Privacy Policy
Version: 1.0 (Draft). Last updated: [DATE]
Preliminary draft for legal review only. Not legal advice. Not to be published before review by qualified counsel.
Read this Policy together with Premier Share's Terms of Use and Risk Disclosure.
Section 0: Introduction & Data Controller
Premier Share is committed to protecting the privacy and security of your personal data. This Policy explains how we collect, use, protect, and disclose your data. "Personal data" includes any data relating to you by which you can be identified, whether collected directly or through technologies such as cookies.
The Data Controller is Premier for Real Estate Development, registered under Commercial Register No. [COMMERCIAL REGISTER NO.], with its head office at [FULL ADDRESS], Arab Republic of Egypt. By using the Platform, you accept the practices described in this Policy.
Note for legal review: Counsel to precisely identify the Data Controller (Premier Share as a separate entity or the parent company), and whether appointing a Data Protection Officer or obtaining a license/permit from the Personal Data Protection Center is required under Law 151 of 2020.
Section 1: Purpose & Legal Basis
Data protection laws, foremost Egyptian Personal Data Protection Law No. 151 of 2020, set the standards governing the handling of personal data. We are committed to processing your data fairly, lawfully, and transparently, focusing on collecting the minimum data necessary to provide our services.
We process your data on one or more of the following legal bases: your explicit consent, performance of a contract between us, compliance with a legal obligation (such as anti-money-laundering), or the Platform's legitimate interest without prejudicing your rights.
Section 2: Data We Collect & Collection Methods
We collect the following types of data:
Personal & identity data: name, email, phone number, national ID, and KYC/AML data.
Financial data: bank account details, payment data, and Wallet balances and transactions.
Investment data: Shares owned, installment plans, Secondary Market transactions, and co-investing.
Partner Program data: referral code, invitee network, and bonuses due.
Usage & technical data: IP address, device and browser type, operating system, browsing patterns, and in-app interaction data.
Notification token (FCM token): to send in-app and push notifications.
Cookies and similar technologies: to improve your experience.
We collect this data when you: register, complete KYC, invest, make payments, participate in the Partner Program or promotional campaigns, and when you browse the Platform (via cookies and technical data).
Section 3: How We Use Your Data
We use your data for the following purposes:
Assessing your eligibility, activating your account, conducting KYC/AML checks, and building your investment profile.
Executing your transactions (purchase, installments, Secondary Market, co-investing) and managing your Wallet.
Operating the Success Partners Program and calculating and verifying bonuses.
Operating AI features (Ahmed Advisor) to provide informational content, subject to Section 7.
Preventing and detecting financial crime (money laundering, fraud) and complying with legal and regulatory obligations.
Managing our relationship with you, support, billing, and notifying you of changes.
Analytics and improving the Platform, and creating anonymized statistics.
Marketing and offering deals that may interest you (with your consent and your right to opt out).
Ensuring Platform security and resolving technical issues.
Section 4: How We Protect Your Data
The security of your data is of utmost importance to us. We apply technical and organizational security measures to protect your data, including encryption of KYC data at rest, secure transport protocols (SSL/TLS) when transmitting data, internal access controls, and we may require proof of identity before disclosing any information.
Nevertheless, internet security cannot be absolutely guaranteed, and transmitting information over it carries inherent risks. You can help protect your data by choosing a strong password, enabling two-factor authentication, not sharing your credentials, and keeping your app updated.
Section 5: Data Retention
We retain your data for as long as necessary to fulfill the purposes for which it was collected or to comply with legal obligations. Financial transaction data is kept for the period required by tax legislation and anti-money-laundering laws. Profile data is retained throughout your membership activity and for up to [period] after activity ceases. Otherwise, we delete or anonymize your data when it is no longer necessary.
Note for legal review: Retention periods to be precisely set by counsel per tax, AML, and Law 151/2020 requirements.
Section 6: To Whom We Disclose Your Data
We may share your data with the following parties, subject to protection standards:
Parent company and affiliates: including Premier for Real Estate Development, for operating the Platform, listing units, and executing transactions. (Important disclosure given the Platform's nature as a Premier product.)
Service providers and contractors: for payment processing, hosting, analytics, and support.
Payment service providers and banks: to execute deposits and withdrawals.
Verification and KYC/AML providers: for identity verification and fraud prevention.
Regulatory and judicial authorities: where legally required.
In case of sale or transfer of assets: customer data may be transferred as part of the assets.
This Policy does not apply to third parties' sites and practices.
Section 7: Automated Decisions & AI
We use tools to analyze your interaction with the Platform to improve our services and manage your account. AI features (such as Ahmed Advisor) also process your data to provide informational content. No decisions producing legal or significant effects on you are made solely by automated processing without human intervention, except as permitted by law. You have the right to request human intervention and to object to automated processing. AI outputs are informational only and not advice, per Section 13 of the Terms of Use.
Section 8: Cross-border Data Transfer
Your data may be stored, processed, or transferred outside the Arab Republic of Egypt (e.g., via cloud or AI service providers). In any transfer, we commit to ensuring an adequate level of protection under Law 151 of 2020, which may require contractual safeguards or a permit from the Personal Data Protection Center. By using the service, you are aware of this transfer.
Note for legal review: Law 151/2020 imposes cross-border transfer restrictions and may require a permit. Counsel to determine actual requirements for our providers (hosting, AI, payments).
Section 9: Your Rights
Under Law 151 of 2020, you have the following rights regarding your data:
Access your data and know how it is processed.
Rectify or amend your data to ensure accuracy.
Erase your data (right to be forgotten), to the extent not conflicting with our legal obligations.
Restrict or object to the processing of your data.
Withdraw your consent at any time without retroactive effect on prior processing.
Port some of your data (portability).
Not be subject to a purely automated decision that significantly affects you.
To exercise any right, contact us at [DATA PROTECTION EMAIL]. We may retain an archival copy for audit and compliance purposes.
Section 10: Consent Withdrawal & Marketing
You have the right to withdraw your consent to data processing at any time. If you wish to opt out of marketing messages, you can do so via the "unsubscribe" link in our messages, by disabling notifications within the app, or by contacting us at [DATA PROTECTION EMAIL]. We will respect your preferences and process your request promptly.
Section 11: Children's Privacy
Premier Share is not intended for persons under 18, and we do not knowingly collect children's data. If you believe a child has provided us data, please contact us and we will remove it promptly.
Section 12: Cookies & Similar Technologies
Our website and app use cookies and similar technologies to operate the Platform, improve your experience, and analyze usage. You can control cookie preferences through your browser or device settings. Disabling some cookies may affect certain Platform functions.
Section 13: Third-party Sites & Social Media
The Platform may include links to external sites whose privacy policies or practices we are not responsible for. We also operate social media accounts to engage with our customers, and we are not responsible for information posted by others on those platforms.
Section 14: Data Breach Notification
In the event of a personal data breach that may threaten your rights or freedoms, we commit to taking the necessary measures and notifying the Personal Data Protection Center and relevant authorities, and notifying you where applicable, within the periods set out in Law 151 of 2020 and its executive regulations.
Note for legal review: Counsel to set precise notification periods (the general framework indicates a 72-hour window) and mechanisms per the executive regulations.
Section 15: Changes to This Policy
We reserve the right to update this Policy from time to time at our discretion. We advise you to review it periodically to stay informed of the latest version. Your continued use of the Platform after publication constitutes acceptance of the updates.
Section 16: Contact & Data Protection Officer
For any inquiries, concerns, or complaints regarding the handling of your personal data, or to exercise your rights, please contact:
Data Protection Officer: [NAME/EMAIL] Email: [DATA PROTECTION EMAIL] Address: [FULL ADDRESS]
You also have the right to lodge a complaint with the Personal Data Protection Center in Egypt.