Wizzpay Technology Holdings Ltd ("our", "us", "we", “Wizzpay”) is committed to the protection of personal data provided by users ("you", "your", "users") to us. This Privacy Policy ("Privacy Policy") provides you with information on how we process your personal data in connection with this mobile application (“Application”).
We take the privacy of our users seriously and we remain committed to safeguarding the privacy of our users while providing a personalised and valuable service.
Should you have any comments or questions with respect to how we process your personal data, please write to us at:
Address: Desk D69, Level 11, Al Sarab Tower, Abu Dhabi Global Market Square, Abu Dhabi, Al Maryah Island, United Arab Emirates;
Email: feedback@wizzpay.com.

Information Collected

A
Traffic Data,
We automatically track, collect and encrypt the following categories of data when you use our Application:
1.
User ID,
2.
Device ID,
3.
Crash logs,
(collectively, the "Traffic Data").
B
Information Collected from You.
In order for you to access certain areas of the Application and use its functionality, we may require you to provide us with certain personal data ("Personal Data"). Personal Data includes the following Personal Data we collect from you, store and encrypt:
1.
Full name,
2.
Telephone number,
3.
User ID,
4.
Details of any transactions you carry out through the Application (the “Transaction History”), and
5.
Other in-app messages.
The following Personal Data will only be collected if you expressly allow us to do so. You may choose not to provide us with this Personal Data while accessing the Application. In such an event, you can still access a limited scope of the Application functionality, however you will not be able to access and use those portions of the Application that require your Personal Data:
1.
Your contact list information, and
2.
Your approximate location.
Traffic Data and Personal Data are collectively referred to as the “Information”.

Purposes for the Information Collection, Usage and Storage

We collect, use and store the Information for the following purposes:
1.
To maintain the Application functionality and provide services that you have requested;
2.
To allow you to participate in interactive features of the Application;
3.
To notify you about changes to our service(s);
4.
To comply with the applicable laws and regulations, including those related to the data protection;
5.
For customer service, including answering questions and responding to feedback and complaints;
6.
To enhance the security of our services;
7.
To ensure that content on our Application is presented in the most effective manner for you and for your computer.

Lawful Basis for Processing

We collect Information only where it is relevant to, and necessary for, specified, explicit and legitimate purposes determined at the time of collection.
We generally process your Personal Data for the purpose of providing you with our Application. However, we also may process your Personal Data under the following lawful bases:
Where it is necessary to do so to comply with a legal obligation to which we are subject;
Where it is in our legitimate interests, or those of a third, and where those legitimate interests are not overridden by your interests or rights.

Retention of Data

You have the right to request us to close your WizzPay account and delete the Personal Data that we have collected from you. Please refer to the guidance posed here: https://www.wizzpay.com/thinking-of-leaving-wz.
Wizzpay will retain your Personal Data for as long as is necessary to comply with applicable laws, regulations, and relevant orders from government authorities, after closure of your Wizzpay account, which may include such Personal Data as your name, contact details, user ID and Transaction History, etc. ("Retained Data"). Other than the Retained Data, we will delete and destroy all Personal Data that we hold about you when your Wizzpay account is terminated. We do not store your online banking login PIN, TAN and/or password. If requested, WIzzpay will do its best to delete obsolete personal data unless it is required to be retained by law or for lawful business purposes.
Please note that we will not store your credit card information.
Please note that we will never ask you to disclose your personal or security details by e-mail. If you receive any e-mail purportedly from Wizzpay requesting your personal or security details, please do not respond to it ("Suspicious E-mail"). Please forward any Suspicious E-mail to infosec@wizzpay.com and thereafter delete the Suspicious E-mail immediately.

Disclosure of Information

We do not disclose your Information to any third parties other than our affiliates and the following:
1.
A prospective buyer of our business or a buyer of a substantial number of the shares in our business;
2.
The police, other lawful enforcement body, regulatory body or court if we are under a duty or required by law to disclose or share your personal data , or to protect the rights, property, or safety of ourselves or our group companies, our customers, or others;
3.
Financial institutions with whom we partner to jointly provide better services, facilities or products to you. These financial institutions may only use your Information for providing to you their services and market Wizzpay-related products without requiring your further consent;
4.
Third parties where you have expressed an interest in receiving information about their goods and services:
(a)
third parties we may occasionally use to provide you with the services that you have requested. We require these third parties to not use your Personal Data for any other purpose;
(b)
third parties with whom we have legal and contractual obligations;
(c)
as may be required under any applicable laws, rules and regulations.
We also use Information in encrypted (anonymized) form (so that no individual user is identified) to audit usage of the Application.

Communications

We may contact you via the phone number registered with your Wizzpay account. You may also receive system-generated transactional messages such as confirmations, notification of receipt of payments, notification of password changes etc. which are necessary for the proper operation and administration of your Wizzpay account. You expressly consent to receive such communications from us.

Web Beacons

In limited circumstances we also may use "Web Beacons" to collect anonymous, non-Information about your use of our Application. Further details can be found within our Cookies Policy.

Confidentiality and Security

Except as otherwise provided in this Privacy Policy, we will keep your Information private and will not share it with third parties.
We are committed to ensuring that your Information is secure. To prevent unauthorised access or disclosure of Information we have physical, electronic and managerial procedures in place to keep your information safe.
However, this high level of protection can only be effective if you follow certain security practices yourself. You must never share your Wizzpay account or login details with anyone. If you are concerned that any of your login details have been compromised, you can change them any time once you are logged on but you should always also immediately contact customer services at service@wizzpay.com and tell us why you think your login details have been compromised.
Although we make good faith efforts to store Information in a secure operating environment that is not open to the public, you should understand that there is no such thing as complete security, and we do not guarantee that there will be no unintended disclosures of your Information. If we become aware that your Information has been disclosed in a manner not in accordance with this Privacy Policy, we will use reasonable efforts to notify you of the nature and extent of the disclosure (to the extent we know that information) as soon as reasonably possible and as permitted by law.

Updates and Changes to Privacy Policy

We reserve the right, at any time, to add to, change, update, or modify this Privacy Policy so please review it frequently. If we do, then we will notify you here, as well as by posting a notice on the Application and, where appropriate, a link to the modified policy so that you can review it. In all cases, use of information we collect is subject to the Privacy Policy in effect at the time such information is collected.

Your Rights

Right

What does this mean?

The right to object to processing
You have the right to object to certain types of processing.
The right to be informed
You have the right to be provided with clear, transparent and easily understandable clarifications about how we use your Personal Data and your rights. This Privacy Policy is designed to serve this purpose.
The right of access
You have the right to obtain access to your Personal Data (if we’re processing it), and certain other information (similar to that provided in this Privacy Policy). This is so you’re aware and can check that we are using your Personal Data in accordance with applicable law.
The right to rectification
You are entitled to have your Personal Data corrected if it’s inaccurate or incomplete.
The right to erasure
This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your Personal Data where there’s no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions.
The right to restrict processing
You have the right to ‘block’ or suppress further use of your Personal Data. When processing is restricted, we can still store your Personal Data, but may not use it further. We keep lists of persons who have asked for no further use of their Personal Data      to be ‘blocked’ to make sure the restriction is respected in future.
The right to data portability
You have the right to obtain and reuse your Personal Information for your own purposes across different services. For example, if you decide to switch to a new provider, this enables you to move, copy or transfer your Personal Information easily between our IT systems and theirs safely and securely, without affecting its usability.
The right to lodge a complaint
You have the right to lodge a complaint about the way we handle or process your Personal Information with ADGM Commissioner of Data Protection.
The right to withdraw consent
If you have given your consent to anything we do with your Personal Information, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your Personal Information with your consent up to that point is unlawful). This includes your right to withdraw consent to us using your Personal Information for marketing purposes (if it is applicable).
If you have questions or concerns, feel free to e-mail us or to correspond at feedback@wizzpay.com and we will attempt to address your issue.
If you want to file a complaint with, or contact, the ADGM Office of Data Protection, you may do so by email to data.protection@adgm.com.