Last Updated: 21 February 2021

ThisPrivacyPolicy(the“Policy”)explainshow Finllect (Digital Technologies) Ltd (“Company,”“Finllect” “we,”“our,”or“us”)collects, stores, uses, shares and protects your Personal Information, which we obtain when you visit our websites, use our mobile application or use our services (collectively, the “Services”). The Services are more fully described in the Terms of Use, and such description is incorporated therein. You accept this Policy and all of its terms whenever you access or use theServices.

Thank you for choosing to be part of our community at Finllect. When you visit our mobile application, and use our services, you trust us with your personal information. We take your privacy very seriously. In this privacy policy, we seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it using a few simple questions. We hope you take some time to read through it carefully, as it is important. If there are any terms in this privacy policy that you do not agree with, please contact us immediately or discontinue the use of our app and our services.

This privacy policy applies to all information collected through the Finllect mobile application, (“App”), and/or any related services, sales, marketing or events (we refer to them collectively in this privacy policy as the “Services”).

Our Services are intended for the U.A.E audience. We currently do not offer products or services to non-U.A. E customers. You must be a resident of the U.A.E to access our mobile application.

1. What information do we collect?

In Short: We collect personal information that you provide to us.
We collect personal information that you voluntarily provide to us when registering on to the App, expressing an interest in obtaining information about us or our products and services, when participating in activities on the App or otherwise contacting us.

(i) Information you give us through the App

• Details you give when you sign up for Finllect, including your name, phone number, gender, home address and date of birth,
• A copy of your passport, Emirates ID and proof of address, including your bank statement or utility bill you choose to upload on signing onto the application.
• The log in credentials and settings you choose for the Finllect app, so We can give you the services you ask for safely.
• Answers you give to surveys so we can improve our services.
• Details of your expenses, income, borrowings, and budgets that you create, track or record within the Finllect app.
• Your credit score, current employment history, current source of income and credit history.
• Details of content consumption and any data you share with us within our feed questions.
• Your financial transactions, which are collected through our open banking provider.

(ii) Information we collect if You get in touch

• The phone number you are calling from and information you give us during the call.
• The email address you use and the contents of your email (and any attachments).
• Public details from your social media profile (like Facebook, Instagram or Twitter) if you reach out to us via these platforms, and the contents of your messages or posts to us.

(iii) Information we collect when You use the App and Our services

We collect this information to give you services in a safe and lawful way, and to keep improving them. This includes:

• Details about services from us and our partners that you express interesting.
• Details about how you use our App.

(iv) Information we collect when You use the App and Our services

• The mobile network and operating system you use, so we can analyse how our app works and fix any issues.
• Your IP address and device ID for security reasons (we’ll link your mobile phone number with your device.
• Your location if you’ve authorised tracking.

(v) Information automatically collected

In Short: Some information — such as IP address and/or browser and device characteristics — is collected automatically when you visit our App.

We automatically collect certain information when you visit, use or navigate the App. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our App and other technical information. This information is primarily needed to maintain the security and operation of our App, and for our internal analytics and reporting purposes.

• Geo-Location Information. We may request access or permission to and track location-based information from your mobile device, either continuously or while you are using our mobile application, to provide location-based services.
• Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device’s camera, contacts, sms messages, and other features.
• Mobile Device Data. We may automatically collect device information (such as your mobile device ID, model and manufacturer), operating system, version information and IP address.
• Push Notifications. We may request to send you push notifications regarding your account or the mobile application. If you wish to opt-out from receiving these types of communications, you may turn them off in your device’s settings.

2. How long do we keep your information?

In Short: We keep your information only for as long as we need are required by law to do so.

We keep most of Your data as long as you use the App, and for 6 years after that to comply with the law and if We face a legal challenge. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives),then we will securely store your personal information and isolate it from any further processing until deletion is possible. To work out how long we keep different categories of data, we consider why we hold it, how sensitive it is, how long the law says we need to keep it for, and what the risks are.

3. How do we store your information?

In Short: We take all necessary steps to store your data in a secure environment through a system of organisational and technical security measures.

We have implemented appropriate technical and organisational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our App is at your own risk. You should only access the services within a secure environment. Some of the key steps we take to protect your data include:

• We store your data in local data centres in a safe and secure manner.
• We test our servers regularly to ensure security is maintained to the highest standards.
• Your login credentials are hashed before being stored in a secure system and not in plain text.
• All connections between the Finllect App and our data servers are managed through a secure system.
• Your personal data is not stored in a local phone storage to ensure optimum security.

4. How do we use your information?

In Short: We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.

We use personal information collected via our App for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.
We use the information we collect or receive:

• To facilitate account creation and logon process: If you choose to link your account with us to a third party account (such as your Google or Facebook account), we use the information you allowed us to collect from those third parties to facilitate account creation and logon process for the performance of the contract.
• To send you marketing and promotional communications: We and/or our third party marketing partners may use the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt-out of our marketing emails at anytime.
• To send administrative information to you: We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.
• Deliver targeted advertising to you: We may use your information to develop and display content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness.
• To manage user accounts: We may use your information for the purposes of managing our account and keeping it in working order.
• To provide you with a better experience: We may use your information to:

• Respond to questions, comments and other requests;

• Send you information, including confirmations, invoices, technical notices, product and service information, updates, security alerts, support and administrative messages and information about information submitted to us via the Services;

• Provide access to certain areas, functionalities and features of our Services;

• Communicate with you, such as to respond to your comments and questions, provide customer service or feedback, or respond to employment opportunities for which you’ve applied, of for any other purposes in connection with the Services;

• Facilitate any transaction requested by you;and

• Allow you to register for additional services offered by us or our partners.

We may use information for internal-business purposes, to:

• Conduct research and analytics to understand our visitors and customers, and tailor our product offerings;
• Operate, maintain, test, enhance, update, monitor, diagnose, fix and improve our Service;
• Develop new products and Services or improve existing products and Services;
• Ensure internal quality control;
• Communicate about individual accounts and activities on our Services and systems and, in our discretion, changes to any our policy;
• Comply with regulatory and legal requirements;
• Prevent, investigate or provide notice of fraud or unlawful or criminal activity, and enforce and carry out contracts and agreements between us and you; and
• Protect the safety of any person, to address fraud, security or technical issues, or to protect our rights or property.

For marketing purposes, we may analyze and use Personal Information to provide you with materials about offers, products and services that may be of interest, including new content or services. We may provide you with these materials by phone, postal mail or email, as permitted by applicable law. Such uses include:

• To provide you with, and to tailor, content, advertisements and offers;
• To notify you about offers, products and services that may be of interest to you
• To provide Services to you and our partners and affiliates.
• For other purposes disclosed at the time you provide Personal Information;
• Facilitate contests, promotions and rewards and provide you with news about products and services offered by us and our selected partners;and
• Otherwise with your consent.

5. Will your information shared with anyone?

In Short: Not unless you agree. We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations.

We may process or share data based on the following legal basis:

• Consent: We may process your data if you have given us specific consent to use your personal information in a specific purpose.
• Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.
• Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.
• Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
• Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved. More specifically, we may need to process your data or share your personal information in the following situations:
• Business Transfers: We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
• Third-Party Advertisers: We may use third-party advertising companies to serve ads when you visit the App. These companies may use information about your visits to our website(s) and other websites that are contained in web cookies and other tracking technologies in order to provide advertisements about goods and services of interest to you.
• Affiliates: We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy policy. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.
• Financial Institutions: We provide your credit score, your financial profile, including information on how your recurring micro-payments, in-app activity and budgets and any information you opt-in to provide a financial institution when you chose to prequalify for a financial service.

6. How do we collect information from other parties?

Information We Get from Third Parties. We may collect Personal Information about you from other users, our affiliates and third parties, as permitted by law. For example, we may collect information from
third-party verification services, credit bureaus, financial institutions, mailing-list providers, landlords, telecommunication providers, merchants with which you may transact and publicly available sources and databases, for purposes described below. We may also collect information about you from third parties in connection with any identity- or account-verification process, fraud-detection process, account payments with third parties with whom you do business, collection procedures, credit-reporting purposes or as may otherwise be required or permitted by applicable law.

7. How do we handle your social log-ins?

In Short: If you choose to register or log in to our services using a social media account, we may have access to certain information about you.

Our App offer you the ability to register and login using your third party social media account details. Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile Information we receive may vary depending on the social media provider concerned, but will often include your name, e-mail address, friends list, profile picture as well as other information you choose to make public.

We will use the information we receive only for the purposes that are described in this privacy policy or that are otherwise made clear to you on the App. Please note that we do not control, and are not responsible for, other uses of your personal information by your third party social media provider. We recommend that you review their privacy policy to understand how they collect, use and share your personal information, and how you can set your privacy preferences on their sites.

8. How do we deal with third-party websites or services?

In Short: We are not responsible for the safety of any information that you share with third-party providers who advertise, but are not affiliated with, our websites.

The App may contain advertisements from third parties that are not affiliated with us and which may link to other websites, online services or mobile applications. We cannot guarantee the safety and privacy of data you provide to any third parties. Any data collected by third parties is not covered by this privacy policy. We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services or applications that may be linked to or from the App. You should review the policies of such third parties and contact them directly to respond to your questions. Your decision to subscribe to a product or service relating to a third-party that is promoted on our App shall be governed by the policies of the respective third-party.

9. What are your privacy rights?

In Short: You may review, change, or terminate your account at any time.
You have a right to:

• access the personal data we hold about you, or to get a copy of it.
• ask for a copy of Your personal data in a portable (machine-readable) format or make us send it to someone else.
• make us correct inaccurate data.
• ask us to delete, ‘block’ or suppress your data, though for legal reasons we might not always be able to do it.
• say no to us using your data for direct marketing and in certain other ‘legitimate interest’circumstances.
• withdraw any consent you have given us.
• ask a member of our staff to review a computer-made (automated)decision.

10. How do we manage risk?

In Short: We act quick and keep your data safe.

A privacy breach occurs when there is unauthorized access to or collection, use, disclosure or disposal of personal information. You will be notified about data breaches when Finllect believes you are likely to be at risk or serious harm. For example, a data breach may be likely to result in serious financial harm or harm to your mental or physical well-being. In the event that Finllect becomes aware of a security breach which has resulted or may result in unauthorized access, use or disclosure of personal information Finllect will promptly investigate the matter and notify the applicable Supervisory Authority not later than 72 hours after having become aware of it, unless the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons.

11. Do we make changes to this policy?

In Short: Yes, we will update this policy as necessary to stay compliant with relevant laws.

We may update this privacy policy from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information.

12. How can you get in touch?

In Short: email us

If you have questions or comments about this policy, you may email us at [email protected].