Privacy notice

A. Who runs the desk

The data controller is Saqalan Expeditions L.L.C., registered at 34 Al-Mina Street, Quseir 84711, Red Sea Governorate, Egypt, under Tax ID (ETA) 819-426-705. The standing day-to-day controller is Mahmoud El-Naggar, who runs the office. Address any data-protection enquiry to [email protected] with the subject line "Data protection". We acknowledge receipt within five working days.

B. Which legal frameworks apply

The desk operates primarily under Egyptian Data Protection Law no. 151 of 2020 and its implementing regulations. Where a subscriber or correspondent is established in the European Union or the European Economic Area, the European General Data Protection Regulation (EU) 2016/679 applies in parallel. UK-resident subscribers benefit from the UK GDPR. If the two regimes diverge, we apply whichever offers the data subject the higher protection.

C. The three categories of data we collect

We collect correspondence data (the name, email address and message body of anyone who writes to the desk through the contact form, by email, by the route-planner form, or by post); subscription data (in addition to the correspondence data: the billing address, chosen tier, currency of payment, and most recent successful payment reference); and access logs (the IP address, requested page, response code and timestamp of every request to the public site, retained briefly for security). We do not run advertising cookies, behavioural cookies, or analytics cookies of any kind.

D. Why each category is collected

Correspondence data is collected to reply to your enquiry; that is the only purpose. Subscription data is collected to issue the invoice, process the payment, mail the printed Field Notebook where the tier requires it, and provide subscriber access to the resources. Access logs are kept solely to detect and respond to attempts to disrupt the site. None of the data is used for marketing without your explicit opt-in, and the desk has not run a marketing campaign of any kind since the company was founded in 2014.

E. The legal bases for processing

Correspondence is processed on the basis of your consent, given when you tick the consent box on the contact form or when you choose to write to the desk by email. Subscription data is processed on the basis of the contract between you and Saqalan Expeditions L.L.C., specifically the subscription agreement on the pricing page. Access logs are processed on the basis of our legitimate interest in maintaining the integrity of the website, balanced against the very limited and short-lived retention of the log content.

F. How long each category is kept

Correspondence is kept for an active period of eighteen months from the date of the last exchange, after which it is moved to a sealed archive for a further six months and is then deleted. A short message thread that resolves a one-off enquiry can be deleted earlier on written request. Subscription data is kept for the duration of the subscription plus the seven-year retention period required by Egyptian tax law; after that the records are purged. Access logs are kept for ten days from the date of the log entry and are then overwritten.

G. Who can read your data

Inside the desk, the four resident editors (Yusuf Abou Khairy, Mounir El-Sharif, Hala Abdelghaffar and Mahmoud El-Naggar) have access to the correspondence and subscription mailboxes. The two contributors on the bench do not. Our accountant in Hurghada, Mr. Hatem Mansour, has access to subscription invoicing data only, under the standing confidentiality clause in his engagement letter. The hosting provider in Frankfurt, Germany has technical access to the access logs under a written processor agreement. No other party has any access.

H. Disclosure to public authorities

We disclose personal data to a public authority only on a written request that meets the requirements of Egyptian Data Protection Law 151/2020 and the standard of necessity and proportionality set out in that law. Where the request concerns a non-Egyptian data subject, we additionally check that the request would be admissible under their home regime. We have not received such a request since the desk opened. If we do, the request and our response will be logged in an annual transparency entry visible on this page.

I. International transfers

The hosting infrastructure is located in Frankfurt, Germany. Personal data of subscribers outside the European Economic Area is therefore transferred into the EEA for technical processing. For correspondents and subscribers inside the EEA the data does not leave the EEA. We have not authorised any onward transfer to a third country outside the EEA or Egypt, and the hosting agreement explicitly forbids the provider from doing so on its own initiative.

J. Cookies and tracking

The site does not set advertising cookies, behavioural-tracking cookies, third-party analytics cookies, or social-media embed cookies. The only cookie the site may set is a strictly-necessary session cookie used to remember whether you have closed the mobile menu on a small screen; it carries no identifying value and is deleted when you close the browser. We do not embed Google Analytics, the Facebook Pixel, Google Tag Manager, Hotjar, or any equivalent. There is no cookie banner on the site because there are no cookies that require consent under Egyptian or EU law.

K. The rights you hold

You have the right to ask what personal data we hold about you, to receive a copy in a readable format, to ask for it to be corrected if it is wrong, to ask for it to be deleted where there is no longer a lawful basis to hold it, to ask for processing to be restricted while a dispute is resolved, and to object to processing carried out on the basis of legitimate interest. Where you are an EEA or UK resident you additionally have the right to data portability. We respond to a rights request within one calendar month from receipt — shorter than the maximum permitted by Egyptian law 151/2020 and matching the GDPR standard. There is no charge for a rights request.

L. How to exercise a right

Write to [email protected] with the subject line "Rights request" and the specific right you wish to exercise. We reply within two working days asking for a piece of identifying information sufficient to confirm you are the data subject — usually the email address you used previously. Where the request comes by post we reply by post to the address on the letter. We do not require notarised identity documents for routine requests; that would be disproportionate to the modest data we hold.

M. Complaints

If you believe we have not handled your personal data correctly, the first step is to write to the desk so that we can address the matter directly. If we cannot resolve it to your satisfaction, you may lodge a complaint with the Egyptian Personal Data Protection Centre (the regulator established under Law 151/2020), or, if you are an EEA resident, with the supervisory authority of your home member state. UK residents may complain to the Information Commissioner's Office. The supervisory authority for the hosting infrastructure is the German Federal Commissioner for Data Protection and Freedom of Information (BfDI).

N. Notes specifically for subscribers

If you cancel your subscription, your correspondence record is moved out of the active mailbox at the end of the paid period, but the billing invoices are retained under section F above for the duration of the tax retention window. If you wish to be removed from the acknowledgements list in the next Annual Digest (Field tier), tell the desk in writing at least one calendar month before the digest goes to press. If you have an unfulfilled service order at the time you request deletion, we will complete the order before erasing the related data; alternatively you can terminate the order and we erase immediately, in which case the engagement is treated as cancelled under the standard terms.

O. Changes to this notice

The date at the head of this page is the date of the last review. Substantive changes are notified to active subscribers by email at least thirty days before they take effect; informational corrections (typographical fixes, link updates, clarifications that do not change the substance) are made without notice. A change log is maintained internally and can be supplied on written request.