Effective Date: May 3, 2026

1. Introduction

Welcome to Castly (Castly Portal LLC). We are committed to protecting your personal information and your right to privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile application.

Castly operates in accordance with the UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (PDPL) and other applicable UAE regulations.

Please read this policy carefully. If you disagree with its terms, please discontinue use of the app.

2. Information We Collect

We collect the following categories of personal information:

Identity & Contact Information

• Full name

• Email address

Financial Information

• IBAN, collected solely for the purpose of initiating payment processing. We do not store your IBAN within the app or on our servers. All financial data is handled exclusively by our licensed payment processor, Mamopay, a regulated financial institution. Please refer to Mamopay's privacy policy for details on how they handle your financial information.

User-Submitted Content

• Profile photos and other images you upload

• Physical details such as height and weight

• Any other information you choose to provide within the app

Usage Data

• How you interact with the app (features used, time spent, actions taken)

• Device information (device type, operating system version)

• App performance and diagnostic data

3. How We Use Your Information

We use the information we collect to:

• Create and manage your account

• Provide and improve the core features of Castly

• Facilitate payment processing through Mamopay

• Personalise your experience within the app

• Respond to your support requests and communications

• Monitor and analyse usage trends to improve performance

• Ensure the security and integrity of our platform

• Comply with applicable UAE laws and regulatory obligations

4. How We Store and Protect Your Information

We implement appropriate technical and organisational security measures to protect your personal information against unauthorised access, alteration, disclosure, or destruction.

Your data is stored and processed within secure infrastructure. We do not store financial data such as your IBAN — this is managed entirely by Mamopay, a licensed financial institution operating under UAE Central Bank regulations.

No method of electronic storage is 100% secure, and while we take all reasonable precautions, we cannot guarantee absolute security.

5. Sharing Your Information

We do not sell your personal information. We may share your information only in the following circumstances:

• Payment Processing: Your IBAN is passed directly to Mamopay, our licensed payment processor, for the sole purpose of completing transactions. Mamopay is regulated under the UAE Central Bank and is bound by applicable financial data protection obligations.

• Service Providers: Trusted third-party vendors who assist in operating our app (e.g., cloud hosting), bound by confidentiality obligations.

• Legal Requirements: If required by UAE law or in response to valid requests by UAE public authorities or regulatory bodies.

• Business Transfers: In connection with a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction.

6. Payment Processing

All payment-related data is handled by Mamopay, a licensed financial institution regulated by the UAE Central Bank. By providing your payment information within the app, you agree to be bound by Mamopay's terms and privacy policy in addition to this policy.

7. User-Generated Content

Photos, physical measurements, and other personal details you submit are used solely to provide you with Castly's core functionality. You may update or delete this information at any time through your account settings.

8. Data Retention

We retain your personal information for as long as your account is active or as needed to provide our services. If you delete your account, we will delete or anonymise your data within a reasonable timeframe, unless we are required to retain it under UAE law or for regulatory compliance purposes.

9. Your Rights Under UAE Law

Under the UAE Personal Data Protection Law (PDPL), you have the following rights regarding your personal data:

• Access: Request a copy of the personal data we hold about you.

• Correction: Request that we correct inaccurate or incomplete information.

• Deletion: Request that we erase your personal data where it is no longer necessary.

• Portability: Request a copy of your data in a structured, commonly used format.

• Objection: Object to the processing of your personal data in certain circumstances.

• Withdrawal of Consent: Where processing is based on your consent, you may withdraw it at any time without affecting the lawfulness of prior processing.

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

10. Age Restriction

Castly is strictly for users aged 18 and above. By registering and using the app, you confirm that you are at least 18 years of age. We do not knowingly collect personal information from individuals under 18. If we become aware that a user is under 18, we will immediately suspend their account and delete their data.

11. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable UAE regulations. We will notify you of any significant changes by updating the effective date at the top of this policy and, where appropriate, notifying you within the app. Your continued use of Castly after changes are posted constitutes your acceptance of the revised policy.

12. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or your personal data, please contact us at:

Castly Email: hi@castly.co Address: Office GAL Business Center, Galadari Building, Dubai Production City, Dubai.

This privacy policy was last updated on May 3, 2026.