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WIREPAYOUTS PRIVACY POLICY

Last Updated: May 4, 2025

1. INTRODUCTION

WIREPAYOUTS (“ICE-PAY,” “we,” “our,” or “us”) is committed to protecting your privacy and personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you engage with our fintech consulting services, use our website, or interact with us in any other way.

This Privacy Policy has been developed in accordance with Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (PDPL), Dubai International Financial Centre (DIFC) Data Protection Law No. 5 of 2020, and other applicable data protection laws in the United Arab Emirates.

2. INFORMATION WE COLLECT

2.1 Personal Data

We may collect the following categories of personal data:

  • Identity Information: Full name, date of birth, nationality, Emirates ID number, passport details, photographs, and signatures.
  • Contact Information: Email address, telephone number, physical address, and other communication details.
  • Professional Information: Job title, employer information, professional qualifications, and work history.
  • Financial Information: Bank account details, payment card information, transaction history, and financial statements (for client companies).
  • Technical Information: IP address, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, and other technology identification on the devices you use to access our services.
  • Usage Information: Information about how you use our website, products, and services.
  • Marketing and Communications Information: Your preferences in receiving marketing from us and our third parties and your communication preferences.

2.2 Special Categories of Personal Data

In accordance with UAE law, we may collect special categories of personal data including:

  • Health information (only when necessary for specific financial advisory services)
  • Biometric data for identity verification purposes
  • Criminal background information (where permitted by law and when necessary for regulatory compliance)

Collection of special category data will only occur with your explicit consent or when legally required for compliance with financial regulations.

3. HOW WE COLLECT YOUR INFORMATION

We collect information through:

  • Direct interactions when you provide information by filling in forms, by email, telephone, or otherwise
  • Automated technologies or interactions when you use our website
  • Third parties or publicly available sources (e.g., regulatory bodies, credit reference agencies, anti-money laundering databases)
  • Client onboarding processes and Know Your Customer (KYC) procedures
  • Business relationships and service agreements

4. LEGAL BASIS FOR PROCESSING

Under Dubai and UAE law, we process your personal data based on:

  • Contractual Necessity: Processing necessary for the performance of our contract with you
  • Legal Obligation: Processing necessary for compliance with legal obligations, particularly those under UAE financial regulations, Central Bank requirements, and anti-money laundering laws
  • Legitimate Interests: Processing necessary for our legitimate interests or those of a third party
  • Consent: Where you have given consent for specific processing activities
  • Vital Interests: In rare circumstances, we may process data to protect someone’s life
  • Public Interest: When processing is necessary for the performance of a task carried out in the public interest

5. HOW WE USE YOUR INFORMATION

We use your personal data for the following purposes:

5.1 Service Provision

  • To provide fintech consulting services and fulfill our contractual obligations
  • To process and manage payments, fees, and charges
  • To collect and recover money owed to us

5.2 Regulatory Compliance

  • To conduct Know Your Customer (KYC) and Anti-Money Laundering (AML) checks
  • To comply with Central Bank of UAE regulations and Financial Services Regulatory Authority requirements
  • To fulfill reporting obligations to governmental authorities

5.3 Business Operations

  • To manage our relationship with you
  • To administer and protect our business and website
  • To use data analytics to improve our website, services, marketing, customer relationships, and experiences

5.4 Marketing and Communications

  • To send you updates, newsletters, and marketing communications (subject to your marketing preferences)
  • To invite you to events or webinars related to fintech developments

6. DISCLOSURE OF YOUR INFORMATION

We may share your personal data with:

6.1 Internal Parties

  • Employees, contractors, and affiliated entities who need access to provide our services

6.2 External Third Parties

  • Service providers acting as processors based in the UAE and other countries who provide IT, system administration, and other services
  • Professional advisers including lawyers, bankers, auditors, and insurers
  • Regulatory bodies, government agencies, law enforcement agencies, courts, and tribunals, including:
    • Central Bank of UAE
    • Securities and Commodities Authority (SCA)
    • Dubai Financial Services Authority (DFSA)
    • Financial Services Regulatory Authority (FSRA)
    • UAE Federal Tax Authority

6.3 Third Party Vendors

We may use third-party vendors to assist us in providing our services. These vendors may be located within or outside the UAE. When we engage third-party vendors, we ensure they provide adequate levels of protection for your personal data through appropriate contractual arrangements and security measures.

7. INTERNATIONAL TRANSFERS

ICE-PAY may transfer your personal data to countries outside the UAE. When doing so, we ensure a similar degree of protection by implementing appropriate safeguards, including:

  • Transferring to countries deemed to provide an adequate level of protection by UAE authorities
  • Using specific contracts approved by UAE authorities that give personal data similar protection to what it has in the UAE
  • For transfers to the United States, ensuring the recipient is certified under applicable privacy framework recognized by the UAE

You may contact us for further information on the specific mechanism used by us when transferring your personal data outside the UAE.

8. DATA SECURITY

We have implemented appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. We limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know.

We have procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

9. DATA RETENTION

We will retain your personal data only for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider:

  • The amount, nature, and sensitivity of the personal data
  • The potential risk of harm from unauthorized use or disclosure
  • The purposes for which we process the data
  • Whether we can achieve those purposes through other means
  • The applicable legal, regulatory, tax, accounting, or other requirements

In accordance with UAE law, certain records must be kept for specific periods:

  • Financial records: Minimum 5 years (as per UAE Commercial Companies Law)
  • AML documentation: Minimum 5 years (as per AML laws)
  • Tax-related information: Minimum 5 years (as per UAE Tax Procedures Law)

10. YOUR LEGAL RIGHTS

Under Dubai and UAE data protection laws, you have rights in relation to your personal data that include:

  • Right to Access: The right to request copies of your personal data.
  • Right to Rectification: The right to request that we correct incomplete or inaccurate data.
  • Right to Erasure: The right to request that we delete your personal data (subject to legal requirements).
  • Right to Restrict Processing: The right to request that we restrict the processing of your personal data.
  • Right to Data Portability: The right to request the transfer of your personal data to you or a third party.
  • Right to Object: The right to object to our processing of your personal data.
  • Right to Withdraw Consent: The right to withdraw consent at any time where we rely on consent to process your personal data.

If you wish to exercise any of these rights, please contact our Data Protection Officer using the contact details provided below.

11. CHILDREN’S PRIVACY

Our services are not intended for children under 18 years of age. We do not knowingly collect personal data from children. If we become aware that we have collected personal data from a child without verification of parental consent, we will take steps to remove that information from our servers.

12. COOKIES AND TRACKING TECHNOLOGIES

Our website uses cookies and similar tracking technologies to distinguish you from other users. This helps us provide you with a good experience when browsing and allows us to improve our site.

The types of cookies we use include:

  • Strictly necessary cookies
  • Analytical/performance cookies
  • Functionality cookies
  • Targeting cookies

You can set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

13. CHANGES TO THIS PRIVACY POLICY

We reserve the right to update this Privacy Policy at any time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the “Last Updated” date at the top.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

14. CONTACT INFORMATION

If you have any questions about this Privacy Policy or our data practices, please contact us at:

ICE-PAY FZ-LLC
Dubai International Financial Centre
Gate District, Building 5
Level 3, Office 307
P.O. Box 123456
Dubai, United Arab Emirates

Email: [email protected]
Phone: +971 4 XXX XXXX
Attention: Data Protection Officer

15. COMPLAINT PROCEDURES

If you have a complaint regarding our processing of your personal data, you have the right to lodge a complaint with the relevant supervisory authority:

For DIFC-based operations:
Commissioner of Data Protection
Dubai International Financial Centre Authority
Level 14, The Gate Building
Dubai International Financial Centre
P.O. Box 74777
Dubai, United Arab Emirates

For mainland UAE operations:
UAE Data Office
Federal Authority for Data Protection
Abu Dhabi, United Arab Emirates

16. GOVERNING LAW

This Privacy Policy is governed by the laws of the United Arab Emirates, and any disputes relating to this policy will be subject to the exclusive jurisdiction of the courts of Dubai, United Arab Emirates.

By using our services, you acknowledge that you have read and understood this Privacy Policy.

This privacy policy is a general template and should be reviewed by qualified legal counsel familiar with UAE data protection laws before implementation.