Hubpay Limited, is a company incorporated under the laws of the ADGM and is regulated by the FSRA with registration number 000004051 and licensed for Providing Money Services under category 3c of the ADGM Financial Services and Markets Regulations. Our registered office and contact address is: 15-123, 15, Khatem Tower, WeWork Hub71, ADGM Square, Al Maryah Island, Abu Dhabi, United Arab Emirates.
We are registered with the ADGM and are subject to the ADGM Data Protection Regulations 2015. This regulation explains how and why we use your personal information when you use Hubpay.
You can chat with us through the app or send us an email at firstname.lastname@example.org
We collect, use, and retain information about you
Information you give us through the Hubpay 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:
i. Your name, phone number, home address, date of birth, residency,
ii. Your email address, details of your device
iii. Your Emirates ID information, or passport and any other identification documents
iv. Your selfie when you set up an account with us, and your photo if you upload one.
v. The log in and registration information and settings you choose for your app (including username, password)
vi. Your bank account details, including account number and IBAN
vii. Your location
viii. Details you give us which we pass to our partners when you let us know you are interested in their services.
ix. Information you give us through the app chat or records of discussions if we contact each other
x. The email address you use and the contents of your email (and any attachments).
xi. 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 us
xii. Answers you give to surveys
xiii. Details about payments to and from your account, including payment reason, and beneficiaries’ details
xiv. Details about services from us and our partners that you express interest in.
xv. Details about how you use our app.
Information we collect from your device:
a. The mobile network information and operating system, the type of mobile browser you use
b. Your log-in information, browser type and version and information
c. The type of device you use, unique device identifier
d. Your IP (Internet Protocol) address and device ID for security reasons
e. Your 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 phone
f. Your location, including GPS and IP address, in order to verify your residential address and also to help protect you against fraud
g. Information on your use of the app, including links to, through and from our website to other sites
h. Transaction data around your payments and beneficiaries
Information from external sources
a. fraud prevention agencies and KYC (Know Your Customer) and AML (Anti Money Laundering) service providers to fulfil our legal duties
b. information from your social media network if you log in to our app from your social media account, we will receive information to authenticate you
i. Recognizing you when you sign-in to use our services. This allows us to provide you with product recommendations, display personalized content, enable you to use 1-Click transactions and provide other customized features and services.
ii. Keeping track of your specified preferences. This allows us to honour your likes and dislikes, such as whether or not you would like to see interest-based ads. You may set your preferences through Your Account.
iii. Keeping track of your financial transactions left incomplete.
iv. Conducting research and diagnostics to improve our content, products, and services.
v. Preventing fraudulent activity.
vi. Improving security.
vii. Delivering content relevant to your interests
viii. Reporting. This allows us to measure and analyse the performance of our services.
ix. Cookies and other similar technologies may collect data such as language preference, country, and previously viewed pages.
x. To summarise, we use the following cookies:
a. Necessary cookies: these cookies enable the basic use of our Service
b. Personalisation cookies: these cookies allow our Service to be personalised for you
c. Analytical cookies: these cookies allow us to see how people use our Service so that we can understand how to improve it
xi. By using our Service, you agree to place the cookies described above on your device. You have the right to withdraw your consent at any time. If you would like to delete our cookies, you can do so by changing the settings of your browser.
xii. Blocking or deleting cookies may mean that some features of the Service may not be available to 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:
i. consider your application, including our KYC, customer due diligence and security checks
ii. give you the services we agreed to in line with our terms and conditions.
iii. to process your transactions
iv. send 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 services
v. verify your residential address
vi. to handle your enquiries in our communications
vii. exercise our rights under contracts we have entered into with you,
viii. allow our partners provide information on their services, if you agree
ix. investigate and resolve complaints and other issues
We need to use your data to comply with the law. We use your details to:
i. check your identity when you sign up or get in touch.
ii. check your record at immigration and fraud prevention agencies.
iii. prevent illegal activities like money laundering, tax evasion and fraud.
iv. keep records of information we hold about you in line with legal requirements.
v. 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).
vi. 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.
i. Product development and marketing:
a. 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.
b. 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.
ii. Special features
a. We will continue to build special features which will give you a unique user experience. We will use your transactional date for these features.
iii.Security and business management:
a. protect the rights, property or safety of us, our customers, or others.
b. carry out security and maintenance checks to make sure our app, website and other services run smoothly for you.
c. 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.
d. 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.
iv. Companies that give services to us:
a. We share your information with companies that so they can help us provide our services
We will ask for your consent to:
i. 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
ii. use your phone's location to verify the residential address you provided us and to help protect you against fraud. You can turn off the location permissions for the Hubpay app at any time by accessing your device's settings.
iii. show your profile picture in the app if you add one.
iv. show your profile picture and name to contacts in their app, provided they have stored your phone number. If you pay someone, they will see your name regardless of whether you have given permission. It is our legal duty to show this, so it is not something you can opt out of.
v. share information about you with companies we work with when we need your permission
You 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.
Who we may share your information with:
1. 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 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:
i. our parent company or subsidiaries
ii. business partners that provide services to us, including IT and payment services
iii. Know Your Customer (KYC) service providers that help us with identity verification or fraud checks.
iv. cloud computing power and storage providers
v. our business intelligence and analytics partners.
vi. companies that help us with functional analytics (to help us solve technical issues with the app for instance).
vii. 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).
viii. software companies that we use for emailing you, or for processing and storing email communications with you
ix. companies that help us with customer support
x. companies that offer benefits or rewards through special programmes you sign up to via the app.
xi. Legal or regulatory authorities where we have a legal obligation to do so or to prevent fraud
We will use this information to:
i. verify your identity and make sure what you have told us is true.
ii. help detect and prevent fraud, crime, and money laundering.
iii. manage your account with us.
iv. make sure our offers are relevant for you.
2. Anyone you give us permission to share it with
i. We tell you in the app when we need your consent to share your data with other applications.
3. Law enforcement and other external parties
i. 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;
ii. the police, courts, or dispute resolution bodies if we have to, or;
iii. 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;
iv. any other third parties where necessary to meet our legal obligations.
4. Corporate Finance events
i. 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 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.
You have the right to:
i. access the personal data we hold about you, or to get a copy of it.
ii. make us correct inaccurate or out of date personal information.
iii. ask us to delete your data unless we have a legal obligation to retain it.
iv. ask us not to contact you for marketing purposes.
v. withdraw any consent you have given us or object to processing of your personal information
vi. ask a member of staff to review a computer-made (automated) decision.
Contact us at email@example.com to exercise your above right(s) over your personal data.
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 ADGM. 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 app or send an email to firstname.lastname@example.org and we will do our best to fix the problem.
Changes to this notice
The “last revised” version is the one accessible on our mobile app and website.