Privacy Policy

1. Introduction

Close Friends ("Close Friends," "we," "us," or "our") is operated by [Close Friends LLC Legal Name], a limited liability company in the process of being incorporated in the United Arab Emirates [insert LLC legal name, trade license number and registered address once incorporation is complete]. We run a community marketplace that allows members to rent, lend, buy and sell fashion items across the UAE. This Privacy Policy explains what personal data we collect, how we use it, who we share it with, and the choices and rights you have. It applies to anyone who uses our app, website, or related services (the "Platform"), whether as a Renter, Buyer, Lender, Seller, brand partner, or visitor.

By using the Platform, you agree to the collection and use of information as described in this Privacy Policy.

2. Information We Collect

• Account & profile information — your name, email address, phone number, date of birth, profile photo, and password when you create an account.
• Identity verification — a copy of your Emirates ID, passport, or other government-issued ID, used to verify your identity, confirm you meet our age requirement, and protect the community against fraud.
• Delivery information — your delivery address(es) and any delivery instructions.
• Payment information — processed securely by our payment partner, Stripe. We do not store your full card details on our own servers.
• Listing information — item details, brand, condition, measurements, and photographs you upload when listing an item to rent or sell, including condition photos taken before and after a rental.
• Communications — messages sent through in-app chat, WhatsApp, customer support conversations, reviews and ratings.
• Usage & device information — how you use the app, pages viewed, app version, device type, IP address, and approximate location, collected automatically through cookies and similar technologies.
• Bank details — for Lenders and Sellers, the bank account information needed to process payouts.

3. How We Use Your Information

We use your information to:

• create and manage your account;
• operate the marketplace, including processing rentals, sales, bookings and listings;
• verify your identity and the authenticity of listed items;
• process payments and payouts, including through Stripe;
• arrange courier pickup, delivery and professional cleaning;
• provide customer support and resolve disputes, including fit returns, damage claims and Close Friends Protect requests;
• send transactional notifications (booking confirmations, delivery updates, payout confirmations) via the app, email or WhatsApp;
• send marketing communications, where you have agreed to receive them, and where relevant, show you advertising about Close Friends on other platforms;
• maintain the safety, security and integrity of the Platform, including fraud and risk screening of orders; and
• comply with our legal and regulatory obligations, including UAE commercial recordkeeping requirements.

4. How We Share Your Information

We share personal data with:

• couriers and logistics partners, to collect and deliver items;
• our payment processor, Stripe, to process payments and payouts;
• our authentication partner, Real Authentication, where an item requires luxury authentication;
• professional cleaning partners, to clean rented items between bookings;
• other members, on a limited basis — for example, a Lender can see the delivery details needed to fulfil an order, and members can see each other's public profile, ratings and reviews;
• service providers who support our app infrastructure, analytics, customer support, and communications, including WhatsApp Business and [insert any analytics/advertising tools used, e.g. Google Analytics, Meta];
• regulators, law enforcement or courts, where required by law; and
• a buyer of our business, in the event of a merger, acquisition or sale of assets.

We do not sell your personal data to third parties for their own marketing purposes.

5. Cookies, Analytics & Online Advertising

Our app and website use cookies and similar technologies (such as log files, tags and pixels) to keep you signed in, remember your preferences, understand how the Platform is used, and, where you have not opted out, to show you relevant advertising about Close Friends on other websites and apps. You can manage cookie preferences through your browser or device settings, and where available, through the opt-out tools offered by our analytics and advertising partners or industry bodies such as the Digital Advertising Alliance.

Because there is no consistent industry standard for responding to browser "Do Not Track" signals, we do not currently alter our data practices when such a signal is detected.

6. International Data Transfers

Some of our service providers, including Stripe, may process data outside the UAE. Where this happens, we take reasonable steps to ensure your data continues to receive an appropriate level of protection, consistent with the UAE's Personal Data Protection Law.

7. Data Retention

We retain your personal data for as long as your account is active, and for a reasonable period afterwards to meet our legal, accounting, tax and dispute-resolution obligations. Records relating to transactions and payments are retained for a minimum of 5 years in line with UAE commercial recordkeeping requirements. Identity verification documents are retained only for as long as necessary for verification and fraud-prevention purposes.

8. Your Rights

Subject to applicable law, you have the right to:

• access the personal data we hold about you;
• request correction of inaccurate or incomplete data;
• request deletion of your data, subject to our legal retention obligations;
• object to, or request that we restrict, certain processing;
• withdraw consent at any time, where processing is based on consent; and
• lodge a complaint with the UAE Data Office if you believe your data has been mishandled.

To exercise any of these rights, contact us using the details in Section 12.

9. Children's Privacy

Close Friends is intended for users aged 18 and over. We do not knowingly collect personal data from anyone under 18. If we learn that we have collected data from a minor, we will take steps to delete it.

10. Security

We use administrative, technical and physical safeguards designed to protect your personal data, including encryption of payment data in transit and restricted access to personal data on a need-to-know basis. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

11. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes to our practices or for other operational, legal or regulatory reasons. We will notify you of material changes through the app or by email, and the date at the top of this page will reflect the most recent revision.

12. Contact Us & Complaints

If you have questions about this Privacy Policy, wish to exercise your rights, or would like to make a complaint, please contact us through the Help section of the app or at Fabiolaandreinaf@gmail.com (we recommend moving to a dedicated business email, e.g. privacy@closefriends.ae, before launch).

13. A Note on Our Legal Structure

Close Friends is currently in the process of incorporating as a limited liability company in the United Arab Emirates. Once incorporation is complete, please insert the final legal entity name, trade license number and registered address in Section 1 above, and have this document given a final review by your lawyer before publishing — particularly to confirm data protection obligations under your chosen jurisdiction (mainland PDPL vs. a free zone's own data protection law, if applicable).