ICE-PAY PRIVACY POLICY
Last Updated: May 4, 2025
1. INTRODUCTION
ICE-PAY (“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
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 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 internal parties, external third parties, or third-party vendors as necessary to provide our services.
7. INTERNATIONAL TRANSFERS
ICE-PAY may transfer your personal data to countries anywhere. When doing so, we ensure a similar degree of protection by implementing appropriate safeguards.
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.
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 satisfying any legal, regulatory, accounting, or reporting requirements.
10. YOUR LEGAL RIGHTS
You have rights in relation to your personal data that include access, rectification, erasure, restriction, portability, objection, and withdrawal of consent.
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.
12. COOKIES AND TRACKING TECHNOLOGIES
Our website uses cookies and similar tracking technologies to distinguish you from other users.
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.
14. CONTACT INFORMATION
Email: [email protected]
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.
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 data protection laws before implementation.
