Privacy Policy

Concierge Nation is operated by [TO CONFIRM: registered legal name and Lebanese company form (for example SAL or SARL) of the operating company], a company registered in Lebanon under commercial registration number [TO CONFIRM: commercial registration number], with its registered office at Majzoub, Metn District, Municipality Avenue, Antoine Mezher Building, Ground Floor, Lebanon [TO CONFIRM: registered office, if different from this office address]. In this policy, "Concierge Nation", "we" and "us" mean that company.

We decide why and how the personal data described here is used, so we are responsible for it as its controller. For anything in this policy, email privacy@concierge-nation.com or call +961 78 842 242 (see Contact us).

This policy covers our members, anyone who visits this website or uses the account area, anyone who calls us or messages our WhatsApp number, and the other people described in What we collect.

We collect only what we need to run your membership and to help you when you call.

• Your details — first, middle and last name, date of birth, the district you live in, and your email address if you choose to give it.
• Your phone numbers — your primary mobile number, which is also how you log in (we confirm it with a one-time code sent on WhatsApp), and any additional numbers you add so that someone else who drives the car, such as a family member, can call us about it. We confirm each additional number with a code sent to it on WhatsApp.
• Identity documents — photos or scans of your national ID card or passport, your driving licence, and the car licence of each car you register. You can add them when you sign up or later from your account (see Identity documents and accident photos).
• Your cars — plate number, vehicle type, model and model year.
• Membership and payments — the plan and price for each car, the currency, when you paid, when your cover starts and ends, the reference and status of each payment and refund, and the number of the Whish account that paid when Whish reports it to us. You pay on Whish's own page: we never see your Whish login or PIN, and we do not collect card details.
• Incident records — when you call after an accident, our agent records the type of incident, its location (an address and a map pin), its priority, notes from our agents and responders, the responders assigned and their estimated arrival time, and each change of status. The case also keeps a fixed copy of your name, email address, contact number, car and cover as they were when it was opened, so it can always show that you were covered.
• Accident photos — photos taken at the scene by our responder and added to your case by our staff: the vehicles, the damage, number plates and where the cars came to rest.
• Calls — calls to our number are handled on our phone system (3CX), which keeps a record of each call: the calling number, the time and the duration. [TO CONFIRM: whether calls are recorded and, if so, why and for how long]
• WhatsApp — a record of each message we send you: which message, to which number, when, and whether it went out (see WhatsApp for messages you send us).
• Your enquiries — if you email us, or call with a question, complaint or request (including a request about your data), we keep your contact details, what you asked and our reply, so that we can deal with it and show how it was handled.
• Your choices — when you sign up we record that you accepted our Terms of Service and this Privacy Policy (which version, and when), and whether you agreed to receive news and offers on WhatsApp, together with the IP address and browser the choice was made from. If you change your mind, we record that too, and we record any change to your renewal-reminder setting (when, and whether you or one of our agents made it).
• Technical data — when you use our website or account area, our servers and hosting provider log your IP address, your browser and device type (as your browser reports them), the page requested and the time, to keep the service secure and to fix faults. We do not track what you do across other websites (see Cookies).

We also hold some data about people who are not our members: the other drivers and vehicles involved in an accident (in scene photos and our staff's notes: name, licence, plate and insurer), and the people whose numbers members add to their accounts. If you add someone's number, please tell them.

These are the most sensitive data we hold, so we handle them with extra care.

• Why — your identity documents let the responder confirm at the roadside that the person and the car in front of them match the membership. This protects you and stops anyone else using your membership. Accident photos give you a reliable record of the scene, for example for your insurer.
• Who can see them — a responder assigned to one of your incidents, who can open your ID or passport and driving licence, the car licence of the car involved and that incident's photos, and keeps that access after the incident is closed; our agents, to handle your call or a request from you; and our administrators. [TO CONFIRM: whether a responder's access should end when the incident is closed] You can see the documents you uploaded in your account, and you can ask us for copies of your incident photos.
• Every view is recorded — each time a member of our staff opens a document or photo, we log who opened it and when.
• Storage — they are kept in private storage (see Where your data is stored), never on a public link, and are delivered only through our own logged-in systems.
• Retention — identity document images are kept for a shorter time than the rest of your record (see How long we keep data).
• Other people — scene photos may show other people, their vehicles and their plates. We use them only for the incident record.

• To create your account, confirm your phone numbers and let you log in with a one-time code.
• To show you your own account: your cars, cover dates, documents and payments. We do not otherwise personalise the website for you.
• To take payment, start your cover after the activation period, and show you your cover dates.
• When you call: to identify you and your car, check that the car is covered, open a case and send a responder.
• To give the responder what they need to reach and identify you, and to tell you who is coming and when.
• To send you service messages on WhatsApp: verification codes, confirmation of your sign-up and payment, when your cover starts or ends, reminders before a membership ends, and updates while an incident is open. You can turn the renewal reminders off (see the WhatsApp section below).
• To send you occasional news and offers from Concierge Nation, only if you have agreed to it. You can withdraw that agreement at any time (see WhatsApp).
• To plan where responders are needed and improve the service, using overall figures such as the number of members in each district.
• To reply to your questions, complaints and service requests, including requests about your data.
• To keep the service secure, prevent fraud and misuse (for example registering a car only after an accident), keep our accounts and meet our legal obligations.

We do not sell your personal data and do not use it for advertising. We do not make decisions about you by automated means alone. The only automatic check is whether a car's cover is active at the moment you call, and our agent tells you the result and what you can do next.

We process personal data in accordance with Lebanese Law No. 81 of 10 October 2018 on Electronic Transactions and Personal Data. We rely on:

• our contract with you — to provide the membership you signed up for, including its service messages and renewal reminders;
• your consent — for news and offers on WhatsApp and wherever the law requires consent. You can withdraw consent at any time, and doing so does not affect your membership;
• our legal obligations — for example keeping accounting records, or answering a lawful request from the authorities;
• protecting you or others — for example giving the incident location to the responder, or to the emergency services if someone is hurt.

[TO CONFIRM: counsel to confirm these grounds and the applicable articles of Law 81/2018]

[TO CONFIRM: declaration of our processing of personal data to the Ministry of Economy and Trade under Law 81/2018 — to be filed (date and reference number), and whether identity documents, or accident photos that may show injuries, require a licence rather than a declaration]

We message members through the WhatsApp Business Platform, which Meta operates. Messages pass through Meta's systems and are also handled under WhatsApp's own privacy policy.

• What we send — verification codes, confirmation of your sign-up and payment, notices when your cover starts or ends, reminders about 30, 15 and 3 days before a membership ends, and updates about an open incident (for example the name, phone number and estimated arrival time of the responder on the way). These are part of the service. [TO CONFIRM: incident updates reach members who phoned us only once approved WhatsApp templates are in place] Renewal reminders are on by default, and you can turn them off, or back on, at any time. Occasional news and offers need your agreement under WhatsApp's rules: they stay off unless you say yes, and we record your choice, and the number it applies to, when you sign up and each time you change it. Your choices belong to your account, so they stay as they are when you replace your primary number. You can change either one at any time in your account, or by calling us on +961 78 842 242: our agent changes it for you, and we record which agent did. [TO CONFIRM: whether replying STOP to our WhatsApp number should also turn renewal reminders or news and offers off — today it does not, and gets only the automatic reply asking you to call]
• What we receive — if you send a message to our number, Meta passes us your number and the message, and our system replies with an automatic message asking you to call (at most once a day). WhatsApp messages do not open a case or reach a responder, so please call us instead. We do not save the content of your message in your account or in any case record, and we do not use your WhatsApp profile name. It may remain in our technical systems (message queue and server logs) for [TO CONFIRM: period — no deletion limit is set yet]. [TO CONFIRM: whether messages to our number are also delivered to our contact-centre inbox (3CX), where agents could read them, and if so how long 3CX keeps them]
• Changing your mind — you have the right to withdraw your agreement to news and offers, or turn renewal reminders off, at any time: in your account or on a call, as described above, or by writing to us (see Contact us). You can also block our number in WhatsApp, but you will then miss service messages such as verification codes and incident updates.

• Our responders — the responders assigned to your incident receive your name, phone number, car, the incident location and the identity documents on file, so they can reach you and confirm who you are. [TO CONFIRM: whether responders are employees of Concierge Nation or contractors]
• E-broker partners — if you joined through one (see If you joined through a partner).
• Service providers acting on our instructions — hosting and storage (Railway, Cloudflare), WhatsApp messaging (Meta), payments (Whish), our phone system (3CX) and maps (OpenStreetMap, Google Maps). They may use your data only to provide their service to us (see Where your data is stored).
• Your insurer and the authorities — we share incident details and photos with your insurer, the police or a court when you ask us to, and we disclose data when the law requires it, for example under a court order.
• To protect safety and rights — where it is needed to protect someone's life or safety (for example giving the incident location to the emergency services if someone is hurt), or to establish, exercise or defend our legal rights.

We do not sell, rent or trade your personal data.

Some members join through an e-broker or insurance broker that offers Concierge Nation at its own checkout.

• What the partner sends us — your name, date of birth, mobile number, email address if you gave one, your car’s details and plate, and the price agreed with you.
• What we send the partner — whether your enrolment was accepted, the status and dates of your cover, and the name and car on the enrolment, so the partner can reconcile what it sold. We never share your identity documents, incident records or accident photos with partners.
• The partner is responsible for its own use of your data, under its own privacy policy.
• Your number counts as confirmed only once you log in with the one-time code we send you on WhatsApp.

We use cloud providers, so your data is stored and processed outside Lebanon:

• Application servers and database — Railway, a US cloud platform, in its EU West region (Amsterdam, the Netherlands). [TO CONFIRM: production region verified in the Railway dashboard]
• Identity documents and photos — Cloudflare R2 private storage (Cloudflare, Inc., USA). [TO CONFIRM: storage location or jurisdiction of the production bucket; it is not currently pinned to a region]
• WhatsApp messages — Meta, which processes messages on its own infrastructure, including in the United States.
• Payments — Whish, in Lebanon. Whish receives the amount, a payment reference and a short description (the plan and your car's plate). [TO CONFIRM: Whish's legal entity name]
• Phone calls — 3CX. [TO CONFIRM: where our 3CX system is hosted]
• Maps — when our staff pin the incident location, the address they search for and the pinned position are sent to OpenStreetMap's services, and map images are loaded from them. Responders open the pin in Google Maps for directions.

Data is encrypted whenever it travels between you, us and these providers (HTTPS/TLS), and each provider receives only what it needs. [TO CONFIRM: counsel to confirm whether Law 81/2018 or our declaration requires any further step for transfers outside Lebanon]

We keep data only as long as we need it, then delete it or make it permanently anonymous.

• Identity document images — while your cover is active, because the responder needs them at the scene; deleted [TO CONFIRM: 90 days] after the last cover on your account ends. When you upload a newer document, the old one is deleted within [TO CONFIRM: 30 days].
• Account, phone numbers and cars — while you are a member and for [TO CONFIRM: 24 months] after your last cover ends, so you can come back easily; then deleted or anonymised.
• Accounts that never paid — kept so you can complete payment from your account, and deleted after [TO CONFIRM: 12 months] without a successful payment.
• Incident records and accident photos — [TO CONFIRM: 24 months] after the incident is closed, or longer while a claim or dispute about it is open.
• Payment records — as long as Lebanese accounting and tax law requires. [TO CONFIRM: period]
• Records of messages we sent, and of staff access to documents — [TO CONFIRM: 24 months].
• Your enquiries and requests — until they are resolved and for [TO CONFIRM: period] afterwards; a request about your data is kept as long as we need to show how we handled it.
• Your consent choices — while your account exists and for [TO CONFIRM: period] afterwards, so we can show what you agreed to.
• Verification codes — stored only in scrambled (hashed) form; each expires after 5 minutes. The record that a code was sent to a number, and when, is kept for [TO CONFIRM: period — no deletion limit is set yet].
• Technical logs — [TO CONFIRM: our hosting provider's log retention period].

[TO CONFIRM: these periods are not yet applied automatically; the retention job and the manual deletion procedure must be in place before this policy is final]

You can ask us to delete your personal data at any time:

• email privacy@concierge-nation.com with the subject "Data deletion" [TO CONFIRM: mailbox live and monitored]; or
• call us on +961 78 842 242.

Please do not send deletion requests as WhatsApp messages: messages to our number get an automatic reply and are not handled as requests.

Tell us your full name and the mobile number on your account. Before acting, we check that the request comes from you, usually by sending a one-time code to that number on WhatsApp. [TO CONFIRM: identity check for deletion requests]

Within [TO CONFIRM: 30 days] of confirming the request, we delete your account, phone numbers, cars, identity documents, accident photos, incident records and message history, or make them permanently anonymous, and we tell you when it is done. We keep only the records the law requires us to keep, such as payment and accounting records, for as long as it requires them, and we use them for nothing else.

Deleting your data ends any active membership, because we cannot identify you or send help without it. [TO CONFIRM: whether any refund applies — see Cancellation and refunds in our Terms] If you joined through a partner, the partner keeps its own copy of the details it sent us, so please ask the partner too.

You can: be told how your data is used (this policy); get a copy of the data we hold about you, including your incident photos; have it corrected or completed (you can update your name, email, district, phone numbers and documents, and add cars, yourself in your account); have it deleted (see Deleting your data); object to our use of it on legitimate grounds; ask us to restrict (pause) our use of it, for example while we check a correction you asked for or an objection you made; and withdraw your agreement to news and offers, or turn renewal reminders off, at any time (you can also do that yourself in your account, see WhatsApp). Contact us (see Contact us) and we will reply within [TO CONFIRM: 30 days].

[TO CONFIRM: counsel to confirm the rights under Law 81/2018 and which authority members can complain to]

• All connections to our website, account area and systems are encrypted (HTTPS/TLS).
• Members log in with a one-time code sent on WhatsApp to their primary number; we do not use member passwords. Codes are stored hashed, expire after 5 minutes and stop working after 5 wrong attempts.
• Staff use individual accounts limited to what their role needs. Staff passwords are stored hashed, and two-factor authentication is available for staff accounts.
• Identity documents and photos are held in private storage, delivered only through our logged-in systems, and every staff view is logged.

No online service is completely secure. Keep your phone and WhatsApp account secure, and tell us straight away if you lose your phone or think someone else has used your membership.

We do not use analytics, advertising or tracking cookies, so we do not show a cookie banner. We store only what the site needs to work:

• a login cookie, set when you log in and renewed while you use your account. It keeps you logged in until you log out or leave the account unused for 7 days, and can be read only by our servers;
• a temporary value in your browser’s session storage while you move from confirming your phone number to signing up, removed as soon as it is used;
• on our staff consoles only, the light or dark display choice, saved in the browser’s local storage.

When you pay, you leave our site for Whish's page, where Whish's own cookie and privacy rules apply.

You can see, block or delete cookies, and clear your browser's storage, in your browser settings. If you block our login cookie, you may not be able to stay logged in to your account; the public pages of the website work without it.

[TO CONFIRM: whether our network provider sets its own security cookie (for example Cloudflare's __cf_bm); if so, list it here as strictly necessary] If we ever add analytics, we will update this policy and ask for your consent first where required.

[TO CONFIRM: whether this policy also covers our separate marketing website at concierge-nation.com, which has its own privacy policy and says it uses cookies to analyse traffic; if it does, list those cookies and the analytics provider here]

Our website and messages link to websites and services run by others — for example WhatsApp, and Whish's payment page when you pay. When you follow such a link, that site's own privacy policy applies, and we are not responsible for its privacy practices.

Membership is for adults aged 18 or over. We do not knowingly collect data from anyone under 18. If you believe a child has given us personal data, contact us and we will delete it. [TO CONFIRM: minimum age for memberships bought through a partner — our own sign-up checks 18 and over, but partner enrollments are not age-checked yet]

For any question about this policy, or to use any of the rights above:

See also our Terms of Service.

When we change this policy, we update the date at the top of this page. If a change materially affects how we use your data, we tell members before it takes effect (for example on WhatsApp or when you next log in), and we ask for fresh consent where the law requires it.