Privacy and Data Processing Policy

1. General Introduction

The Digital Platform for Foreign Marriages, affiliated with TCMG Group, is committed to the highest global standards of data protection and privacy. Given the nature of our services, which require handling sovereign documents and legal procedures to conclude official marriage contracts across borders, we adopt strict policies that match banking and governmental institutions in the precision of handling information. This policy aims to clarify how we collect, use, and protect your personal, biometric, and legal information.

2. Information We Collect

As the largest digital platform for foreign marriages, we collect multiple categories of data to ensure the validity of legal procedures:

A. Identity and Official Documents

We collect and store digital copies of: • Citizenship, Passports, and National IDs: To verify citizenship and the validity of national IDs. • Civil Status Certificates: (Singlehood certificates, divorce documents, or death certificates of a former spouse) to ensure freedom from religious and legal impediments. • Residency and Address Information: Proof of residence for both spouses in their respective countries.

B. Personal, Religious, and Financial Data

• Religion: To ensure the marriage contract complies with Islamic Sharia or relevant religious laws (including the calculation of inheritance and lineage later on). • Dowry (Mahr) Data (for Islamic Marriage): Details of the advanced and deferred dowry to be documented in the body of the contract. • Special Conditions in the Contract: Any conditions dictated by one of the spouses (such as the condition of work, housing, or Isma [authority to divorce]) which are recorded textually in our database for inclusion in the contract. • Contact Information: International phone numbers, email, and social media accounts (if necessary for verification).

C. Biometric Data and Digital Verification

To ensure the highest levels of security and prevent fraud, we use advanced technologies to collect: • Face Print and Biometric Features: We use Face Mapping algorithms to confirm that the applicant is the owner of the official documents. • Liveness Detection: To ensure that the user is a real person and not a photo or recorded video, and to detect any Deepfake attempts. • Video and Audio Recordings: We retain visual and audio recordings of video calls in which the Offer and Acceptance (Ijab and Qubool) or Power of Attorney takes place, as conclusive legal evidence that negates ignorance and confirms complete consent, in order to ward off future suspicions.

D. Legal Data and Powers of Attorney

• Mandates and Powers of Attorney: Copies of official Powers of Attorney (POA) or mandates that grant us the right to proceed with marriage procedures on your behalf.

3. How We Use Your Data (Purposes of Processing)

We use this data for the following purposes: • Concluding the Official Marriage Contract: Drafting contracts and documenting them with government authorities (Ministries of Justice, Foreign Affairs, and Embassies) based on the submitted data. • Legal and Religious Compliance: Ensuring there are no impediments to marriage (such as the Iddah waiting period, the existence of a standing marriage that prevents polygamy in some laws, or difference in religion that prevents marriage). • Combating Fraud and Forgery: Using biometric data and video analysis to prevent impersonation or the use of Artificial Intelligence (Deepfake) techniques in concluding fake contracts. • Legal Archiving: Retaining permanent records of contracts and videos to use as legal evidence in the event of any future dispute regarding the validity of the marriage.

4. Data Sharing with Third Parties

Due to the nature of our legal work, we may share your data with the following entities "on a need-to-know basis": • Governmental and Judicial Authorities: Courts, notary offices, and Ministries of Foreign Affairs to complete documentation. • Embassies and Consulates: For the legalization of contracts. • Religious Officiants (Maazoons) and Legal Notaries: Partners accredited by TCMG to conduct the ceremonies. • Security Auditors: Third-party technical parties we may use exclusively for the purpose of analyzing document validity and preventing forgery.

5. Information Security and Data Storage

The TCMG platform handles your data with a high level of security: • Encryption: All sensitive data (IDs, videos) is encrypted In-Transit and At-Rest using advanced encryption protocols. • Restricted Access: No one has the right to view original documents or videos except legal consultants and the specialized verification team within the Group.

6. Compliance with the General Data Protection Regulation (GDPR) and International Transfer

Given the global nature of TCMG services, we acknowledge that your data may be transferred and processed outside the European Economic Area (EEA) to complete marriage procedures in other jurisdictions. • Basis of Legal Transfer: By agreeing to this policy, you grant us "explicit and informed consent" to transfer your data across borders due to Contractual Necessity. • Data Processing: We act as a "Data Controller" regarding the collection of information, and as a "Processor" regarding its submission to government authorities.

7. Data Retention and Secure Disposal Policy

The platform adheres to the principle of "Storage Limitation" to reduce digital risks. • Retention Period: All sensitive digital data (including recorded videos, biometric data, passport copies, and chat logs) are retained on our active servers for only 90 days from the date of service completion (the date of issuance of the marriage contract or final refusal). • Secure Disposal: After the 90-day period expires, data is automatically and permanently erased from all TCMG servers and databases using Data Overwriting techniques to ensure it cannot be recovered. • Applicant Responsibility: The applicant must download and retain their own copies of contracts and videos during this period. After the 90 days, the platform disclaims all responsibility for any loss of documents, and we cannot recover any files that have been destroyed.

8. Limitation of Liability and Indemnification

• Disclaimer regarding Third Parties: TCMG does not control, and is not responsible for, the privacy practices of government authorities, embassies, or independent religious officiants who receive your documents to conclude the marriage. Once your papers are handed over to them, your data is subject to their own policies.

9. Technology Evolution and Artificial Intelligence (AI & Future Tech)

Given the rapid development of technology, you acknowledge and agree to the following: • Automated Decision Making: TCMG platform may use current or future Artificial Intelligence algorithms (not yet invented) to verify papers or analyze videos. You agree in advance to the accuracy of these systems and waive your right to challenge the "Automated Rejection" of the transaction if the algorithms suspect manipulation. • Blockchain Technologies: We reserve the right to use Distributed Ledger Technologies or "Smart Contracts" to document the marriage digitally in the future. In this case, the Digital Ledger constitutes conclusive and final evidence of the occurrence of the transaction that cannot be disproven.

10. The Digital Hash Exception

TCMG reserves the right to retain a (Cryptographic Hash) or Metadata record of the transaction forever. This record does not contain your photos or readable personal data, but is an encrypted digital code that proves before courts that (File X) was created on (Date Y) with the consent of (User Z). This record is considered a legal argument to ward off any future claim regarding the non-existence of the transaction or its forgery.

11. Professional Notes of Proxies

• Self-Assessments of Lawyers: We collect and store written notes and oral reports provided by lawyers or legal proxies (TCMG Proxies) who handled your file or met you (virtually). These data include their professional impressions regarding your seriousness, your mental capacity at the time of the contract, and the extent of your understanding of the procedures, and are considered a confidential part of the applicant's file.

12. Telemetry and Crash Reports

• Technical Stability Logs: In the event of a technical error while using the platform or application, your device automatically sends reports containing (Stack Traces), memory status, and the last action you took before the crash. This data is necessary to fix errors and ensure contract data is not lost due to software problems.

13. Audio-Visual Legal Records

Since marriage is a contract that requires "Offer and Acceptance," we collect and retain: • Legal and Religious Consent Video: A full video (audio and visual) is recorded containing the spouses' declaration of consent, the platform mandate, and the recitation of personal data. This video is treated as an "Official Deed" or "Forensic Evidence" to prove complete consent and negate ignorance. • Video Metadata: We do not suffice with the video only, but we collect background data about the video such as (recording time, type of camera used, geographical location at the time of recording, and the absence of technical modifications to the file) to ensure its authenticity.

14. Technical and Device Information

To ensure there is no electronic fraud, we collect automatically when using the platform: • Device IDs: Device type, operating system, and IP Address to identify the country from which access is made and match it with the declared country of residence. • Log Data: Time of entry, pages visited, and duration of stay at each step of the registration steps.

15. Communication and Support Logs

• Text Chat Logs: We retain full copies of all Chat Logs that take place between applicants and the legal support team or consultants via the platform or approved messaging applications (such as WhatsApp Business API). • Support Audio Recordings: In the case of telephone contact with the customer service center, calls are recorded for quality control purposes and to document legal instructions provided to the applicant, and these recordings are considered part of the applicant's file.

16. Background Check and Sanctions Screening

• Blacklist Screening: We process your name and data to match them (via automated systems) with declared international sanctions lists (such as UN lists, OFAC, and Interpol lists) to ensure services are not provided to persons banned from international dealings. • Number Validation: We use third-party services to verify that the phone number used is registered and active and is not a fake number (Virtual Number) used for one time.

17. Payment and AML Compliance

• Transaction Logs: We do not retain full bank card numbers, but we retain "Transaction Tokens", payment date, amount value, currency, and cardholder name, to comply with Anti-Money Laundering (AML) laws and prove financial contracting.

18. Device Permissions Data

• Media Permissions: We request and store temporary access to the camera and microphone (to record the consent video and check liveness) and access to the photo/file gallery (to upload documents). The timing of granting these permissions is recorded as evidence of the user's voluntary consent to recording.

19. Guardians Data

• Witness Identities: We collect nominal data and ID numbers or passports of the "Witnesses" who sign the contract (whether provided by the platform or by the applicant) to ensure their legal eligibility to testify. • Guardian Data (for Islamic Marriage): In cases requiring a "Guardian" (Wali) (such as a virgin in some sects), we collect the Guardian's identity data and their explicit consent (whether via video or written mandate).

20. Behavioral Biometrics

• Interaction Dynamics: We collect data on how you interact with the platform (Keystroke Dynamics, mouse movements, hesitation before clicking the "Agree" button). This data helps us detect if the user is being coerced during signing or if an automated "Bot" is filling out the data.

21. Time-Zone and Geolocation Consistency

• Time Zone Match: We compare your "Device Time" with the "Actual Time of your IP Address". This discrepancy reveals the use of VPN software or attempts to hide the real location, which is an important indicator for accepting or rejecting the transaction securely.

22. Language Preferences

• Correspondence and Contract Language: We record the language you chose to browse the site and conduct the video.

23. Cookies and Tracking Pixels

• Technical Tracking Data: We collect data via Cookies necessary to run the secure session, prevent account hacking while filling out forms, and remember your steps in case of connection loss.

24. Logistics and Physical Fulfillment Data

• Physical Delivery Address: We collect the precise "Shipping Address" (which may differ from the residence address mentioned in the contract) including the postal code and special delivery instructions. • Authorized Receiver Data: Name and phone number of the person authorized to receive (if not the husband/wife), and the Proof of Delivery provided by the logistics service provider (such as DHL/FedEx) as final evidence that you received the original contract, which releases us from responsibility for lost documents later.

25. Referral and Attribution Data

• Applicant Source: We collect data on how you reached the platform (referral link from a partner lawyer, specific advertisement, or discount code). This helps us track the "Chain of Trust" and know who vouched for you or referred you to us, which is a preventive measure in "Know Your Customer" (KYC) protocols.

26. Severability Clause

In the event that any competent court or legislative authority rules that any clause of this policy is invalid or illegal in the future, such invalidity shall be limited to that clause only, and the remaining clauses and terms shall remain in full force and effect and productive of all their legal effects, and shall be interpreted to achieve the original purpose of protecting the platform.

27. Governing Language

This policy may be translated into multiple languages to serve our customers around the world. However, in the event of any conflict or difference in interpretation between the texts, the Arabic text is the reference and the sole legally relied upon text before courts and arbitration bodies.

28. Contact, Updates, and Governing Law

A. Data Protection Officer (DPO) We take your privacy seriously. If you have any inquiries about this policy, or wish to exercise your legal rights regarding your data, please contact the Legal Affairs and Data Protection Office at TCMG Group directly via: Official Email: legal@tcmg.love B. Changes to the Privacy Policy Due to continuous changes in international laws and documentation technologies, we reserve the full right to amend or update this policy at any time without prior notice. Any amendments will be posted on this page with the "Effective Date" updated at the top. It is your responsibility to review this policy periodically, and your continued use of the platform after the posting of amendments constitutes your final and binding acceptance of the amended terms. C. Jurisdiction and Dispute Resolution This policy is governed by and interpreted in accordance with the laws of the Arab Republic of Egypt. In the event of any dispute regarding privacy or data, jurisdiction shall be vested exclusively in the Courts of Greater Cairo, as stipulated in the Terms of Service, excluding any conflict of laws rules.

By clicking the Agree button, you declare that you have read and understood the terms of this Privacy and Data Processing Policy, and you agree voluntarily and without coercion to the collection and processing of your personal, sovereign, biometric, and financial data for the purposes outlined above, including its cross-border transfer and retention for the specified periods.