Privacy Policy

Last updated: May 21, 2025

This Privacy Policy describes our policies and procedures on the collection, use, and disclosure of your information when you use the Service. By creating an account, you agree to our Terms & Conditions and this Privacy Policy in accordance with Egyptian data protection laws (including Law No. 151/2020).

1. Interpretation and Definitions

1.1 Interpretation

Words with initial capitals are defined below. Definitions apply equally in singular and plural.

1.2 Definitions

For this Privacy Policy:

• Account – a unique account created for you to access our Service.
• Application – Glow List, the software provided by the Company.
• Company – Glow List GEEX Technology Solutions LLC, Dokki, Cairo, Egypt.
• Country – Egypt.
• Device – any device that can access the Service (e.g. phone, tablet).
• Merchant – a business user who can add products, articles, and redeem promotions.
• Personal Data – any information relating to an identifiable individual.
• Service – the Application and related services provided by Glow List.
• Service Provider – third parties (e.g. Firebase) processing data on our behalf.
• Usage Data – data generated automatically by use of the Service (e.g. click events, OS).
• User – an individual accessing the Service to find and redeem promotions.

2. Collecting and Using Your Personal Data

2.1 Personal Data We Collect

When you register for an Account we collect:

• First name and Last name
• Phone number (Egyptian)*
• Date of Birth (DOB)
• Username
• Email address
• Password

*We use your phone number to send security alerts, and may contact you by SMS or phone call in the event of a data breach.

Users may also submit text reviews. Merchants may upload images/videos of their products or articles.

2.2 Usage Data

We collect Usage Data automatically (device OS, click events, timestamps, IP address via Firebase logs, etc.).

2.3 Device Permissions

Merchants: Camera & Gallery access to upload product/article media and scan user QR codes.

Users: No camera required for core consumer flows (users generate QR codes only).

Location: When you tap “View in Maps” on a product, we briefly access your location to open your native Maps app with directions for in-store redemption.

2.4 Automated Decisions

We do not use your data for profiling or any automated decision-making.

2.5 Lawful Basis & User Rights

We process your Personal Data (including phone number) based on your explicit consent under Egyptian PDPL Article 6. You may request access, correction, or deletion of your data by emailing our Data Protection Officer at support@glow-list.com. We will comply within 30 days.

2.6 Account Deletion & UGC

When you delete your account, we will anonymize any reviews you submitted by removing your personal identifiers and replacing your name with “Anonymous” within 30 days.

3. How We Use Your Data

• To provide & maintain the Service: account management, promotion redemptions.
• To contact You: by email, SMS, or phone call for support, security updates, or in the event of a data breach.
• For analytics: to improve functionality and user experience via our in-app analytics (e.g., button presses, redemption events).
• To enable Merchant flows: posting products, articles, managing promotions.
• To facilitate transactions: recording online/in-store redemptions.
• For business transfers: merger, sale, or reorganization (if it occurs).
• For other legitimate purposes: data analysis, trends, marketing improvements.

4. Retention of Your Personal Data

We retain your Personal Data for up to two years after your last activity, unless a longer period is required by law.

5. Data Transfers

Your data is stored and processed on:

• Firestore database: Dammam, Saudi Arabia
• Cloud Storage bucket: Belgium

By using the Service, you consent to these cross-border transfers. We have implemented standard contractual clauses and other safeguards to ensure an adequate level of protection in compliance with PDPL Articles 30–31.

6. Security of Your Personal Data

We use Firebase Auth (secured by Google) to store passwords and follow industry-standard security practices, including encryption in transit and at rest.

7. Children’s Privacy

We do not knowingly collect data from children under 13. If discovered, we will delete it.

7.1 Breach Notification

In the unlikely event of a data breach, we will notify the Personal Data Protection Center and affected users within 240 hours, detailing the nature of the breach and our remedial measures. We may also contact you directly via SMS or phone call if your phone number is affected.

8. Your Rights

You may request access, correction, or deletion of your data by emailing support@glow-list.com or admin@glow-list.com. We will respond within 30 days.

9. Changes to This Privacy Policy

We will notify you of material changes via email or in-app notification.

10. Contact Us

If you have any questions, email us at admin@glow-list.com or our DPO at support@glow-list.com.