M A R K E T D A T A & D A T A P R O T E C T I O N
We are registered with the DIFC and are subject to the DIFC Data Protection Law 2020. This regulation explains how and why we use your personal information when you use Pasiv. You can chat with us through the app or send us an email at email@example.com if you have any questions or concerns.
We collect, use, and retain information about you:
Information you give us through the Pasiv app, when you register to use the app, sign up for an account, correspond with us, use the app chat, engage in promotions or reward schemes, or other communications:Your name, phone number, home address, date of birth, residency,Your email address, details of your deviceYour Emirates ID information, or passport and any other identification documentsYour photo if you upload one.The login and registration information and settings you choose for your app (including username, password)Your bank account details, including account number and IBANYour locationYour employment information and your source of wealthDetails you give us which we pass to our partners when you let us know you are interested in their services.Information you give us through the app chat or records of discussions if we contact each otherThe email address you use and the contents of your email (and any attachments).Public details from your social media profiles (Facebook, Instagram, or Twitter) if you reach out to us via these platforms, and the contents of your messages or posts to usAnswers you give to surveysDetails about deposits and withdrawals to and from your account, including amounts and beneficiaries’ bank detailsDetails about services from us and our partners that you express interest in.Details about how you use our app.
Information we collect from your device:
As part of the mobile service we provide you, the mobile app allows us to collect certain information of yoursThe mobile network information and operating system, the type of mobile browser you useYour login information, browser type and version and informationThe type of device you use, unique device identifierYour IP (Internet Protocol) address and device ID for security reasonsYour mobile advertising ID, so we can share it with companies that help us with advertising online. You can reset this ID or limit tracking in ‘Settings’ on your phoneYour location so we can help protect you against fraud which we track your location using GPS and your IP addressYour phone contacts solely to show you who in your contact list uses Pasiv if you give us access to do soInformation on your use of the app, including links to, through and from our website to other sitesTransaction data to do with your investments and holdings
Information from external sources:
We obtain information about you from external sources to enable us complete an appropriate risk assessment on your account applicationfraud prevention agencies and KYC (Know Your Customer) and AML (Anti Money Laundering) service providers to fulfil our legal dutiesInformation from your social media network if you log in to our app from your social media account, we will receive information to authenticate you
Why we use your information:We must have a lawful basis for using your personal data. At least one of the following must apply: contractual or legal duty, legitimate interest, public interest, vital individual interest, or consent. In this section we explain which one we rely on to use your data in a certain way.
We need to use your data for a contract we have with you, or to enter into a contract with you. We use details about you to: consider your application, including our KYC, customer due diligence and security checksgive you the services we agreed to in line with our terms and conditions. to process your transactionssend you updates and communications about your account and other services you use if you get in touch, or we need to notify you of changes to our Services, tell you about something or contact you through customer support servicesto handle your enquiries in our communicationsexercise our rights under contracts we have entered into with youallow our partners provide information on their services if you agree to receive such informationinvestigate and resolve complaints and other issues
We need to use your data to comply with the law. We use your details to: check your identity when you sign up or get in touch.check your record at immigration and fraud prevention agencies.prevent illegal activities like money laundering, tax evasion and fraud.keep records of information we hold about you in line with legal requirements.adhere to banking laws and regulations (these mean we sometimes need to share customer details with regulators, tax authorities, law enforcement or other third parties).compare information we hold about your account with your tax residency information to make sure we do not have a reason to doubt it.
When it is in our ‘legitimate interest: We need to use your data for our legitimate interests, or those of a third party. This means using data in a way that you might expect us to, for a reason which is in your and/or our (or a third party’s) interest and which does not involve overriding your privacy rights.
Product development and marketing:We will tell you about products and services through the app or other channels, like social media companies, based on how you use our products and services and other information we hold about you. We do this so we can make sure our marketing is useful. We do not share any identifying information with social media companies other than your mobile advertising ID.We track, analyse, and improve the services we give you and other customers and how you respond to ads we show. We may ask for feedback if you have shown interest in a service. We do this so that we can make our products better and understand how to market them.
Special features:We will continue to build special features which will give you a unique user experience. We will use your transactional data for these features.
Security and business management: protect the rights, property or safety of us, our customers, or others carry out security and maintenance checks to make sure our app, website and other services run smoothly for you.share information with fraud prevention agencies so we can benefit from up-to-date information when we make decisions about accounts. This helps us fight financial crime.share your name, title and account number with other banks and financial institutions so that people making payments to you can confirm the name they have for you matches the name we hold in our records. This helps us fight financial crime.
Companies that give services to us: We share your information with companies that help us provide our services
Consent: We will ask for your consent to: tell you about our products and services, and those of our partners by email or push notification if we think they are of interest to you. You can unsubscribe from these by email or via the app.help protect you against fraud by sending you a One Time Password to consent to trade execution and/or withdrawals from your accountshow your profile picture in the app if you add one.show your profile picture and name to contacts in the app, provided they have stored your phone number & you consent to enable our community feature & share with the community.share information about you with companies we work with when we need your permissionYou do not have to share information about yourself if you do not want to. But if you do not, you may not be able to use some (or any) of our services.
We may share your data with (Companies that give services to us): Here we mean companies that help us provide services you use and need to process details about you for this reason. We share as little information as we can and encrypt and/or make it impossible for you to be identified by the recipient where possible (for instance by using a User ID rather than your name).
We may share your data with (Compliance with Applicable Laws): We share your personal data with third parties that help us provide services you use or to comply with applicable laws. We will never sell your personal data to other organisations.
We may share your data with (Others) : business partners that provide services to us, including IT and brokerage servicesKnow Your Customer (KYC) service providers that help us with identity verification or fraud checks.cloud computing power and storage providersour business intelligence and analytics partners.companies that help us with functional analytics (to help us solve technical issues with the app for instance).companies that help us with marketing (but we will not share identifiable personal data with third parties for their own direct marketing unless you give us permission, and you can opt out any time).software companies that we use for emailing you, or for processing and storing email communications with youcompanies that help us with customer supportFinancial institutions that provide complementary services such as money remittance to or from your bank accountLegal or regulatory authorities where we have a legal obligation to do so or to prevent fraudWe will use this information to:verify your identity and make sure what you have told us is true.help detect and prevent fraud, crime, and money laundering.manage your account with us.make sure our offers are relevant for youAnyone you give us permission to share it withWe tell you in the app when we need your consent to share your data with other applications.Law enforcement and other external parties.We may share your details with authorities that spot and stop financial crime, money laundering, terrorism, and tax evasion if the law says we have to, or if it is necessary for other reasons, or; the police, courts, or dispute resolution bodies if we have to, or; other banks to help trace money if you are a victim of fraud or other crimes or if there is a dispute about a payment, or; any other third parties where necessary to meet our legal obligations.
Corporate Finance events: We may also share your details with people or companies if there is a corporate restructure, merger, acquisition or takeover.
Retention of data: We keep most of your data as long as you are using your account, and for 6 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.
Your rights: You have the right to: access the personal data we hold about you, or to get a copy of it.make us correct inaccurate or out of date personal information.ask us to delete your data unless we have a legal obligation to retain it.ask us not to contact you for marketing purposes.withdraw any consent you have given us or object to processing of your personal informationask a member of staff to review a computer-made (automated) decision.contact us at firstname.lastname@example.org
Where we store or send your data: To provide our services to you we may transfer and store the data we collect from you to organisations outside of the DIFC. When we do this, we make sure that your data is protected and that appropriate security measures are in place.
How we keep your data secure: Your data is stored on secure servers. We maintain reasonable security measures to safeguard your personal data from loss, interference, misuse, unauthorised access, disclosure, alteration, or destruction. We also maintain reasonable procedures to help ensure that such data is reliable for its intended use and it is accurate, complete, and up to date. Any payment transactions carried out by us or our payment-processing providers will be encrypted using Secured Sockets Layer technology or a secure virtual private network Encrypted using transport layer security (TLS).
How to make a complaint: If you have a complaint about how we use your personal information, please contact us through the website or send an email to email@example.com and we will do our best to fix the problem.