Privacy Policy
Draft — pending legal reviewLast updated: [insert date at publish] · Effective date: [insert date at publish]
Important note before you publish this: this is a first draft, written to reflect common practice among established business-intelligence and due-diligence providers (the kind of language used by firms like LexisNexis, Refinitiv/World-Check, and Dow Jones Risk & Compliance). It is not legal advice. Ident-ity operates across multiple jurisdictions (Egypt, GCC states, and others) and processes personal data about third parties as part of its core service — this is a higher-risk legal profile than a typical marketing website. Please have this reviewed by a lawyer qualified in Egyptian data protection law (and any other jurisdiction where you have staff, servers, or active clients) before publishing. Bracketed items [like this] need to be filled in or confirmed by you or your counsel.1. Who We Are
Ident-ity (“Ident-ity,” “we,” “us,” or “our”) is a business intelligence and corporate due-diligence company operating across the Middle East and North Africa (MENA) region. This Privacy Policy explains how we collect, use, disclose, and protect information in two distinct contexts:
- (A) Information about visitors to our website and users of our registration/portal system (e.g., you, browsing ident-ity.com); and
- (B) Information about third-party individuals and companies that appears within the due-diligence reports, corporate records retrieval, and structured data products we deliver to our clients.
These two categories are governed differently, and we address each separately below because the obligations that apply to them are not the same.
Data controller: [Ident-ity legal entity name], registered in [jurisdiction]. Contact: [privacy@ident-ity.com or equivalent].
2. Part A — Website Visitors, Registrants & Contacts
2.1 What we collect
- Contact form submissions: name, work email, company name, jurisdiction of interest, service interest, and any message you provide.
- Registration / access-request submissions: company name, your role at the company, nationality, work email address, and LinkedIn profile URL, submitted when you request access to gated service, pricing, or coverage information.
- Account verification data: a one-time verification code sent to your work email to confirm you control that address.
- Technical & usage data: IP address, browser/device type, pages visited, and similar analytics data collected automatically via cookies and similar technologies (see our Cookie Policy).
2.2 Why we collect it
- To respond to inquiries and provide requested information or quotes.
- To evaluate and process registration/access requests, including verifying that the requester is a legitimate business user (not a consumer) before granting access to our service catalogue, pricing, or data-coverage details.
- To operate, secure, and improve our website and (once launched) our client portal.
- To send you information you have requested, and — only with your consent where required — occasional updates about our services.
2.3 Legal basis (where applicable, e.g., under GDPR-equivalent frameworks)
We process this data on the basis of: (a) our legitimate interest in responding to business inquiries and vetting access requests to protect commercially sensitive information; (b) taking steps at your request prior to entering into a contract; and (c) consent, where you have opted in to marketing communications.
2.4 Registration review & approval
Access to our detailed service catalogue, pricing, and data-coverage information is granted only after internal review of your registration submission. We may decline or revoke access at our sole discretion, including where we cannot verify your business affiliation, where your registration email does not correspond to a genuine business domain, or where we reasonably believe access is being sought for a purpose inconsistent with our Terms of Service.
2.5 Retention
We retain website-visitor and registrant data for as long as reasonably necessary to fulfil the purposes above, resolve disputes, and enforce our agreements, and in any case no longer than [X months/years — confirm with counsel] after your last interaction with us, unless a longer period is required by law.
2.6 Your rights
Depending on your location, you may have rights to access, correct, delete, or restrict our use of your personal data, and to object to certain processing. To exercise these rights, contact us at [privacy@ident-ity.com]. We will respond within the timeframe required by applicable law.
3. Part B — Third-Party Data Within Our Reports & Data Products
This section is central to our business and should be read carefully by anyone whose information appears in an Ident-ity product, and by every client who uses one.
3.1 Nature of the data
Our Ident-RR, IdentBase, and IdentMedia products contain information about companies and, in some cases, named individuals (e.g., directors, shareholders, or subjects of a reverse-directorship or verification check). This information is compiled from official government registries, public filings, licensed data sources, and publicly available media in the jurisdictions where we operate. We do not solicit or process this data directly from the individuals concerned, and in most cases we have no direct relationship with them.
3.2 Basis for processing
Where applicable law requires a lawful basis for processing personal data about identifiable individuals who are not our direct customers, we rely on our (and our clients’) legitimate interest in verifying corporate and individual identities for due diligence, compliance (e.g., KYC/AML), legal, and risk-management purposes — interests that are widely recognized as legitimate under data protection frameworks applicable to the regulated industries our clients serve (banking, law, compliance).
3.3 No guarantee of accuracy or completeness
Data in our reports and products is provided “as is” and “as available.” It is sourced from third parties and official channels we do not control, may be incomplete, outdated, or contain errors originating at the source, and must not be treated as a substitute for independent verification. We disclaim liability for decisions made in reliance on this data — see our Terms of Service for the full disclaimer and limitation of liability.
3.4 Permitted use by clients
Clients who receive our reports or data agree, under our Terms of Service, to use them only for lawful purposes (such as legitimate KYC, AML, litigation support, or commercial due diligence), and not to use them for unlawful discrimination, stalking, harassment, or any purpose prohibited by the law of the jurisdiction in which the data subject is located.
3.5 Requests from individuals named in our data
If you are an individual who believes information about you appears in an Ident-ity report or database and you have concerns about its accuracy or your rights regarding it, contact us at [privacy@ident-ity.com]. We will review requests on a case-by-case basis consistent with our obligations to our clients and applicable law; where source data originates from an official government registry, corrections generally need to be made at the source, and we will direct you accordingly where possible.
4. Security
We use administrative, technical, and physical safeguards designed to protect the data we hold, including access controls limiting who within our team can view registration and report data. No system is completely secure, and we cannot guarantee absolute security.
5. International Transfers
Because we operate across multiple MENA jurisdictions and may use cloud infrastructure hosted outside your country (e.g., AWS regions), your data may be transferred to and processed in countries other than your own. [Insert transfer-mechanism language once your hosting regions and client base are finalized — this typically needs counsel input.]
6. Children’s Privacy
Our website and services are directed at businesses and professionals, not consumers, and are not intended for use by anyone under 18.
7. Changes to This Policy
We may update this Privacy Policy from time to time. The “Last updated” date at the top reflects the most recent revision. Material changes will be reflected on this page.
8. Contact Us
[Ident-ity legal entity name]
[Registered address]
[privacy@ident-ity.com]