Privacy Policy

Amanda is committed to protecting your privacy and handling your personal data with the utmost discretion and care. This policy explains what data we collect, why we collect it, how we use it, and what rights you have in relation to it. Please read it carefully.

1. Who We Are

Amanda (“we”, “us”, “our”) is a private, curated quality-of-life membership club operating through the platform at amanda-club.com. We connect accomplished women with carefully selected male companions (Misters) for social, cultural and professional occasions. Contact: concierge@amanda-club.com For the purposes of the UAE Federal Decree-Law No. 45 of 2021 on Personal Data Protection (PDPL) and, where applicable, the European General Data Protection Regulation (GDPR), Amanda is the data controller responsible for your personal data.

2. Data We Collect

2.1 Mister Applicants and Registered Misters When you apply to join Amanda as a Mister, we collect the following categories of personal data: Mandatory (collected at Stage 2 of the registration form) • Identity: first name, last name, date of birth, nationality • Location: country of residence, city or cities of primary presence • Contact: email address • Referral source: the QR code or link through which you accessed the form Optional (collected at Stage 3 of the registration form, if provided) • Professional background: current occupation, level of education • Languages spoken and fluency levels • Cities available for engagements, availability windows • Interests and areas of expertise • Personal statement • Photograph • Phone number • Referral or invitation code Generated during the application and vetting process • Application status and history (pending, under review, approved, rejected) • Internal notes added by the concierge team • Background verification results (see Section 5) • Interview records and outcome

2.2 Members (Amandas) When you register and use the Amanda platform as a member, we collect data necessary to create your account, process your membership and facilitate bookings. The specific fields collected during member registration will be confirmed and published in an updated version of this policy prior to member onboarding launch. In all cases, member data is treated with the highest standards of discretion. Member identity is not disclosed to Misters without explicit consent and specific booking context.

2.3 All Users — Platform and Technical Data When you access our platform or website, we may automatically collect the following: • Device and browser information • IP address and approximate location • Pages visited, time spent, and navigation patterns • Referral source (including QR code slug where applicable) • Cookies and similar tracking technologies (see Section 11)

3. How We Use Your Data

3.1 Mister Applicants and Registered Misters We use your personal data for the following purposes, each with its corresponding legal basis: • To process your application and assess your suitability as a Mister — Legal basis: Performance of a pre-contractual arrangement • To conduct background verification and identity checks — Legal basis: Consent (explicitly provided at Stage 4 of the registration form) and, where applicable, legal obligation • To manage your profile on the platform, including displaying it to members — Legal basis: Performance of contract • To communicate with you regarding your application, status updates and bookings — Legal basis: Performance of contract and legitimate interests • To track the referral source of your application for platform analytics — Legal basis: Legitimate interests • To maintain the safety, quality and integrity of the platform — Legal basis: Legitimate interests • To send you platform updates, policy changes and service communications — Legal basis: Legitimate interests • To send you marketing communications (only if you have opted in) — Legal basis: Consent

3.2 Members We use member personal data to provide platform access, facilitate bookings, process payments and maintain account security. Full details will be published prior to member onboarding.

4. Data We Do Not Collect or Use

Amanda does not collect or process any personal data for purposes unrelated to the operation of the platform. We do not: • Sell your personal data to any third party, under any circumstances • Use your data for advertising targeting on external platforms • Profile you using automated decision-making in ways that produce legal or similarly significant effects, without human review • Collect data beyond what is necessary for the stated purposes (data minimisation principle)

5. Background Verification and Special Category Data

As part of the Mister vetting process, Amanda conducts or commissions background verification checks. This may involve the processing of data relating to criminal convictions and offences, which is considered sensitive personal data under applicable law. Such processing is conducted exclusively on the basis of your explicit consent, provided at Stage 4 of the registration form, and solely for the purpose of assessing your suitability to engage with Amanda members. Background verification is carried out by Amanda or a vetted third-party KYC and verification provider. Results are accessible only to authorised members of the concierge and management team and are not shared with members or other Misters.

6. Sharing Your Data

We do not share your personal data with third parties except in the following circumstances: • Service providers: trusted third-party providers who process data on our behalf, including KYC and background verification providers, cloud hosting and infrastructure providers, and payment processing providers. These providers are contractually bound to process data only on our instructions and in accordance with applicable law. • Regulatory and legal authorities: where we are required to disclose data by applicable law, court order or regulatory requirement. • Business transfers: in the event of a merger, acquisition or sale of all or part of Amanda’s business, your data may be transferred as part of that transaction, subject to equivalent privacy protections. • With your consent: in any other case, only with your explicit prior consent. We do not share Mister profile data with members beyond what is displayed within the platform (profile photo, name, biography, cities, interests). We do not share member identity with Misters except as specifically required for a confirmed booking and only to the extent necessary.

7. International Data Transfers

Amanda is headquartered in the United Arab Emirates. Your personal data may be processed and stored on servers located within or outside the UAE. Where data is transferred internationally, we apply appropriate safeguards in accordance with UAE PDPL requirements and, for EU/EEA residents, GDPR requirements. Transfers to countries not recognised as providing an adequate level of data protection will be made only on the basis of appropriate safeguards, such as standard contractual clauses or equivalent mechanisms.

8. Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, subject to legal and regulatory requirements. • Rejected applications: personal data submitted during the registration process will be retained for [X months — TBD] following rejection, after which it will be securely deleted, unless retention is required for legal purposes. • Active Mister profiles: data is retained for the duration of your active status on the platform. • Deactivated or suspended profiles: data will be retained for 2 years following deactivation, to comply with legal obligations and legitimate business interests. • Booking records: retained for 3 years for legal and dispute resolution purposes. • Background verification records: retained in accordance with applicable legal requirements and the policies of the verification provider.

9. Data Security

Amanda applies appropriate technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration or destruction. These measures include: • Encryption of data in transit and at rest • Access controls limiting data access to authorised personnel only • Regular security assessments and reviews • Secure cloud infrastructure with EU-compatible data residency options While we take every reasonable precaution, no system is entirely immune to risk. In the event of a data breach that is likely to result in a risk to your rights and freedoms, we will notify you and, where required, the relevant supervisory authority, in accordance with applicable law.

10. Your Rights

10.1 Rights Under UAE Law (PDPL) If you are subject to UAE data protection law, you have the following rights in relation to your personal data: • Right of access — to request a copy of the personal data we hold about you • Right to rectification — to request correction of inaccurate or incomplete data • Right to erasure — to request deletion of your data, subject to legal limitations • Right to restriction — to request that we limit the processing of your data in certain circumstances • Right to data portability — to receive your data in a structured, commonly used format • Right to object — to object to processing based on legitimate interests • Right to withdraw consent — where processing is based on consent, to withdraw it at any time without affecting the lawfulness of prior processing

10.2 Rights Under EU/EEA Law (GDPR) If you are resident in the European Union or European Economic Area, you have all the rights listed in Section 10.1 above, as well as the following additional rights under GDPR: • Right not to be subject to automated decision-making — including profiling, where this produces legal or similarly significant effects • Right to lodge a complaint — with the supervisory authority in your country of residence or establishment Your EU/EEA data rights are fully preserved regardless of the fact that these Terms are governed by UAE law, as stated in our Terms and Conditions.

10.3 How to Exercise Your Rights To exercise any of the above rights, please contact us at: concierge@amanda-club.com We will respond to your request within 30 days. We may request proof of identity before processing your request. We will not charge a fee for reasonable requests. Where requests are manifestly unfounded or excessive, we reserve the right to charge a reasonable fee or decline to act.

11. Cookies and Tracking Technologies

Our platform and website use cookies and similar technologies to provide functionality, improve user experience and analyse usage patterns. • Essential cookies: required for the platform to function. Cannot be disabled. • Analytics cookies: used to understand how users interact with the platform. Can be disabled. • Referral tracking: we use unique QR code slugs to track the source of Mister applications. This data is used solely for internal analytics and quality management. You may manage your cookie preferences through your browser settings or through the cookie preference centre on the platform. Disabling non-essential cookies will not affect your ability to use the core features of the platform.

12. Minors

The Amanda platform is strictly for adults. Misters must be 25 years of age or older to register. Members must be adults in accordance with the law of their country of residence. We do not knowingly collect personal data from individuals below the applicable minimum age. If we become aware that data has been submitted by an individual below the minimum age, we will delete it promptly.

13. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology or applicable law. When we make material changes, we will notify registered users via the email address on file and update the effective date at the top of this document. Your continued use of the platform following notification constitutes acceptance of the updated policy.

14. Contact

If you have any questions, concerns or complaints regarding this Privacy Policy or the way we handle your personal data, please contact us: • Email: concierge@amanda-club.com • Website: amanda-club.com