1. About Xpence
Xpence Global Holdings Ltd. (Xpence), is a limited liability company incorporated under the laws of Abu Dhabi Global Market, with commercial registration number 000002192 and with its registered head office address at DD-15-134-004 – 007, Level 15, WeWork Hub71, Al Khatem Tower, Abu Dhabi Global Market Square, Al Maryah Island, Abu Dhabi, United Arab Emirates. (“Xpence”). You can contact us via the support button in the application or email us at email@example.com
2. Our Approach to Your Data
At Xpence, we recognise the importance of protecting your data. Our mission is to empower entrepreneurs to successfully grow and scale their businesses, and provide better access to Financial Services. This includes taking our responsibilities towards your data seriously. We will always use your data in a way that is legal, complies with the regulations under which we are authrosied to operated, that takes care of your privacy and ensures that Xpence works for you. We will never use your data in a way that could harm you. If you have any concern about your data or how it is used, please email us at firstname.lastname@example.org, we take all feedback, suggestions and complaints seriously.
4. Collecting and Using Your Personal Data
Information that you give to us when you apply to become an Xpence customer, or though your use of our Products and Services, use in-app chat or email, speak to us on the phone or engage in promotions, reward schemes and other communications will be used and retained to allow Xpence to provide you with its Products and Services.
4.1 Data Collected
While using Our Service, We will ask You to provide Us with certain information including, but is not limited to:
- Your first name and last name
- Your e-mail address
- Your phone number and details of your mobile device
- Your home address
- Your date of birth
- Your residency and visa information
- Your national identity documents and passport
- A selfie that you take when you set up your relationship with Xpence, or your photo if you upload one
- Any other demographic information you chose to share via application process or user surveys
- Your log in and registration information and settings you chose in the app (including your user name and password)
- Your company information and documents that you provide
- Your bank account details including your account number and IBAN
- Your location
- Details which you give us which we pass to partners when you let us know that that you are interested in their services
- If you contact us, we may keep a record of that correspondence
- Any surveys or feedback sessions that you participate in
- Public details from any social medial profiles that you provide to us
- Public information from any websites that you provide to us
- Details about top-ups into your account, payments to and from your account, and transfers you make between your account and other accounts including payment reason, and beneficiaries’ details
- Details about how and when you use Xpence services
- Details of any marketing information that we have sent to you
- Information we collect from your device
- The mobile network, operating system and browser information
- The type of device that you use and unique identifier
- IP address
- Your location
- Your phone contacts if you give Xpence access to these
- Your photos if you give Xpence access to these
- Information on your usage of the app
- Information from external sources
- Data provided by third parties to help us fulfil our regulatory duties with respect to financial crime management including fraud, anti-money laundering and counter-terrorist financing.
- We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
4.2 Tracking Technologies and Cookies
Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close your web browser.
We use both session and persistent Cookies for the purposes set out below:
Necessary / Essential Cookies
Type: Session Cookies Administered by: Us
Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.
Cookies Policy / Notice Acceptance Cookies
Cookies Administered by: Us
Type: Persistent Cookies
Administered by: Us
Purpose: These Cookies allow us to remember choices You make when You use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide you with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website.
4.3 Use of Your Personal Data
Xpence may use Personal Data for the following purposes:
- To provide and maintain our Service, including to monitor the usage of our Service.
- To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
- For a contract we have with your or to enter into a contract with you. We use your data to:
- Consider your application including KYC, customer due diligence and security checks
- Provide the products, items or services You have purchased or of any other contract with Us through the Service in line with our Terms and Conditions
- To process your transactions
- To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
- To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
- To manage Your requests: To attend and manage Your requests to Us. We may share your personal information in the following situations:
With Service Providers: We may share Your personal information with Service Providers to monitor and analyse the use of our Service, to show advertisements to You to help support and maintain Our Service, to contact You, to advertise on third party websites to You after You visited our Service or for payment processing.
For Business transfers: We may share or transfer Your personal 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.
With Business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.
With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside. If You interact with other users or register through a Third-Party Social Media Service, Your contacts on the Third-Party Social Media Service may see You name, profile, pictures and description of Your activity. Similarly, other users will be able to view descriptions of Your activity, communicate with You and view Your profile.
4.4 Retention of Your Personal Data
We keep most of your data as long as you are using Xpence products and services, and for 7 years after that to comply with the law and if we face a legal challenge. In some circumstances, like cases of anti-money laundering or fraud, we may keep data longer if we need to (that is in our legitimate interest) and/or the law says we have to.
4.5 Where We Store Your Personal Data
All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website or mobile application, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
4.6 Transfer of Your Personal Data
Your information, including Personal Data, is processed at the Company’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to and maintained on computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.
5. Disclosure of Your Personal Data
5.1 Law enforcement
Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
5.2 Other legal requirements
The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:
- Comply with a legal obligation
- Protect and defend the rights or property of the Company
- Prevent or investigate possible wrongdoing in connection with the Service
- Protect the personal safety of Users of the Service or the public
- Protect against legal liability
6. Security of Your Personal Data
The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.
7. Links to other Websites
9. Contact Us
Last Update: January 2023