Latest update: 26/04/2022
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Owner and Data Controller
The Platform is owned and operated by Payables Technology Ltd, a private company under the Companies Law, DIFC Law No. 5 of 2018 with registered number 5546(referred to as “we”, “our”, “us” and “Payables Technology”)
We are committed to protecting your personal information and other data provided to us via the Platform.
Because of the financial nature of our business, our products and services are not designed to appeal to or to be sold to persons under the age of 18. Therefore, we do not knowingly attempt to solicit or receive any information from persons under the age of 18.
We have appointed a Data Protection Officer in our business who can deal with any data protection related matters. You can contact our Data Protection Officer by email at firstname.lastname@example.org
Types of Data collected
Personal Data is any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
Among the types of Personal Data that this Platform collects, by itself or through third parties, there are:
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose.
We do not usually collect any special categories of Personal Data about you, but you may choose to disclose this data to us. Special categories of Personal Data include details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data. Unless we are required to do so to comply with a legal obligation, or as an integral part of providing the Service to you, we do not usually collect any Personal Data about you relating to criminal convictions or offences.
We may use the Data we collect to personalise your experience of the Service, to help you to maintain a logged-in session, and to help us select services or materials for inclusion in the Service which may be of interest to you. We may, from time to time, use your Personal Data to send you important notifications, updates and information regarding the Service. If you do not want to receive communications regarding the Service, you must cease to use the Service and ask us to delete your account. You can request this by contacting us by email at email@example.com.
Where you provide Personal Data to us, you represent and warrant to us that (i) the relevant individual has been notified of the purposes for which the data will be collected, processed, used and disclosed; and (ii) you have obtained the relevant individual's consent for the collection, processing, use and disclosure of such Personal Data by Payables Technology, and have been duly authorized by the relevant individual to provide the Personal Data to us. You must promptly inform us upon you becoming aware of the withdrawal by the relevant individual of his/her consent to the collection, processing, use and/or disclosure by us of the Personal Data provided to us. The withdrawal of such consent may affect the Service which we are able to provide to you.
How we collect the Data
We collect information through one or more of the following ways:
Methods of processing
We take appropriate security measures to prevent unauthorized access, disclosure, copying, modification, or unauthorized destruction of the Data.
We implement and maintain appropriate technical, security and organisational measures in relation to the processing of your Personal Data so that the processing will meet the requirements of applicable data protection laws and ensure the protection of your rights.
If you provide us with your credit card information, the information is encrypted. Although no method of transmission over the Internet or electronic storage is 100% secure, we follow all PCI-DSS requirements and implement additional generally accepted industry standards.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated below.
In some cases, the Data may also be made accessible by us to certain types of persons in charge, involved with the operation of this Platform (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed by us, if necessary, as data processors . The updated list of these parties may be requested at any time.
Legal basis of processing
We may process your Personal Data if one of the following applies:
We may also use Personal Data as we believe to be necessary or appropriate: (a) to comply with applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including those outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations; (f) to protect our rights, privacy, safety or property, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
In any case, we will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
To ensure you are kept up to date with our products, we use Personal Data for marketing purposes, and may send you emails to update you on the latest offers and events. We may also show you online media communications through external social media platforms and external digital advertisers.
You have the right to opt out of receiving promotional emails at any time.
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
We may be allowed to retain Personal Data for a longer period whenever you have given consent to such processing, as long as such consent is not withdrawn. Furthermore, we may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
The purposes of processing
We may use your Personal Data for our business purposes, such as:
a) to develop, improve and provide payment facilities, products or services (whether made available by us or through us), including but not limited to:
i. executing payments, commercial or other transactions and requests, including processing, settlement, clearing or reporting on these transactions;
ii. carrying out research, planning and statistical analysis; and
iii. analytics for the purposes of developing or improving our products, services, security, service quality, advertising or customisation strategies;
b) assessing and processing Platforms, instructions or requests from you;
c) communicating with you, including providing you with updates on changes to products, services and payment facilities (whether made available by us or through us) including any additions, expansions, suspensions and replacements of or to such products, services and payments facilities and their terms and conditions;
d) managing our infrastructure, business operations and complying with internal policies and procedures;
e) responding to queries, complaints or feedback;
f) addressing or investigating any complaints, claims or disputes;
g) verifying your identity for the purposes of providing payments facilities, products or services;
h) conducting credit checks, screenings or due diligence checks as may be required under applicable law, regulation or directive;
i) complying with all applicable laws, regulations, rules, directives, orders, instructions, guidance and requests from any local or foreign authorities, including regulatory, governmental, tax and law enforcement authorities or other authorities;
j) monitoring products and services provided by or made available through us;
k) complying with obligations and requirements imposed by us from time to time by any credit bureau or credit information sharing services of which we are a member or subscriber;
l) creating and maintaining credit and risk related models;
m) financial reporting, regulatory reporting, management reporting, risk management (including monitoring credit exposures), audit and record keeping purposes;
n) enabling any actual or proposed assignee or transferee, participant or sub-participant of our rights or obligations to evaluate any proposed transaction;
o) in connection with any sale, acquisition, merger or restructuring of our business;
p) for the marketing of products and services ancillary or related to the use of the Platform;
q) to detect, prevent and investigate fraud;
r) enforcing obligations owed to us;
s) in connection with performance of our duties and obligations when seeking consultancy or professional advice, including legal advice; and/or
t) administering benefits or entitlements in connection with our relationship with you or arising from your participation in events, campaigns, or marketing promotions by us or in conjunction with our partners. This will include the administration of loyalty, rewards programmes, lucky draws, and/or sending gifts and awards.
Where necessary to fulfil our obligations in the course of or in connection with our provision of the goods and services requested by you, or to fulfil our business purposes stated above, we may from time to time disclose Personal Data to third parties such as the following whether inside or outside of DIFC:
a) regulatory authorities, courts, dispute resolution tribunals, and governmental agencies;
b) any agent, affiliate, business partner, supplier, vendor and sub-contractor which provides products and services to us in connection with the Platform and Services (for example, vendors who we engage to perform fraud detection and monitoring, payment intermediaries who we work with to provide payments services, and card issuers who we work with to offer you debit cards);
c) any actual or proposed assignee of us or transferee of our rights in respect of all or any part of our assets, properties or business;
d) any credit bureau as well as the members of such credit bureau (for example, banks, financial intermediaries, payment intermediaries, card network members and insurers);
e) financial institutions and other business partners with whom we jointly offers or develops the Service (but they may not use your Personal Data to independently market their own products or services to you unless you consent that they can do so); and
f) analytics and search engine providers that assist us in the improvement and optimisation of the Platform; and
g) anyone we consider necessary in order to provide our Service.
SOME PARTIES THAT PROCESS OR STORE PERSONAL DATA IN ACCORDANCE WITH THIS PRIVACY STATEMENT MAY BE LOCATED IN JURISDICTIONS OUTSIDE YOUR COUNTRY OF RESIDENCE OR OUR COUNTRY OF INCORPORATION. THEREFORE, BY GIVING YOUR CONSENT, YOU UNDERSTAND AND UNAMBIGUOUSLY AGREE THAT YOUR INFORMATION MAY BE PROCESSED AND STORED IN THESE JURISDICTIONS AND THAT DIFFERENT PRIVACY LAWS MAY APPLY IN THESE COUNTRIES WHICH MAY NOT ENSURE THE SAME LEVEL OF DATA PROTECTION AS GRANTED IN YOUR COUNTRY OF RESIDENCE.
You may exercise certain rights regarding your Data.
In particular, you have the right to do the following:
Details about the right to object to processing
Where Personal Data is processed for the purposes of the legitimate interests pursued by us, you may object to such processing by providing a ground related to their particular situation to justify the objection.
You must know that, however, should your Personal Data be processed for direct marketing purposes, youcan object to that processing at any time without providing any justification. To learn, whether weare processing Personal Data for direct marketing purposes, please see the relevant sections of this document.
How to exercise these rights
Any requests to exercise yourrights can be directed to us through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by us as early as possible and always within one month.
Additional information about Data collection and processing
With your consent, we will keep your name, address and contact details (including telephone numbers and email addresses) in our databases and may from time to time use that information to make you aware of our related products and services as well as updates on developments in our industry sector generally which may be of interest to you. We may contact you in writing, by telephone or email for this. If permitted by applicable law, we may share such information with our event sponsors and/or partners for their own commercial purposes without your consent. If at any time you decide that you do not want your contact details used or shared for these purposes, where applicable, you may object or revoke your consent for receiving marketing communications by following the instructions in the relevant marketing communication (e.g., clicking on the “Unsubscribe” button), by contacting us.
Your Personal Data may be used for legal purposes by us in Court or in the stages leading to possible legal action arising from improper use of this Platform or the related Services.
You declare to be aware that we may be required to reveal Personal Data upon request of public authorities.
Additional information about your Personal Data
System logs and maintenance
For operation and maintenance purposes, this Platform and any third-party services may collect files that record interaction with this Platform (System logs) use other Personal Data (such as the IP Address) for this purpose.
Information not contained in this policy
More details concerning the collection or processing of Personal Data may be requested from us at any time. Please see the contact information at the beginning of this document.
How “Do Not Track” requests are handled
This Platform does not support “Do Not Track” requests.
To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.
Should the changes affect processing activities performed on the basis of your consent, we shall collect new consent from you, where required.
If you experience any technical problems during your interaction with the Platform, please contact us here: firstname.lastname@example.org
What are Cookies?
A cookie is a small text file placed on your computer or mobile device when you visit a website or use a mobile application. Cookies collect information about users and their visit to the website or mobile application, such as their Internet protocol (IP) address, how they arrived at the website (for example, through a search engine or a link from another website) and how they navigate within the website or mobile application.
Storage and Types of Cookies
Cookies can be stored on your device anywhere from a few minutes through to [two years].
We use a few different types of cookies:
Session & Persistent Cookies
Session and persistent cookies track what you're doing during a specific visit. We use session cookies to improve our Platform, to give you a better experience. Session cookies let us see where you spend your tim and work out which areas are most effective. We use persistent cookies to recognise you when you come back. When we spot that it's you, we're able to show you the things that we think you may like.
We also use third party cookies to find out if the ads we run encourage more people to visit our Platform. Third-party cookies work by sharing your browser identification with a third party, so they can show you ads on their sites and apps. These cookies can be session specific or persistent.
Turning off Cookies
If you wish to deny the use and saving of cookies from the Platform on to your computers and/or other electronic devices, you should take the necessary steps within your internet browsers’ security settings to block all cookies from the Platform.
You can choose to delete the cookies at any time. However, do note that when you enable blocking of cookies, certain features and functions may be limited in your use of our Platform.