Your Data. Your Privacy. Our Responsibility.

UPPAIR is a digital platform owned and operated by EUMENA (ايومينا), a limited liability company. EUMENA decides the purposes and means of processing your personal data through UPPAIR and is responsible for it as the data controller.

For questions and requests about privacy and data protection, contact us at our official email address: info@eumena.net.

The only service currently available on UPPAIR is the early-access waiting list, on the website or in the mobile app. UPPAIR does not yet offer accounts, passwords, profiles, posts or messages.

When you join early access, we collect:

• Your name.
• Your email address.
• Your WhatsApp number, which is optional and collected only if you enter it.
• Your role (professional or business owner) and your specialty or type of business.
• The interface language you signed up in and the platform you used (website, iOS or Android).
• A record of your consent: when you gave it and which version of the text you agreed to, plus when you opted in to marketing, if you did.

We also handle limited technical data to run and protect the service:

• Your device's IP address: used at the moment of your request to limit repeated sign-up attempts and abuse. We don't store the address itself, only a code produced by a keyed hash function (HMAC) that cannot be turned back into the address without the secret key. It is deleted periodically after a short time.
• Technical error logs that do not contain what you type into the sign-up form.
• Your language preference: one cookie in your browser, or a setting saved on your device in the mobile app (see Cookies and Analytics).

When new features launch, we may collect further categories of data, including:

• Account and sign-in information.
• Professional and business profiles and portfolio work.
• Posts and other content you publish.
• Pair Requests and accepted Pairs.
• Messages and their metadata.
• Project, collaboration and Virtual Office information.
• Notifications and notification settings.

We will not start collecting any of these before this policy is updated to explain what is collected, why, and on what legal basis.

UPPAIR is intended for adult business owners and professionals. We do not knowingly collect personal data from children.

When accounts and social features launch, we will use the related data for registration and sign-in, showing and discovering professional and business profiles, managing Pair Requests, messaging, collaboration, managing teams and Virtual Offices, and essential notifications. We will set out the legal basis for each purpose in an update to this policy before it launches.

We send marketing messages only to people who explicitly opted in, and opting in is never a condition of joining early access.

Early-access information is private: it is not shown to other users or on any page of the platform.

When profiles and posts launch, the platform will follow these principles:

• The professional or business profile, posts and portfolio work you publish are designed to be visible to UPPAIR users.
• Private account details such as your email address, phone number and password are not shown on your public profile.
• Private messages, collaboration content and Virtual Office data are available only to authorized participants.

We will describe the visibility and privacy settings that actually exist when these features launch, and we will not promise settings that don't exist.

Our users' data is not for sale. EUMENA does not sell UPPAIR users' personal data to advertisers or anyone else.

We share data only in the following cases, and only as much as each one needs:

• Infrastructure providers: companies that host and run the platform and its database for us, processing data only on our instructions.
• Communication channels: if we contact you on WhatsApp, messages pass through WhatsApp's service and are also subject to its privacy policy; if we email you, our email service provider processes your address to deliver the message.
• Other users: once profiles and posts launch, other users see only what you choose to publish.
• Competent authorities: when the law requires it, or to protect rights and safety as permitted by law.

We do not currently use any third-party analytics, advertising or tracking service.

We treat data protection as a core design requirement, not a marketing promise. Our measures include:

• Encryption in transit: in production the platform runs only over encrypted connections (HTTPS/TLS), and the connection between our servers and the database is encrypted too. The application's configuration refuses to run otherwise.
• Encryption at rest: the database and its backups are stored with a hosting provider that encrypts stored data, and we will not launch before verifying that this is enabled.
• Passwords: when accounts launch, passwords will never be stored as readable text, only as a one-way hash produced by an algorithm designed for this purpose (Argon2id).
• Access control: there is no public interface for reading sign-up data, and access is limited to authorized EUMENA staff, only as needed.
• Protected keys: secrets and keys are kept outside the source code and are never sent to the browser or the app.
• Data minimization: we ask for as little as possible, and your WhatsApp number is optional.
• Abuse protection: a limit on repeated attempts, and the same response whether or not an email address is already registered.

No online system is completely secure. If a security incident affects your personal data, we will act on it immediately and notify you and the competent authorities as the law requires.

Encryption in transit and at rest is not the same as end-to-end encryption. UPPAIR does not currently offer end-to-end encryption.

Messaging and Virtual Offices are not available yet. When they launch they will follow these principles, and we will describe them in detail in an update to this policy:

• Private messages are available only to the people in the conversation, and sending a message never creates a Pair.
• A Pair does not give either person access to the other's private information.
• Joining a Virtual Office requires an explicit invitation and does not automatically grant access to every document, discussion or task; office administrators set permissions within their office.
• Authorized EUMENA support staff access private content only when necessary, for example to investigate a report or a security issue or to meet a legal obligation, and only as much as needed.

Under the Egyptian Personal Data Protection Law No. 151 of 2020 and other applicable laws, you have the right to:

• Know what personal data we hold about you, and access and obtain it.
• Have inaccurate data corrected, completed or updated.
• Request the erasure of your personal data.
• Withdraw your consent at any time, without affecting processing that took place before you withdrew it.
• Request that processing be restricted to a specific scope, or object to processing where the law allows.
• Be informed of any breach affecting your personal data.

We respond to requests within the time limits set by law. If you are not satisfied with our response, you have the right to complain to the Personal Data Protection Center.

To protect your data, we verify the identity of whoever makes a request before acting on it, usually by asking that the request come from, or be confirmed through, the email address you registered with. We will never ask for a password or for information the request does not need.

We may be unable to fulfil some requests in full where the law requires us to keep certain data. If so, we will explain why.

You can unsubscribe from marketing messages at any time by contacting us, or through the unsubscribe link in the message where one is provided.

We keep personal data only as long as needed for the purpose it was collected for:

• Early-access data: until its purpose ends with the launch of the platform and our contact with you about it, or until you ask us to delete it or withdraw your consent, whichever comes first.
• The hashed IP code used to limit repeated attempts: deleted periodically after a short time.
• Backups: data is removed from them automatically when the backup retention cycle ends.
• Consent records: kept as long as needed to demonstrate that we comply with the law; for marketing, consent records are kept for the period the law requires after the last marketing message.

UPPAIR does not offer accounts yet, so early-access data is deleted on request via info@eumena.net. When accounts launch you will be able to request account deletion, and we will explain what is deleted immediately and what may need to be kept for a defined period for legal or security reasons.

The UPPAIR website uses one cookie, which is essential to how it works:

• bsp_locale: remembers the language you chose (Arabic or English) for one year. It contains nothing that identifies you.

We do not use advertising, tracking or analytics cookies. The website's fonts are hosted on our own servers, so your browser does not contact external font services.

In the mobile app, we store on your device only your chosen language, your progress through the welcome screens and whether you have signed up. We do not store the sign-up form's contents on the device.

If we later add analytics or any other non-essential technology, we will ask for your consent first where the law requires it, and we will update this policy.

To operate UPPAIR we rely on the following categories of service providers, each processing only the data its role requires:

• Hosting for the platform and its database.
• An email service, to contact you.
• WhatsApp, if you add your number and agree to be contacted there.

Some of these providers' servers may be located outside the Arab Republic of Egypt. We transfer personal data outside Egypt only in accordance with the conditions and safeguards the law sets for cross-border transfers.

We may update this policy when new features launch or applicable laws change. The date of the latest update is shown at the top of this page. If a change is significant, we will tell you before it takes effect, by the email address you registered with or with a clear notice on the platform, and we will ask for your consent again where the law requires it.

For any question or request about your data, such as accessing, correcting or deleting it, withdrawing your consent or unsubscribing from marketing, email us at info@eumena.net. Tell us what kind of request it is, and please don't send passwords or sensitive information.