NEOPAY respects your privacy and is committed to protecting it. We provide this Privacy Notice to inform you of our privacy procedures and practices, including what personal information we collect about you, how we obtain your personal information and how we use your personal information. “Personal information” means information that is about you or from which we can identify you. NEOPAY shall protect the personal information that you provide in compliance with our Data Privacy Policies which are in line with the applicable Data Privacy Laws (“Laws”) and it’s implementing rules and regulations. We are the data controller of this information under the Laws and other relevant data protection regulations because in the context of our business relationship with you we decide how and why your personal information is processed in the ways explained in this Privacy Notice. When we use terms such as “we”, “us” and “our” in this Privacy Notice, we mean NEOPAY. We may be required to update or change the Privacy Notice from time to time. We will upload an updated Privacy Notice on www.neopay.ae and / or other NEOPAY websites. If there are any significant changes to the Privacy Notice (e.g. if we decide to use your personal information in a manner different from that stated at the time it was collected), we will notify you by way of an email.
Our products and services are available through our own branches and on our own website as well as through professional and financial advisors and anyone else who acts as a person sitting in between you and us in relation to what we do for you. In this Privacy Notice we will call these persons “brokers and other intermediaries”. When a broker or other intermediary processes your personal information on our behalf, this Privacy Notice will apply and you should contact us to exercise your rights under the Laws. When a broker or other intermediary processes your personal information as a data controller (i.e. they decide how and why your personal information is processed), their own privacy notice will apply and you should ask them for a copy if you do not have one by the time you are introduced to us.
This will depend on the products or services you apply for and (if your application is successful) obtain from us. We set out below the personal information that we generally process in connection with all our products and services, followed by the personal information that we generally process in connection with specific products and services.
This includes:
To comply with our legal obligations, we may be required to share your personal information with regulatory bodies governing the jurisdiction, such as the UAE Central Bank.
We will generally collect your personal information from you directly. If you are introduced to us by an approved intermediary, we will obtain some personal information about you indirectly from them when they introduce you to us. In addition, we obtain your personal information from other sources such as fraud prevention agencies, credit reference agencies, your employer, landlord, other lenders, publicly available directories and information (e.g. telephone directory, social media, internet, news articles), debt recovery and/or tracing agents, other organisations to assist in prevention and detection of crime, police and law enforcement agencies. In addition, some of your personal information may come from other members of our Group if you already have a product with them. Some of the personal information obtained from Credit Reference Agencies will have originated from publicly accessible sources. In particular, credit reference agencies draw on court decisions, bankruptcy registers and the electoral register (also known as the electoral roll). We explain more about Credit Reference Agencies below. We have also mentioned above in the lists of personal information that we process some of the Credit Reference Agencies’ other sources of information (which are our own source of information too).
Certain Laws require us to explain what legal grounds justify our processing of your personal information (including when we share it with other organisations). For some processing more than one legal ground may be relevant (except where we rely on a consent). Here are the legal grounds that are relevant to us in accordance with applicable Laws:
When we share your personal information with these other people or organisations (under our legitimate interests):
When we share your personal information with these other people or organisations (to comply with our legal obligations):
For processing that is based on your consent, you have the right to take back that consent for future processing at any time (unless the personal data is required for our business operations related to the provisions of products and services to you). You can do this by contacting us using the details provided in below. We will tell the broker or other intermediary who introduced you to us that you have withdrawn your consent if it is our data processor (this means an organisation who is processing personal information on our behalf) or if we are required to do when you exercise certain rights under the Laws. You should make sure to contact them directly to withdraw your consent for what they do with your personal information as a data controller in their own right. To comply with payment services regulations, we have to share some of your personal information with other payment service providers in some circumstances such as when you ask us to share information about your account with them. Whilst those payment services regulations require your ‘consent’ for such disclosure, ‘consent’ in under such regulations does not have the same meaning as ‘consent’ under the Laws. The legal grounds which may be relevant to for our disclosure of your personal information with other payment service providers is compliance with our legal obligations, performance of our contract with you, our legitimate interests, or a combination of these. Therefore, if you ask to withdraw consent from what we do with your personal information where we need to share it with payment services providers, we may still have to hold and use your personal information in order to be able to provide our services to you and to comply with our legal obligations.
Sometimes, where we are able to do so in accordance with applicable Laws, your personal information may be transferred outside the Dubai International Financial Centre or the country from which you may be accessing our services. Some territories outside your country may not have adequate protection for personal information under the laws that apply to us. We will make sure that suitable safeguards are in place before we transfer your personal information to territories outside your country which do not have adequate protection under laws that apply to us; for example, by implementing specific contractual clauses with entities to whom we share your personal information. For more information about suitable safeguards and (as relevant) how to obtain a copy of them or to find out where they have been made available you can contact us using the details provided in below.
You should tell us without delay so that we can update our records. If you were introduced to us by a broker or other intermediary who is data controller in its own right, you should contact them separately. In some cases where you exercise rights against us under the Laws (see below), under certain circumstances, we may need to inform the broker or other intermediary.
We are unable to provide you with products and services or to process your application without having personal information about you. Your personal information is required before you can enter into the relevant contract with us, or it is required during the life of that contract, or it is required by laws that apply to us. If we already hold some of the personal information that we need – for instance if you are already a customer – we may not need to collect it again when you make your application.
In this section monitoring means any listening to, recording of, viewing of, intercepting of, or taking and keeping records (as the case may be) of calls, email, text messages, social media messages, in person face to face meetings and other communications. We may monitor where permitted by law and we will do this where the law requires it. Some of our monitoring may be to comply with regulatory rules, self-regulatory practices or procedures relevant to our business, to prevent or detect crime, in the interests of protecting the security of our communications systems and procedures, to have a record of what we have discussed with you and actions agreed with you, to protect you and to provide security for you (such as in relation to fraud risks on your account) and for quality control and staff training purposes. Some of our monitoring may check for obscene or profane content in communications. We may conduct short term carefully controlled monitoring of your activities on your account(s) where this is necessary for our legitimate interests or to comply with our legal obligations. For instance, where we suspect fraud, money laundering or other crimes. Telephone calls and/or in person meetings between us and you in connection with your application and/or your account(s) may be recorded to make sure that we have a record of what has been discussed and what your instructions are. We may also record these types of calls for the quality control and staff training purposes.
Unless we explain otherwise to you, we will hold your personal information as long as is necessary to respond to any queries from you, to improve our services, to respond to any legal claims by you, or to comply with any legal and/or regulatory requirements to which we are subject. To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve such purposes through other means, and the applicable requirements.
Under certain Laws, you may have the following rights:
For any of the above, you may raise a request using the link provided on this page. You can also email us at dpo@neopay.global or send postal mail to the following address: NEOPAY, Attn: Customer Care Center, P.O. Box 1250, Dubai, UAE. We may require further information from you in order to carry out any of the above requests. We may ask you to provide proof of your identity. If you wish to exercise any of these rights against the credit reference agencies, the fraud prevention agencies, or a broker or other intermediary who is data controller in its own right, you should contact them separately.
Your personal information may be converted into statistical or aggregated data which cannot be used to re-identify you. It may then be used to produce statistical research and reports. This aggregated data may be shared and used in all the ways described in this Privacy Notice.
We have mentioned that we share your personal information with fraud prevention agencies and credit reference agencies. They require us to pass on to you information about how they will use your personal information to perform their services or functions as data controllers. These notices are separate to our own. All banking transactions requested by NEOPAY customers are governed by our Terms and Conditions. If you have any questions about our privacy practices write to us at dpo@neopay.global or NEOPAY, Attn: Customer Care Center, P.O. Box 1250, Dubai, UAE.
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