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Privacy Policy
Table of Contents
About this Policy
We, Pay Ten Payment Services Provider LLC (“Pay10”, “We”, “Us”, “Our” or the “Company”), take your privacy very seriously. Please read this privacy policy (“Privacy Policy”) carefully as it contains important information on who we are and how and why we collect, store, use and share your personal data when we engage with you through your use of our website (https://pay10.ae) or our application or through a call or email to us. This Privacy Policy also explains your rights in relation to your personal data and how to contact us or any regulatory authority in the event that you have any concerns.
We collect, use and are responsible for certain personal data about you. When we do so we are subject to the laws and regulations applicable in the United Arab Emirates (“UAE”).
PAY10 is the ‘data controller’ of your personal data as defined by applicable laws. Our full details are set out at the end of this Privacy Policy.
Your Obligations
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with Us.
If you provide Us with information about any other person, for example your customer, then you must ensure that you have their consent to share their personal details with Us and their permission for Us to use those details in accordance with this Privacy Policy. You should also make sure that you make such third parties fully aware of the provisions of this Privacy Policy.
Key Terms
| Personal data | Any information relating to an identified or identifiable individual. |
| Special category personal data | Personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership, genetic and biometric data (when processed to uniquely identify an individual), data concerning health, sex life or sexual orientation. |
| Data subject | The individual who the personal data relates to. |
| Wallet | Known as a digital wallet (or electronic wallet) within a financial transaction application that runs on mobile devices. It securely stores your payment information and passwords. The Pay10 application allows you to pay when you’re shopping using your device so that you don’t need to carry your cards on your person. You enter and store your debit card, or bank account information, deposit the funds and can then use your device to pay for further sending funds, bill payments and purchases. |
Personal data we collect about you
We may collect, use and transfer the personal data about you that includes but is not limited to:
- Identity and Contact Data such as your name and contact information, including email address (if applicable), date of birth, telephone number, company details (if applicable) and your gender.
- Financial Data such as your billing information, information about your transactions (such as direct debits and standing orders), your bank account details (or any other bank account connected via our services), IBAN details and your payment card information.
- Special Categories of Data including biometric data such as facial recognition.
- Technical Data including information about how you use Our website or our application, IT, communication and other systems, internet protocol (IP) address, your location data, login data, browser type and version, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website and Our application. This will include information about how you use Our website, Our application and Our products and/or services.
- Marketing and Communications Data which includes your preferences in receiving marketing from us and your communication preferences, and your responses to surveys, competitions and promotions.
- Profile Data including username and password details and profile photographs.
How your personal data is collected
- Publicly accessible sources ie Companies and/or Land Registries.
- Directly from a third party ie
- sanctions screening providers.
- credit reference agencies.
- customer due diligence providers.
- Third party with your consent ie your bank.
- Cookies on our website.
- Our IT systems ie automated monitoring of our website and application, and other technical systems, such as our computer networks and connections, communications systems, email and instant messaging systems (for example, via the use of cookies and similar technologies).
How and why we use your personal data
- To comply with Our legal and regulatory obligations.
- For the performance of Our contract with you or to take steps at your request before entering into a contract;
- For Our legitimate interests or those of a third party.
- Where you have given consent.
The table below explains what we use your personal data for and why:
| What we use your personal data for | Types of personal data used | Our reasons |
|---|---|---|
| To provide products and/or services to you, including for example, to contact you or deal with our internal record keeping. To manage the relationship which we have with you, such as dealing with enquiries or complaints. | Identity and Contact Data Financial Data | To fulfil our contract with you or to take steps at your request before entering into a contract. This is also in our legitimate interests in ensuring that our services we provide are properly managed, and to comply with our regulatory obligations to handle complaints. |
| We, us, our | Pay Ten Payment Services Provider LLC | Pay Ten Payment Services Provider LLC |
| Preventing and detecting fraud against you or us | Identity and Contact Data Financial Data Technical Data | For our legitimate interests or those of a third party, i.e. to minimize fraud that could be damaging for you and/ or us |
| Conducting checks to identify our customers and verify their identity Screening for financial and other sanctions or embargoes Other activities necessary to comply with professional, legal and regulatory obligations that apply to our business, e.g. under anti-money laundering legislation or rules issued by the DIFC/DFSA To gather information on your use of our services and to provide you with custom information relating to your use of finances and/or our services | Identity and Contact Data Financial Data Technical Data | To comply with our legal and regulatory obligations This will be necessary for our legitimate interests in the operation of our business |
| Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies | Identity and Contact Data Financial Data Technical Data | To comply with our legal and regulatory obligations |
| We, us, our | Pay Ten Payment Services Provider LLC | Pay Ten Payment Services Provider LLC |
| Ensuring business policies are adhered to, e.g. policies covering security and internet use | Technical Data Profile Data | For our legitimate interests or those of a third party, ie to make sure we are following our own internal procedures so we can deliver the best service to you |
| Operational reasons, such as improving efficiency, training and quality control. To administer our website, including troubleshooting, data analysis, testing, system and maintenance support. | Identity and Contact Data Technical Data Marketing and Communications Data Profile Data | For our legitimate interests or those of a third party, ie to be as efficient as we can by improving our website and our customer service to you, improving the services and/or products we offer so we can deliver the best service to you at the best price, and in ensuring that our website works properly and for network security. |
| Ensuring the confidentiality of commercially sensitive information | Technical Data | For our legitimate interests or those of a third party, ie to protect trade secrets and other commercially valuable information To comply with our legal and regulatory obligations |
| Statistical analysis to help us manage our business, eg in relation to our financial performance, customer base, product range or other efficiency measures | Identity and Contact Data Financial Data Technical Data Marketing and Communications Data | For our legitimate interests or those of a third party, ie to be as efficient as we can so we can deliver the best service to you at the best price |
| Preventing unauthorised access and modifications to systems | Identity and Contact Data Special Categories of Data Technical Data Profile Data | For our legitimate interests or those of a third party, ie to prevent and detect criminal activity that could be damaging for you and/or us To comply with our legal and regulatory obligations |
| Updating and enhancing customer records | Identity and Contact Data Marketing and Communications Data Profile Data | To perform of our contract with you or to take steps at your request before entering into a contract To comply with our legal and regulatory obligations For our legitimate interests or those of a third party ie making sure that we can keep in touch with our customers about existing orders and new products n |
| Statutory returns | Identity and Contact Data Financial Data | To comply with our legal and regulatory obligations |
| Ensuring safe working practices, staff administration and assessments | Career Data | To comply with our legal and regulatory obligations For our legitimate interests or those of a third party ie to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you |
| Marketing our services and those of selected third parties to: · existing and former customers; · their parties who have previously expressed an interest in our services; · third parties with whom we have had no previous dealings. | Identity and Contact Data Marketing and Communications Data | For our legitimate interests or those of a third party ie to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you, by developing, marketing and promoting our services and products. |
| To ensure our third-party providers can perform their obligations to us, such as to complete credit reference checks via external credit reference agencies | Identity and Contact Data Technical Data Profile Data | For our legitimate interests in ensuring our third-party providers perform their services to us. From time to time we may also use IT providers and marketing consultants for the proper function of the website and to help us promote our services and products. |
| External audits and quality checks ie for ISO or Investors in People accreditation and the audit of our accounts | Identity and Contact Data Financial Data Technical Data Profile Data | For our legitimate interests or those of a third party, ie to maintain our accreditations so we can demonstrate we operate at the highest standards To comply with our legal and regulatory obligations |
| To deal with new enquiries and contacts | Identity and Contact Data Financial Data Career Data | This will be necessary for our legitimate interests in the operation of our business in order to be able to respond to and deal with new enquiries, and to assess your application if you have applied for a job vacancy. |
| To gather your feedback on our services. | Identity and Contact Data Marketing and Communications Data | This will be necessary for our legitimate interests in seeking to improve the quality of our services. |
| To authenticate your access to your account, for example by using your biometric data, or by sending a temporary pass code to your phone. | Identity and Contact Data Special Categories of Data | This will also be necessary for complying with our legal obligations under payment services legislation, and for our legitimate interests in providing our services to you, and so that our applications are easy for you to use and are as secure as possible. In addition, we will only process Special Categories of Data, such as biometric data, on the basis that you have given your express consent for us to process it for this purpose. |
Where We process special category personal data, We will also ensure We are permitted to do so under data protection laws ie:
- We have your explicit consent.
- The processing is necessary to protect your (or someone else’s) vital interests where you are physically or legally incapable of giving consent.
- The processing is necessary to establish, exercise or defend legal claims.
In addition, We may disclose information about you to the extent that We are required to do so by law, regarding any legal proceedings or prospective legal proceedings, in order to establish, exercise or defend Our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk) and / or where We may otherwise do so in accordance with applicable data protection legislation.
Marketing
- Contacting us at contactus@pay10.ae.
- Using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts.
Who we share your personal data with
- Companies within the Pay10 group.
- Third parties we use to help deliver our products and/or services to you ie payment service providers, and providers of identity and screening checks. Our identity and screening checks (known as KYC and AML checks) are outsourced to our KYC partner.
- Other third parties we use to help us run our business ie marketing agencies or website hosts.
- Third parties approved by you ie social media sites you choose to link your account to or third party payment providers.
- Credit reference agencies.
- Our bank.
- Money exchange companies.
We only allow our service providers to handle your personal data pursuant to such third party providing Us with confidentiality undertakings and the implementation of appropriate measures to protect your personal data. We also impose contractual obligations on service providers to ensure they can only use your personal data to provide services to Us and to you.
We may also need to:
- Share personal data with external auditors ie in relation to ISO or Investors in People accreditation and the audit of our accounts.
- Disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
- Share some personal data with other parties, such as potential buyers of some or all of our business or during a re-structuring.
Third-party links
Where your personal data is held
Personal data may be held at our offices (cloud servers through an aggregated provider) ensuring compliance with their structure on the global data privacy certification, third party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal data with’).
Some of these third parties may be based outside the UAE. For more information, including on how we safeguard your personal data when this happens, see below: ‘Transferring your personal data out of the UAE.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know it. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place 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.
How long your personal data will be kept
- To respond to any questions, complaints or claims made by you or on your behalf.
- To show that we treated you fairly.
- To keep records required by law.
To determine how long we should keep the different types of personal data we hold about you, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. We will not keep your personal data for longer than necessary.
In some circumstances, we may anonymize personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further policy to you.
Transferring your personal data out of the UAE
- With Our offices or other companies within Our group located outside the UAE.
- With your and Our service providers located outside the UAE.
- If you are based outside the UAE.
Transfers with appropriate safeguards
Transfers under an exception
- You have explicitly consented to the proposed transfer after having been informed of the possible risks.
- The transfer is necessary for the performance of a contract between Us or to take pre-contract measures at your request.
- The transfer is necessary for a contract in your interests, between Us and another person.
- The transfer is necessary to establish, exercise or defend legal claims.
Your rights
| Access | The right to be provided with a copy of your personal data |
| Rectification | The right to require us to correct any mistakes in your personal data |
| Erasure (also known as the right to be forgotten) | The right to require us to delete your personal data—in certain situations |
| Restriction of processing | The right to require us to restrict processing of your personal data in certain circumstances ie if you contest the accuracy of the data |
| Data portability | The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations |
| To object | The right to object: at any time to your personal data being processed for direct marketing (including profiling); in certain other situations to our continued processing of your personal data ie processing carried out for the purpose of our legitimate interests. |
| Not to be subject to automated individual decision-making | The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you |
You will not have to pay a fee to access your personal data (or to exercise any other rights). However, We may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, We may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help Us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure personal data is not disclosed to a person who has no right to receive it. We may also contact you to ask you to clarify your request to speed up Our response.
We try to respond to all legitimate requests within one month. Occasionally it may take Us longer than a month if your request is particularly complex or you have made several requests in which case we will keep you updated.
If you would like to exercise any of your rights, please:
- Email, call or write to us – see below: ‘How to contact us.
- Let us have enough information to identify you (ie your full name, address and customer or matter reference number).
- Let us have proof of your identity and address (a copy of your driving license or passport and a recent utility or credit card bill).
- Let us know what right you want to exercise and the information to which your request relates.
Keeping your personal data secure
We have appropriate security measures to prevent personal data from being accidentally lost or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
How to complain
Please contact us if you have any query or concern about our use of your information (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.
You also have the right to lodge a complaint with PAY10 at support@pay10.ae or telephone: 800-PAY10
Changes to this privacy policy
How to contact us
- Email: info@pay10.ae
- Address: 1002, U-bora Office Tower, Business Bay – Dubai, UAE
