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Privacy policy

Introduction

This privacy policy (Privacy Policy) applies between Eradah Capital LLC (we, us or our) and you (you or your), the person accessing or using any of our websites (such as www.zand.ae), our mobile applications or our portals (the Site). By using the Site or otherwise indicating your consent, you agree to be bound by this Privacy Policy. If you do not agree with any provision of this Privacy Policy, you should stop using the Site immediately.

We are the data controller of personal data obtained via our Site, meaning we are the organisation legally responsible for deciding how and for what purposes it is used.

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share any information relating to you (your personal data) in connection with your use of our Site. It also explains your rights in relation to your personal data and how to contact us or a relevant regulator in the event you have a complaint.

We collect, use and are responsible for certain personal data about you.

What this policy applies to

This privacy policy relates to your use of our Site only.

Throughout our Site we may link to other websites owned and operated by certain trusted third parties. Those third party websites may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to those third party websites, please consult their privacy policies as appropriate.

Personal data we collect about you

The personal data we collect about you depends on the particular activities carried out through our Site. Personal data we collect includes, for instance information about your identity and contact details (such as name, email id, contact number), your transactions, your financial information, interactions or dealings with us, including information received from third parties and information collected through use of our Sites, cookies or other similar tools and our electronic banking services.

If you do not provide personal data we ask for where it is required, it may prevent us from providing our products and services to you.

We collect and use this personal data for the purposes described in the section 'How and why we use your personal data'.

How your personal data is collected

We collect personal data from you:

  • directly, when you enter or send us information, such as when you register with us, contact us (including via email), send us feedback, acquire products or services via our Site, post material to our Site and complete customer surveys or participate in competitions via our Site; and

  • indirectly, such as your browsing activity while on our Site; we will usually collect information indirectly using the technologies explain in the section on 'Cookies and other tracking technologies' below.

We also collect personal data about you from other sources as follows:

Types of personal information Description
Financial Your financial position, status and history with us or other entities.
Locational (Static) Your registered address with us and location for card delivery.
Socio-Demographic This includes details about your work, nationality, education, income and net worth.
Engagement Includes financial and non-financial transactions/events related to the use of our digital assets and underlying products.
Contractual Details about the products or services we provide to you within your relationship with us
Locational (Dynamic) Location data generated by the our mobile app and website. Location data related to the usage of our card.
Technical Static and dynamic information related to the devices and technology you use to access Zand services and products.
Communications What we learn about you from letters and emails you write to us, and conversations between us across all channels.
Documentary Data Copies of documents submitted to us as part of the initial onboarding and any subsequent product and/or service request.
Consents Consents and permissions related to the configuration of preferences that influence how we provide our services and products as well as consents to obtain 3rd party data related to the approval process of onboarding and/or product and services requests (e.g. AECB credit score).
National Identifier Your Emirates ID or passport copy. Your Tax Identification Number for US customers.
Marketing

We may use your personal data to send you updates (by email, text message, telephone or post) about our services, including exclusive offers, promotions or new services.

We have a legitimate interest in using your personal data for marketing purposes (see the 'How and why we use your personal data'). This means we do not usually need your consent to send you marketing information. However, where consent is needed, we will ask for this separately and clearly.

We may ask you to confirm or update your marketing preferences if you ask us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.

Who we share your personal data with

We may share personal data with third parties, such as:

  • external auditors, eg in relation to the audit of our accounts, in which case the recipient of the information will be bound by confidentiality obligations;
  • professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations;

  • law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations;

  • other parties in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible, however, the recipient of the information will be bound by confidentiality obligations; or

  • third party service providers to help us analyse certain online activities. For example, these service providers may help us measure the performance of our online campaigns or analyze visitor activity. We may permit these service providers to use cookies and other technologies to perform these services for us. We do not share any Personal Information about our customers with these third party service providers, and these service providers do not collect such Personal Information on our behalf. Our third party service providers are required to comply fully with this privacy policy.

Cookies and other tracking technologies

Please read our Cookie policy for more information.

How and why we use your personal data

The table below explains what we use your personal data for and why.

What we use your personal data for Our reasons
Creating and managing your account with us/Providing products and/or services to you.

We are able to create, develop, operate, deliver and improve our Services, personalized content, and make suggestions for you by using your Personal Information to understand how you use and interact with our Services and the people or things you're connected to and interested in on and off our Services.

When we have location Personal Information, we use it to tailor our Services for you and others, like helping you to check-in and find local events or offers in your area.

We conduct surveys and research, test features in development, and analyze the Personal Information we have to evaluate and improve products and services, develop new products or features, and conduct audits and troubleshooting activities.

Conducting checks to identify you and verify your identity or to help prevent and detect fraud against you or us. To comply with our legal and regulatory obligations.
To enforce legal rights or defend or undertake legal proceedings.

Depending on the circumstances:

  • to comply with our legal and regulatory obligations; or
  • in other cases, for our legitimate interests or those of a third party, ie to protect our business, interests and rights or those of others.
Customise our Site and its content to your particular preferences based on a record of your selected preferences or on your use of our Site. Your consent as gathered by the separate cookies tool on our Site - see 'Cookies and other tracking technologies'.
Retaining and evaluating information on your recent visits to our Site and how you move around different sections of our Site for analytics purposes. This helps us to understand how people use our Site so that we can make it more intuitive or to check our Site is working as intended. Your consent as gathered by the separate cookies tool on our Site - see 'Cookies and other tracking technologies'.
Communications with you not related to marketing, including about changes to our terms or policies or changes to the services or other important notices.

Depending on the circumstances:

  • to comply with our legal and regulatory obligations;
  • in other cases, 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.
Protecting the security of systems and data.

To comply with our legal and regulatory obligations.

We may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests or those of a third party, ie to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us.

Statistical analysis to help us manage our business, eg in relation to our financial performance, customer base, product range or other efficiency measures. 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.
Updating and enhancing customer records.

Depending on the circumstances:

  • to perform our contract with you or to take steps at your request before entering into a contract;
  • to comply with our legal and regulatory obligations; or
  • where neither of the above apply, for our legitimate interests or those of a third party, eg making sure that we can keep in touch with our customers about existing orders and new products.
Disclosures and other activities necessary to comply with legal and regulatory obligations that apply to our business. To comply with our legal and regulatory obligations.
Marketing our services to existing and former customers.

For our legitimate interests or those of a third party, ie to promote our business to existing and former customers.

See the 'Marketing' section for further information.

External audits and quality checks, eg for the audit of our accounts.

For our legitimate interests or a those of a third party, ie to maintain our accreditations so we can demonstrate we operate at the highest standards, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency.

In such cases information will be anonymised where possible and only shared where necessary.

To share your personal data with members of our group and third parties in connection with a significant corporate transaction or restructuring,

Depending on the circumstances:

  • to comply with our legal and regulatory obligations; or
  • in other cases, for our legitimate interests or those of a third party, ie to protect, realise or grow the value in our business and assets.

See the 'Who we share your personal data with' section for further information on the steps we will take to protect your personal data where we need to share it with others.

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.

We also have procedures, processes and controls 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.

Changes to this privacy policy

We may change this privacy policy from time to time, as published on our Site from time to time. Changes take effect immediately upon posting.