سياسة الخصوصية

ELGARAGE is a managed used-car marketplace operating in Alexandria and Cairo, Egypt. We provide on-site vehicle inspections, 360° visual listings, and pricing consultation, and we mediate communication between buyers and sellers.

The entity responsible for your personal data (the "Data Controller") is:

الجراج سيرفيس للوساطة التجارية

Email: privacy@elgaragegy.com

In this policy, "ELGARAGE", "we", "us", and "our" refer to this company. "You" refers to any person who uses our app or website, whether as a visitor, a seller, or a buyer.

If you have any question about this policy or wish to exercise your rights, contact us at privacy@elgaragegy.com. If you believe we have not handled your data lawfully, you also have the right to complain to Egypt's Personal Data Protection Centre (PDPC).

This policy applies to:

• The ELGARAGE mobile application (iOS and Android);
• The ELGARAGE website;
• All personal data we collect through these channels and during the in-person inspection and vehicle-handover process.

You can browse listings on our app and website without creating an account. You only need to register when you want to submit a request to sell your car or submit a formal offer to buy a car. Different parts of this policy apply depending on how you use ELGARAGE, and each section below makes clear who it applies to.

We only collect data we actually need. What we collect depends on how you use ELGARAGE.

3.1 When you browse without an account You can view listings, inspection reports, and 360° views without registering. In this mode we do not ask you for identifying information, but we automatically collect limited Technical Data and Usage Data (see 3.6).

3.2 When you register Registration is required to sell a car or to make an offer. To create an account we collect:

• Your mobile phone number;
• A password you choose.

We then send a one-time password (OTP) via WhatsApp, with SMS as a fallback, to verify that the phone number is yours. We do not collect your name, email, or national ID at the registration stage.

3.3 When you submit a request to sell your car After registering, if you request an inspection to list your car, we collect:

• Vehicle details — brand, model, year of manufacture, and kilometres driven;
• Your chosen inspection location — a point you pin on a map inside the app, so our inspection team can visit you;
• Your preferred appointment — the date and time you would like to be visited.

3.4 When you make an offer to buy a car If you submit a formal price offer on a listed car, we collect your offer and associate it with your registered account (phone number).

3.5 When you contact a seller (call / WhatsApp) On a car's details page you can choose to call by phone or send a WhatsApp message. To protect seller privacy, these do not connect you directly to the seller — they route to ELGARAGE. If you use the WhatsApp option, your message and phone number are handled through WhatsApp (a Meta service); see Section 6. We do not record calls and we do not operate an in-app chat.

3.6 Automatically collected data (all users) When you use our app or website, we automatically collect:

• Technical Data — IP address, device type and identifiers, operating system, browser type and version, and general location inferred from your IP;
• Usage Data — pages and listings you view, searches you run, dates and times of visits, and how you navigate the app or website;
• Log Data — successful and unsuccessful login attempts.

3.7 Data collected during the inspection and vehicle handover (sellers) When our team visits to inspect your car, and later if a sale completes:

• The inspection report describing the vehicle's condition;
• Vehicle identifiers recorded during inspection, including chassis number and engine number, used for the Documents & Verification checks;
• 360° images and photographs of the vehicle. Vehicle number plates are covered with an ELGARAGE plate and are not shown to buyers.

We currently do not collect national ID documents inside the app. If, in future, ID copies are collected at the traffic-department handover (إدارة المرور), that is sensitive personal data under the PDPL and requires separate explicit written consent and stricter handling. This policy will be updated before any such collection begins.

Under Article 6 of Law No. 151 of 2020, we process your personal data on one or more of the following bases:

• Your consent — for example, when you agree to receive marketing messages, or provide data to list your car;
• Performance of a contract — to provide the services you request, such as scheduling and carrying out an inspection or processing your offer;
• Compliance with a legal obligation — for example, tax, accounting, and record-keeping requirements under Egyptian law;
• Our legitimate interests — to operate, secure, and improve our platform, and to prevent fraud and misuse, provided these interests do not override your rights.

Where we rely on consent, you may withdraw it at any time (see Section 9). Withdrawal does not affect processing carried out before withdrawal.

We use your personal data to:

• Create and manage your account and verify your phone number by OTP;
• Receive and process your request to sell a car, and schedule the inspection at your chosen location, date, and time;
• Prepare, publish, and manage vehicle listings, inspection reports, and 360° views;
• Receive and manage buyer offers and mediate communication between buyers and sellers;
• Contact you about your account, your listing, an offer, or an appointment (including push notifications, if enabled — see Section 6);
• Operate, maintain, secure, and improve our app and website;
• Detect and prevent fraud, abuse, and unauthorised access;
• Send you marketing communications where you have consented, and let you opt out at any time;
• Comply with our legal, tax, and regulatory obligations.

We do not sell your personal data. We share it only with the following categories of recipients, and only as needed:

Service providers (data processors) who operate our platform on our behalf:

• DigitalOcean — cloud hosting and storage of our database and 360°/image assets. Servers are located in Germany (European Union).
• Zoho — business email. Zoho's data centre for our account is located in the United States.
• A licensed messaging provider (SendAPI) that delivers the one-time verification code to your phone via WhatsApp and/or SMS.
• Push notification services (where enabled) to deliver account and appointment notifications.

Meta (Facebook / WhatsApp):

• If you use the WhatsApp button to contact us about a car, your message and phone number are processed through WhatsApp, a Meta service, and Meta may hold that conversation on its servers (located outside Egypt).
• Our website uses the Meta Pixel to measure and improve our advertising. See our Cookie & Tracking Notice for detail.

Authorities and legal recipients:

• Courts, law-enforcement, regulators, and the PDPC, where we are required to disclose data to comply with a legal obligation, court order, or lawful request, or to establish, exercise, or defend a legal claim.

In the event of a business transfer: If ELGARAGE is involved in a merger, acquisition, or sale of assets, your data may be transferred to the successor entity, which will remain bound by this policy or a policy no less protective.

We require our service providers to process your data only on our instructions and to protect it with appropriate safeguards.

Some of our service providers store and process data outside Egypt:

• Our hosting and stored data (database, images, 360° assets) are located in Germany (European Union) via DigitalOcean.
• Our business email is stored in the United States via Zoho.
• WhatsApp messages and Meta Pixel data are processed by Meta on servers outside Egypt.

Where your personal data is transferred outside Egypt, we take steps to ensure it receives a level of protection consistent with Egyptian data protection law, including relying on providers that apply recognised technical and organisational safeguards. Cross-border transfers are made in accordance with the requirements of Law No. 151 of 2020 and its Executive Regulations.

We keep your personal data only as long as necessary for the purposes described in this policy:

• Account data — for as long as your account is active. If you delete your account, we delete or anonymise your personal data, except where we must keep certain records to meet a legal obligation.
• Listings, inspection reports, and 360° assets — for the life of the listing and for a reasonable period afterwards for our records and for any related transaction.
• Transaction and financial records — for the period required by Egyptian tax and commercial law.
• Marketing preferences — until you withdraw consent or object.

We may keep data longer where there is an active complaint or a reasonable prospect of a legal claim.

You can request deletion of your account and personal data at any time from within the app, or by emailing privacy@elgaragegy.com.

Under Law No. 151 of 2020, you have the right to:

• Be informed about how we process your personal data (this policy);
• Access the personal data we hold about you;
• Correct or update inaccurate or incomplete data;
• Erase your personal data where there is no lawful reason for us to keep it;
• Object to or restrict certain processing;
• Withdraw consent at any time, where processing is based on consent;
• Complain to the Personal Data Protection Centre (PDPC).

To exercise any of these rights, use the controls in the app where available, or email privacy@elgaragegy.com. We will respond within the period required by law. We do not charge for exercising your rights, except where the law permits a fee for excessive or repetitive requests.

We use administrative, technical, and physical measures to protect your personal data against unauthorised access, loss, misuse, or alteration — including access controls and encryption in transit. No system can be guaranteed completely secure, and the security of data transmitted over the internet cannot be absolutely guaranteed.

If a personal data breach occurs that affects your data, we will notify the PDPC within 72 hours of becoming aware of it, and we will inform affected users within three working days of notifying the PDPC, as required by the Executive Regulations.

ELGARAGE is not intended for anyone under the age of 18, and we do not knowingly collect data from anyone under 18. If we learn that we have collected personal data from a person under 18 without appropriate consent, we will delete it.

Our website uses cookies and similar technologies (including the Meta Pixel) to keep you logged in, remember your preferences, measure and improve our advertising, and understand how our website is used. Full detail, and how to control these, is set out in our separate Cookie & Tracking Notice.

We may update this policy to reflect changes in the law, our services, or our data practices. If we make a material change, we will post the updated policy in the app and on our website and update the "Last updated" date above. Where the law requires, we will ask for your consent again.

For any question, request, or complaint about your personal data or this policy, contact:

الجراج سيرفيس للوساطة التجارية (ELGARAGE)

Email: privacy@elgaragegy.com

You also have the right to lodge a complaint with the Personal Data Protection Centre (PDPC), Egypt.