Privacy Policy

Introduction

The Information We Process

The type of personal information we collect:

Personal data is, in simple terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

We collect and process various categories of personal and confidential information at the start of, and for the duration of, your relationship with us and beyond (subject to appropriate retention periods). We use different methods to collect data from and about you such as:

• Personal information such as your name, postal address, email address and phone numbers
• Financial information, including account information and transactional information and history
• Know Your Customer (KYC) records such as passport, proof of address, drivers licence social security/tax number, date and place of birth, utility bills and disclosures
• Education and Employment information, such as your professional background, employer and role
• Products and services provided by CASHCOM PAYMENT SERVICES PROVIDER L.L.C, and online and social media information and activity, based on your interaction with us on our websites, applications and social media profiles, including for example, your Internet Protocol (IP) address, device information, location coordinates, your communications with us and any information or content you've visited or downloaded

This may include information relating to:

• Information revealing racial or ethnic origin
• Political opinions
• Religious or philosophical beliefs
• Biometric data used for fraud prevention and identification purposes including physical, physiological and behavioural identification
• Information concerning health
• Data concerning a person's sexual orientation and personal life

How We Obtain Information

Your information is made up of all the financial and personal information we collect and hold about you/your business and the proprietors, officers and beneficial owners of that business and your transactions.

Data can be collected by us in the following ways:

• Information you give us while using our website – When you register with our website, participate in surveys or complete forms
• Information you give us – When you communicate with us by phone, email, post, in person or otherwise
• Information provided by our clients and partners
• Information from credit reference, fraud prevention, law enforcement or government agencies
• Information from industry and trade bodies
• Information from other banks (where permitted by law)
• Information from publicly available sources including social media
• Technical information including IP addresses, browser information, and website usage data
• API & Developer centre usage data
• Cookies and similar tracking technologies

What Do We Do With the Information We Collect?

We will process your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you
• Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests
• Where you have granted consent to such processing
• Where we need to comply with legal or regulatory obligations
• Where we need to improve and analyse our products, website, systems and tools

Examples of how we may process your personal data include:

• To manage risk and protect against fraud, abuse and other illegitimate activities
• To comply with our legal obligations and enforce our terms
• To administer your account and communicate with you
• To verify your identity and prevent fraud
• To provide you with information about our products and services
• To improve our services and website functionality
• For training, quality, and security purposes
• To investigate complaints and resolve disputes

Do We Share Your Data?

CASHCOM PAYMENT SERVICES PROVIDER L.L.C may share your personal data with selected third-party providers performing services on behalf of CASHCOM PAYMENT SERVICES PROVIDER L.L.C who will only use the information to provide a service that we have requested.

We may share data in the following circumstances:

• With service providers for delivering cards, completing identification checks, and providing technical assistance
• With fraud prevention agencies to prevent fraud and money-laundering
• When legally required due to legal proceedings, court orders, or government authority instructions
• In the event of business sale, transfer, or merger (subject to appropriate safeguards)

Storage and International Transfers

We may store or transfer some or all of your personal data in countries outside the United Arab Emirates. We can only do this if:

• We have entered into appropriate contracts to ensure your information is protected
• The transfer is to countries with adequate data protection levels as deemed by applicable UAE data protection regulations

Retention of Your Data

CASHCOM PAYMENT SERVICES PROVIDER L.L.C will retain personal data only for as long as necessary to achieve the purpose for which such data was collected, subject to legal or regulatory obligations and business purposes.

In some instances, we may store and process personal data for longer periods when there is a specific legal requirement to do so, such as in the event of a complaint or to establish, exercise or defend legal rights.

Security

CASHCOM PAYMENT SERVICES PROVIDER L.L.C is committed to ensuring your personal data is secure. We have implemented suitable physical, technical and organizational policies to safeguard and secure the information we collect, process and store.

We limit access to your personal information to employees and third parties on a "need-to-know" basis. They are subject to contractual obligations of confidentiality and will only process your personal information on our instructions.

Your Data Protection Rights

Under the Data Protection Legislation, you have the following rights:

• The right to access – Receive a copy of the personal data we hold about you
• The right to rectification – Request correction of inaccurate or incomplete personal data
• The right to be forgotten – Ask us to delete your personal data in certain circumstances
• The right to restrict – Ask us to restrict processing of your personal information
• The right to object – Object to the processing of your personal information
• The right to data portability – Receive your personal data in a portable format
• The right to withdraw consent – Withdraw your consent where we rely on it for processing
• Rights relating to automated decision-making and profiling (note: we do not currently use your personal data in this way)