Edmanly Last updated: May 26, 2026 Effective date: May 26, 2026
1. Introduction
This Privacy Policy explains how Edmanly LLC ("Edmanly," "we," "us," or "our") collects, uses, shares, and protects your personal data when you use the Edmanly mobile application, website, and related services (collectively, the "Service").
Edmanly is a peer-to-peer escrow platform registered in the Arab Republic of Egypt under Commercial Registration No. 290693.
By using the Service, you agree to the practices described here. If you do not agree, do not use the Service.
2. The Data We Collect
We collect data in three main ways: (a) information you give us, (b) information we collect automatically, and (c) information we receive from third parties.
2.1 Information you give us
| Category | Examples |
|---|---|
| Identity data | Full name, date of birth, gender, nationality |
| Government ID data | National ID number, passport number, ID image |
| Biometric data | Selfie/liveness video used for identity verification |
| Contact data | Email address, phone number, postal address |
| Account data | Username, password (hashed), profile photo |
| Financial data | Bank account details, mobile wallet number, transaction history. We do not store full payment card numbers; they are tokenized and handled by our payment processors. |
| Transaction data | Counterparty, amount, currency, description of goods or services, delivery details, messages exchanged in the transaction |
| Support data | Information you provide when contacting customer support |
2.2 Information we collect automatically
| Category | Examples |
|---|---|
| Device data | Device model, operating system, language, time zone, unique device identifiers (IDFA/IDFV where applicable), crash reports |
| Usage data | Screens viewed, features used, taps, session length, referral source |
| Diagnostics | Error logs, performance metrics |
| Approximate location | Derived from IP address (we do not collect precise GPS location unless you explicitly opt in for a specific feature) |
2.3 Information from third parties
| Source | Purpose |
|---|---|
| Didit | Identity verification (KYC) results, document authenticity checks, biometric match results |
| Akedly | Phone number verification results |
| Payment processors | Payment confirmation, fraud signals, tokenized payment-method references |
| Sanctions screening providers | Match results against sanctions and politically-exposed-person ("PEP") lists, where required by AML/CFT law |
3. How We Use Your Data
We use your data for the following purposes:
- To provide the Service: create and manage your account, process transactions, hold funds in escrow, release or refund funds, and resolve disputes.
- To verify your identity: comply with AML/CFT obligations, prevent fraud, and confirm you are the person you claim to be.
- To communicate with you: send transaction notifications, security alerts, support responses, and important account updates.
- To improve the Service: analyze usage trends, debug issues, and build new features.
- To prevent harm: detect and prevent fraud, money laundering, sanctions evasion, abuse, and other illegal or harmful activity on the platform.
- To comply with law: respond to lawful requests from public authorities, maintain records required by Egyptian law, and enforce our Terms.
- With your consent: send marketing communications about new features or promotions, which you can opt out of at any time.
4. Legal Bases for Processing
Where applicable data protection law requires us to identify a legal basis, we rely on:
- Performance of a contract: to provide the Service you signed up for.
- Legal obligation: to meet AML/CFT, tax, and other regulatory requirements.
- Legitimate interests: to keep the Service secure, prevent fraud, and improve our product, balanced against your rights.
- Consent: for optional features such as marketing communications and precise location, where applicable. You can withdraw consent at any time.
5. Who We Share Your Data With
We do not sell your personal data. We share data only as follows:
5.1 Service providers acting on our behalf
| Provider | Purpose | Data shared |
|---|---|---|
| Supabase (database & authentication) | Hosting account, transaction, and message data | Account data, transaction data, hashed passwords, encrypted records |
| Didit (KYC) | Identity verification | Identity data, government ID data, biometric data |
| Akedly (phone verification) | Phone verification | Phone number |
| Payment processors | Payment processing, fund custody, payouts | Financial data, transaction data, basic identity data |
| Crash and analytics tools | Performance monitoring | Device data, diagnostics, usage data |
| Cloud infrastructure providers | Hosting, storage, content delivery | All data, encrypted in transit and at rest |
| Customer support tools | Helpdesk and ticketing | Contact data, support data |
We require each provider to protect your data with appropriate security measures and to use it only for the purposes we authorize.
5.2 Your transaction counterparty
When you transact with another Edmanly user, we share a limited profile with them so the transaction can take place, typically your display name, profile photo, verification status, and the messages you choose to send within the transaction. We do not share your national ID number, full date of birth, or financial account details with your counterparty.
5.3 Authorities and legal requirements
We may disclose your data if we are required to do so by Egyptian law, a court order, a regulatory request, or to enforce our legal rights, prevent fraud, or protect the safety of users or the public.
5.4 Business transfers
If Edmanly is involved in a merger, acquisition, restructuring, or sale of assets, your data may be transferred as part of that transaction. We will notify you and ensure your data continues to be protected.
6. International Data Transfers
Some of our service providers operate or store data outside Egypt. Where we transfer your data internationally, we take steps to ensure it is protected, including by contractual safeguards with the provider and limiting transfers to providers with strong security practices.
7. How Long We Keep Your Data
We retain your data only as long as needed for the purposes described above.
| Data type | Retention period |
|---|---|
| Active account data | While your account is open |
| KYC and AML records | At least five (5) years after account closure, as required by Egyptian AML/CFT law |
| Transaction records | At least five (5) years after the transaction is completed |
| Marketing data | Until you opt out, then deleted |
| Support correspondence | Up to two (2) years after the case is closed |
| Logs and analytics | Up to twelve (12) months in identifiable form, then aggregated or deleted |
After the relevant retention period, we delete or irreversibly anonymize your data.
8. Your Rights
Subject to applicable law, you have the right to:
- Access the personal data we hold about you;
- Correct inaccurate or incomplete data;
- Delete your data (subject to our legal retention obligations; see Section 7);
- Restrict or object to certain uses of your data;
- Withdraw consent where processing is based on your consent;
- Portability: receive your data in a portable format;
- Lodge a complaint with the competent Egyptian data protection authority.
To exercise any of these rights, contact us at privacy@edmanly.net, or use the in-app options described below. We will respond within thirty (30) days.
8.1 In-app account deletion
You can delete your Edmanly account at any time from:
Settings → Account → Delete Account
Account deletion removes your profile and most of your personal data immediately. However, transaction and KYC records required by AML/CFT law are kept for the retention periods in Section 7 in a restricted form, accessible only for compliance purposes.
You cannot delete your account while transactions are pending. Complete or cancel them first.
9. Security
We take security seriously. Our measures include:
- Encryption of data in transit (TLS) and at rest;
- Hashed and salted password storage;
- Role-based access controls and the principle of least privilege for staff;
- Regular security reviews and penetration testing;
- Logging and monitoring of unusual access patterns;
- Vendor due diligence for all third-party processors.
No security system is perfect. If we discover a data breach that materially affects you, we will notify you and the relevant authorities as required by law.
10. Children
Edmanly is not directed to and is not intended for use by anyone under the age of eighteen (18). We do not knowingly collect personal data from minors. If you believe we have collected data from a person under 18, contact us at privacy@edmanly.net and we will delete it.
11. Cookies and Similar Technologies
Our app uses limited tracking technologies for authentication, security, and analytics. We do not use third-party advertising trackers and do not engage in cross-app behavioral tracking. On iOS, we do not request App Tracking Transparency permission because we do not track you across apps and websites owned by other companies.
12. Marketing Communications
If you opt in, we may send you product updates, tips, and promotional offers by email or push notification. You can unsubscribe at any time using the link in any email or by turning off promotional notifications in Settings.
Transaction notifications (e.g., "your funds were released") are operational, not promotional, and cannot be disabled while you have an active account.
13. Third-Party Links
Our Service may contain links to third-party websites or services. We are not responsible for their privacy practices. Review their policies before using them.
14. Prevailing Language
This Privacy Policy is made available in both Arabic and English. In the event of any conflict or inconsistency between the two versions, the Arabic version shall prevail for users residing in the Arab Republic of Egypt.
15. Changes to This Policy
We may update this Privacy Policy from time to time. If we make material changes, we will notify you through the app or by email at least 30 days before the changes take effect. The "Last updated" date at the top of this policy reflects the most recent revision.
16. Contact Us
For privacy questions, requests, or complaints:
- Email: privacy@edmanly.net
- In-app: Settings → Help & Support → Privacy
- Commercial Registration: 290693
If you are not satisfied with our response, you may contact the competent Egyptian data protection authority.