempt to extract the source code of the Platform; or use automated tools to scrape or collect data from the Platform.

6. Your data rights

Subject to applicable law, you have the right to:

  • Access: request a copy of the personal data we hold about you.
  • Rectification: request correction of inaccurate or incomplete data.
  • Erasure: request deletion of your personal data, subject to our legal retention obligations.
  • Restriction: request that we limit how we process your data in certain circumstances.
  • Portability: receive your data in a structured, machine-readable format.
  • Objection: object to processing based on legitimate interests.
  • Withdrawal of consent: where processing is based on consent, withdraw it at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, contact us at privacy@sawatraining.com. We will respond within 30 days. If you are not satisfied with our response, you have the right to lodge a complaint with your local data protection authority. In Spain, this is the Agencia Española de Protección de Datos (AEPD) at www.aepd.es.

7. Acceptable use

You agree not to use the Platform to:

  • upload, transmit, or share content that is unlawful, defamatory, discriminatory, or harmful;
  • impersonate another person or misrepresent your identity or affiliation;
  • interfere with or disrupt the Platform's infrastructure, security, or integrity;
  • attempt to gain unauthorised access to any account, system, or network connected to the Platform;
  • use the Platform in any way that violates applicable laws or regulations.

Sawa reserves the right to suspend or terminate access for Users who breach this section without prior notice.

8. Disclaimer and limitation of liability

The Platform is provided "as is" and "as available". While we strive for high availability, Sawa does not warrant that the Platform will be uninterrupted, error-free, or free of viruses or other harmful components. Content is provided for professional development purposes only and does not constitute professional advice.

To the maximum extent permitted by applicable law, Sawa's total liability to any User for all claims arising out of or in connection with these Terms or the use of the Platform shall not exceed the greater of (a) the amount paid by the Hotel Client for the service in the 12 months preceding the claim, or (b) €100.

Nothing in these Terms limits or excludes liability for death or personal injury caused by negligence, fraud, or any other liability that cannot be excluded or limited by law.

9. Modifications to the platform and terms

Sawa reserves the right to modify, suspend, or discontinue any part of the Platform at any time with reasonable notice. We may update these Terms from time to time. If we make material changes, we will notify you by email or in-app notification at least 14 days before the changes take effect. Continued use of the Platform after that date constitutes acceptance of the updated Terms.

10. Governing law and dispute resolution

These Terms are governed by the laws of the Kingdom of Spain, without regard to conflict of law principles. The parties submit to the exclusive jurisdiction of the courts of Barcelona, Spain, for the resolution of any dispute arising under or in connection with these Terms.

Before initiating formal proceedings, both parties agree to attempt resolution through good-faith negotiation for a period of 30 days following written notice of the dispute.

11. Contact

For questions about these Terms, data privacy, or your rights:

  • General: help@sawatraining.com
  • Privacy and data requests: privacy@sawatraining.com
  • Postal: Sawa Hospitality Learning S.L., Gran Vía Carlos III, 94, 08028, Barcelona, España
  • Web: sawatraining.com/terms

These Terms have been prepared for general informational and contractual purposes. They do not constitute legal advice. Sawa recommends that the Hotel Client and individual Users seek independent legal advice if they have specific questions about their rights or obligations.

12. Acceptance record

By clicking "I accept" within the Sawa application or onboarding email, you confirm that:

  • you have read and understood these Terms in full;
  • you are at least 18 years of age or have obtained parental or guardian consent;
  • you accept these Terms on your own behalf and, where applicable, on behalf of the organisation you represent; and
  • you consent to the collection and use of your data as described in Section 4.

Sawa Hospitality Learning S.L. · Gran Vía Carlos III, 94, 08028, Barcelona, España