Privacy Policy

1General Provisions

This Privacy Policy describes how personal data of users of the Partnears digital platform (the “Platform”) is collected, used, stored, transferred, deleted and protected.

Controller: SOLUS CITY PORTAL CO. L.L.C, Dubai, United Arab Emirates. Trade name: SOLUS CITY PORTAL L.L.C. Commercial registration: 2422986. Trade licence: 1420253. Address: Office No. 6, Building B-3, Al Muteena, Deira, Dubai, United Arab Emirates. P.O. Box: 118660. Privacy contact: legal@partnears.com.

This Policy covers the mobile application, website and available features, including professional profiles, AI Search, AI Projects, Smart Circles, messaging, contacts, events, digital business cards, Caller ID and AI Professional Insights. Features not yet launched will be addressed before any additional data processing begins.

Processing is subject to applicable UAE law, including Federal Decree-Law No. 45 of 2021, and mandatory laws of other applicable jurisdictions, including the EU, UK, Russia and United States.

2User Categories

Free users are registered users who have not completed identity verification. They may make up to three basic AI searches per day, initiate up to two new conversations per day, continue existing conversations, view available profiles and events, aggregate attendee counts and visible Response Time metrics. Free users do not have discoverable professional profiles, do not appear in professional search or Smart Circles, cannot see identifiable event attendee lists and cannot mark “Planning to attend.” Message recipients may see minimal account information and the unverified status.

Verified users have completed identity verification. They may create a professional profile, appear in internal AI Search and recommendations, use one Smart Circle, see permitted attendee lists, indicate intended attendance, and use QR codes and digital business cards, including Apple Wallet.

Pro users are verified subscribers. Subject to feature availability, they may use multiple Smart Circles, advanced AI Search, AI Projects, AI Professional Insights, event-management tools and Caller ID. A subscription does not grant access to other users’ private messages.

3Categories of Personal Data

Registration data: name or display identifier, email address, phone number if provided, account ID, verification status, login and registration information.

Professional profile: name, photo, title, company, profession, skills, experience, industry, interests, description, city, country, portfolio and social links, projects and achievements.

Sumsub verification: depending on the procedure, name, date of birth, nationality, identity-document information and images, facial image, liveness-check information, verification results and identifiers. Some data is processed directly by Sumsub; Partnears’ access depends on the integration and contracts. Verified status confirms identity checks, not professional qualifications or trustworthiness.

Location: with the user's permission, approximate location, country, city, region and selected Circle geography. Precise coordinates are not used for professional matching or shown to other users. More precise location data, if received, is reduced to the necessary level of precision. Device permission can be withdrawn in device settings.

Contacts: saved professional contacts, dates added, reciprocal connections, mutual contacts and communication preferences. Saving a contact within Partnears does not grant access to the device address book. Any future address-book import will require an appropriate notice and permissions.

Messages: message text, photos, documents, attachments and metadata such as sender and recipient identifiers, conversation ID, send and delivery times, read status if available, number of conversations, reply intervals, interaction frequency, blocks and technical events. Content is processed to deliver and display conversations, but not for AI analytics, recommendations, matching or model training.

AI requests and projects: query text, professional tasks, criteria, history, results, interactions with search results, AI Projects, roadmaps and professional shortlists. Users should not submit passwords, payment details or third parties' confidential information without a lawful basis.

Events: event and organizer information, intended attendance, invitations, registrations and visibility preferences. Free users see only permitted aggregate information.

Business cards: QR codes, profile links, Apple Wallet passes and selected profile details. Non-public data is not disclosed through them.

Caller ID: verified phone number, display name, consent status, user ID, preferences and technical information. Number verification is available to Verified and Pro users; caller identification is available to Pro on supported devices. Caller ID does not guarantee a caller's authenticity.

Technical and payment data: IP address, device, operating system, app version, sessions, diagnostics, security logs; subscription type, purchase status, transaction ID, payment and cancellation dates. Payment credentials may be processed directly by the App Store or a payment provider.

4Purposes of Processing

Data is processed for account registration and authentication, account administration, identity verification, professional profiles, AI Search and matching, Smart Circles, message delivery, contacts, interaction statistics and Response Time, events, digital business cards, Caller ID, AI Professional Insights, subscriptions, support, fraud prevention, anti-spam, security, legal compliance and service reliability. Only permitted metadata, not message content, is used for AI analysis of communications.

5Legal Bases

Depending on the applicable law, processing may be based on performance of a contract; consent (for example, location, Caller ID and marketing); legitimate interests where permitted (including security and abuse prevention); and legal obligations. Sensitive categories and biometric data are processed only with an appropriate legal basis and safeguards.

6Availability of Professional Profiles

Verified and Pro profiles are available only to authenticated users within Partnears, subject to access controls. The Platform does not publish profiles on the open web or make their contents available for search-engine indexing.

Depending on settings, users may see a name, photo, headline, experience, skills, company, specialization, city, portfolio, social links, verification status and aggregate Response Time. Verified and Pro profiles may appear in internal AI Search.

QR codes and digital business cards direct people to profiles inside Partnears; unauthenticated visitors may be asked to sign in or register. Non-public information is not disclosed.

Response Time is displayed by default, but profile owners may hide it in privacy settings. Hiding the metric does not automatically delete metadata required for lawful service or security purposes.

7Personalized Professional Matching

“Circles → People” automatically recommends professionally relevant users without requiring a text search. Signals may include profession, skills, experience, industry, interests, profile information, selected geography, professional connections, preferences and permitted interaction metadata. Private-message content, topics, meaning and sentiment are not analyzed. Recommendations do not guarantee successful cooperation, qualifications or reliability.

8Artificial Intelligence and Analytics

AI supports professional search, matching, AI Projects, professional-profile analysis and AI Professional Insights. For communications analytics, Partnears follows a Metadata-Only AI Analysis principle: message text and attachments are not analyzed by AI.

Third-party AI providers may receive data necessary to perform specific features, subject to applicable legal bases and contractual safeguards.

The Company prohibits third-party AI model training or fine-tuning using Partnears user data, professional profiles, search queries, AI Projects, messages, attachments or communication metadata, and implements contractual and technical restrictions. Processing required to fulfill a specific user request may take place under agreed terms.

Where automated decisions have legal or similarly significant effects, applicable rights and safeguards are provided. AI outputs may be inaccurate and do not replace independent verification of professionals.

9Response Time

Response Time is an aggregate estimate of how quickly a professional replies to a first incoming message. It is calculated solely from metadata over a rolling period of up to 180 calendar days; a median may be used to reduce outliers. Message content is not analyzed.

The metric is visible by default to authenticated users where sufficient data exists, but the profile owner may hide it. It does not reveal individual message timestamps, conversation participants or message contents, does not guarantee a reply within a given period and is not a qualification rating.

10AI Professional Insights

AI Professional Insights is an analytics feature offered under eligible paid plans. It may report profile views, appearances in AI Search, incoming inquiries, conversion, number of contacts, interaction trends and first-response times, and suggest improvements to profiles and Smart Circles.

Sources include professional-profile data, profile-view and search statistics, interaction events, permitted messaging metadata and Circle settings. Private-message content and attachments are not used. Extended individual analytics are intended for the account owner. The Company does not guarantee commercial outcomes.

11Events and Attendee Protection

Partnears provides tools to discover events and interact with attendees. Free users can view available event information and aggregate attendee counts but not identifiable attendee lists, and cannot mark “Planning to attend.” Verified and Pro users may see permitted attendee information and indicate intended attendance. Visibility depends on privacy and safety settings. An intention to attend does not establish actual physical presence; the Platform applies safeguards against tracking and harassment.

12Women Circle

Women Circle is a feature under development. Before its official launch, the Company does not specifically collect or process data to determine eligibility for this feature. Before deployment, the Company will define the relevant data categories, eligibility criteria, legal bases, verification methods, privacy settings and retention periods. Additional safeguards will apply where special-category data is processed.

13Disclosure to Third Parties

The Company may engage Sumsub for identity checks, cloud providers, AI vendors, analytics, notification, payment and information-security services. Only data needed for the relevant function is shared, subject to appropriate legal bases and safeguards. Information may be disclosed to competent authorities in response to lawful requests. Private-message content is not provided to AI vendors for professional analytics, matching or recommendations.

14International Data Transfers

Partnears serves users in multiple countries. Personal data may be transferred to and processed outside a user's country of residence. The Company applies legally required international-transfer safeguards, including appropriate contractual protections where applicable.

15Data Retention

Data is retained for as long as needed for the relevant purposes, contractual obligations, security and legal requirements. For operational data without a specific mandatory period, the maximum retention period is up to 180 calendar days after the relevant processing purpose ends, provided a lawful basis exists. Active-account data may be retained longer while necessary to provide the service.

Registration and profile data: while the account is active; following deletion, up to 180 days where legally justified. Messages and attachments: while needed by conversation participants; following the end of that purpose, up to 180 days where legally justified. Messaging metadata, AI query history, event data and ordinary security logs: up to 180 days. Response Time: a rolling calculation window of up to 180 days. AI Projects: while the project exists, then up to 180 days where justified. Geographic settings: while the account is active, then up to 180 days where justified. A persistent history of precise coordinates for matching is not kept. Caller ID: while enabled, then up to 180 days where justified. Complaints and moderation cases: up to 180 days after closure unless a justified exception applies. KYC, payment and accounting records: as required by actual processing arrangements and applicable mandatory retention rules. Backups: a deletion rotation of up to 180 days, subject to legal requirements.

Account deletion removes the user's professional profile and presence in search. Messages previously sent to other users may remain in recipients' histories where a lawful basis exists; both parties' rights are considered. Deletion requests are fulfilled without undue delay and within mandatory legal deadlines; the six-month period is not itself a legal basis to retain data.

Longer retention may be required for tax, accounting, KYC and other legal obligations, disputes, investigations and legal claims. Access is limited to the relevant purpose. At expiry, data is deleted or irreversibly anonymized. Backups are protected, and previously completed deletions are reapplied after restoration. Stricter applicable legal requirements take precedence.

16Information Security

The Company uses organizational and technical safeguards, which may include secure connections, access controls, encryption in transit, server protection, security logs, suspicious-activity monitoring, backups, employee access management and incident response. AI systems are excluded from access to private-message content for analytics, matching and recommendations. Absolute security cannot be guaranteed.

17Abuse Prevention

Partnears seeks to prevent spam, fraud, impersonation, harassment, stalking, bulk harvesting of personal data, circumvention of blocks and unauthorized access. Permitted metadata, complaints, blocking records and technical events may be used for security. Authorized personnel may review relevant message content when handling complaints, security threats or lawful requests. This does not permit using messages for AI Professional Insights or professional matching.

18User Rights

Depending on applicable law, users may request information, access, correction, deletion, restriction or portability; object to certain processing; withdraw consent; exercise rights regarding automated decisions; and lodge complaints with supervisory authorities. Requests may be sent to legal@partnears.com. Identity verification may be required to protect personal data. Requests are handled within applicable legal deadlines. Withdrawal of consent does not affect prior lawful processing.

19Privacy Settings

Users may manage available settings for in-app profile visibility, location permissions, Smart Circles, event participation, incoming-message restrictions, blocking, Caller ID, public Response Time and notifications. Specific controls depend on the Platform version.

20Account Deletion

Users may request account deletion in the application or by contacting legal@partnears.com. Data is deleted or anonymized within applicable deadlines, subject to lawful exceptions for legal duties, security, disputes and claims. Previously sent messages may remain in recipients' conversation histories as described in Section 15.3. The Company cannot guarantee deletion of copies independently saved by third parties outside Partnears.

21Age Restrictions

Partnears is intended exclusively for users aged 18 or older. Registration and use by anyone under 18 are prohibited. By registering, users confirm they are at least 18. If an underage account is discovered, the Company restricts access and takes steps to cease processing and delete data in accordance with applicable law. The Platform is not directed at children and does not knowingly solicit their personal data.

22Cookies and SDKs

The website and related services may use cookies, SDKs and similar technologies for authentication, preferences, security, diagnostics, service analytics and user-experience improvements. Non-essential analytics and advertising technologies are subject to applicable notice and consent requirements. A separate Cookie Policy may be published where needed.

23Policy Updates

The Company may update this Policy following changes to features, infrastructure, law or processing practices. The current version is published at partnears.com. Users are notified of material changes where required by law, and fresh consent is obtained before processing where legally necessary.

24Contact Information

SOLUS CITY PORTAL CO. L.L.C. Trade licence: 1420253. Commercial registration: 2422986. Address: Office No. 6, Building B-3, Al Muteena, Deira, Dubai, United Arab Emirates. P.O. Box: 118660. Telephone: +971 52 870 8860. Privacy email: legal@partnears.com. Website: partnears.com.